ML20141L709

NRC-2019-000279 - Resp 4 - Interim, Agency Records Subject to the Request Are Enclosed. (Released Set of 2014-0488 3, Part 1 of 2)

ML20141L709
Person / Time
Site:	Diablo Canyon
Issue date:	05/14/2020
From:	NRC/OCIO
To:
Shared Package
ML20141L707	List: ML20141L708 ML20141L709 ML20141L710 ML20141L711 ML20141L712 ML20141L713 ML20141L714 ML20141L715 ML20141L716 ML20141L717 ML20141L718
References
FOIA, NRC-2019-000279
Download: ML20141L709 (190)

Text

NRC FORM 464 Part I (00.2013)

U.S. NUCLEAR REGULATORY COMMISSION FOIA/PA RESPONSE NUMBER RESPONSE TO FREEDOM OF INFORMATION ACT (FOIA) / PRIVACY ACT(PA)REQUEST 2014-0488

RESPONSE

TYPE 3

D FINAL

[ZJ PARTIAL REQUESTER Damon Moglen DATE JAN 2 "f,t.015 D

D Ill 0

Ill D

Ill 0

PART I. - INFORMATION RELEASED No additional agency records subject to the request have been located.

Requested records are available through.another public distribution program. See Comments section.

iGROUP---,

E

[ Agency records subject to the request that are identified in the specified group are already available for public inspection and copying at the NRC Public Document Room.

.. -****----*1 (GROUP I Agency records subject to the request that are contained in the specified group are being made available for jF_& G ___ _

! public inspection and copying at the NRC Public Document Room.

'GROUP

!F & G

! Agency records subject to the request are enclosed.

_.,_, _ _____ __J Records subject to the request that contain information originated by or of interest to another Federal agency have been referred to that agency (see comments section) for a disclosure determination and direct response to you.

We are continuing to process your request.

See Comments.

AMOUNT° PART I.A - FEES D You will be billed by NRC for the amount listed.

D You will receive a refund for the amount listed.

D None, Minimum fee threshold not met.

D Fees waived.

s I I

• See comments for details D

Ill D

PART 1.8 -- INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE No agency records subject to the request have been located. For your information, Congress excluded three discrete categories of law enforcement and national security records from the requirements of the FOIA. See 5 U.S.C. § 552(c)

(2006 & Supp. IV (2010). This response is limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is given to all our requesters and should not be taken as an indication that excluded records do. or do not, exist.

Certain information in the requested records is being withheld from disclosure pursuant to the exemptions described in and for the reasons stated in Part II.

This determination may be appealed within 30 days by writing to the FOIA/PA Officer, U.S. Nuclear Regulatory Commission.

Washington. oc* 20555-0001. Clearly state on the envelope and in the letter that it is a "FOIA/PA Appeal."

PART I.C COMMENTS ( Use attached Comments continuation page if regulred)

The incoming request FOIA/PA 2014-0488 is available in ADAMS as ML14261A399.

Portions of documents have been marked out of scope as the infonnation does not concern Diab lo Canyon and the DPO. If there are attachments referenced in e-mail messages that are not included, they are duplicates, were addressed in prior interim responses, or already publicly available.

Records with an ML acce ~ion number are available in the NRC Library at www.nrc.gov/reading-nn/adams.html. For assistance in obtaining an public rec1 as, please contact the NRC's Public Document Room (PDR) at 1-800-397-4209 or by e-mail at PDR.

Resource@; Li) / i SIGNATURE - FREEDOM OF INFORM ION ACT ANO PRIVACY ACT OFFICER Roger D. Andoh NRC FORM 464 Part 1 (08-2013)

NRt FORM 464 Part II (OS.2013).... _.,..

\\*~

/l U.S. NUCLEAR REGULATORY COMMISSION FOIA/PA 2014-0488 RESPONSE TO FREEDOM OF INFORMATION ACT (FOIA) / PRIVACY ACT (PA) REQUEST DATE I.HJ unn 2 7, JOI.5 PART II.A - APPLICABLE EXEMPTIONS

• IGGROUP I Records subject to the request that are contained in the specified group are being withheld in their entirety or in part under the Exemption No.(s) of the PA and/or the FOIA as indicated below (5 U.S.C. 552a and/or 5 U.S.C. 552(b)).

~-----'

D D

Exemption 1: The withheld information is property classified pursuant to Executive Order 12958.

Exemption 2: The withheld information relates solely to the internal personnel rules and practices of NRC.

D Exemption 3: The withheld information is specifically exempted from public disclosure by statute indicated.

D Sections 141-145 of the Atomic Energy Act, which prohibits the disclosure of Restricted Data or Formerly Restricted Data (42°U.S.C.

2161-2165).

D 0

0 D

D D

Section 147 of the Atomic Energy Act, which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).

41 U.S.C., Section 4702(b), prohibits the disclosure of contractor proposals in lhe possession and control of an executive agency to any person under section 552 of Title 5, U.S.C. (the FOIA), except when incorporated into the contract between the agency and the submitter of the proposal.

Exemption 4: The withheld information is a trade secret or commercial or financial information that is being withheld for the reason(s) indicated.

D D

D D

The inforry,ation is considered to be confidential business (proprietary) information.

The information is considered to be proprietary because it concerns a licensee's or applicant's physical protection or material control and accounting program for special nuclear material pursuant to 10 CFR 2.390(d)(1).

The information was submitted by a foreign source and received in confidence pursuant to 10 CFR 2.390(d)(2).

Disclosure will harm an identifiable private or governmental interest.

Exemption 5: The withheld information consists.of interagency or intraagency records that are not available through discovery during litigation.

0 D

D Applicable privileges:

Deliberative process: Disclosure of predecisional information would tend to inhibit the open and frank exchange of ideas essential to the deliberative process. Where records are withheld in their entirety, the facts are inextricably intertwined with the predecisional information.

There also are no reasonably segregable factual portions because the release of the facts would perniit an indirect inquiry inlo the predecisional process of the agency.

Attorney work-product privilege. (Documents prepared by an attorney in contemplation of litigation)

Attorney-client privilege. (Confidential communications between an attorney ~nd his/her client)

Exemption 6: The withheld information is exempted from public disclosure because its disclosure would result in a clearly unwarranted invasion of personal privacy.

Exemption 7: The withheld information consists of records compiled for law enforcement purposes and is being withheld for the reason(s) indicated.

D D

D D

(A) Disclosure could reasonably be expected to interfere with an enforcement proceeding (e.g., it would reveal the scope, direction, and focus of enforcement efforts, and thus could possibly allow recipients to take action to shield potential wrong doing or a violation of NRC requirements from investigators).

(C) Disclosure could constitute an unwarranted invasion of personal privacy.

(D) The information consists of names of individuals and other information the disclosure of which could reasonably be expected to reveal identities of confidential sources.

(E) Disclosure would reveal techniques and procedures for law enforcement investigations or prosecutions, or guidelines that could reasonably be expected to risk circumvention of the law.

D (F) Disclosure could reasonably be expected to endanger the life or physical safety of an individual.

D OTHER <SoeciM I

PART 11.B - DENYING OFFICIALS Pursuant to 10 CFR 9.25(9), 9.25(h), and/or 9.65(b) of the U.S. Nuclear Regulatory Commission regulations, it has been determined that the information withheld is exempt from production or disclosure, and that its production or disclosure is contrary to the public interest. The person responsible for the denial are those officials identified below as denying officials and the FOIA/PA Officer for any denials that may be appealed to the Executive Director for Operations (EDO).

RECORDS DENIED

.APPEL.LA TE OFFICIAl DENYING OFFICIAL TITLE/OFFICE EDO SECY IG Eliot Brenner Director, Office of Public Affairs G5-G6, GS D0D Rachel Bavol Director, Office of the Secretary of the Comm.

Gl-G2 LJ 0 D William M. Dean Director, Office of Nuclear Reactor Regulation G3-G4, GS, G9-G36 0DD Appeal must be made in writing within 30 days of receipt of this response. Appeals should be mailed to the FOIA/Privacy Act Officer, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, for action by the appropriate appellate official(s). You should clearly state on the envelope and letter that it is a "FOIA/PA Appeal."

NRC FORM 464 Part II (08-2013)

U.S. NUCLEAR REGULATORY COMMISSION FOIA/PA RESPONSE TO FREEDOM OF INFORMATION ACT (FOIA) / PRIVACY ACT (PA) REQUEST PART II.A -- APPLICABLE EXEMPTIONS DATE 2014-0488 I

GGROUP I Records subject to the request that are contained in the specified group are being withheld in their entirety or in part under the Exemption No.(s) of the PA and/or the FOIA as indicated below (5 U.S.C. 552a and/or 5 U.S.C. 552(b)).

D D

Exemption 1: The withheld information is property classified pursuant to Executive Order 12958.

Exemption 2: The withheld information relates solely to the internal personnel rules and practices of NRC.

D Exemption 3: The withheld information is specifically exempted from public disclosure by statute indicated.

D Sections 141-145 of the Atomic Energy Act. which prohibits the disclosure of Restricted Data or Formerly Restricted Data (42 U.S.C.

2161-2165).

D D

Section 147 of the Atomic Energy Act. which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).

41 U.S.C., Section 4702(b), prohibits the disclosure of contractor proposals in the possession and control of an executive agency to any person under section 552 of Title 5, U.S.C. (the FOIA), except when incorporated into the contract between the agency and the submitter of the proposal.

D Exemption 4: The withheld information is a trade secret or commercial or financial information that is being withheld for the reason(s) indicated.

D 0

D D

D D

D The information is considered to be confidential business (proprietary) information.

The information is considered to be proprietary because it concerns a licensee's or applicant's physical protection or material control and accounting program for special nuclear material pursuant to 10 CFR 2.390(d)(1).

The information was submitted by a foreign source and received in confidence pursuant to 10 CFR 2.390(d)(2).

Disclosure will harm an identifiable private or governmental interest.

Exemption 5: The withheld information consists of interagency or intraagency records that are not available through discovery during litigation.

D Applicable privileges:

Deliberative process: Disclosure of predecisional information would tend to inhibit the open and frank exchange of ideas essential to the deliberative process. Where records are withheld in their entirety, the facts are inextricably intertwined with the predecisional information.

There also are no reasonably segregable factual portions because the release of the facts would permit an indirect inquiry into the j:)redecisional process of the agency.

D """'Attorney work-product privilege. (Documents prepared by an attorney in contemplation of litigation)

D Attorney-client privilege. (Confidential communications between an attorney and his/her client)

Exemption 6: The withheld information is exempted from public disclosure because its disclosure would result in a clearly unwarranted invasion of personal privacy.

Exemption 7: The withheld information consists of records compiled for law enforcement purposes and is being withheld for the reason(s) indicated.

D D

D D

(A) Disclosure could reasonably be expected to interfere with an enforcement proceeding (e.g., it would reveal the scope, direction, and focus of enforcement efforts, and thus could possibly allow recipients to take action to shield potential wrong doing or a violation of NRC requirements from investigators).

(C) Disclosure could constitute an unwarranted invasion of personal privacy.

(D) The information consists of names of individuals and other information the disclosure of which could reasonably be expected to reveal identities of confidential sources.

(E) Disclosure would reveal techniques and procedures for law enforcement investigations or prosecutions, or guidelines that could reasonably be expected to risk circumvention of the law.

D (F) Disclosure could reasonably be expected to endanger the life or physical safety of an individu~I.

D OTHER (Specify)

I PART 11.B -- DENYING OFFICIALS Pursuant to 10 CFR 9.25(g), 9.25(h). and/or 9.65(b) of the U.S. Nuclear Regulatory Commission regulations. it has been determined that the information withheld is exempt from production or disclosure, and that its production or disclosure is contrary to the public interest. The person responsible for the denial are those officials identified below as denying officials and the FOIA/PA Officer for any denials that may be appealed to the Executive Director for Operations (EDO).

RECORDS DENIED APPEU ATE OFFICIAL DENYING OFFICIAL TITLE/OFFICE ECO SECY 1G Marc L. Dapas Regional Administrator, Region IV G7 0DD LJ LJ LJ OD D Appeal must be made in writing within 30 days of receipt of this response. Appeals should be mailed to the FOIA/Privacy Act Officer, U.S. Nuclear Regulatory Commission, Washington. DC 20555-0001, for action by the appropriate appellate official(s}. You should clearly state on the envelope and letter that it is a "FOIA/PA Appeal."

NRC FORM 464 Part II (08-2013)

From:

Sent:

To:

Cc:

Subject:

Bloomer, Tamara Tuesday, August 26, 2014 9:35 AM Ostendorff, William Cubbage, Amy; Benner, Eric web post of Diablo Canyon DPO Friends of the Earth has posted the document on our website at: www.foe.org/diablo.

Tamara E. Bloomer Policy Advisor for Materials Office of Commissioner Ostendorff 301-415-2896 1

Status of Dlablo Canvon DPO - this Is all we can sav publicly at this time The DPO panel is comprised of three independent staff members who have not previously worked on the seismic issues at Diablo Canyon (and one of which had been recommended by the DPO submitter).

The OPO panel forwarded its results to Eric Leeds on April 3, 2014.

Eric Leeds has reviewed the panel's recommendation and supporting basis and has made a decision on the DPO.

o The DPO decision is currently considered pre-decisional.

o The DPO submitter has a right to appeal the decision to the EDO.

Next steps:

If the decision is not appealed, the DPO process is complete.

o If the DPO submitter requests that the DPO be made public, it would become public.

If the decision is appealed, once the EDO has rendered a decision on the appeal, the DPO process would be complete.

o If the DPO submitter requests that the DPO be made public. it would become public.

From; Sent:

To:

Ostendorff, William Tuesday, October 07. 2014 2:20 PM Marsh, Molly Subjed:

FW: info: cover letter transmitting diablo canyon state ot California report Attachments:

~-------~

cover letter transimitting diablo canyon state of california report.pdf Note: The attachment is From: Cubbage, Amy Sent: Wednesday, September 10, 2014 3:56 PM To: Ostendorff, WIiiiam Cc: Benner, Eric; Bloomer, Tamara

Subject:

FW: Info: cover letter transmitting dlablo canyon state of california report publicly available in ADAMS as ML14260A387.

Sir - Another update this afternoon - PGE submitted the "Central Coastal California Seismic Imaging Project~

report today.

As we discussed earlier in the week, the Shoreline fault is longer and more capable than previously determined.

PG&E concluded that "the ground motions from updated shoreline fault and other regional faults remain less than-the Hosgri Design Ground Motions for which the plant was evaluated and demonstrated reasonable assurance of safety."

1

From:

Sent:

To:

Cc:

Subject:

Attachments:

Sir, 1

Bloomer, Tamara Wednesday, September 10, 2014 4:15 PM Ostendorff, William Benner, Eric Sff4Sliffo'f If4fEIU4J8cl U4FORMJ8cff0t4. COS notes and other items Budget Formulation MD.pdf; 9 10 14 COS meeting notes.pdf Non-Responsive Record Non-Responsive Record Diablo Canyon DPO and Finding will be public tomorrow.

I-lave a safe trip.

Tamara E. Bloomer Policy Advisor for Materials Office of Commissioner Ostendorff 301-415-2896 Non-Responsive Record Non-Responsive Record Non-Responsive Record 1

eFFICIAL tJSE eNtY 8EN81Trt1E INTERNAL INf'OftMA:TION LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE Non-Responsive Record Non-Responsive Record Non-Responsive Record CHAIRMAN MORNING MEETING INPUT Tuesday, September 9, 2014 Non-Responsive Record Non-Responsive Record Non-Responsive Record Non-Responsive Record (b)/5)

Non-Responsive Record Non-Responsive Record LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE

err1e1J1ct tJ9E 8ff LY - 9!f491Tl\\f! lffT!fUfAL lff raftMATlaH LIMITED TO NRC UNLESS THE COMMISSION DETERMINES OTHERWISE Non-Responsive Record

\\

Non-Responsive Record Non-Responsive Record CHAIRMAN MORNING MEETING INPUT Wedrasdav Seotember 'O* 2014 No: -Respons1ve Record Non-Responsive Record Non-Responsive Record Non-Responsive Record Non-Responsive Record

~6)51

........,., A i I 1<<" r_ I.... V le f!!*lelTI\\IE,-.,... c:cn., A I,-.,c:ADII ATIAt.l

~

7?

I

From:

Sent:

To:

Cc:

Subject:

Attachments:

Gilles, Nanette Monday, June 02, 2014 1:57 PM Apostolakis, George Sosa, Belkys; Davis, Roger; Baggett, Steven FW: FYI: Diablo Canyon DPO info ML14140A22S.pdf; DPO Panel Report.pd(

Note: Both attachments are publicly available in ADAMS as part of the DP0.2013-002 package (ML14252A743).

FYI, Eric signed out the final DPO Panel report on the OPO from the former Diablo Canyon Senior Resident Inspector related to the t reatment of the Shoreline fault by the staff. I have saved the report and transmittal memo to the EPW hearing folder (as well as to the Seismic folder for Diablo) on G. Here are the panel's summary conclusions:

The Panel concluded that there was not a significant or immediate concern with the current understanding of seismic safety of the OCNPP. The Panel also concluded that the seismic llcensing history at DCNPP is extremely complex and that the licensee the U.S. Nuclear Regulatory Commission (NRC) staff. and you were unable to make an appropriate range of comparisons between the plant's licensing basis and new seismic information. The Panel acknowledged that you were a positive contributor to the staff and the licensee on seismic safety at DCNPP. As a result of your DPO additional information was developed by the licensee to clearty demonstrate that potential ground motions from nearby faults would not exceed the levels of ground motion already considered during the design and licensing of the plant.

In addition. the Panel concluded that the licensee and the staff followed its processes for technical specification operability of plant equipment and Title 1 0, Code of Federal Regulations 50.59 evaluations with a reasonable technical and safety rationale.

Finally, the Panel concluded that the lack of formal regulatory guidance for evaluating new information on naturaJ hazards appears to be a contributing cause in creating many of the differing interpretations for the potential significance of this information, along with confusion with regard to the regulatory process for evaluating the impact of new seismic information on system operability.

After considering all the information, I have concluded that this is not a safety significant issue as independent groups (as documented in Research Information Letter 12-01 and the DPO Panel report) have verified that the new seismic information is bounded within the existing analysis for DCNPP. Further, during our discussion you indicated that you defer judgment of the safety significance of this issue to the NRC technical staff who are trained and qualified to make those judgments. Finally, I agree with the Panel report with respect to its assessment of your technical concerns.

From: Sanfilippo, Nathan Sent: Friday, May 30, 2014 8:15 AM To: Krsek, Robert; Gilles, Nanette; Jolicoeur, John; castleman, Patrick; Kozak, Laura; Cubbage, Amy

Subject:

RE: FYl: Diablo Canyon DPO info

All, Here is the response.

Thanks,

Nathan From: Krsek, Robert Sent: Thursday, May 29, 2014 1:19 PM To: Sanfilippo, Nathan; Gilles, Nanette; Jolicoeur, John; Castleman, Patrick; Kozak, Laura; Cubbage, Amy

Subject:

RE: FYI: Diablo Canyon DPO info Thank you Nathan.

Commissioner Magwood asked me to see if we could get a copy of the final DPO response after is signed by Eric today, in preparation for the hearing.

We had previously seen the original DPO itself in preparation for the last EPW hearing.

If it is not possible, or if management is unwilling, please let me know.

Thank you, Robert G. Krsek U.S. Nuclear Regulatory Commission Technical Assistant for Reactors Office of Commissioner William D. Magwood, IV Office: 301.415.1769 From: Sanfilippo, Nathan Sent: Thursday, May 29, 2014 1:10 PM To: Gilles, Nanette; Jolicoeur, John; Krsek, Robert; Castleman, Patrick; Kozak, Laura; Cubbage, Amy SUbject: RE: FYI: Diablo Canyon DPO info No problem. We expect the DPO submitter will likely appeal, which would delay any public release.

Nathan From: Gilles, Nanette Sent: Thursday, May 29, 2014 1:09 PM To: Sanfilippo, Nathan; Jolicoeur, John; Krsek, Robert; Castleman, Patrick; Kozak, Laura; Cubbage, Amy

Subject:

RE: FYI:.Diablo Canyon DPO info Thanks, Nathan. Very helpful. With the EPW hearing next week, it's important that we all stay "in the loop" on this issue. Please keep us informed as the process proceeds.

Nan From: Sanfilippo, Nathan Sent: Thursday, May 29, 2014 1:03 PM To: Jolicoeur, John; Krsek, Robert; Castleman, Patrick; Kozak, Laura; Cubbage, Amy; Gilles, Nanette

Subject:

FYI: Diablo Canyon DPO info DPO on Diablo Canyon ]Non-PubliG/Predetisiona[

What is it?

In 2011, Pacific Gas and Electric (PG&E) submitted a report to the NRC that included a reevaluation of the local geology surrounding the Diablo Canyon Power Plant. This report included deterministic evaluations concluding that three local earthquake faults are capable of generating significantly greater 2

vibratory ground motion than was used to establish the facility safe shutdown earthquake (SSE) design basis. The DPO submitter believes that the resulting NRC actions have been inconsistent with existing regulatory requirements and the facility design bases and Operating License.

Eric is signing the response to the DPO today.

What is the response?

The DPO Panel, a group of three independent staff members who have NOT worked on the seismic issues at Diablo Canyon previously (and one of which had been recommended by the DPO submitter),

concluded that there is not a significant or immediate safety concern regarding the seismic design of the Diablo Canyon Nuclear Power Plant (DCNPP). The Director of the Office of Nuclear Reactor Regulation has concluded that this is not a safety significant issue as independent groups have verified that the most recent seismic information is bounded by the existing analysis for DCNPP.

The NRC is currently re-evaluating the seismic hazards at all the nuclear power plants in the US, as part of its response to the accident at the Fukushima Dai-ichi nuclear power plant. The Diablo Canyon plant is required to provide its response to the re-evaluation in March 2015.

In order to clarify the regulatory process in this area, the NRC is committed to revise its formal regulatory guidance for evaluating new information on natural hazards, including new seismic information, as part of its response to the Fukushima accident.

What is the process for making it public?

Once issued, the DPO author can request that the DPO and response be made publicly available (with or without his/her identity). The documents would undergo a FOIA review for releasability and the appropriate documents would be made public by the agency.

Also, the DPO author can also appeal the decision to the EDO. The DPO decision is considered pre-decisional if the DPO submitter decides to appeal the decision to the EDO since in that circumstance, the EDO has to review the case and make a final agency determination regarding the appeal. If this occurs, any public release would occur after an EDO decision.

If the DPO author does not request the documents be made publicly available, they remain non-public.

The process is described in MD 10.159.

Until/unless the decision Is made public, the decision should not be discussed outside the agency.

Attached is a communication Marc Dapas sent to the Mothers for Peace regarding the DPO and the process for making it public.

If you'd like any additional info, please let me know.

Nathan 3

From:

Gilles, Nanette Sent To:

Monday, June 02, 2014 5:28 PM Apostolakis, George Cc:

Subject:

Sosa, Belkys; Davis, Roger; Baggett, Steven FW: FYI: Diablo Canyon DPO info This is a reminder from staff that the Diablo Canyon DPO Panel report is not pu_bl_ic.

From: Sanfilippo, Nathan...

sent: Friday, May 30, 2014 8:22 AM To: Cubbage, Amy; Krsek, Robert; Gilles, Nanette; Jolicoeur, John; castleman, Patrick; Kozak, Laura

Subject:

RE: FYI: Diablo canyon DPO info Yes. non-public.

If the DPO submitter wants to appeal the decision to the EDO, it will remain non-public until after that process (he has a few weeks to submit the appeal and EDO has 30 days to conduct the review).

If the DPO submitter doesn't want to appeal, he can request public release, at which time we would conduct a SUNSI review and subsequently make a public version available.

If the DPO submitter doesn't want it to be made public, it will not be made public.

From: Cubbage, Amy \\.

sent: Friday, May 30, 2014 8:17 AM To: Sanfilippo, Nathan; Krsek, Robert; Gilles, Nanette; Jolicoeur, John; castJeman, Patrick; Kozak, Laura

Subject:

RE: FYI: Diablo canyon DPO info Again, this is non-public until further notice, correct?

From: Sanfilippo, Nathan....

sent: Friday, May 30, 2014 8:15 AM To: Krsek, Robert; Gilles, Nanette; Jolicoeur, John; castleman, Patrick; Kozak, Laura; Cubbage, Amy

Subject:

RE: FYI: Diablo canyon DPO info

All, Here is the response.

Thanks, Nathan From: Krsek, Robert Sent: Thursday, May 29, 2014 1:19 PM To: Sanfilippo, Nathan; Gilles, Nanette; Jolicoeur, John; Castleman, Patrick; Kozak, Laura; Cubbage, Amy

Subject:

RE: FYI: Diablo Canyon DPO info Thank you Nathan.

Commissioner Magwood asked me to see if we could get a copy of the final DPO response after is signed by Eric today, in preparat ion for the hearing.

1

CHAIRMAN MORNING MEETING INPUT Tuesday, August26. 2014 (b)(5)

An array of outlets. primarily California media. covered the leaked Differing Professional Opinion minus the on oin staff review and res onse re ardin Diablo Can on's seismic desi n.

Non-Responsive Record Nothing from OIP today.

OCA Input

~

~'~ ~ !Je ~,dt l-'6 J'<-

qJB.J? ilJ<~if *~tt!.'~ ~r /k~"'<1" Sen. Mark~y'&' (0-MA) asked for details, including stafutory language, to supf,ort the V

Commission's recent response to his "job shadow" inquiries.

Staff to Sen. Feinstein (D-CA) asked for copy of DPO filing re: Diablo Canyon seismic studies following media coverage of the same; they have also requested a briefing on seismic issues at/

Diablo Canyon.

-o

,a, l.~ -G, c; li~c-~ o""' IOt<blo.

Non-Responsive Record Non-Responsive Record

4 uJCD

,FE:;;~:mr"itimt:=::::~:~~~WI~ ~t ~

CHAIRMAN MORNING MEETING INPUT

~t/;j/1 VYednesday, August27, 2014 Non-Responsive Record (b)(5)

OPA input

!Non-Responsive Record I ja Today's coverage 1s dominated by s

well as follow-up on the leaked Differing Professional Opin* n (minus the ongoing staff review and res nse re arding Diablo Canyon's seismic design on-esponsNe ecord AMN\\ r,~ h c"" Ge~~ Aj~tR,,.-.o"'f GP.1e 5TLf,.,~ o<I- ~,JS

{if;~pUt ~r Vf ~-r wt.

Nothing from OIP today.

OCA input L~1~,tk ~

r::1J/AL vorG t,µ ~ ~R ~

e.v,*/1 ~

kl. ~va!,,-.,. tttl -/h:6 Tuesday afternoon, OCA, NRR, and RES 6riefed staff to Sen. Feinstein (D-CA) re: seismic F,.J.

issues at Diablo Canyon, focusing on the NRC's work to date. Working with the Commission for

~.,

clearance, OCA afso delivered the DPO filing - with appropriate handling instructions - to the Senator's staffrL* ---------------------------,

(b)(5)

L

From:

Cubbage, Amy Sent:

Thursday, September 11, 2014 9:18 AM Ostendorff, Wilham To:

Cc:

Benner, Eric; Bloomer, Tamara

Subject:

FW: Comm Plan for DPO & Appeal Attachments:

Draft mini-Comm Plan on DCPP DPO_final.docx Importance:

High 1 he EDO has made his decision on the DPO Appeal and the DPO Case File has now been made public.

,\\dd1t1onal "lfo The DPO panel completed its report in May 2014 and a decision on the DPO was rendered in letter dated May 29 2014 to the DPO submitter The DPO submitter appealed the decision to the EDO in accordance with the NRCs DPO process.

The EDO completed his consideration of the DPO appeal on September 9, 2014, concluding that he was in agreement with the original decision.

The EDO and the DPO submitter have both agreed that the issues raised in the DPO do not present an immediate safety concern for Diablo Canyon The DPO submitter and the DPO submitter has agreed to allow the DPO case file to be made publicly ava 1able Regarding the operational status of D1ablo Canyon Power Plant, Units 1 and 2 The plant remains within its approved design and licensing basis There are no current operability concerns resulting from the DPO

eFFICIAL use ONLY Sl!t4Slfl'Vl! INTl!"NAL INfiO~MAflON - NOf P'OR i-ueuc ReteAS!

Background

Communications Plan -

Diablo Canyon Power Plant Topics of Interest Differing Professional Opinion and Appeal The former SRI at the Diablo Canyon Power Plant (DCPP) submitted non-concurrence papers (NCPs) in January 2011 and January 2012, followed by a Differing Professional Opinion (DPO)

In July 2013 detailing a disagreement with the NRC about how new seismic information should be compared to the plant's current seismic license requirements. OPO 2013-02 restated the issues presented in NCP 2012*01 and added a concern that a license amendment was needed incorporate the Shoreline fault into Diablo Canyon's FSAR as described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults. In accordance with Management Directive 10.159, a DPO Ad Hoc Review Panel was established to review the DPO submittal, meet with OPO submitter, and issues a DPO report including conclusions and recommendations regarding disposition of the issues presented in the DPO. The panel completed its report in May 2014 and a decision on the DPO was rendered in letter dated May 29, 2014, to the OPO submitter. The DPO submitter appealed the decision to the EDO in accordance with the NRCs OPO process. The EOO completed his consideration of the OPO appeal on September 9, 2014, concluding that he was in agreement with the original decision The purpose of this communication plan is to provide key messages associated with the EDO's decision on the DPO appeal and public release of the DPO Case File.

Key Messages:

1 NRC strives to establish and maintain an environment that encourages all NRG employees and contractors to raise concerns and differing views promptly without fear of reprisal through various mechanisms. The free and open exchange of views or ideas conducted in a non*threatening environment provides the ideal forum where concerns and alternative views can be considered and addressed in an efficient and timely manner that improves decision making and supports the agency's safety and security mission

2. The NRC appreciates members of the staff bring issues like this to its attention

3. The NRC encourages the use of non--concurrences and the Differing Professional Opinion (DPO) process

4. The NRC reviews all non-concurrences and DPOs thoroughly and in accordance with agency guidance (MO 10.158, MO 10 159) and believes that this is a healthy and necessary part the regulatory process

5. The NRC believes that in the end, all of our regulatory decisions are better because of this process

eFFICIAL USE 6f4LY SEf~S1Tl¥E lfnERNAL lf~FORMATt6t4 - P40T F6R PUBLIC RELEASE

6. The NRC does not tolerate retallation against employees who engage in our processes for raising differing views (l.e., Open Door Policy, NCP, and DPO Program).

7, Persons serving on the DPO Panels are independent of the issues raised In the OPO 8

Upon disposition of the DPO via a Director's decision. the DPO submitter has appeal rights to the EDO 9

While the DPO is under review or appeal. NRC is prohibited from engaging in discussions with external stakeholders regarding the specifics of the of the OPO submittal

10. After the EDO's decision on the appeal, the DPO submitter can request U,at the OPO Case File be made public. Management performs a review consistent with agency policies to support discretionary release Regarding the DPO for Diablo Canyon, the NRC has been and will continue to be as open and scrutable as possible while protecting the privacy rights of the individual 11 The NRC does not know the source of the public release of the Diablo Canyon DPO submittal prior to the EDO rendering a decision on the appeal 12 The NRC can, however. comment on a few aspects of the OPO appeal review o

A Director's Decision has been made and the DPO appeal to the EDO has been finalized o

The EDO and the DPO submitter have both agreed that the issues raised in the DPO do not present an immediate safety concern for Diablo Canyon o

The NRC has sought permission from the DPO submitter to allow the DPO case file to be made publicly available and the DPO submitter has agreed o

We would expect the public release of the DPO case file to be within a few days of the EOO's appeal decision

13. Regarding the operational status of Diablo Canyon Power Plant, Units 1 and 2 o

The plant remains within its approved design and licensing basis o

There are no current operability concerns resulting from the DPO o

The recent earthquake in the Napa Valley did not reach Diablo Canyon - it was neither felt nor detected Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate. and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.

Team Member Position Organization Telephone Troy Pruett Division Director (Acting)

RIV/DRP 817-200-1291 Wayne Walker I Branch Chef R-IV/DRP/RPB-A 817-200-1148 I Ryan Alexander R-IV/DRP/RPB*A 817~200-1 195 1 Sr. Project Engineer

OFFICIAL USE Ot~LY SEt481Tl\\'E IP4TERNAL lf4FORMA1'10f~ - t40T FOR PUBtle RELEASE Thomas Hipschman I Sr. Resident Inspector -

DCPP R-IV/DRP/RPB-A 805-595-2354 John Reynoso Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 DCPP Thomas Farnholtz Branch Chief RIV/DRS/E81 817-200-1243

, Jon Ake Senior Seismologist RES/OE/SGS EB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/OORL/LPLIV 301-415-3016

-Renee Pedersen DPOPM OE/CRB 301-415-2742 Scott Burnell Public Affairs Officer OPA 301-415-8204 l Angel Moreno Congressional Affairs OCA I 301-41 s-1e91

~ my Powell Associate Director OCA 301-415-1673 L~1ctor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 j Bill Maier State Liaison Officer RIV 817-200-1267 Non-concurrence and DPO Questions (NOTE - this information ts generally NON-PUBLIC, but is provided as background only]

NOTE: General FAQs on the DPO Program are included on the DPO Web site (look under Employee Resources-Employee Concerns.

1. Was the former OCPP SRI reassigned because he filed two non-concurrences?

No. Michael Peck was not reassigned. He applied for an instructor position in his area of expertise at the NRC's technical training center in Chattanooga, TN. at about the time he submitted his non-concurrence in accordance with the Non-Concurrence Process described in MD 10.158 He was competitively selected for this sought-after position. and reported to his new assignment in September 2012. Resident inspector assignments are limited to 7 years to ensure objectivity. It is common for resident inspectors to apply for their next Job when a desirable position comes open.

2. When were the non-concurrences filed?

Two non-concurrences were filed by the DCPP SRI.

11/7/11 The DCPP SRI submitted NCP 2011-103, on inspection report 05000275; 323/201104

6FPICIAL 1:19E erRY 9Ef4Sl'fl't1E INTERP~AL INF6RMAfl6f4 - N6l F6R Pttet1e RELEASE 1/26/12. The DCPP SRI submitted NCP 2012-01, on inspection report 05000275; 323/201105.

3. What were the non-concurrences?

Both non-concurrences involve the same subject; regulatory actions in response to the discovery of the Shoreline Fault.

NCP 201 1-103 was filed by the OCPP SRI on the basis that no violation was issued (as he had submitted in the draft report) related to operability evaluation of the Shoreline fault in Report 2011-04. NCP 2011*103 was disposnioned finalizing the violation in IR 2011-05 issued on 2/14/12 (The employee requested that the NCP be non-public.)

NCP 2012-01 was filed by the DCPP SRI because the SRI believed the v1olatron in NRC IR 2011-05 should be for an inadequate operability evaluation of the Shoreline Fault rather than not doing an operability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault. NCP 2012-01was discussed with NRC stakeholders representing NRR/OE, NRR/OORL, RIV, and RES. NCP 2012-01 was dispos,ttoned as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 201 1 existed because the licensee completed the RIS 2005-020 immediate (interim) operability evaluation in June 2011. Additionally, the offices involved m NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the time of Inspection Report 2011-05 issuance it was expected that the requirements and methods would be addressed in a License Amendment Request that was under consideration However, by 30/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the L TSP method of analysis used tn the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event (The employee supported public release of the NCP ADAMS ML 121A173.)

4. When was the OPO filed?

July 18, 2013. The former OCPP SRI filed Differing Professional Opinion (DPO) 2013-02 associated with the regulatory response following the discovery of the Shoreline Fault.

NRC employees are encouraged to file a DPO if they believe an agency decision is in error. The OPO process is in keeping with the agency's open and collaborative working environment.

5. What is the DPO?

DPO 2013-02 restated the issues presented 1n NCP 2012-01 and added a concern that a license amendment was needed incorporate the shoreline fault into Diablo Canyon's FSAR as

OFFICIAL use ONLY S!!P4SIT1'0 1! INTE"NAL INfiO"MATION - NOT f'O~ f'tJe tte tU!lb\\!!!

described 1n the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults.

6. What is the status of the DPO?

A decision on the DPO was issued by the Office Director for NRR on May 29, 2014 consistent with the NRC's process included in MD 10.159. The OPO submitter appealed this decision to the EDO on June 23, 2014, and the appeal was thoroughly evaluated by the EDO and decision on the appeal was rendered on September 9, 2014.

As part of the agency's open and collaborative work environment, the NRC has established the DPO program as a means for employees to have their concerns reviewed by high level managers. The DPO Program is a formal process that allows all employees and contractors to have their differing views on established, mission-related issues considered by the highest level managers in their organizations, i.e

• Office Directors and Regional Administrators. The process also provides managers with an independent, three-person review of the issue (one person chosen by the employee). After a decision is issued to an employee, he or she may appeal the dec1s1on to the Executive Director for Operations (or the Chairman for those offices reporting to the Commission).

7. Will the decision regarding the DPO be made public?

The NRG supports openness and will include a summary of the disposition of the DPO in the Commission's Weekly Information Report included on the NRC Web site (see Commission Documents under the Document Collections in the NRC Library). The DPO submitter has been contacted regarding the EOO s decision on the OPO appeal and has communicated support for the public release of the DPO Case FIie (with appropriate redactions). The DPO Case File should be publicly available within a few days of the EDO's DPO appeal decision.

8. Was the SRI wrongfully reassigned after filing two non-concurrences and a DPO?

No. As noted in Q&A #1 above, the SRI applied for and was selected to a highly sought instructor position at the NRC's Technical Training Center. The NRC does not tolerate retaliation for engaging in the NCP or the DPO Program and both MOs reiterate this policy and direct employees to resources in the event they believe that they have been retaliated against.

9. Would the DPO panel's conclusions or the OPO appeal decision change based on the new seismic information found in the State of California report?

PG&E, the licensee for Diablo Canyon,,s providing a report to the State of California that includes the results of its most recent evaluation of the seismic hazards for the Diablo Canyon facility. The NRC understands that the report will be provided to the State of California on September 10, 2014, and that a copy will be provided to the NRC as well. Prior to performing a detailed review of this report, the NRC is not able to ascertain whether the new seismic

eFFlelAL USE ONLY SEP4Slfttf'E lfff !fitf~AL INP'OfitMAftOP~ - NOT f6fit lltJetre fltELEASE information contained in the report would change the DPO panel's conclusions or the DPO appeal decision The NRC understands that PG&E plans to incorporate the findings from this report into their ongoing probabilistic seismic hazards analysis required by the NRC Post*

Fukushima task force recommendatlons that are due in March 2015. The NRC believes tnis more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the ground motions resulting from the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

NRC Resident Inspectors and Region IV staff looked at the licensee's correctlve action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event The NRC staff will review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.

From:

Ostendorff, William Sent:

Tuesday, October 07, 2014 2:20 PM Marsh, Molly To:

Subject:

FW: diablo canyon state of california report DC_Calif_seismic_rpt comm plan 9-10-14_ final rev l.docx Attachments:

From: Cubbage, Amy Sent: Thursday, September 11, 2014 9:24 AM To: Ostendorff, William Cc: Benner, Eric; Bloomer, Tamara

Subject:

diablo canyon state of california report Since you are headed to CA, here is the latest Comm plan for the PG&E/Diablo Canyon Power Plant seismic report submitted to the state of California this week.

Key Messages from the Comm plan on the Diablo Canyon State of California report.

1.

NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event. PG&E's evaluation of the new seismic information, as documented in the report, concludes that the ground motions resulting from the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

2.

The NRC staff will review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.

3.

PG&E will incorporate the findings from Bill 1632 report into their upcoming March 2015 probabilistic seismic hazard analysis as part of the NRC's post-Fukushima activities. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

1

DRAFT - OfiPICbtlt use ONLY Sl!NSITftf! INT!ftNAL INfSO"MATION - NOT l'O",.UBLIC ftl!L!l<S!

Background

UPDATED: 9/10/14 10:30 eastern Communications Plan -

Diablo Canvon Power Plant Topics of Interest State of California Seismic Report (ABN-1632}

Califomia Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerabmty of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report. This is a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.

The purpose of this communication plan is to provide key messages associated with the public release of this report.

Key Messages

1. NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event.

PG&E's evaluation of the new seismic information, as documented in the report, concludes that the ground motions resulting from the faults discussed in the report (i.e.,

Shoreline, Hosgri, San Simeon, Los Osos. and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant

2. The NRC staff will review the new Information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.

3. PG&E will Incorporate the findings from 81111632 report Into their upcoming March 2015 probabilistic seismic hazard analysis as part of the NRC's post-Fukushima activities.

The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

1

DRAFT - eFFlelAt: USE ONLY SENS11'l't1E INTERNAL INFORMATION - N6T P'6" l'U9LIC "!L~A!!

Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.

Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195 Thomas Hipschman Sr. Resident Inspector -

R-IV /DRP/RPB-A 805-595-2354 OCPP John Reynoso Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 OCPP Jon Ake Senior Seismologist RES/OE/SGSEB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal OCPP Project Manager NRR/OORULPUV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Aff ajrs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Elaine Keegan License Renewal NRR/DLR 301-415--8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick OIFrancesco Japan Lessons Learned JLD 301-415-1115 Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Oiablo Canyon, should be used to accomplish these actions. The table below is based on a target public release date of the report on September 10, 2014.

Timeframe Action Responsible Party{ies)

Sept 8 PG&E provides a draft of the report in the PG&E electronic reading room for initial staff assessment Sept9 PG&E notifies NRC of seismic report submittal to PG&E the state of California 2

DRAFT - 6ff'ICtM: tf 9E 6NlY SENS1f1"t1E IN'fERN>\\L INF6RMlcTl6N - NM f6ft l'tf8Ue RetE>'c9E Timeframe Action Responsible Party(ies)

Sept10 PG&E/Diablo Canyon Power Plant submit seismic PG&E report to the state of California and issue a press release Promptly Region IV notifies the Communications T earn of R-IV/RPB-A

{within Sept PG&E's actions as currently understood and 10+1 business implements the Communications Plan day)

Entirety of Communications Team notifies R-IV; NRR/DORL; applicable Senior Managers in their respective NRR/DLR; NRR/JLO reporting chain OPA; OCA; OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. Blog possible Oct 3 JLD/NRO/RES completes preliminary assessment JLO/NRO/RES/RJV of published report and management decision is made if any additional actions should be taken prior to the submittal of the seismic reevaluation in March 2015. Updates to communication plan as appropriate As requested Complete a Commissioners Assistants Brief R-IV; NRR

1. Questions and Answers What is the impact of this new information on seismic design and licensing of DCPP?

Has the licensee entered this new information into the corrective action program and performed an operability evaluation?

In accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has entered the new preliminary seismic information into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of OCPP.

In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:

"tf during PG&E's ongoing collection of seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information (Reference 2)." Reference 2 is NRC letter to All Power Reactor licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54{f)

Regarding Recommendations 2.1. 2.3. and 9.3 of the Near-Tenn Task Force Review of Insights from the Fukushima Oai-lchi Accident," March 12, 2012.

NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation In their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there Is an Immediate threat to public health and safety nor did it call into question the ability of SSCs to 3

DRAFT - 6f flCIAt: US! 6NLY SENS1Trt1t: IN'fERNAt: 1Nf6RMM'l6N - N6T f6R ftUBLle REtEASE perfonn their specified safety functions or necessary and related support functions.

In addition, the NRC staff's review of the new seismic Information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

The NRC will review the new information provided in the report to the State of California inciuding the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit the conclusions in the RIL.

2. Has DCPP provided the seismic report to the NRC?

Yes, in accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has provided the information to the NRC. In addition, the report was also provided to address license renewal issues (see question 8).

3. What does the new report state?

The new report includes information obtained from 2-dlmensional and 3-dimenslonal high energy and low-energy seismic surveys both onshore and offshore of the DCPP site. The report provides more details on the regional faults, including more precise readings and additional data points where preV1ously there were gaps. While a lot of the infonnation from the previous Shoreline Fault report of 2011 was confirmed, some of the new data suggests the following:

Reduced slip rate on the Hosgri Fault Zone and the Shoreline Fault Zone Postulated connection of the Hosgri and the San Simeon faults which could result in a longer, larger, but more infrequent earthquake The unique geometry involved with intersecting the Hosgri Fault and the Shoreline Fault Zone results in an extension of a few kilometers, but with a lower frequency of occurrence Extension of the Shoreline Fault zone southern segment The new data does not alter the assessment of the closest approach of the Shoreline fault to DCPP which is 600 meters from the power block and 300 meters from the intake structure. Because the Shoreline fault is considered to be somewhat longer, potential earthquakes could also occur farther from the plant Updated analysis for the San Luis Bay, and Los Osos faults The report concludes that the ground motions for the Hosgrl and L TSP evaluations continue to bound potential ground motions from the regional fauJts, including the Shoreline Fault, San Luis Bay, Los Osos. San Simeon and Hosgrl. The DCPP continues to operate safely within the seismic margin they were designed to withstand.

4

DRAFT - 6FFlelAL US! 6NLY S!NSl1'fiE IN'ft:FtNAL INF6R:MAll6N - N6T Feft,ueue Ft!tl!1<9!

4. How will the AB 1632 seismic report be coordinated with the 50.54(f) required submittal In March 2015?

PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

(If pushed on any "unknowns" in the report: If necessary, actions could Include orders to halt operations if new information suggests there is an immediate safety concern. The NRC will fulfill its mandate to protect public health and safety).

(If asked what things the plant has done since Fukushima: It is important to note that DCPP Is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).

5. Why Is the report "final" for the state but "preliminary" for the NRC?

For the State, the report is final. For the NRC, this information is expected to be incorporated into the more comprehensive 50.54f analysis due to the NRC in March 2015.

However, because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is safe to continue to operate. PG&E's evaluation of the new seismic information. as documented in the report, concludes that the ground motions resulting from the faults discussed in the report (i.e.* Shoreline. Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

6. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault in 2011 prior to issuing the RIL?

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of Calrfomia's largest base-load power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station, to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs arid impacts from nuclear waste accumulating at these plants; and lo evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 report.

The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analyses which is due for DCPP in March 2015.

7. What is the impact of this new information on seismic design and licensing of DCPP?

Based on the preliminary results of the studies that are under review, PG&E determined that 5

DRAFT - 6PfilCl~L USI! 6NLY

!EN91fttif INTERN>>ed: INF6RMATl6N - N6T fOlt l'UBLIC ltl!t!AS!

the Shoreline Fault Zone may be capable of producing somewhat larger earthquakes than considered In the January 2011 Shoreline report The NRC staff is independently assessing PG&E's determination. The process outlined in the 50.54(f) letter includes a detailed analysis of new seismic information (including shoreline faults and other faults around the plant). PG&E is scheduled to provide this assessment in the March 2015 time frame. The staff will continue to review the Information in the new CA 1632 report and the final results of the new data from the more rigorous analysis to be completed by March 2015. The NRC staff will take appropriate regulatory action up to and including issuing Orders to ensure safe operation of the plant.

8. Will the Report be considered in the License Renewal Process Yes. In addition to the report being developed to address California Assembly Bill 1632, PG&E is providing the report to the State of California as part or the State of California coastal z.one consistency certification associated with the license renewal for OCPP. The State of California coastal zone consistency certification is considered by the NRC during the license renewal environmental review process. In addition, the Staff will be reviewing the report to see how. if at all, it is relevant to the Staff's license renewal review. There is a contention related to the Shoreline fault and its consideration in the facility's severe accident mitigation alternatives analysis that is admitted in the license renewal proceeding (see ML14224A320; See CU-11-11 ).

6

From:

Sent To:

Cc:

Subject:

Uselding, Lara Friday, September 05, 2014 10:01 AM Sebrosky, Joseph Burnell, Scott; Harrington, Holly; Brenner, Eliot; Dricks, Victor RE: question: who has the lead on the DPO communication plan and changes needed when DPO is released Hello Joe-I'm looping in HQ OPA so they know about the two efforts. I haven't heard anything on a separate OPO comm plan as we do have talkers in our current comm plan. I'm sure Mike or Eric can find out what the EDO's office message will be. We had discussed on one call that the EDO cover letter will include language that can be used as key messages.

Lara From: Sebrosky, Joseph Sent: Friday, September OS, 2014 7:18 AM To: Oesterle, Eric; Singal, Balwant; Markley, Michael; Walker, Wayne; Useldlng, Lara

Subject:

question: who has the lead on the DPO communication plan and changes needed when DPO is released Mike, Eric, Balwant, Wayne, and Lara, The purpose of this email is to inquire as to who has the headquarters lead on the DPO comm plan and adjustments to this comm plan that will be made to reflect when the DPO's panel's recommendations and the DPO appeal are made publicly available?

It is my current understanding that the DPO panel's response and the DPO appeal decision maybe made publicly available next week. Although independent of the public release of the State of California report, the two issues are sure to be tied together in questions to the NRC.

I understand that I have the headquarters lead to work with the Region on the draft communication plan for the State of California report (which will be adjusted on 9/9 based on our quick look at the report).

Who has the lead for making changes to the DPO communication plan to reflect questions that we may get after the OPO panel's recommendation and DPO appeal decision are made publicly available? A second related question is whether or not the DPO comm plan or the State of California comm plan will address the following question:

Would the OPO panel's conclusions or the DPO appeal decision change based on the new seismic information found in the State of California report?

Any insights would be appreciated.

Thanks, Joe 1

From:

Sent:

To:

Uselding, Lara Friday, September 05, 2014 2:25 PM McIntyre, David; Harrington, Holly Subject RE: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?

Yes, this is our life From: McIntyre, David Sent: Friday, September 05, 2014 1:25 PM To: Useldlng, Lara; Harrington, Holly

Subject:

FW: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?

Yeesh.

From: Markley, Michael Sent: Friday, September OS, 2014 2:22 PM To: McIntyre, David

Subject:

RE: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?

Okay, thanks!

From: McIntyre, David Sent: Friday, September 05, 2014 2:18 PM To: Markley, MichaeJ; Oesterle, Eric CC: Walker, Wayne; Wertz, Trent; Singal, Balwant; Lyon, Fred; Sebrosky, Joseph; Walker, Wayne; Burnell, Scott; Alexander, Ryan; Uselding, Lara; Burnell, Scott; Pedersen, Renee; Lund, Louise

Subject:

RE: cAN YOU PLEASE SEND DAVE THE LATEST COMM PL.AN?

Mike, Joe, et al - the Comm Plan was NOT given to the Commission. This was one of those "hair on fire* things that went like this:

1. I was asked by the Chairman's COS to prepare talking points on the Foreign Ownership SECY in time for him to present to other COSs at 1030.

2. At 1015, Chairman's COS asks me to attend the 1030 uand bring the Diablo DPO Comm Plan"

3. I call Lara, who sends the urgent request to you guys.

4. I get several documents and print out a pile at 1028 and rush upstairs.

5. The other COS don't want to see the Comm Plans. I mentioned that it was in draft and would be updated after staff is briefed on the CA seismic study and sees EDO's letter on the DPO decision. Everyone was satisfied, and I brought the stack of papers back downstairs with me.

So please pretend that all this never happened and do what you intended to do all along.

And thanks for your help! © From: Markley, Michael Sent: Friday, September 05, 2014 2:05 PM To: Oesterle, Eric Cc: Walker, Wayne; Wertz, Trent; Singal, Balwant; Lyon, Fred; Sebrosky, Joseph; Walker, Wayne; Burnell, Scott; Alexander, Ryan; Uselding, Lara; Burnell, Scott; Pedersen, Renee; McIntyre, David; Lund, 1

Louise

Subject:

FW: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?

Eric, Joe raises a worthy point. Since the RIV Communications Plan is now with the Commission, it makes no sense for us to finalize the communications plan we had in process. Our task on Monday will be to update the DPO portion of what is already out there with insights from the DPO case file. We will need to get that incorporated and routed quickly so that it is ready to use when the appeal is issued.

Likewise, once we have access to the AB1632 report, we will need to update that section as well.

Mike From: 5ebrosl<y, Joseph sent: Friday, 5eptember OS, 2014 1:10 PM To: Markley, Michael; Oesterle, Eric Cc: Singal, Balwant

Subject:

RE: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?

Mike and Eric, If you look at the email chain below you will see that the attached pdf version of RIV's Diablo Canyon communication plan has been provided to the Chairman's staff (Phillip Niedzielski-Eichner) with the caution that the DPO portion and the State of California report section is to be updated.

I will call you at 1 :30 in Mike's office to discuss this and other things.

Thanks, Joe From: McIntyre, David Sent: Friday, September 05, 2014 10:41 AM To: Alexander, Ryan Cc: Uselding, Lara; McIntyre, David; 5ebrosky, Joseph; Walker, Wayne; Buchanan, Theresa

Subject:

RE: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?

Understood. Thanks!

Sent via My Workspace for iOS On Friday, September 5, 2014 at 10:34:55 AM, "Alexander, Ryan" <Ryan.Alexander@nrc.gov>

wrote:

David:

Per your request of Lara, attached is the current "best version" of the DCPP Comm Plan.

HOWEVER, please note:

2

(1) The section on AB-1632 California Report is only a limited strawman pending input from Joe Sebrosky (NRR) on Tuesday, 9/9 following the staff's initial review of the AB-1632 report (limited availability on 9/8).

(2) The Non-Concurrences/OPO section is only updated to the point knowing that the OPO is still in process without any additional information regarding what the DPO Panel's/NRR Director's conclusions were.

RIV (with NRR's input) plans to put the Comm Plan into concurrence on or about 9/9 so that this document can finally be formalized and available on the OEOO Comm Plan website.

Please contact Wayne Walker (RIV DRP BC for OCPP - Office: 817-200-1148) with any questions.

Thank you, Ryan D. Alexander Senior Project Engineer NRC Region IV, Div. of Reactor Projects, Branch A Office:

817 200-1195 Cell:

!b)(6)

~

Please consider the environment before printing this e-mall.

From: Useldlng, Lara sent: Friday, September 05, 2014 9:15 AM To: Sebrosky, Joseph; McIntyre, David; Walker, Wayne; Alexander, Ryan

Subject:

Joe: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?

Importance: High f rom: McIntyre, David Sent: Friday, September OS, 2014 9:11 AM To: Useldlng, Lara

Subject:

Oiablo OPO Lara - can you help with this?

f rom: Niedzielskl-Eichner, Phillip Sent: Friday, September OS, 201410:10 AM To: McIntyre, David

Subject:

RE: REVISED FOCD Talking Points One additional questlon...is there a Com Plan for Diablo Canyon?

From: Niedzielski-Eichner, Phillip Sent: Friday, September OS, 2014 10:09 AM To: McIntyre, David

Subject:

RE: REVISED FOCO Talking Points Dave... will we have talking points for the Diablo Canyon DPO? Are you planning to join us at 10:30 am? Thanks. Phil From: Mcintyre, David Sent: Friday, September OS, 2014 10:04 AM

)

To: Niedzielski-Eichner, Phillip Cc: Dorman, Dan; Howe, Allen; Layton, Michael; Mizuno, Beth; Dusaniwskyj, Michael; Simmons, Anneliese; Morris, Scott; Galloway, Melanie; Uhle, Jennifer; Burnell, Scott; Harrington, Holly; Brenner, Eliot; Vietti-COOk, Annette; Schwartzman, Jennifer

Subject:

REVISED FOCD Talk!ng Points Importance: High Phil - Attached are revised talking points on the FOCD SECY paper, for your use in this morning's COS meeting. These incorporate edits and comments from NRR (Scott Morris) and OGC (Ed Williamson).

Dave 4

From:

Sent:

To:

Subject:

Brenner, Eliot Wednesday, September 03, 2014 12:16 AM Niedzielski-Eichner, Phillip; Harrington, Holly Re: FOCD and Diablo Canyon Communication Planning With me gone, I think dave mcintyre would be our likely suspect.

- ----Original Message-----

From: phillip niedzielski-eichner To: Helton, Shana To: Gilles, Nanette To: Jennifer Schwartzman To: Vrahoretis, Susan To: Eliot Brenner To: Eugene Dacus To: amy powell To: holly harrington To: Margaret Doane To: Vietti-Cook, Annette To: Brock, Kathryn To: Galloway, Melanie To: AMMGroupCalendar Resource

Subject:

FOCD and Diablo Canyon Communication Planning Sent: Sep 2, 2014 11:15 PM All - please see request from Phil, below. Please determine the appropriate person from your office to attend, given the topic and forward the meeting invitation as needed. If you have a conflict, please let me know directly. Thanks, Patti Pace X1750 "The Commission has, or will soon have, before it two high visibility issues: (1) the Foreign Ownership, Control, and Domination and (2) Diablo Canyon Seismic Risks. Will you please invite OCA, OPA, OGC, SECY, and OEDO to a 45 minute staff-level discussion this week on how we will be prepared to respond, in particular, to anticipated strong interest from the Hill for background information? The outcome would be a path forward for discussion with the Commission offices early next week. Thanks. Phil" 1

From:

Sent:

To:

Subject:

Uselding, Lara Tuesday, August 26, 2014 3:17 PM Brenner, Eliot; Harrington, Holly; Burnell, Scott Update Per the below status on state report I want to wait and write a blog to correspond with its release. So for now, no blog coming from me on Diablo Original Message---

From: Hipschman, Thomas Sent: Tuesday, August 26, 2014 2:12 PM To: Sebrosky, Joseph; Markley, Michael; Oesterle, Eric; Kanatas, Catherine; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Clifford; OKeefe, Neil; Folk, Kevin; Wrona, David; DiFrancesco, Nicholas; Balazik, Michael; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Lyon, Fred Cc: Well, Jenny; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott

Subject:

RE: action: request for feedback on Diablo Canyon communication plan associate with State of California seismic report The licensee stated they are now looking at September 9 or 10 for the release of the report, and stakeholder outreach the day before.

Tom

--Original Message--

From: Sebrosky, Joseph Sent: Tuesday, August 26, 2014 10:25 AM To: Markley, Michael; Oesterle, Eric; Kanatas, Catherine; Hipschman, Thomas; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Clifford; OKeefe, Neil; Folk, Kevin; Wrona, David; DiFrancesco, Nicholas; Balazik, Michael; Hipschman, Thomas; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Useldlng, Lara; Lyon, Fred Cc: Weil, Jenny; U, Yong; Manely, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott

Subject:

action: request for feedback on Diablo Canyon communication plan associate with State of California seismic report To all, The purpose of this email is to request your comments on the attached draft communication plan associated with PG&E's pending release of a report to the State of California related to seismic issues. PG&E has indicated to the staff that the report will include an updated evaluation of the Shoreline Fault and concludes that the Shoreline Fault Is more capable than assumed in PG&E 2011 report that was provided to the NRC.

Comments from Jon Ake, Britt Hill would be appreciated by noon tomorrow. I will incorporate their comments and provided the product to the Region IV by COB tomorrow. (Britt I tried to capture some of your comments that you have provided and also some verbal comments t hat Jon provided me)

I understand that Tom Hipschman will talk to PG&E to confirm when they intend to issue the report to the State of California. PG&E previously indicated that it would be between 8/28 and 9/8. Tom believes that PG&E is now leaning towards issuing the report on 9/8 or 9/ 9. Once Tom confirms the target date for issuance of the report, the folks on distribution for this email will be informed.

1

Please let me know if you have any questions. I will be working with DORL and the JLD to coordinate headquarters review of the communication plan.

Thanks, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph.sebrosky@nrc.gov 301-415-1132 2

DRAFT - 6FFl611ct tJ9E 6NL¥ Sl!NSITl't11! INTl!"NAL INIIOftMAl'ION - NOT l'Oft f'tJ9LIC M!!Let<SI!

UPDATED:

09/25/2014 3:51 PM Communications Plan -

Diablo Canyon Power Plant Topics of Interest State of California Seismic Report (ABN-1632)

Background

California Assembly Bill 1632 (Blakeslee. Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety. and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio.

The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report. This is different methodology than what was used for the 201 1 Shoreline Fault.

The purpose of this communication plan is to provide key messages associated with the public release of this report.

Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.

Team Member Position Organization T&tephone Wayne Walker Branch Chief R-IV/DRP/RPB-A 81 7-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195 Thomas Hipschman Sr. Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 DCPP John Reynoso Resident Inspector -

R-IV/DRP/RPB-A 805-595-2354 OCPP Jon Ake Senior Seismologist RES/OE/SGSEB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 1

DRAFT - Ol'l'ICIAL t'JS! 6NLY S!f4SITl't1! INT!ftNAL INflOftM>tTION - NM fl6ft fltH!tle ft!L!ASE Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Jenny Weil Congressional Affairs OCA 301-415-1691 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-151 9 Bill Maier State Liaison Officer RIV 817-200-1267 Dave Wrona License Renewal NRR/DLR OGC Nick DiFrancesco JLD Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Diablo Canyon, should be used to accomplish these actions.

Timeframe Action Responsible Party(iee)

T -1 PG&E notifies NRC of seismic report submittal to PG&E the state of California T=O PG&E/Diablo Canyon Power Plant submit seismic PG&E report to the state of California and issue a press release Promptly Region IV notifies the Communications Team of R-IV/RPB-A (within T+1 PG&E's actions as currently understood and business day) implements the Communications Plan Entirety of Communications Team notifies R-IV; NRR/DORL; applicable Senior Managers in their respective NRR/DLR; NRR/JLD reporting chain OPA; OCA; OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. NO blog OR press release planned.

WithinT+2 Other actions??

???

business days As requested Complete a Commissioners Assistants Brief R-IV; NRR

1. Questions and Answers What Is the Impact of this new information on seismic design and licensing of DCPP?

Has the licensee entered this new infonnation into the corrective action program and performed an operabiHty evaluation?

As required by the NRC, as document in RIL 2012-001, PG&E has entered the new 2

DRAFT - OlililCIAL tJS! ONLY 9EN91ll't1e INlERNAL INFORMAllON - NOT FeR PUBLIC RELEASE preliminary seismic Information Into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.

In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:

"If during PG&E's ongoing collection of seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information (Reference 2)." Reference 2 is NRC letter to All Power Reactor Licensees and Holders of Construction Permits Jn Active or Deferred Status.

"Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," March 12, 2012.

Region IV, including the resident inspectors, have taken an initial review of PG&E's assessment of this new information to verify that it does not affect the plant's ability to operate safely and to be able to remain safely shutdown following an earthquake. NRC's preliminary review Is that the Diablo Canyon Units are safe to continue to operate based on:

Based on assertions made by PG&E that the Shoreline Fault response spectra are still bounded by those for the Hosgri and L TSP earthquakes for which the plant was previously analyzed The preliminary assessment by PG&E that the Shoreline Fault is capable of generating a magnitude 6. 7 earthquake. As documented in the RIL the NRC staff has analyzed a scenario involving a Shoreline Fault of magnitude 6. 7 and concluded that the response spectra developed by such an earthquake is bounded by the Hosgri and L TSP spectra The NRC will review the new information provided in the report to the State of Califomia including the Shoreline Fault characteristics, and the upda1ed characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate If the NRC staff concludes that the new Information associated with the Shoreline Fault causes the NRC staff to revisit the conclusions in the RIL.

2. Has OCPP provided the seismic report to the NRC?

The new information, required by the state of CA AB 1632, has been provided to the NRC and shows that some previously separated segments of the Shoreline fault system are connected. These connections indicate that if the Shoreline Fault slips in the future. the earthquake from that slip might be slightly higher than previously considered possible for the Shoreline Fault. But because the Shoreline Fault is somewhat longer, potential earthquakes could also occur farther from the plant. For these reasons, PG&E continues to believe that the ground motions for the Hosgri and L TSP evaluations continues to bound potential ground motions from the Shoreline Faull 3

DRAFT - Ol'fllCl,tt tJS! ONLY 9EN9tfl*,*e IN'ffRNl<L INF6RMl<fl6N - Nef FeR PtlBLte RELUcSe

3. How will the AB 1632 seismic report be coordinated with the 50.54(f) required submittal in March 2015?

The NRC has reviewed the plant's corrective action program documentation for this new information. All indications are that the Shoreline fault remains bounded by the Hosgri fault for which the plant was licensed to withstand. The staff will continue to review the new information associated with the Shoreline Fault causes the NRC staff to revisit the conclusions in the RIL.

The 1000-page document has also been given to the Japan Lessons lea med Directorate to be considered in the 50.54(f) review. Consistent with the UFSAR, the new preliminary information regarding regional source characterization (i.e. fault capability) and potential site ground motion will be evaluated in accordance with the process defined by the NRC in their Fukushima 50.54(f) letter, through the SSHAC process and a final seismic hazard and Ground Motion Response Spectra (GMRS) that will be submitted to the NRC by March 2015. The updated Seismic Hazards/GMRS will be used as input to an updated Seismic Probabilistic Risk Assessment (SPRA), which will be submitted to the NRC by June 2017.

(If pushed on any "unknowns* in the report: If necessary, actions could include orders to halt operations if new information suggests there is an immediate safety concern. The NRC will fulfill its mandate to protect public health and safety).

(If asked what thins the plant has done since Fukushima: It is Important to note that DCPP is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).

4. Why is the report 11flnal" for the state but "preliminary" for the NRC?

For the state, the report is final. For the NRC1 this lnformation will is expected to be incorporated considered into the more comprehensive 50.54f analysis due to the NRC in March 2015. However, because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is safe to operate. The NRC has looked at this evaluation and its preliminary assessment is that based on the information presented by PG&E the Shoreline Fault does not exceed previously considered seismic hazards.

5. Why didn't the NRC discover the length of the faults when it did Its seismic review of the Shoreline fault in 2011 prior to issuing the RIL?

California Assembly Bill 1632 (Blakeslee, Chapter 72-2. Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station, to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of -the-art 2D and 3D geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide 4

DRAFT - OfifilCIAt tJSE ONLY 9ENS1fl't1E IN'fl:ftNAL 1Nfi6"M*'16N - NO'f fi6ft,-tJ8UC ftl!~A9!

higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 report.

The NRC has requested licensees to submit a seismic hazard reevaluation using up-to-date methodologies and analysis which is due for DCPP In March 2015. (Lauren, JLLD: anything to add here?)

6. What is the impact of this new Information on seismic design and licensing of DCPP?

Based on the preliminary results of the studies that are under review, PG&E determined that the Shoreline Fault Zone may be capable of producing slightly larger earthquakes than considered in the January 2011 repQrt. However, the ground motions from these larger earthquakes are still bounded by the Hosgri and L TSP ground motions. Since the seismic design of DCPP considered a range of ground motions from both a double design earthquake and a Hosgri earthquake, and the new ground motions do not exceed the Hosgri earthquake, the new information Is not expected to adversely impact the seismic design of DCPP. As a result, the assessment associated with the January 2011 Shoreline Fault Report remains valid.

5

NRC FORM 464 Part I (06-2013)

U.S. NUCLEAR REGULATORY COMMISSION FOIA/PA 2014-0488 RESPONSE NUMBER 3

RESPONSE TO FREEDOM OF INFORMATION ACT (FOIA) / PRIVACY ACT (PA) REQUEST

RESPONSE

TYPE D FINAL 0 PARTIAL REQUESTER Damon Moglen DATE D

D 0

0 PART I. - INFORMATION RELEASED No additional agency records subject to the request have been located.

Requested records are available through.another public distribution program. See Comments section.

rGRoui:>--* Agency records subject to the request that are identified in the specified group are already available for

E

! public inspection and copying at the NRC Public Document Room.

""-****----*1

!GROUP I Agency records subject to the request that are contained in the specified group are being made available for

!F & G **--

! public inspection and copying at the NRC Public Document Room.

1/1

°GROUP I

L!.J !F & G I Agency records subject to the request are enclosed.

D 0

0

'-* ________ _J Records subject to the request that contain information originated by or of interest to another Federal agency have been referred to that agency (see comments section) for a disclosure determination and direct response to you.

We are continuing to process your request.

See Comments.

AMOUNT' PART I.A** FEES D You will be billed by NRC for the amount listed.

D You will receive a refund for the amount listed.

D None, Minimum fee threshold not met.

D Fees waived.

s I I

• See comments for details D

0 D

PART I.B -- INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE No agency records subject to the request have been located. For your information, Congress excluded three discrete categories of law enforcement and national security records from the requirements of the FOIA. See 5 U.S.C. § 552(c)

(2006 & Supp. IV (2010). This response is limited to those records that are subject to the requirements of the FOIA. This is a standard notification that is given to all our requesters and should not be taken as an indication that excluded records do, or do not, exist.

Certain information in the requested records is being withheld from disclosure pursuant to the exemptions described in and for the reasons stated in Part II.

This determination may be appealed within 30 days by writing to the FOIA/PA Officer, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Clearly state on the envelope and in the letter that it is a "FOIA/PA Appeal."

PART LC COMMENTS ( Use attached Comments continuation page if reciuired)

The incoming request FOIA/PA 2014-0488 is available in ADAMS as MLl4261A399.

Portions of documents have been marked out of scope as the information does not concern Diablo Canyon and the DPO. If there are attachments referenced in e-mail messages that are not included, they are duplicates, were addressed in prior interim responses, or already publicly available.

Records with an ML acce iion number are available in the NRC Library at www.nrc.gov/reading-nn/adams.html. For assistance in obtaining an 1public rec7 ~s, please contact the NRC's Public Document Room (PDR) at 1-800-397-4209 or by e-mail at PDR.

Resomce@; t;J {

SIGNATURE

• FREEDOM OF INFORM ION ACT ANO PRIVACY ACT OFFICER Roger D. Andoh NRC FORM 464 Part 1 (08-2013)

NRt FORM 464 Part II U.S. NUCLEAR REGULATORY COMMISSION FOIA/PA (08-2013)

/~

".\\

2014-0488

\\

j RESPONSE TO FREEDOM OF INFORMATION

~CT (FOIA) / PRIVACY ACT (PA) REQUEST PART II.A - APPLICABLE EXEMPTIONS DATE I.U.J w,n 2 7, )DIS

• IGGROUP I Records subject to tlie request that are contained in the specified group are being withheld in their entirety or in part under the Exemption No.(s) of the PA and/or the FOIA as indicated below (5 U.S.C. 552a and/or 5 U.S.C. 552(b)).

~-----'

D D

Exemption 1: The withheld information is property classified pursuant to Executive Order 12958.

Exemption 2: The withheld information relates solely to the internal personnel rules and practices of NRC.

D DExemplion 3: The withheld information is specifically exempted from public disclosure by statute indicated.

Sections 141-145 of the Atomic Energy Act, which prohibits the disclosure of Restricted Data or Formerly Restricted Data (4iU.S.C.

2161-2165).

D 0

0 D

D Section 147 of the Atomic Energy Act, which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).

41 U.S.C., Section 4702(b), prohibits the disclosure of contractor proposals in the possession and control of an executive agency to any person under section 552 of Title 5, U.S.C. (the FOIA), except when incorporated into the contract between the agency and the submitter of the proposal.

Exemption 4: The withheld information is a trade secret or commercial or financial information that is being withheld for the reason(s) indicated.

D D

D D

The information is considered to be confidential business (proprietary) information.

The information is considered to be proprietary because ii concerns a licensee's or applicant's physical protection or material control and accounting program for special nuclear material pursuant to 10 CFR 2.390(d)(1).

The information was submitted by a foreign source and received in confidence pursuant to 10 CFR 2.390(d)(2).

Disclosure will harm an identifiable private or governmental interest.

Exemption 5: The withheld information consists.of interagency or intraagency records that are not available through discovery during litigation.

0 D

D Applicable privileges:

Deliberative process: Disclosure of predecisional information would tend to inhibit the open and frank exchange of ideas essential to the deliberative process. Where records are withheld in their entirety, the facts are inextricably intertwined with the predecisional information.

There also are no reasonably segregable factual portions because the release of the facts would permit an indirect inquiry into the predecisional process of the agency.

Attorney work-product privilege. (Documents prepared by an attorney in contemplation of litigation)

Attorney-client privilege. (Confidential communications between an attorney 13nd his/her client)

Exemption 6: The withheld Information is exempted from public disclosure because its disclosure would result in a clearly unwarranted invasion of personal privacy.

Exemption 7: The withheld information consists of records compiled for law enforcement purposes and is being withheld for the reason(s) indicated.

D D

D D

D (A) Disclosure could reasonably be expected to interfere with an enforcement proceeding (e.g., it would reveal the scope, direction, and focus of enforcement efforts, and thus could possibly allow recipients to take action to shield potential wrong doing or a violation of NRC requirements from investigators).

(C) Disclosure could constitute an unwarranted invasion of personal privacy.

(D) The information consists of names of individuals and other information the disclosure of which could reasonably be expected to reveal identities of confidential sources.

(E) Disclosure would reveal techniques and procedures for law enforcement investigations or prosecutions, or guidelines that could reasonably be expected to risk circumvention of the law.

D (F) Disclosure could reasonably be expected to endanger the life or physical safety of an individual.

D OTHER /Soecifvl I

PART 11.B - DENYING OFFICIALS Pursuant to 10 CFR 9.25(9), 9.25(h), and/or 9.65(b) of the U.S. Nuclear Regulatory Commission regulations, it has been determined that the information withheld is exempt from production or disclosure, and that its production or disclosure is contrary to the public interest. The person responsible for the denial are those officials identified below as denying officials and the FOIA/PA Officer for any denials that may be appealed to the Executive Director for Operations (EDO).

RECORDS DENIED APPELi.A TE OFFICIAl DENYING OFFICIAL TITLE/OFFICE EOO SECY IG Eliot Brenner Director, Office of Public Affairs G5-G6, GS D0D Rachel Bavol Director, Office of the Secretary of the Comm.

G1-G2 LJ 0 D William M. Dean Director, Office of Nuclear Reactor Regulation G3-G4, GS, G9-G36 0D D Appeal must be made in writing within 30 days of receipt of this response. Appeals should be mailed to the FOIA/Privacy Act Officer, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, for action by the appropriate appellate official(s). You should clearly state on the envelope and letter that it is a "FOIA/PA Appeal."

NRC FORM 464 Part II (08-2013)

NRC: FORM 464 Part II U.S. NUCLEAR REGULATORY COMMISSION FOIA/PA (08-2013)

.~¥.;..,.

2014-0488 r

<i

~

\\

.l RESPONSE TO FREEDOM OF INFORMATION ACT (FOIA) / PRIVACY ACT (PA) REQUEST PART II.A ** APPLICABLE EXEMPTIONS DATE I

GGROVP I Records subject to the request that are contained in the specified group are being withheld in their entirety or in part under the Exemption No.(s) of the PA and/or the F01A as indicated below (5 U.S.C. 552a and/or 5 U.S.C. 552(b)).

D D

Exemption 1: The withheld information is properly classified pursuant to Executive Order 12958.

Exemption 2: The withheld information relates solely to the internal personnel rules and practices of NRC.

D Exemption 3: The withheld information is specifically exempted from public disclosure by statute indicated.

D Sections 141-145 of the Atomic Energy Act, which prohibits the disclosure of Restricted Data or Formerly Restricted Data (42 U.S.C.

2161-2165).

D D

Section 147 of the Atomic Energy Act, which prohibits the disclosure of Unclassified Safeguards Information (42 U.S.C. 2167).

41 U.S.C., Section 4702(b), prohibits the disclosure of contractor proposals In the possession and control of an executive agency to any person under section 552 of Tille 5, U.S.C. (the FOIA), except when incorporated into the contract between the agency and the submitter of the proposal.

D Exemption 4: The withheld information is a trade secret or commercial or financial information that is being withheld for the reason(s) indicated.

D 0

D D

D D

D The information is considered to be confidential business (proprietary) information.

The information is considered to be proprietary because it concerns a licensee's or applicant's physical protection or material control and accounting program for special nuciear material pursuant to 1 O CFR 2.390(d)( 1 ).

The information was submitted by a foreign source and received In confidence pursuant to 10 CFR 2.390(d)(2).

Disclosure will harm an identifiable private or governmental interest.

Exemption 5: The withheld information consists of interagency or intraagency records that are not available through discovery during litigation.

Applicable privileges:

D Deliberative process: Disclosure of predecisional information would tend to inhibit the open and frank exchange of ideas essential to the deliberative process. Where records are withheld in their entirety, the facts are inextricably intertwined with the predecisional information.

There also are no reasonably segregable factual portions because the release of the facts would permit an Indirect inquiry into the predecisional process of the agency.

D,.....

Attorney work-product privilege. (Documents prepared by an attorney in contemplation of litigation)

D Attorney-client privilege. (Confidential communications between an attorney and his/her dient)

Exemption 6: The withheld information is exempted from public disclosure because its disclosure would result In a clearly unwarranted invasion of personal privacy.

Exemption 7: The withheld information consists of records compiled for law enforcement purposes and is being withheld for the reason(s) indicated.

D D

D D

(A) Disclosure could reasonably be expected to interfere with an enforcement proceeding (e.g., it would reveal the scope, direction, and focus of enforcement efforts, and thus could possibly allow recipients to take action to shield potential wrong doing or a violation of NRC requirements from investigators).

(C) Disclosure could constitute an unwarranted invasion of personal privacy.

(D) The information consists of names of individuals and other information the disclosure of which could reasonably be expected to reveal identities of confidential sources.

(E) Disclosure would reveal techniques and procedures for law enforcement investigations or prosecutions, or guidelines that could reasonably be expected to risk circumvention of the law.

D (F) Disclosure could reasonably be expected to endanger the life or physical safety of an individual.

D OTHER (Soeciw)

I PART 11.B -- DENYING OFFICIALS Pursuant to 10 CFR 9.25(g}, 9.25(h), and/or 9.65(b) of the U.S. Nuclear Regulatory Commission regulations. it has been determined that the information withheld is exempt from production or disclosure, and that its production or disclosure is contrary to the public interest. The person responsible for the denial are those officials identified below as denying officials and the FOIA/PA Officer for any denials that may be appealed to the Executive Director for Operations (EDO).

RECORDS DENIED APPEi.i.A TE OFFICIAL DENYING OFFICIAL TITLE/OFFICE EDO SECY 1G Marc L. Dapas Regional Administrator, Region IV G7 0DD LJ LJ LJ DOD Appeal must be made in writing within 30 days of receipt of this response. Appeals should be mailed to the FOIA/Privacy Act Officer, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, for action by the appropriate appellate official(s). You should clearly state on the envelope and letter that it is a "FOIA/PA Appeal."

NRC FORM 464 Part II (08-2013)

From:

Sebrosky, Joseph Se nt:

Tuesday, September 16, 2014 11:23 AM Buchanan, Theresa To:

Cc:

Alexander, Ryan; Walker, Wayne; Hipschman, Thomas; Uselding, Lara; Maier, Bill; Williams, Megan; Oesterle, Eric; Singal, Balwant; Moreno, Angel; Markley, Michael

Subject:

FW: Diablo Canyon Topic.s of Interest Communication Plan review and concurrence Updated Memo Req Concurrence on Rev O.docx; Diablo Communication Plan - Rev 0 (9-11-14).docx Attachments:

Theresa, I concur on the communication plan with the understanding that the following major comments will be resolved:

Major Comments Current licensing basis questions - question 4 page 50 o

I believe this answer needs to be rewntten such that 1t is consistent with the statement PG&E makes in its withdrawal letter. See withdrawal letter found at following link http://pbadupws.nrc.gov/docs/ML 1335/ML133548966.html. That is, PG&E withdrew the LAR due to the issuance of the process outlined in the 50.54(f} letter and the NRC's letter dated October 12, 2012. Based on these letters PG&E no longer believed it needed to define an evaluation process for newly identified seismic information and the license amendment was withdrawn. The second paragraph in the response is not accurate. The NRC did not require that the hosgri fault be assessed against the DOE. Rather the NRC.requested the licensee to provide a comparison of the hosgri evaluation against the guidance in the current SRP. PG&E subsequently provided a 130 page response detailing a comparison of the hosgri evaluation against SRP guidance Current license basis questions - question 5, 6, 7, and 8 o

The response indicates that the FSAR will be required to be updated as a result of the 50.54(f) letter. This Is not true. Phase 2 of the 50.54(f) process will make that determination. It is not been predetermined that this will be required. It is also not true to suggest that 50. 71 (e) requires licensees to update their FSARs for new seismic or flooding information. This position is inconsistent with the position OGC took on North Anna seismic issues, and if it were true would render the Fukushima action to periodically assess new seismic and flooding information unnecessary Minor comments DPO stuff on page 6 and 7 needs to be updated based on the DPO now being publicly available DPO stuff on pages 43, and 44 should also be updated at some point Current licensing basis question 1 on page 49 suggests that 1 O CFR Part 50 Appendix A applies to Diablo. Diablo is a pre-GDC plant. The response should include a discussion that the pre GDC 2 and GDC 2 are similar in nature. I don't think we should leave the impression that Diablo is a Part 50 Appendix A GDC plant Let me know if you have any questions or if I am missing something

Thanks, Joe From: Buchanan, Theresa Sent: Thursday, September 11, 2014 2:53 PM To: Sebrosky, Joseph subject: FW: Diablo canyon Topics of Interest Communication Plan review and concurrence From: Buchanan, Theresa Sent: Thursday, September 11, 2014 1:20 PM To: Alexander, Ryan; Walker, Wayne; Prue~ Troy; Hay, Michael; Hipschman, Thomas; Uselding, Lara; Maier, Bill; WIiiiams, Megan; Oesterle, Erle; Singal, Balwant; Moreno, Angel SUbJect: Diablo Canyon Topics of Interest Communication Plan review and concurrence

Hello, You are all listed on the attached memo for concurrence on the also attached Diablo Canyon "overall" communication plan. Because this communication plan was extensively reviewed and commented upon back in March, I am asking that you do a review of only the significant changes, specifically associated with the AB 1632 report, DPO, and Sewell report sections. Each section can be reached from the table of contents on page 8. Since both the AB-1632 and DPO sections are excerpted from their own reviewed and approved communication plans, I am asking for you to review and comment \\Yithin the next few days so that I can get this communication plan issued the beginning of next week. I realize that is short turnaround, but as I said, the majority of this document has already been reviewed, commented upon, and comments incorporated.

Thank you for your timely response to this short turnaround item.

Theresa Buchanan Senior Project Engineer RIV DRP Branch A 817-200-1503 2

MEMORANDUM TO:

FROM:

SUBJECT:

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E LAMAR BLVD ARLINGTON, TX 76011-4511 September 11, 2014 Wayne Walker, Chief Division of Reactor Projects, Branch A Multiple Addressees, as listed below COMMUNICATIONS PLAN - DIABLO CANYON POWER PLANT TOPICS OF INTEREST The purpose of this memo is to transmit and request comments/concurrence on the enclosed Communications Plan for Diablo Canyon Power Plant (DCPP}. The enclosed docunnent is based on several iterations of informal communication plans, Q&A documents, and responses to congressional questions developed primarily by Region IV, NRR, OPA, and OCA over the last several years.

This communication plan describes the methods and resources that NRC staff will use to communicate with internal and external stakeholders regarding the DCPP seismic history and ongoing seismic evaluations being conducted in response to the Japan Lessons Learned Near-Term Task Force recommendations. Additionally, as applicable to current issues of interest to DCPP stakeholders, this communications plan integrates key messages related to spent fuel/dry cask storage and waste confidence issues (primarily by referencing other active communication plans).

This revision also incorporates Q&As for the most recent issues of concern including the licensee's AB-1632 Report to the State of California and the "Sewell Report."

Once finallzed, the Communications Plan will be posted on the OEDO Communications website for use by the communications team and more broadly across the agency as necessary.

Most of those on concurrence have each provided significant input to iterations of this document (or documents from which this Plan was developed}. As such, we are requesting your review/comments/concurrence in the next few days (due by COB, Monday, September 15). Please forward your comments/concurrence on the document to Theresa Buchanan (Theresa.Buchanan@nrc.gov and/or ph: (817) 200-1503) of my staff.

The concurrence block noted on the next page will be used to document your concurrence on the enclosed Communications Plan.

Enclosure:

As stated

Multiple Addressees The individuals whose concurrence is requested for this Communications Plan are:

T. Pruett, Acting Division Director, RIV/DRP M. Hay, Acting Deputy Division Director, RIV/DRP W. Walker, Chief, RIV/DRP/RPB-A T. Hipschman, Sr. Resident Inspector, RIV/DRP/RPB-A L. Uselding, RIV/OPA W. Maier, RIV/RSLO M. Williams, RIV/DRS/EB1 E. Oesterle, Acting Chief, NRRIDORULPL-IV-1

8. Singa~. Senior Project Manager, NRR/DORL/LPL-IV-1 A. Moreno, OCA RIV/DRP/A RIV/DRP/A RIV/DRP/A RAlexander TBuchanan THipschman 09/

/2014 09/

/2014 I

/2014 RIV/RSLO RIV/DRS/EB1 NRR/DORULPL-IV-1 WMaier MWilliams BSingal I

/2014 I

/2014 I

/2014 OCA RIV/DRP RIV/ORP AMoreno MHay TPruett I

/2014 I

/2014 I

/2014 RIV/DRP/A WVValker I

/2014 NRR/DORULPL-IV-1 EOester1e I

/2014 OFFICIAL RECORD COPY RIV/OPA LUselding I

/2014 NRR/JLD JSebroskv I

/2014

Purpose Ofl11CIAL t:19! eNtY 8!:N9ffl'if lf4ff:fOtAL lrtf8RMAif48U UPDATED:

10103/20141:13 PM Communications Plan -

Diablo Canyon Power Plant Topics of Interest This communication plan describes the methods and resources that NRC staff will use to communicate with internal and external stakeholders regarding the Olablo Canyon Power Plant (DCPP) seismic history and ongoing seismic evaluations being conducted in response to the Japan lessons learned Near-Term Task Force recommendations. This plan also provides key messages concerning NRC current and historical actions and decisions concerning seismic issues involving DCPP to be used by staff.

Additionally, as applicable to current questions raised by OCPP stakeholdefS, this communications plan integrates key messages related to spent fuel/dry cask storage and waste confidence (primarily by referencing other active communication plans).

This communications plan will be continuously evaluated for the need to update key messages, and a full review/update will be evaluated approximately once per calendar quarter.

NOTE: Although this communication plan is marked as OUO-SII, all sections marked as 11Key Messages" and "Questions and Answers" are releasable to the public.

Summarv of Background Seismic Information and Assessments Pacific Gas & Electric (PG&E) proposed 0.2g ground acceleration for an Operating Basis Earthquake (OBE) and 0.4g ground acceleration for a Safe Shutdown Earthquake (SSE) in its construction permit applications in 1967 and 1968. (Note: PG&E uses the terms Design Earthquake and Double Design Earthquake when referring to the OBE and SSE, respectively.)

After construction permits were issued, during the Atomic Energy Commission's and NRC's review of information submitted to support operating licenses, new information became available as a result of offshore seismic surveys. These surveys identified the Hosgri fault, approximately 3.5 miles offshore of the OCPP site. After assessing information provided by PG&E and the U.S. Geological Survey (USGS) during the operating license review, NRC issued operating licenses for the two unjts in 1984 and 1985. The OBE and SSE remained 0.2g and 0.4g, respectively.

However, OCPP was required to have additional seismic protection that would automatically initiate reactor shutdown if ground acceleration dunng a seismic event exceeded the, OBE and SSE, and PG&E was required to re-evaluate the seismic design basis for DCPP. PG&E was also required to evaluate the plant's response to ground motion of 0.75g, a value believed to bound the expected ground motion resulting from an earthquake occurring along the Hosgri fault. PG&E established its Long Term Seismic Program (LTSP) to guide additional seismic evaluations and updated the Final Safety Analysis Report to incorporate the results of its L TSP study. PG&E concluded that DCPP Units 1 and 2 could withstand ground motion up to 0.75 g.

In 2008, PG&E notified the NRC about the newly discovered Shoreline fault zone. PG&E completed characterization of the Shoreline and other local earthquake faults in January 2011.

Page 1 8ffl81AL ~8E 8UL\\G 81!U8:12MYf ltl$1fUtAL UtPORUJ!:'1111

errl81Jlcl ~8@ 8HL¥ 8!UIITI¥! IUf!flUAL IUP8flMAll81.

On October 20, 2011, PG&E submitted a license amendment request for approval to revise the current licensing basis, as described in the Updated Final Safety Analysis Report and Technical Specifications, to provide requirements for the actions, evaluations, and reports necessary when PG&E identifies new seismic information relevant to the design and operation of DCPP.

The NRC completed its independent review of the new seismic information and documented the results in a Research Information Letter (RIL) issued on October 10, 2012, which was subsequently communicated to PG&E two days later. NRC concluded that maximum ground motion at the site from a seismic event along tlhe Shoreline fault is bounded by previous analyses of potential seismic events, including analyses of the Hosgri fault and lhe L TSP ground motion response spectra.

Specifically the October 12, 2012, letter indicated that PG&E was to evaluate new seismic Information in accordance with the process outlined in the March 12, 2012, 50.54(f) request for information issued to all operating reactors, and provided further guidance that the ground motion response spectrum that is developed should be reviewed against the Double Design Earthquake (OBE) spectrum at DCPP.

Therefore, the October 12, 2012, letter in conjunction with the March 12, 2012, 50.54(f) request for information provides a process for assessing new seismic information at Diablo Canyon and rendered the portion of the October 20, 2011, PG&E license amendment in this area unnecessary. In a letter dated October 25, 2012, PG&E provided the basis for withdrawing its October 20, 2011, license amendment request. The staff accepted the withdrawal of the license amendment in a letter dated October 31, 2012.

PG&E is currently performing a seismic hazard update through a SSHAC Level 3 process. The resulting site-specific probabilistic seismic hazard analysis will be used to respond to the NRC's March 2012 50.54(f) request for information letter.

Key Messages Although the original OBE and SSE values of 0.2g and 0.4g were specified as part of the design basis (calculation} in 1968, the 0.75g Hosgri event was incorporated in the licensing basis (along with the OBE and SSE} prior to issuance of the DCPP units' operating licenses in 1984 and 1985.

o, Upon discovery of the Hosgri fault (1971), PG&E reanalyzed and significantly upgraded the structures, systems, and components to accommodate the postulated ground motion values (up to 0.75g) from the Hosgri fault.

o The NRC staff reviewed and accep*ted PG&E's revised seismic analysis in the Supplement to Safety Evaluation Report 7 (SSER 7) in 1978.

o The Advisory Committee on Reactor Safeguards (in 1978) and Atomic Safety Licensing Board (in 1979} subsequently reviewed the ticensee's and NRC staff analyses of the revised seismic impact and as-constructed tests and analyses (including the 0. 75g value associated with the Hosgri event). Both the ACRS and ASLB concluded that the revised seismic design basis was appropriately conservative and there was reasonable assurance that both units could be operated at full power without undue risk to the health and safety of the public.

The INRC performed an independent deterministic analysis of new seismic information provided by PG&E in 2011 relating to the Shoreline fault. NRC's conclusions are Page 2 8FFIIIAL Ill& IUttf 8&PJ81~\\f& lfJl&liltlAk IPIFIAMAiflltl

8FF181AL ~8E 8 HLY ll!Ull'4\\FI! UJillAU/:t IFJFIRM C TICHI documented in Research Information Letter (RIL} 12-01, dated October 10, 2012 (publically available in ADAMS Ml 121230035). NRC determined that the maximum ground motion expected at DCPP from a seismic event occurring along the Shoreline fault would be bounded by previous analyses of expected ground motion for seismic events associated with the Hosgri fault and PG&E's Long Term Seismic Program {LTSP) ground motion response spectra.

In addition to analysis of information relating to the Shoreline fault, NRC analyzed new information relating to increases in expected ground motion for seismic events occurring along the Los Osos and San Luis Bay faults. Ground motion at OCPP from seismic events along these faults is also bounded by prior analyses of expected ground motion for seismic events associated with the Hosgri fault and PG&E's L TSP ground motion response spectra.

In March 2012, NRC requested all U.S. nuclear power plants to re-evaluate plant specific seismic hazards in response to the Japan Lessons Learned Near-Term Task Force recommendations. 1 The results of PG&E's re-evaluation of seismic hazards for DCPP will include identification of any changes in seismic risks (due to new information identified during more recent seismic surveys) and a comparison to the current plant seismic design basis. This evaluation is to be submitted to NRC by March 2015. If the updated seismic hazards exceed the current SSE (the value that NRC directed PG&E to use for comparison),

PG&E has indicated they will complete an expedited seismic evaluation process by January 2016 and a full seismic risk analysis by June 2017. Plant modifications, if required, would likely be completed in the 2018 timeframe.

The expectation that the seismic issues will take some years to resolve at DCPP is not a safety concern. The NRC has followed the progress of PG&E's seismic re-evaluation process since the beginning. The NRC will continue to evaluate seismic data to ensure our understanding of the seismic hazard is informed and that there is no new challenge to safety.

The NRC continues to conclude Diablo Canyon is built to safely withstand the effects of a Hosgri earthquake and that the plant would protect the public and the environment. The reasons for this are laid out in the RIL.

If new information suggests that the plant has the potential to not withstand new seismic hazards, the NRC would take action. This could include a plant shutdown until the issues could be resolved.

The ll'esldent inspectors and regional staff reviewed the licensee's documentation in their corrective action process of new preliminall)' information concerning OCPP seismic and licensing bases that the Shoreline fault may be more capable than previously determined (ref: AB*1632 report). The information did not indicate there is an immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions. The licensee's current actions 1 See NRC letter, dated March 12, 2012, issued to all power reactor licensees "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50. 54(() Regarding Recommendations 2. 1, 2. 3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident. *

(htto:llobaduows.nrc.govldocs/ML1205/ML12QSJA34Q.pdf)

Page3 6f flelAL ~9E 8HL¥ = 9!ft81llVI! lftf!!.. U.t.L lflPIRMAflefl

,o,.,1e1.-rt tJ31! erR'f = 9Ef491flVE ttnERf4ilcL IP4F8AMAll8U meet the Manual Chapter 0326 guidance for having reasonable assurance of operability, pending further evaluation.

The NRC will continue to review the new information In the AB-1632 report and will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit its preliminary evaluation.

Diab,lo Canyon will incorporate the AB~1632 report's information into its March 2015 seismic hazard re-analysis submittal to the NRC.

Page4 6FFlelilcL ~9E 8NLY 8fH81"'11f IUfERUAL IUP8RMAfl8U

eFFlelAL tJ9E 6Nt'f

• 91!H91flV7! lfOf:ftNAL IHr e"MAllON Background Documents The following documents are not attached, but are available electronically:

Research Information Letter (RIL) 09-01, "Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon NPP from Newly Identified Shoreline Fault," April 8, 2009 Licensee letter to NRC: "Report on the Analysis of the Shoreline Fault Zone, Central Coast California to the USNRC,.ADAMS Ml 110140400, January 7, 2011 Task Interface Agreement (TIA) 2011-010, "C<>ncurrence on Diablo Canyon Seismic Qualification Current licensing and Design Basis,* August 1, 2011 TIA 2012-012, "Revised Response to Task Interface Agreement-Oiablo Canyon Seismic Qualification Current Licensing and Design Basis. IA 201 1-010 (TIA 2012-012) (TAC NOS.

ME9840i and ME9841 ).

• November 19, 2012 Rll 2012-01, "Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone," September 19, 2012 (Ml 121230035)

Page 5 eprr1e1At lf8! 8Ul¥ 8E!Ullf1Vli IUfliRfJAk ltlf@AMITl@Pl

OFFICIAL 632 OHCI SEHSII 1ft 1141 !ANAL INPURMA 1101*

Non-Concurrences & Differing Professional Opinions

Background

The former SRI at the Diablo Canyon Power Plant (OCPP) submitted non-concurrence papers (NCPs) in January 2011 and January 2012, followed by a Differing Professional Opinion (DPO) in July 2013 detailing a disagreement with the NRC about how new seismic information should be compared to the plant's current seismic license requirements. DPO 2013-02 restated the issues presented in NCP 2012-01 and added a concern that a license amendment was needed incorporate the Shoreline fault into Diablo Canyon's FSAR as descnbed in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults. In accordance with Management Directive 10.159, a DPO Ad Hoc Review Panel was established to review the DPO submittal, meet with DPO submitter, and issues a DPO report including conclusions and recommendations regarding disposition of the issues presented in the DPO. The panel completed its report in May 2014 and a decision on the DPO was rendered in letter dated May 29, 2014, to the DPO submitter. The DPO submitter appealed the decision to the EDO in accordance with the NRCs DPO process. The EDO completed his consideration of the DPO appeal on September 9, 2014, concluding that he was in agreement with the original decision.

The purpose of this communication plan is to provide key messages associated with the EDO's decision on the DPO appeal and public release of the DPO Case File.

Key Messages:

1. NRC strives to establish and maintain an environment that encourages all NRG employees and contractors to raise concerns and differing views promptly without fear of reprisal through various mechanisms. The free and open exchange of views or ideas conducted in a non-threatening environment provides the ideal forum where concerns and alternative views can be considered and addressed in an efficient and timely rmanner that improves decision making and supports the agency's safety and security mission.

2. The NRG appreciates members of the staff bring issues like this to its attention

3. The NRC encourages the use of non-concurrences and the Differing Professional Opinion (DPO) process

4. The NRC reviews all non-concurrences and DPOs thoroughly and in accordance with agency guidance (MD 10.158, MD 10.159) and believes that this is a healthy and necessary part the regulatory process

5. The NRC believes that, in the end, all of our regulatory decisions are better because of this process

6. The NRC does not tolerate retaliation against employees who engage in our processes for raising differing views (i.e., Open Door Policy, NCP, and DPO Program).

7. Persons serving on U,e DPO Panels are independent of the issues raised in the DPO

8. Upon disposition of the DPO via a Director's decision, the DPO submitter has appeal rights to the EDO Page6 OFPIIIAI: Wlii ern.v 8EU8" 1¥E lfff[fUfAL INFeRMATl0N

e r r1e1At tf8! 8 Hl!V 8!U8Mil\\11! lfllaAU/ L UJFeRM,~eN

9. While the DPO is under review or appeal, NRC is prohibited from engaging in discussions with external stakeholders regarding the specifics of the of the DPO submittal

10. After the EDO's decision on the appeal. the OPO submitter can request that the OPO Case File be made public. Management performs a review consistent with agency policies to support discretionary release. Regarding the DPO for Diablo Canyon, the NRC has been and will continue to be as open and scrutable as possible while protecting the privacy rights of the individual

11. The NRC does not know the source of the public release of the D1ablo Canyon DPO submittal prior to the EDO rendering a dec1s1on on the appeal

12. The NRC can, however, comment on a few aspects of the DPO appeal review o A Director's Decision has been made and the OPO appeal to the EDO has been finalized o The EDO and the DPO submitter have both agreed that the issues raised in the DPO do not present an immediate safety concern for Diablo Canyon o The NRC has sought permission from the DPO submitter to allow the DPO case file to be made publicly available and the DPO submitter has agreed o We would expect the public release of the OPO case file to be within a few days of the EDO's appeal decision

13. Regarding the operational status of Oiablo Canyon Power Plant, Units 1 and 2 o The plant remains within its approved design and licensing basis o There are no current operability concerns resulting from the DPO o The recent earthquake in the Napa Valley did not reach Diablo Canyon - it was neither felt nor detected Background Documents

[NON-PUBLIC] Non-concurrence NCP 2011-103, dated November 7, 2011 Non-concurrence NCP 2012-01, dated January 26, 2012 [publically available in ADAMS]

[NON-PUBLIC] Differing Professional Opinion 2013-02, dated July 18, 2013 OEPICIOI 119F 8NI..

9FN91Jnee ltlfliRPISL UIF&AUCll&tl Page 7

err1e1,ct t,91! et4LY Sff431fft'£ INTEftN>'<L 1Nf'6RM>'<ll6f4 ATIACHMENTS Audience/Stakeholders............................................................................................................... 9 Communication Team............................................................................................................... 10 Communications Tools............................................................................................................ 11 List of Applicable Acronyms and Abbreviations......................................................................... 14 Timeline of Seismic Issues at DCPP....................................................................................... 15 Specific Q&As Design/Initial Licensing Basis Questions (DE/DDE/Hosgri/Tsunami)....................................... 21 Long Term Seismic Program (L TSP) Questions....................................................................... 24 Shoreline Fault Questions......................................................................................................... 26 State of California Seismic Report (AB-1632)........................................................................... 30 Los Osos and San Luis Bay Faults........................................................................................... 34 Research Information Letter (RIL) Questions............................................................................ 35 "Sewell" Report I Tsunami......................................................................................................... 36 Non-concurrence and DPO Questions......................................................................................42 RIS 2005-20, 2013-005, and Operability Evaluation Questions................................................. 47 Enforcement Questions............................................................................................................ 48 Current Licensing Questions..................................................................................................... 49 50.54(f) Questions.................................................................................................................... 52 Tier 3 Expedited Transfer of Spent Fuel to Dry Cask Storage................................................... 57 DCPP Licensing Basis Verification Project (LBVP)................................................................... 60 Continued Storage Rule (formerly "Waste Confidence")........................................................... 63 Public Cancer Risks.................................................................................................................. 64 Emergency Preparedness Concerns....................................................................................... 65 Page 8 61'f'lel>'<L ~9E 8NL¥ 9!14Slfl'lf ltUERHAL lf4F8AMAll8U

errielJlcL tl9E eNLV 9EH8ff1¥E lfffEfUt~L 1Hf8AM~lt8U Internal Allegations Coordinator Office of Public Affairs (OPA)

Audience/Stakeholders Office of Congressional Affairs (OCA)

Office of Federal and State Materials and Environmental Management Programs (FSME)

Office of Nuclear Regulatory Research (RES)

Office of Nuclear Security and Incident Response (NSIR)

Office of Nuclear Material Safety and Safeguards (NMSS)

Office of General Counsel (OGC)

Office of the Inspector General (OIG)

Office of the Executive Director of Operations (OEOO)

Office of the Advisory C~mmittee on Reactor Safeguards (ACRS)

Office of New Reactors (NRO)

Office of Nuclear Reactor Regulation (NRR)

Regions Commission External General Public San Luis Obispo Mothers for Peace (http://mothersforpeace.orqD The Alliance for Nuclear Responsibility (http://a4nr.org)

U.S. Congressional representatives for the area around DCPP:

Senator Dianne Feinstein Senator Barbara Boxer Representative Lois Capps (CA-24th}

State and local Government agencies, including:

California Governor's Office of Emergency Services, California Public Utilities Commission, California Independent Peer Review Panel (IPRP)

California Energy Commission, and California Coastal Commission.

Industry groups (e.g., Nuclear Energy Institute) err1e1At ~91!! er4t2i - 91!!148ITI II!! 114,!ft14AL 114PeftMAfl9ft Page9

Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication s.taff named below.

Team Member Position Organization Telephone Troy Pruett Division Director {Acting)

RIV/ORP 817-200-1291 Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195 Theresa Buchanan Acting Sr. Project R-IV/ORP/RPB-A 817-200-1503 Engineer Thomas Hipschman Sr. Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 DCPP John Reynoso Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 DCPP Thomas Farnholtz Branch Chief RIV/DRS/EB1 817-200-1243 Jon Ake Senior Seismologist RES/DE/SGSEB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Joseph Sebrosky Senior Project Manager NRR/JLD 301-415-1132 Scott Burnell Public Affairs Officer OPA 301-415-8204 Jenny Weil Congressional Affairs OCA 301-415-1691 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State liaison Officer RIV 817-200-1267 Elaine Keegan License Renewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DIFrancesco Japan Lessons Learned JLO 301-415-1115 Page 10 IFFIIII* wee 8UI:¥ llifUIFf4VI lfM!fUtAL IUf8RMAifl8U

Communications Tools The communication team may and have used any of the following tools to communicate with our stakeholders:

Internal Briefings The communication team will conduct internal briefings as required to keep internal stakeholders informed of activities and messages.

Public Meetings In May 2009, a town hall public meeting was conducted in San Luis Obispo, Califomla, to discuss the Shoreline Fault. In September 2010, a two-day public workshop was conducted In San Luis Obispo, California, to present topics of interest regarding seismic issues. In January 2011, a public meeting was conducted in San Luis Obispo, Cahfornia, between DCPP licensee representatives and NRC staff to discuss the results of the Shoreline Fault Zone report. In November 2012, the NRC held a public meeting to discuss the results of its RIL in which the staff determined that the new SFZ is bounded by the Hosgri.

In December 2013, Region IV held a public meeting to discuss our annual assessment DCPP's performance in 2012 through mid-2013, and a similar meeting was held in May 2014 to discuss our annual assessment for the entire 2013 inspection year. During both these meetings, the staff provided status relative to DCPP's actions to date in response to the post-Fukushima actions, iincluding the seismic and flooding reevaluation activities, and the mitigating strategies and spent fuel pool instrumentation orders.

Information Availability The staff has placed publically available documents regarding seismic issues at the DCPP in ADAMS. Presentation materials and videos of all public meetings have been posted on the public NRC web site.

Press Releases/Meeting Notices Issuance of press releases regarding key decisions and actions relative to DCPP will be considered by the Region as needed and consistent with CPA guidance. The most recent press release issued for DCPP announced the annual (2012) assessment public meeting in San Luis Obispo on December 18, 2013. A meeting notice for the next annual assessment meeting (for CY2013), held May 22, 2014, in San Luis Obispo was issued.

Past & Present Activities for Communicating with Stakeholders Activity I Report I Document Title Lead Office Date (ADAMS/Reference number, as aooropriate)

Submitted 50. 72 notification wrth an operability 1

assessment to the NRC PG&E November 21, 2008 (Event Number: 44675) 2 FAQ developed Region IV November 26, 2008 3

Summary of tsunami hazard RES December 8, 2008 (ML090820140 and ML083400496}

4 Action Plan submitted to the NRC PG&E December 17, 2008 (ML090720505}

Page 11 er FlelAL ~BE 8HL¥ 8EUBlflVE OJl'EflU:Stk ltlf8f1Ms\\ift8tl

Activity / Report I Document Title Lead Office Date (ADAMS/Reference number, as aooropriate)

The NRC,concluded the Action Plan and 5

schedule are reasonably complete and NRR January 5, 2009 comprehensive in scope for this study.

(ML090820113)

Issue summary of results of a deterministic 6

seismic hazard assessment in a Research RES April 8, 2009 Information Letter (ML090330278)

Presentation of more definitive results during a USGS and 7

Seismological Society of America meeting. NRC PG&E April 9, 2009 staff members plan to attend.

Issue a safety evaluation regarding the operability 8

of DCPP based on a deterministic hazard NRR DE &

April 30, 2009 assessment and a preliminary review of the DORL tsunami hazard by RES.

9 Complete an operability evaluation of potential PG&E April 30, 2009 ground deformation Support a town-hall meeting, conducted by

NRR, 10 Region IV, in which the Shoreline Fault is NRO, &

May 28, 2009 expected to be discussed.

RES 11 Meeting with PG&E to discuss status PG&E January 5, 201 O 12 PG&E to submit Secondary Rupture Hazard PG&E February 29, 201 O Analysis NRR/ Division of Operating Reactor Licensing 13 (DORL) to submit Research Assistance Request NRR April 29, 2010 for review of Secondary Rupture Meeting with RES, NRO, and NRR/DORL to 14 discuss User Need Request to determine future NRR March 29,2010 actions regarding the Shoreline Fault 15 RES to provide confirmatory review of secondary RES July 31, 2010 rupture analysis RES to review Evaluation of Shear-Velocity at the 16 Independent Spent Fuel Storage Installation RES July 31, 201 0 (1$FS1) 17 Brief the Chairman on the status of the Shoreline NRR August 11, 201 O Fault 18 Seismic Workshop in San Luis Obispo Region IV September 8 and 9, 2010 19 Complete seismicity studies PG&E December 2010 20 Complete geophysical studies PG&E December 2010 21 Complete geologic studies PG&E December 201 O 22 Complete Shoreline Fault source charac1!erization PG&E December 2010 for lnteQration into final report.

23 Complete ground motion studies to be integrated PG&E December 2010 into final report.

Page 12

Ol'l'lelAL tf 9! er~t¥ = 9ENS1fl¥E 1NfERt4'4l ltff8RM'4'fl8U Activity / Report / Document Title Lead Office Date (ADAMS/Reference number. as aooropriate) 24 Meeting on L TSP Amendment NRR/

December 9. 2010 DORL 25 Research Assistance Request for pre-application NRR/

March 2011 discussions on L TSP Amendment DORL 26 Research User Need Request to support review NRR/

TBD of L TSP Amendment DORL Interim reports will not be complete until PG&E integrates all data Into final report; therefore, 27 interim reports will not be submitted to NRR/DE January 2011 stakehofders for review until all data are inteQrated into final reoort in December.

28 Complete final Shoreline report PG&E January 2011 29 Research User Need Request to support review NRR/

January 4, 2011 of Final Shoreline Report and update RIL 09-001 DORL 30 Regional Meeting in California to discuss final Region IV January 19, 2011 Shoreline Fault zone report 31 Second Meeting on L TSP Amendment NRR/

January 26, 2011 DORL 32 Third Meeting on L TSP Amendment NRR/

March 2011 DORL 33 L TSP Amendment submittal (LAR 11--05)

PG&E October 20, 2011 34 The NRC held an annual assessment meeting RIV June 2011 and discussed seismic at Diablo 35 The NRC issued the RIL NRR October 10, 2012 36 Regional Meeting in California to discuss NRC's Region IV November 28, 2012 rev1iew of the Shoreline Fault Regional Meeting in California to discuss annual performance assessment for CY 2012 37 (Note - this meeting was held late in 2013 when Region IV December 18, 2013 the govt. shutdown resulted in cancellation of planned meetino 10/16/2013)

Written response to questions posed by U.S.

NRR (w/

38 Senate Environmental & Public Works OCA)

Late January 2014 subcommittee staff 39 Regional Meeting in San Luis Obispo to discuss Region IV May 22, 2014 annual performance assessment for CY 2013 40 Diablo Canyon issued the ABN-1632 seismic NRR/JLD September 10, 2014 report to the state of California Page 13 Aff!Cltl,,se AHi *., - 9fN9II:1't'E INft'BNA! !NfABNtflAN

List of Applicable Acronyms and Abbreviations ACRS ASLB ASW CLB OCNPP or OCPP ODE OE DGEIS OPO GMC HE IPRP LAR LBVP LTSP NCP NEPA NTIF OBE PG&E PGA RG RIL RIS SER /SSER SFZ SMA SPRA SRI SRP SSC SSC SSE SSHAC TIA TS U/FSAR Two-Dimensional/Three-Dimensional (relative to seismic mapping studies)

NRC's Advisory Committee on Reactor Safety NRC's Atomic Safety and Licensing Board DCPP Auxiliary Salt Water System Current Licensing Basis Diablo Canyon (Nuclear) Power Plant Double Design Earthquake (DCPP specific term, equivalent to SSE)

Design Earthquake (DCPP specific term, equivalent to OBE)

Draft Generic Environmental Impact Statement Differing Professional Opinion Ground Motion Characterization (relative to SSHAC process)

Hosgri Event (i.e., s*eismic event occurring on the Hosgri fault)

Independent Peer Review Panel (multi-agency panel of seismic hazard specialists e*stablished by the California Public Utilities Commission)

License Amendment Request DCPP's Licensing Basis Verification Project PG&E's 1991 Long Term Seismic Program Non-Concurrence Paper National Environmental Policy Act NRC's Japan Lessons Learned Near Term Task Force Operating Basis Earthquake Pacific Gas & Electric Peak Ground Acceleration Regulatory Guide Office of Research Information Letter Regulatory Information Summary Safety Evaluation Report I Supplement to Safety Evaluation Report Shoreline Fault Zone Seismic Margin Analysis Seismic Probabilistic Risk Analysis Senior Resident Inspector Standard Review Plan Systems, Structures, and/or Components Seismic Source Characterization (relative to SSHAC process)

Safe Shutdown Earthquake Senior Seismic Hazard Analysis Committee Task Interface Agre,ement Technical Specification Updated/Final Safety Analysis Report Page 14 GI I :CIA[ USE Olk I - 3!143.llf ! IIH!IUU,t n*re"M""e,4

er, 1e1At tJ9E 8HLY = 9ff49 t1flVI! lfftf fUt.-t IUf8.. MAfl8ft Timeline of Seismic Issues at DCPP 4/12/62 Initial version of 10 CFR 100 was issued (revised in 1996)

Prior to 1969 The original seismic study included geological and seismic investigati'ons to validate the acceptability of the site. This included regional studies and detailed offshore investigations, including trenching, core drilling and geological mapping near the site. During this review, 10 CFR 100 was in the ear1y stages of development, and the concepts, of SSE and OBE were still being developed.

2/23/69 Construction permit issued for Unit 1 PG&E concluded, and the AEC concurred, that the earthquake design bases for Diablo Canyon would be a peak horizontal ground acceleration (PGA) of 0.4g for safety-related structures (DOE) and a PGA of 0.2g for operational-related s,tructures (DE) These seismic design criteria were based on consideration of two design~basis earthquakes: a magnitude 7.25 earthquake on the Nacimiento fault 20 miles from the site, and a magnitude 6.75 aftershock at the site associated with a large earthquake on the San Andreas fault. It was also concluded that there was no surface displacement hazard in the site vicinity. This conclusion was based on the absence of any displacement of the 80,000 year-old and 105,000 year-old marine terraces underlying the site area.

12/9/70 Construction permit issued for Unit 2 2/20/71 Final version of 10 CFR 50, Appendix A, General Design Criteria, was issued 1971 Oil company geoscientists discovered an offshore fault zone, calling it the East Boundary Fault Zone. This zone later became known as the Hosgri fault.

11/13/73 Initial version of Appendix A to 10 CFR 100 was issued (further revised in 1977) 1973 Regulatory Guide (RG) 1.61, "Damping Values for Seismic Design of Nuclear Power Plants,* was issued. The RG allowed more damping to be used in seismic evaluations than had previously been used in the DE and ODE at Diablo Canyon. PG&E used the RG 1.61 values in the Hosgri evaluation and did not revise the DE or DOE.

1/10/77 Revision of Appendix A to 10 CFR 100 was issued 6/3m PG&E submitted their Hosgri Report. This evaluation used the latest regulatory guidance, including 10 CFR 100, Appendix A. The new guidance from the NRC was not used to revise the DE and DOE.

1977 The Hosgri analysis was accepted by the NRC and documented in SER 34.

5/26/78 NRC staff documents a significant portion of its review of PG&E's Hosgri Report and seismic reevaluation in Supplement No. 7 to the SER (SSER 7). In particular, SSER 7 notes *we [NRC staff} require that the plant design be shown to be adequate for the Hosgri event and the applicant is proceeding with the work necessary to demonstrate this:

Page 15 8Ffl81AL ~8E 8 HL¥ l!rtllf Pcll IUliAft:P:ls ltlFIRM:\\1*1et1

o,-f'ICIAL t,S! 01*t I - S!HSI I If E 114 I EkiiAE U.F8RMATl8'4 Tlmellne of Seismic Issues at OCPP (cont'd) 7/14/78 11/15/78 9/27/79 11/2/84 8/25/85 1989 June 1991 1992 12/11/96 ACRS Letter to the Commission notes "The Applicant's analyses and tests related to the reevaluation of the structural and mechanical components for the Hosgri event have been subjected to an unprecedently intensive and comprehensive review by the NRC Staff... : However, the ACRS also noted that "the theory and analyses of earthquake and seismic wave generation, of seismic wave transmission and attenuation, and of soil-structure interaction are in a state of active development. The Committee recommends that the seismic design of Diablo Canyon be reevaluated in about ten years taking into account applicable new information "

NRC staff issues Supplement No. 8 of the SER (SSER 8) which includes a conclusion that *matters related to seismic design have now been resolved as discussed in this supplement. In part, the resolutions are based on requirements that we have stated.* (The stated requirements included the design, analysis, and construction activities completed by PG&E in addressing the potential ground motion from an earthquake on the Hosgri fault.]

The Atomic Safety Licensing Board (ASLB) issues *... a Partial Initial Decision in this operating license proceeding, concluding that... (2) the Diablo Canyon plant will be able to withstand any earthquake that can reasonably be expected to occur on the Hosgri fault....

• Operating license was issued for Unit 1. In response to the ACRS recommendation for PG&E to conduct a seismic reevaluation after approximately 10 years, the license contained License Condition 2.C.(7) requiring the licensee to perform further assessments of the seismic sources and ground motions applicable to OCPP, beyond that considered in the development of the Hosgri Event (HE). The Long Term Seismic Monitoring Program (LTSP) was developed by PG&E in response to License Condition 2.C(7).

Operating license was issued for Unit 2.

Diablo Canyon submits their L TSP Report.

The NRC reviewed and accepted the results of the L TSP. as documented in SSER-34. The SSER included the following statement in Section 1.4: "The staff notes that the seismic qualification basis for Diabto Canyon will continue to be the original design basis plus the Hosgri evaluation basis, along with the associated analytical methods, initial condi1ions, etc."

The PG&E - USGS Cooperative Research and Development Agreement (CRADA) was created to improve rapid earthquake notifications and develop new geosciences data and advanced analysis methods leading to reducing earthquake risks in PG&E's service territory in northern and central California (Including ongoing research and review of OCPP and nearby region).

Revision of 10 CFR 100 was issued Page 16 8FFl81AL ~ec 8HL¥ 9EH81fWE UffERUAL INF8RMAifl8N

OPFICIAE 051! 014L I 5l!l4S1Tft!! INTl!!"NAt: INl'eftMA,.eN Timeline of Seismic Issues at OCPP (cont'd) 2006 A new phase of the CRAOA is implemented and includes both a large set of new field studies and the application of new advanced seismological techniques to small magnitude recorded earthquakes.

11/14/08 PG&E notified the NRC of a potential line of epicenters about one mile offshore from the plant. This was followed up on 11/21/08 with Event Notification 44675. This line of epicenters became known as the Shoreline Fault Zone.

Dec 2008 Using the L TSP methods, PG&E completes a seismic margin assessment which demonstrates that the Shoreline Fault is bounded by the Hosgri evaluations.

4/8/09 The NRC issued Research Information letter (RIL) 09-01, "Preliminary Deterministic Analysis of Seismic Hazard at Oiablo Canyon NPP from Newly identified Shoreline Fault." This independent study of potential impacts concluded adequate seismic margin exists for the Shoreline Fault.

1 /2/1 O Public meeting between NRC and PG&E was held to discuss what was known about the Shoreline fault.

Jan 2010 PG&E submitted a progress report on the Shoreline Fault Action Plan.

Sept 2010 The NRC sponsored a seismic workshop in San Luis Obispo, CA, to help inform the public about seismic evaluations and design. Independent seismic experts were invited to make presentations.

Sept 201 O OCPP SRI becomes aware that the PG&E preliminary results show peak ground acceleration for the Shoreline Fault is in excess of the values used in the ODE.

Oct 2010 DCPP SRI questions PG&E on the capability/operability of SSCs to withstand the Shoreline Fault acceleration using the DE/DOE evaluation method.

Dec 2010 PG&E concluded that no operability evaluation was needed to compare the Shoreline Fault ground acceleration to the DE/DOE evaluations. PG&E believed that they had documented that the L TSP had contained new seismic information and the NRC had allowed PG&E to address it through a seismic margin assessment and seismic PRA.

1ll/11 PG&E issued the results of their seismic evaluation in the Shoreline Report "Report on the Analysis of the Shoreline Fault Zone, Central Coast California to the USNRC, * (ADAMS ML110140400). This report included deterministic evaluations for the Shoreline, Los Osos, and San Luis Bay earthquak:e faults, as well as probabilistic hazard calculations. The licensee concluded that each or these faults were bounded by the existing L TSP.

6/3/1 1 Region IV submits Technical Interface Agreement (TIA) memorandum 2011-010 posing questions needed to help resolve seismic operability evaluation issues Involving Diablo Canyon's use of the Hosgri and L TSP methods as the only bounding design basis condttio111s for newly Identified faults.

Page 17 8PFl81At ~Ii 8Ub¥ liUIWIVI lttTIRfll:k ltlfelilM:\\llOfl

Ol'flCIAL t:JSE ONLY - 9EH91l'tVf: lfnERNAL INF6RM>'cll6N Timeline of Seismic Issues at DCPP (conrd, 8/1/11 9/18/1 1 10/20/11 11/23/11 11/29/11 12/15/11 Feb 2012 03/12/12 May 2012 10/12/12 Sept-TIA 201 1-010 was issued by NRR. The TIA concluded that, "New seismic information developed by the licensee is required to be evaluated against all three of the seismic design basis earthquakes and the assumptions used in the supporting safety analysis as described in the FSARU. Comparison to the LTSP by itself is not sufficient to meet this requirement* (NOTE: This TIA. has been superseded by TIA 2012-012 dated November 19, 2012)

NRC issues Inspection Report 05000275;323/201104.

In response to the operability evaluation violation in Inspection Report 05000275; 323/2011002, PG&E submitted a license amendment request (LAR) related to the Shoreline fault and methods of seismic evaluation.

PG&E initially commits to use the SSHAC level 3 process to perform a probabilistic seismic hazard assessment. PG&E SSHAC Level 3 plan revised in July 2012 to reflect the NRC's evaluation request in March 2012 pursuant to the 1 O CFR 50.54(f) letter. Once completed (anticipated March 2015), the PG&E SSHAC Level 3 study will update/replace the PG&E LTSP.

PG&E conducts SSHAC workshop #1 in San Luis Obispo, CA The workshop is open to the public and presentations are posted on PG&E's website. NRC seismologists attend the workshop as observers. This workshop was for both the Seismic Source Characterization (SSC) and Ground Motion Characterization (GMC) portions of the SSHAC study. However, later they would decide to combine their GMC workshops with SONGS (SCE) and Palo Verde (APS). As such, the consortium ultimately re-conducted GMC SSHAC workshop #1, so this workshop essentially became SSC SSHAC workshop #1 for DCPP.

The NRC's Branch Chief for DCPP discussed the LAR with PG&E.

Issuance of RIL 12-01 is delayed to support the agency's seismic and flooding 50.54(f) letter effort. An NRC inter-office agreement was reached to require PG&E to submit the results of the seismic hazard reevaluation in terms that compare the 50.54(f) letter results to the Diablo Canyon DOE.

50.54(f) Request for lnfonnation letters are issued for seismic and flooding hazard reevaluations. PG&E was specifically requested to report the seismic results by comparing them to the ODE (the SSE-equivalent for DCPP)

Issuance or RIL 12-01 is delayed until assumptions concerning shear wave travel in generic vs. site-specific material are verified.

NRC issued RI L 2012-01. The cover letter stated that the NRC has concluded that the Shoreline fa ult was considered to be a lesser included case of the Hosgri event, and should be documented as such in the UFSAR.

Page 18 6fflelAL tJ9E eNtY - 9EN91"Tfl'E INl'ERNAL INFORMATl6N

8FFlel>fcl l:f9E 8NLV - 9l:f~9ffff'E INTl:RN*t INfORM*TleN Oct 2012 lntemal NRC discussions oocurred about the acceptability of the LAR under the acceptance review criteria. The NRC staff believed that PG&E thought they were asking for an administrative clarification by trying to get the HE declared as the SSE, however doing so would actually require a major revtew using the latest SRP criteria. DORL asks the RIV Branch Chief to discuss this difference with PG&E.

10/25/12 Diablo Canyon withdraws the lAR submitted in October 2011.

11/6/12 PG&E conducts SSC SSHAC workshop #2 in San Luis Obispo, CA. The workshop is open to the public and presentations are posted on PG&E's website.

NRC seismologists attend the workshop as observers.

11/9/12 NRC held a meeting to discuss the results of Rll 2012 and concluded that ground shaking from the Shoreline fault earthquake scenarios are less than the Hosgri and L TSP ground motions for which the plant was previously evaluated.

11/1 9/12 NRC issued TIA 2011-010, "Revised Response to Task Interface Agreement-Diablo Canyon Seismic Qualification Current Licensing and Design Basis, TIA 2011-010 (TIA 2012-012) (TAC NOS. ME9840 and ME9841t 11/27/12 PG&E completes seismic walkdowns for accessible areas required by 50.54(f) letter (ML123330362, ML123330375}

11 /28/12 NRC held a public meeting in San Luis Obispo to help inform the public about the results of RIL 2012-01. Twenty-three NRC personnel from multiple offices were in attendance to explain different aspects, including post-Fukushima actions.

3/19/13 PG&E, Southern California Edison (San Onofre), and Arizona Power Service (APS - Palo Verde) jointly conduct GMC SSHAC workshop #1 in Oakland, CA.

The workshop is not open to the public but presentations are posted on the Southwestern US Ground Motion Characterization Project website. NRC seismologists attend the workshop as observers.

June 2013 PG&E completes seismic walkdowns (including inaccessible areas) required by 50.54(f) letter.

June 2013 NRC completes inspection of seismic walkdown efforts.

Oct 2013 PG&E and APS jointly conduct GMC SSHAC workshop #2 in Berkeley, CA. The wor1<shop is open to the public and presentations are posted on the Southwestern US Ground Motion Characterization Project website NRC seismologists attend the workshop as observers.

March 2014 PG&E conducts SSC SSHAC wor1<shop #3 in San Luis Obispo, CA. This workshop was open to the public. and was the final planned SSC SSHAC workshop.

March 2014 PG&E and APS jointly conducted GMC SSHAC workshop #3 In Berkeley, CA.

This workshop was open to the public, and was the final planned GMC SSHAC workshop.

Page 19 8FFlelAL tJ9E ONLY - !l!N!ITl't! INT1!~NAL '""e~MAT'ION

8FFl81>>tcl l:ISE 8NL'f - 9EN9ffflE INTERN1'cl INF6RM>lcTl6N Future Events.

Sept. 2014 PG&E expected to submit the AB-1632-mandated SEISMIC REPORT to State of California (IPRP to review). A copy will be provided to NRC for review.

March 2015 PG&E due to submit ground motion response spectrum to the NRC in response 1o March 2012 50.54(f) request. Current Information from the SSHAC process supports the expected conclusion that the new ground motion response spectrum will be bounded by the original HE ground motion response spectrum.

June 2017 PG&E due to submit the results of the new Seismic PRA to the NRC in response 1o 50.54(f) request.

Page 20 er f 1e1>1ct t:J9E 6NLV - 9EN91'fl¥E INTERNAL 1Nfi6RMATl6N

Of fleb\\L USE or*tv - 9ENS1fl't'E INff:RNAL INfORMA'flOt*

Design/Initial Licensing Basis Questions (DE/DDE/Hosgrl/Tsunami) 1, When was the Ho*gri fault identified?

1971. During geological investigations in support of the OCPP operating license applications, oil company geoscientists discovered a major zone of faulting a few miles off shore. When the DCPP Final Safety Analysis Report (FSAR) was initially submitted for NRC review in 1973, it briefly described the offshore fault zone. calling It the East Boundary Fault Zone. The zone became known as the Hosgri fault

2. How was the Hosgri fault addressed in the licensing and design of OCPP?

Although the original OBE and SSE values of 0.2g and 0.4g were specified as part of the design basis (calculation) in 1968, the 0.75g Hosgri event was incorporated in the licensing basis (along with the OBE and SSE) prior to issuance of the DCPP units' operating licenses in 1984 and 1985.

Upon discovery of the Hosgri fault (1971). PG&E reanalyzed and significantly upgraded the structures, systems, and components to accommodate the postulated ground motion values (up t,o 0.75g) from the Hosgri fault.

The NRC staff reviewed and accepted PG&E's revised seismic analysis in the Supplement to Safety Evaluation Report 7 (SSER 7) in 1978.

The Advisory Committee on Reactor Safeguards (in 1978) and Atomic Safety licensing Board (in 1979) subsequently reviewed the licensee's and NRC staff analyses of the revised seismic impact and as-constructed tests and analyses (including the 0.75g value associated with the Hosgri event). Both the ACRS and ASLB concluded that the revised seismic design basis was appropriately conservative and there was reasonable assurance that both units could be operated at full power without undue risk to the health and safety of the public.

(See Questions #4 & #5 below for additional specifics.)

3. How are the design basis earthquakes defined? How are they different?

Each design basis earthquake is defined ln terms of a peak ground acceleration and a corresponding response spectrum that is constructed of peak accelerations at various frequencies. The peak ground accelerations for each of the three design basis earthquakes are:

DE.

0.2g DOE: 0.4g HE*

0.75g The OE response spectrum is enveloped by the ODE response spectrum at all frequencies, and the DOE response spectrum is enveloped by the HE response spectrum at all frequencies. In addition to the magnitudes of the spectra being different. the shapes of the spectra are also different. This is due to differences in how the response spectra were developed as well as differences in the hypothetical earthquake that each design basis level Page 21 10f'fllCIAL t:19E ONLY - 8EN91fl'\\IE INTEftNM: ltfflO"MATION

Ol'l'ICIAL t:19! ONLY - 9!N91fl'i£ ltffERt*At. INF6RMM16N is based on. Generally speaking, the response spectra were constructed based on modified versions of similar real earthquakes, nonnallzed to the desired peak ground acceleration.

Specific real earthquake records were carefully selected for the construction of each response spectrum, due to the fact that the magnitude of the earthquake and the distance from the site will cause the response spectra to peak at different frequencies.

4. Is It accurate t.o state that the DCPP operating license defines the ODE to bet.he SSE?

Yes. For the Diablo Canyon, the Double Design Earthquake (DOE) is equivalent to the Safe Shutdown Earthquake (SSE). During initial licensing of the Diablo Canyon site, two design basis earthquakes (ground motion) were established. The operating basis earthquake (OBE) represents the ground motion reasonably expected during the lifetime of the plant. At DCPP, this is called the Design Earthquake (DE). and Is 0.2g. The safe shutdown earthquake is defined as having twice the acceleration of the operating basis earthquake to ensure safety margin. At DCPP, this is called the Double Design Earthquake, and is 0.4g.

Pacific Gas and Electric (PG&E, the licensee) was required to show that all equipment necessary for continued operation without undue risk to the health and safety of the public would withstand the OBE/DE (i.e., remain functional), and that all safety-related equipment needed to safely shut the plant down and maintain a safe shutdown condition would withstand the SSE/DOE.

The licensee obtained the construction pennits for both Diablo Canyon units and had begun plant construction before it became aware of the Hosgri fault, located offshore. The fault was studied in detail as part of a collaborative research program between PG&E and the U.S. Geological Survey (USGS). The NRC worked with the USGS office to ensure that the seismic hazard was properly characterized. This effort determined that the Hosgri fault could produce up to 0.75g ground motion at the Dlablo Canyon site (called the Hosgrl Evaluation, or HE). However the frequency of such a large earthquake was far smaller than what is considered under the safe shutdown earthquake requirements (i.e., unlikely to occur during the life of the plant), thus, it was categorized as an extreme event that was beyond the intent of the SSE requirements. However, the NRC did not grant authorization to operate the plant until the additional external hazard presented by the Hosgri fault was adequately addressed. PG&E addressed the issue by demonstrating that the plant equipment needed to safely shut down the plant and maintain a safe shutdown condition could also withstand 0. 75g ground motion. This effort required re-evaluation, testing, and plant modifications beyond the approved ODE seismic design bases, and provided additional margin. This aspect of the design and licensing basis is unique to Diablo Canyon.

6. ts it accuraite to state that t.he SSEJOOE requires the licensee to ensure that this type of earthquake would not damage the reactor pressure boundary components (which are needed to ensure the cooling water can cool the core while the reactor is shut down) using ASME code acceptance limits as per 10 CFR 50.55a?

Yes, the reactor pressure boundary components, and all safety-related equipment needed to sa1fely shut the plant down and maintain a safe shutdown condition, must be a1ble to withstand the SSE/ODE. At Diablo Canyon, this was demonstrated through a combination of calculations and tests. Because the ASME, Section Ill requirements for design of pressure boundary components and supports were not mandated by 10 CFR 50.55a until the mid-1980's, the acceptance criteria for DCPP rely on a combination of the ASME Code and ANSI Code for piping, applicable at the time of initial licensing, that provide an equivalent level of safety assurance as required by 1 O CFR 50 55a Page 22 Ol'l'IClAL t:191! efR'( - 9EN91f l\\'E 114:PERNAL INF6RMA'fl6N

Ofll'ICb\\L US! ONL'f - 3EN91f1\\'£ IN'ffRNAL INF6RMM18N In addition, during the licensing of Oiablo Canyon, PG&E demonstrated that all structures, systems and components that are required to remain function al following a DOE/SSE would also remain functional during a postulated HE event (0. 75g). In most cases, following ex1ensive plant upgrading, each component met the same standard for the HE as it had under the SSE. In a limited number of cases, the NRC approved alternative Code criteria; thus these components still meet the applicable Code. The limited cases were individually approved and specifically documented in the NRC's safety evaluation report. The NRC's approach and conclusions were also independently reviewed by the Advisory Committee on Reactor Safeguards (ACRS), and the Atomic Safety and Licensing Board (ASLB). The ACRS reviewed the NRC staff criteria utilized in the seismic re-evaluation of OCPP for the postulated Hosgr1 event and concluded that *... the staff's approach leads to an acceptable level of safety for OCPP.

• The ASLB held hearings on the DCPP seismic issues, and in a partial decision Issued September 27, 1979, the ASLB concluded "... the Diablo Canyon plant will be able to withstand any earthquake that can reasonably be expected to occur on the Hosgri fault".

6. Is it accurate to state that meeting the SSE/DOE also means that the licensee has to test and model some of the other reactor's structures, systems and components (SSCs) to ensure they can withstand the sort of shaking that could be caused by the SSEIDDE?

Yes, licensees are required to demonstrate through modeling, testing, and evaluation that specific structures, systems, and components are seismically qualified up to the DOE/SSE.

As discussed in the answer to Question 5, this same rigor was also required for Diablo Canyon up to the HE (0.75g) design basis for the same equipment.

7. Is It accurate to state that NRC did not require the licensee to meet all of the requirements of the SSE/ODE when it came to its Hosgri earthquake analysis (and that this Is basically what you sent in the documents)?

No. The functional requirements remained the same, and were met. As indicated in the answer to Question 5, although a limited number of components relied on alternative Code acceptance criteria to demonstrate functionality up to the HE, those components still meet the applicable Code.

8. What size tsunami Is the plant designed/built to withstand?

The design basis tsunami is 35 feet. The DCPP site sits atop a coastal bluff, 85 feet above sea level, decreasing its vulnerability to a tsunami hazard. The only safety-related system that has components within the projected sea wave zone is the Auxiliary Saltwater (ASW)

System. The ASW pump motors are housed in watertight compartments within the intake structure. The intake structure is designed with an elevated air intake (48 feet) so that the ASW pumps can operate during the design combination of a tsunami and storm wave run up.

9. How Is the plant designed for each design basis earthquake? How are those design criteria/methodologies/analytical methods different? Why are they different?

{Answer under development.)

Page 23 OFFlelAt: t:ISE 8NLV - 8EN91'fl'f1E INlERNAL INF8RMATION

Ol'l'ICli'cL t:t9! 6NLY - SENSfflt/'E INTERN>'<L INFORM>'cTION Long Term Seismic Program (L TSP} Questions

1. Why is there a L TSP?

In 1984 the NRC issued the operating license for Oiablo Canyon Unit 1. The license included License Condition 2.C.(7} which required further assessment of the seismic sources and ground motions applicable to DCPP, beyond that considered in the development of the Hosgri Event. The L TSP was developed by PG&E in response to this NRC mandated License Condition.

2. What Is the Long Term Seismic Program (LTSP)?

The L TSP is a *seismic margin analysis* included as an original plant license condition. The L TSP addressed concerns at the time the plant was hoensed; including uncertainty related to the Hosgri Fault. This license condition required PG&E to develop and implement the program to reevaluate the seismic design bases used for the DCPP.

3. Did the NRC accept and approve use of the LTSP at Diablo Canyon?

In 1985 Diablo submitted the L TSP to the NRC. The L TSP included updated information on seismic hazard curves and a new deterministic ground motion response spectrum, governed by a Richter Magnitude 7.2 earthquake on the Hosgri Fault. The implementation of the L TSP included a deterministic seismic margin assessment and a seismic probabilistic risk assessment/seismic hazard analysis.

In 1991 the NRC documented acceptance of the LTSP results in SSER-34. The L TSP used much more modern techniques than had been used for the DE and the DOE. The L TSP methods were consistent with the Hosgri event review method. Section 1.4 of SSER 34 stated, MThe staff notes that the seismic qualification basis for Oiablo Canyon will continue to be the original design basis plus the Hosgri evaluation basis, along with the associated analytical methods, initial conditions, etc." As part of the close-out of license Condition No.

2.C.(7), PG&E committed to maintain the LTSP.

4. What Is the difference between the Hosgri method and the L TSP method?

The L TSP was derived using the Hosgri event. The L TSP uses seismic response data in a statistical model that is 16% more conservative than the Hosgri event. New seismic data bounded by the l TSP model is well below the Hosgri evaluation method.

5. Was Olablo Canyon's sole use of the L l SP appropriate for evaluating the Shoreline Fault?

No. In August 2011, the NRC issued TIA 2011-010. The TIA stated: "New seismic inf ormatlon developed by the licensee is required to be evaluated against all three of the seismic design basis earthquakes and the assumptions used In the supporting safety analysis as described in the FSARU. Comparison to tne L TSP by itself is not sufficient to meet this requirement.

Page 24 OFFlelAL t:JSE ONLY SEN91Ti'f'E INfERNAL INF6RMATION

Of'f'ICIAL l19E 6NLY - 9EN91fl'f'E: INff.RNAL INF6RM>'rTl6N Following issuance of the TIA, the NRC documented a violation for the failure to perform an operability evaluation in NRC Report 05000275; 323/201105. The violation has low safety significance because NRC reviews concluded the Hosgri event bounds the Shoreline fault.

TIA 2012-012 was issued on November 19, 2012. This TIA superseded TIA 2011-010 and identified that the Shoreline scenario should be considered a lesser Included case under the Hosgri evaluation and that the licensee should update the FSAR, as necessary.

The NRC's independent evaluation, documented in RIL 12-01, concluded that there is very little evidence that the Shoreline fault has ever been active. While its size was used to create a worst reasonable case ground motion curve, the region shows only some symptoms of a fault There is no evidence that there is slippage, which would indicate this was an active fault in the past. Therefore, it is reasonable to bound the Shoreline fault by the L TSP/Hosgri method.

Page 25 OfflCl,CL l19E 6HLY SENSITIVE INTERHAL INF8RMAll8N

ernelAL USE 8NLY - S!HSITI¥! INT!ftNAL INfi6ftMAfl6N Shoreline Fault Questions

1. Whe1n was the Shoreline Fault Identified?

November 2008. PG&E notified the NRC of a potential line of epicenters about one mile offshore from the plant. This was followed up on 11/21/08 with Event Notification 44675.

This line of epicenters became known as the Shoreline Fault Zone.

2. Wheire is the Shoreline fault located?

The closest segment of the Shoreline fault is located about 600 meters {1970 feet) southwest of the Power Block (the reactors) and 300 meters (985 feet) southwest of the Intake Structure.

3. What are the characteristics of the Shoreline fault?

Studies conducted in 2009 and 201 O concluded that the Shoreline fault is a right-lateral strike slip fault, approximately 23 kilometers (14.3 miles) in length, with a slip rate between 0.2 and 0.3 millimeters per year. The closest segment of the fault is located about 600 meters southwest of the Power Block (the reactors) and 300 meters southwest of the Intake Structure.

The studies also updated information on other faults in the region. The lioensee concluded that predicted ground motions from the Hosgri fault have decreased and predicted ground motions from earthquakes on the Los Osos and San Luis Bay fault zones have increased.

4. What method was used to evaluate the Shoreline fault?

In November 2008 Diablo Canyon used the L TSP method to evaluate the Shoreline Fault.

The analysis demonstrated that the Shoreline Fault was bounded by the Hosgri Fault. The Shoreline Fault has not been evaluated using the DE/ODE method.

In November 2012, the NRC concluded that it was appropriate to treat the Shoreline fault as a special case, and that using the same methods and criteria as was used for the L TSP/Hosgri, this case was bounded by the L TSP/Hosgri evaluation. This was because the Shoreline Fault frequency and peak ground acceleration at the plant were shown to be less than what L TSP/Hosgrl would produce at the plant.

6. Hat the NRC evaluated the Shoreline Fault?

In April 2009 the NRC issued Research Information Letter (RIL) 09-01, *Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon NPP from Newly Identified Shoreline Fault." This was an independent study of potential impacts of the Shoreline Fault.

The NRC concluded that adequate seismic margin existed and the plant was safe to operate.

The NRC concluded that it was appropriate to use the same methods and criteria as was used for the L TSP/Hosgri to evaluate the Shoreline fault. This was because the Shoreline Faull frequency and peak ground acceleration at the plant were below what LTSP/Hosgri would produce at the plant.

Page 26 6fflelAL t:ISE ef4t>( set*SITIVE INT!ftt*At 1t*P'eftMAT18N

Offl01AL t::fSE ONLY - SEN91fl~ fNT~HAt INf6RMAlleN

6. Was Dlablo Canyon's sole use of the L TSP appropriate for evaluating the Shoreline Fault?

No. The design and licensing basis for Diablo Canyon Included two different evaluation methods with two different acceptance criteria which could be considered bounding. The licensee could not use the method that had been used to evaluate and accept the Hosgri eve nit without the NRC agreeing that this was appropriate for new seismic information. No blanket set of rules was created from the original review that could be used without the NRC involvement.

In August 2011, the NRC issued TIA 2011-010. The TIA stated: "New seismic information developed by the licensee is required to be evaluated against all three of the seismic design basis earthquakes and the assumptions used in the supporting safety analysis as described in the FSARU. Comparison to the L TSP by itself is not sufficient to meet this requirement.

Following issuance of the TIA, the NRC documented a violation for the failure to perform an operability evaluation in NRC Report 05000275; 323/201105. The violation has low safety significance because NRC reviews concluded the Hosgri event bound the Shoreline fault.

The NRC's independent evaluation, documented in RIL 2012-01, concluded that there is very little evidence that the Shoreline fault has ever been active. While its size was used to create a worst reasonable case ground motion curve, the region shows only some symptoms of a fault. There is no evidence that there is slippage, which would indicate this was an active fault in the past. Therefore, it is reasonable to bound the Shoreline fault by the L TSP/Hosgri method.

7. Is there a threat of a tsunami from an earthquake occurring on the Shoreline fault zone?

No. PG&E's final report on the Shoreline fault zone indicates that the faulting mechanism is principally a right-lateral strike-slip. It is highly unusual for strike-slip faulting to cause a sizable tsunami. Most seismically induced tsunamis result from reverse faulting events, which have the capactty to cause rapid vertical displacement of the sea floor.

8. Why are they safe to operate?

Diablo Canyon has completed an operational evaluation to show the plant is safe to operate.

The NRC reviewed and agreed the evaluation indicates the plant is safe to withs.tand earthquake hazards. Based on what the NIRC has independently verified and detailed in Rll 2012-01, Oiablo Canyon has an operational assessment in place to show that the plant is built to wtthstand the most severe expected ground motion at the site. If new i1nformation suggests the facility is not safe the NRC would take immediate action to resolve the issue.

9. Why is the NRC allowing Dlablo Canyon to operate when experts inside and outside the NRC believe the Shoreline Fault represents a threat to the plant and serious questions have been raised regarding whether the facility meets NRC 1s license requirements?

Page 27 0ffl01AL ~SE ONLY - 9CN91fl't'E lt4f£RNM:: INFORMAflON

8FFl81,lrl t::ISE 8NLY - Stt*Slfrt'e lffff RNAL INF6RMAf16N When the NRC set out to perform an independent assessment of the Shoreline Fault we put together a team of NRC seismic experts as well as a team of consultants from outside the agency to ensure that we had the right expertise to perform the analysis and that the resulting document would be technically defensible. Our Independent deterministic analysis of the Shoreline Fault determined that the ground shaking at the plant site that could result from earthquakes on the Shoreline Fault is bounded by the larger ground motions that could result at the plant site from earthquakes on the Hosgri fault. Based on the NRC's independent analysis of the fa ult displacements and ground motions from the Shoreline Fault, and the conclusion that these ground motions are less than those used in the Hosgri evaluation, the Shoreline Fault does not pose a new safety hazard to the Oiablo Canyon Power Plant.

The former NRC senior resident inspector has questioned how the Shoreline Fault fits within the seismic design and licensing basis of Dlablo Canyon, and the November 2013 Union of Concerned Scientists report echoes this concern. The NRC has determined that the ground motions from the Shoreline Fault should be considered a lesser included case under the Hosgri event, which the plant was evaluated for during original licensing.

The Hosgri evaluation was a major effort undertaken at the time of Diablo Canyon's licensing and underwent an extensive review by NRC seismic experts as well as consultants from outside the agency. For the Hosgri evaluation, PG&E performed a new set of calculations for equipment that was needed to safely shutdown the plant, they took out electrical cabinets and shake table tested them again to a higher level, and in cases where equipment could not meet the Hosgri level, plant modifications were made. Specifically, the turbine building required extensive modification, above ground outdoor water storage tanks were also modified significantly, and other major modifications were performed on the fuel handling building crane, turbine building cranes, electrical equipment, and the diesel fuel oil transfer system. Both the ASLB and the ACRS performed extensive reviews of the NRC's unique approach to the Hosgri Evaluation, and agreed with the staffs results. The plant was eva'luated and licensed for the Hosgri ground motions; therefore the facility does meet NRC's license requirements.

10. Is it accurate to state that generally speaking, when a licensee does not meet its license requirements, there are 3 typical options: 1) NRC can order the reactor to shut down until the license requirements are met, 2) NRC can approve a set of' mitigation measures the licensee could take that would satisfy the license requirements, or 3)

NRC can approve a license amendment to alt.er the requirements of the license?

The options listed are valid approaches that could be used to address a ncensee's failure to meet a requirement, but there are many other avenues available that licensees and NRC could consider to restore compliance and ensure that safety and security are maintained.

NRC licensees are ultimately responsible for ensuring the safe operation of the plant and for meeting all the applicable requirements, and they have an obligation to recognize and address safety problems and potential non-compliances. If a licensee is not meeting those requirements, they must evaluate the issue and determine its safety significance, and take timely and appropriate corrective action to ensure adequate safety is maintained and to restore compliance. It should be recognized that not all departures from NRC requirements involve an impact to safety. There are substantial safety margins and redundancy bum into nuclear power plants.

Page 28 erF1e1,-t tJSe eNLV 9EN91fl't'E ltUERNAL INF6RM,-flet*

6'5f1Chtct tf3E 6NLY 9EN91fl't'E lffTE"NAt INf6ftMAfl6N Many potential paths to resolution are built into the NRC's regulations or specified in the licenses and technical specifications. Some provide very specific actions the hcensee must take, including shutting the reactor down if the issue cannot be resolved quickly, while others provide flexibility to identify and consider possible options. Depending on the sltua1ion and its significance, the NRC also has a number of enforcement options available (such as issuing violations, civil penalties, and Orders) if a licensee is not meeting its regulatory requirements. These options are described in the enforcement guidance listed on NRC's Enforcement web page at http://www.nrc.gov/about.

nrc/regulatory/enforcement html. The NRC Enforcement Policy describes the process NRC uses to assess and disposition violations of NRC requirements to ensure that NRC's enforcement actions proper1y reflect the significance of the violations.

Regardless of the resolution path followed, the NRC will take whatever action is necessary to ensure that adequate protection of public health and safety is maintained.

11. Is It accurate to state that NRC has not done any of the options listed in Question 11 (above) for DCPP to address NRC's own conclusion that the reactor has likely not met its SSE/ODE license requirements whe11 It considers the ground shaking that could be caused by Shoreline earthquake?

No. As discussed below, the NRC has concluded that the existing DCPP design basis is sufficient to withstand ground motions from the Shoreline fault, and OCPP remains capable of withstanding ground shaking associated with the design characteristics approved for the DOE/SSE. The NRC has not identified a safety issue at Diablo Canyon in this case.

Shortly after PG&E notified the NRC of the potential for a new fault (later referred to as the Shoreline Fault), it provided the NRC with sets of initial scientific data and information related to the hypothesized fault. Based on this initial information, the NRC staff immediately performed a preliminary review of possible implications of the Shoreline fault to the DCPP to determine if an immediate safety concern existed. The NRC continued to review new data and information on the Shoreline fault resuhing from a collaborative effort between the U.S. Geological Survey and PG&E.

The NRC's October 12, 2012, letter to PG&E provided, in part, a summary of the results of NRC's independent assessment (which included independent external experts} of the licensee's January 7, 2011 Shoreline Fault analysis report (the detailed assessment is in NRC's Research Information Letter (RIL) 12-01 "Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone" ). The licensee's report provided NRC with new geological, geophysical, and seismological data on the Shoreline fault, obtained using up.to-date methods and technologies The NRC's independent assessment determined that the Shoreline fault could create ground motion lower than the ground motion for which the plant had previously been evaluated (i.e., the 0. 75g, HE). As such, the NRC's October 12, 2012, letter concluded that the existing design basis for the plant is sufficient to withstand ground motions from the Shoreline fault.

Page 29 6ffolelAL tJ9E 8P4LV - 9EN91'fl'f'E INTERNAL INf8RMAfl8N

Ol'l'ICIAL t:ISe ONLY 9EN91flVE IN"fEfU4AL 1Nf69'M1Cfl6N State of California Seismic Report (AB-1632)

Note: This section is excerpted from the *communications Plan - Diablo Caynon Power Plant Topics of Interest State of California Seismic Report" dated 9/10/14. Please refer to that communications plan for the most current information,

Background

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerabitlty of California's largest baseload power plants, Dlablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report. This is a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.

The purpose of this communication plan is to provide key messages associated with the public release of this report.

Key Messages NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning OCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event.

PG&E's evaluation of the new seismic information, as documented in the report, concludes that the ground motions resulting from the faults discussed in the report (i.e.,

Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

The NRC staff will review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.

PG&E will incorporate the findings from Bill 1632 report into their upcoming March 2015 probabilistic seismic hazard analysis as part of the NRC's post-Fukushima actlvilles.

The NRC believes this more rigorous analysis will provide the most accurate a:ssessment of faults affecting lhe OCPP.

Questions andl Answers

1. What is the impact of this new infonnation on seismic design and licensing of OCPP?

Has the licensee entered this new information into the corrective action program and Page 30

6JifletAL USE ONLY - SEHSlflVI! INTl!MNAL INl'O"Ml<TIOf4 perfonned an operability evaluation?

In accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has entered the new preliminary seismic infonnation into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.

In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commttment to the NRC:

"If during PG&E's ongoing collection of seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable *than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staff's March 12, 2012, request for information (Reference 2)." Reference 2 is NRC letter to All Power Reactor licensees and Holders of Construction Permits in Active or Deferred Status, "Reqiuest for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident.ft March 12, 2012.

NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary infonnation concerning DCPP seismic and licensing bases. The licensee's infonnation did not indicate there is an immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions.

In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

The NRC will review the new infonnation provided in the report to the State of California including the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate if the NRC staff concludes that the new infonnation associated with the Shoreline Fault causes the NRC to revisit the conclusions in the Rll.

2. Has OCPP provided the seismic report 1!0 the NRC?

Yes, in accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has provided the infonnation to the NRC. In addition, the report was also provided to address license renewal issues (see question 8).

3. What does the new report state?

The new report includes information obtained from 2-dimensional and 3-dimensional high energy and low-energy seism1c surveys both onshore and offshore of the OCPP site. The report provides more details on the regional faults, including more precise readings and additional data points where previously there were gaps. While a lot of the information from the previous Shoreline Fault report of 2011 was confinned, some of the new data suggests Page 31 6Jif telfcl tf9E 6fRY SEN!l'flf/E UffERN>'cL 1Nf'6RMATl6N

eF FrelAL USE eNtY - 9ENelfl'l'e IHfl!ftNAL INf6ftMAf16N the following:

Reduced slip rate on the Hosgri Fault Zone and the Shoreline Fault Zone Postulated connection of the Hosgri and the San Simeon faults which could result in a longer, larger, but more infrequent earthquake The unique geometry involved with intersecting the Hosgri Fault and the Shoreline Fault Zone results in an extension of a few kilometers, but with a lower frequency of occurrence Extension of the Shoreline Fault zone southern segment The new data does not alter the assessment of the closest approach of the Shoreline fault to DCPP which is 600 meters from the pawer block and 300 meters from the intake structure. Because the ShoJl'eline fault is considered to be somewhat longer, potential earthquakes could also occur farther from the plant.

Updated analysis for the San Luis Bay, and Los Osos faults The ll'eport concludes that the ground motions for the Hosgri and L TSP evaluations continue to bound potential ground motions from the regional faults, including the Shoreline Fault, San Luis Bay, Los Osos, San Simeon and Hosgri. The DCPP continues to operate safely within the seismic margin they were designed to withstand.

4. How will the AB 1632 seismic report be coordinated with the 50.54(f) required submittal in March 2015?

PG&E plans to incorporate the findings from Bill 1632 repart into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

(If pushed on any "unknowns" in the report: If necessary, actions could include orders to halt operations if new information suggests there is an immediate safety concern. The NRC will fulfill its mandate to protect public health and safety).

(If asked what things the plant has done since Fukushima: It is important to note that DCPP is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).

5. Why Is the report "final" for the state but "preliminary" for the NRC?

For the State, the report is final. For the NRC, this information is expected to be incorporated Into the more comprehensive 50.54f anatysis due to the NRC in March 2015.

However, because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is sare to continue to operate. PG&E's evaluation of the new seismic information, as documented In the report, concludes that the ground motions resulting from the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos. and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

Page 32 o,,,erAt t:191: ONLY - 91:N91fl't1E INlERNAL INF6RMATl6N

OfflelAL t:191! 6NLV - 9EN91ftVE lfffERNAL INF6RMA'fl6N

6. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shore11ne fault In 2011 prior to issuing the RIL?

California Assembly 81111632 {Blakeslee, Chapter 722, Statutes of 2006) directs the California EJlergy Commission to assess the potential vulnerablllty of California's largest base-load power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station, to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 report The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analyses which is due for DCPP in March 2015.

7. What is the impact of this new infonnation on seismic design and licensing of DCPP?

Based on the preliminary results of the studies that are under review, PG&E determined that the Shoreline Fault Zone may be capable of producing somewhat larger earthquakes than considered in the January 2011 Shoreline report. The NRC staff is independen11y assessing PG&E's determination. The process outlined in the 50.54(f) letter includes a detailed analysis of new seismic information (including shoreline faults and other faults around the plant). PG&E is scheduled to provide this assessment in the March 2015 time frame. The staff will continue to review the information in the new CA 1632 report and the final results of the new data from the more rigorous analysis to be completed by March 2015. The NRC staff will take appropriate regulatory action up to and including issuing Orders to ensure safe operation of the plant.

8. Will the Report be considered in the License Renewal Process Yes. In addition to the report being developed to address California Assembly Bill 1632, PG&E is providing the report to the State of California as part of the State of California coastal zone consistency certification associated with the license renewal for DCPP. The State of California coastal zone consistency certification,s considered by the NRC during the license renewal environmental review process. In addition. the Staff will be reviewing the report to see how, if at all, it is relevant to the Staffs license renewal review. There is a contention related to the Shoreline fault and its consideration in the facility's severe accident mitigation alternatives analysis ttiat is admitted in the hcense renewal proceeding (see ML14224A320; See CLl-11-11).

Page 33 eff 1e1At t:191! 6NLV - S!NSITIV! INT!"NAL INf'O"MATfON

OfflelAL l19E ONLY - SENSff PIE IPf'FERNAL 1Nf6RM.trfl6N Los Osos and San Luis Bay Faults

1. Old the licensee and NRC evaluate the Los Osos and San Luis Bay Faults?*

Yes. The Los Osos and San Luis Bay Faults are also near Diablo Canyon. They were studied and reported to the NRC as part of the L TSP. These faults were mentioned in PG&E's January 2011 Shoreline Report for comparison. though no new data on these faults was presented.

The NRC reviewed these faults under its review of the L TSP, and concluded they were bounded by the Hosgn event and there was no specific need to discuss them in the Updated Final Safety Analysis Report Page 34 OflfllelAL l19E et~LY - 9EN91ftlfE INTERNAL INf6RMAll6N

OfflCIAL use ONLY - SENSITl'f'E INTERNl(L INF8RMATl8N Research Information Letter (RIL} Questions

1. What Is a RIL?

Rlls are documents issued by the Office of Nuclear Regulatory Research (RES) to the NRC Regulatory and Regional Offices that summarize, synthesize, and/or interpret significant research information, provide new or revised information, and discuss how that information may be used in regulatory activities. Rll's allow NRC Regulatory Offices or Regional Offices to readily understand what new iniormation has been obtained, and the significance of that information fo'r current and future licensing reviews or other regulatory activities.

2. What is the purpose of RIL 2009.. 001?

Research Information Letter (RIL) 2009-001 was issued on April 8, 2009. RIL 2009.001 was initiated for RES to complete an independent analysis of the Shoreline Fault.

In RIL 2009-001, the NRC concluded that the seismic-loading levels predicted for a maximum magnitude earthquake on the Shoreline fault were below those levels for which the plant was previously analyzed in the LTSP.

3. What Is the purpose of RIL 2012-01 ?

Research Information Letter 2012-01 was issued on September 19, 2012. RIL 2012-01 was initiated for RES to complete an independent analysis of seismic hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone.

The NRC's independent evaluation, documented in RIL 2012-01, concluded that there is very little evidence that the Shoreline fault has ever been active. While its size was used to create a worst reasonable case ground motion curve, the region shows only some symptoms of a fault. There is no evidence that there is slippage, which would indicate this was an active fault in the past. Therefore, it is reasonable to bound the Shoreline fault by the L TSP/Hosgri method.

4. Now that the Rlls have been issued, is PG&E done with its studies?

No. PG&E has performed additional studies including three-dimensional (3-0) marine and two-dimensional (2-0) onshore seismic reflection profiling, additional potential field mapping, Global Positioning System monitoring, and the feasibility of installing an ocean bottom seismograph network. These activities are being used to further refine the characterizalion of those setsmic sources and ground motions most important to the DCPP: the Hosgri, Shoreline, Los Osos, and San Luis Bay fault zones and other faults within the Southwestern Boundary z,one. PG&E are performing seismic and flooding walkdowns per the March 2012 50.54(() request from the NRC. The results from PG&E's actions will be due in March 2015.

Page 35 8FFlelAL t19E ONLY - 9ENS1fltte INfERNAL INFORM>tffiON

et'l'ICIAL tJSI! e,~tY - 9EN91'ftY! INT!f'NAL INl'OlltMATIOH "Sewell" Report J Tsunami Concerns

Background

In March of 2004, as part of the review for the Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) license review. the Center for Nuclear Waste Regulatory Analysis (CNWRA, a division of Southwest Research Institute), transmitted to the NRC a Tsunami Hazard Study that applied to the Diablo Canyon site. Within the scope of the CNWRA review of the Diablo Canyon ISFSI application, a CNWRA contractor. Dr. Robert Sewell, developed a draft report (the "Sewell Report") on the potential for landslide tsunamis impacting the site. The report postulated wave elevations from potential landslide tsunami scenarios that could exceed the current licensing basis tsunami height for D1ablo Canyon.

CNWRA did not endorse Dr. Sewell's work, but did transmit the report to the NRC to inform the NRC of developments in the landslide generated tsunami area of study. The Sewell Report was reviewed by the Seismic Issues Technical Advisory Group (SITAG) in the NRC's Office of Research. In November 2005, the SITAG review concluded that the tsunami scenarios contained in the Sewell Report were based on rudimentary modeling with little geologic and geotechnical data. SITAG further concluded that the study should not be used in any licensing actions.

In February 2006, the Office of Nuclear Reactor Regulation's (NRR's) Division of Engineering terminated further consideration of the Sewell Report, based on NRC participation in other cooperative government reviews of tsunami hazards under the President's Office of Science and Technology Policy (OTSP). NRR concluded that the OTSP effort would provide a more technically credible forum to broaden the NRC's understanding of tsunamis and inform efforts to reassess the tsunami design criteria in the Standard Review Plan.

The design basis tsunami for DCPP considers distantly-generated tsunamis and locally-generated tsunamis. The design basis tsunami is the greater of these tsunamis and is 34.6 feet. Additionally, DCPP sits atop a coastal bluff, 85 feet above sea level, decreasing its vulnerability to a tsunami hazard.

The intake structure auxiliary salt water pump room vents are extended with steel snorkels to prevent seawater ingestion due to splash-up during the design flood event and is thus ensured of operation during extreme tsunami drawdown and combined tsunami and storm wave conditions. The only safety-related system that has components within the projected sea wave zone is the auxiliary salt water system. The auxiliary salt water pump motors are housed in watertight compartments within the intake structure. These compartments are designed for a combination tsunami-storm wave activity to elevation +48 feet MLLW (+45.4 feel MSL). The massive concrete intake structure ensures that the pumps remain in place and operate during extreme wave events. The intake structure is arranged to provide redundant paths for seawater to the pumps, ensuring a dependable supply of seawater.

A 2011 staff overview of Diablo Canyon (http;//adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML111290158 )

includes reference to a 2010 PG&E report on updated tsunami hazards (http://peer.berkeley.edu/tsunamVtasks.ltask-1-tsunami-hazard-analysis/ ), part of an academic review of California tsunami hazard.

Page 36 6fifil61>9tl tJ91! 6NLV - 9!NSITl9'! INTEf'N>9tL lf4F6f'MATl6N

Offl'ICIAL US!! ONLY - S!NSlfl't 1!! INT!ftNAL INl'6ftMA'f16N After identification of the Shoreline fault in 2008, PG&E determined that the tsunami hazard threat from Shoreline is relatively small since it Is a strike-slip fault rather than a reverse fault and there Is not expected to exceed the design basis. The NRC performed an evaluation of the tsunami hazard and an independent deterministic seismic hazard analysis of the fault based on Information provided by the licensee to confirm DCPP's conclusions regarding safe operation.

After the earthquake and tsunami in Japan on 'March 11, 2011, the NRC issued in March 2012 a request for information (also known as a 50.54(f) letter) requesting each nuclear power plant to re*evaluate the flooding hazard at their site, including tsunami. This re-evaluation Is due from DCPP in March 2015. DCPP was given 3 years to respond due to the technical complexities involved in their re--evaluation.

Key Messages The NRC did not publicly release the draft report for two reasons:

1. Although the staff considered the report during the licensing of DCPP Independent Spent Fuel Storage Installation (ISFSI), it did not form the basis for any licensing action

2. The draft report was considered preliminary and its conclusions based on limited data and methods The design basis tsunami for DCPP considers distantly-generated tsunamis and locally-generated tsunamis. The design basis tsunami is the greater of these tsunamis and 34.6 ft.

Additionally, DCPP sits atop a coastal bluff, 85 ft above sea level, decreasing its vulnerability to a tsunami hazard The NRG licensed DCPP independent spent fuel storage installation based on its conclusion that the probable maximum tsunami flooding at the proposed ISFSI was adequately addressed by PG&E, based on the licensee's assessment of more recent tsunami information in the area, as well as the much higher elevations of the ISFSI site and transporter route relative to the previously analyzed hazard for the power plant. This conclusion was reached with full consideration of this report.

The NRC is continuing to re-evaluate the tsunami hazard. After the earthquake and tsunami in Japan on March 11, 2011, the NRC issued in March 2012 a request for information (also known as a 50.54(f) letter} requesting each nuclear power plant to re-evaluate the flooding hazard at their site, including tsunami. This re-evaluation is due from DCPP in March 2015.

DCPP was given 3 years to respond due to the technical complexities Involved in their re-evaluation.

DCPP's ability to withstand large waves and the maximum wave height at the intake structure were determined through extensive and detailed scaled model wave testing. The only safety-related components within the project sea wave zone (auxiliary salt water system) are protected from tsunami effects.

Questions and Answers

1. Why did the NRC decide to not release the draft report to the public?

The NRC did not release the report for two reasons. First. although considered during the Page 37 Of'f'ICIAL tJS!! ONLY - SEffSITl't'E IN'f EMffAL U4F6RMA-Tl6ff

6fflel1'L \\19E eNtV - 9ENSfflYE INTERN,.l 1Nf6RM'4Tl6f4 licensing of DCPP 1SFSI, It did not fonn the basis for that licensing action. Second, the draft report was considered preliminary and its conclusions based on limited data and methods.

2. Wha,t has the NRC done to evaluate the report?

The NRC was assisted by experts from the Center for Nuclear Waste Regulatory Analyses (CNWRA) in performing a comprehensive safety and technical review of PG&E's license application for an ISFSI. The CNWRA, in turn, contracted the services of Dr. Robert Sewell specifically to assess PG&E's application with respect to tsunami hazards The NRC and CNWRA concluded that the probable maximum tsunami flooding at the proposed ISFSI was adequately addressed by PG&E, based on PG&E's assessment of more recent tsunami information in the area, and the much higher elevations of the ISFSI site and transporter route relative to the previously analyzed hazard for the power plant.

The CNWRA assessed the information in Or. Sewell's report upon receiving It in November 2003. The report was forwarded for NRC's consideration in March 2004, after CNWRA had completed its review of the DCPP ISFSI application. Both the principal investigator for the CNWRA, an expert geologist and seismologist, and the NRC determined that the findings in the report were too speculative to be considered in current licensing decisions, but that they might warrant further review by the NRC. In February 2005, the NRC staff initiated further review of the report, consistent with its efforts to assess the December 2004 tsunami in southeast Asia. In May 2005, the NRC directed that a special review of the report be performed by NRC seismic experts. That group reached its preliminary conclusions on Dr.

Sewell's report in November 2005, and completed its evaluation in January 2006.

3. Why did it take the NRC group of seismic experts from SITAG so long to review the report?

The NRC group made an initial assessment of the hazard and the credibility of the report and determined that a 6 to 12 month review time frame was appropriate in consideration of NRC.'s other high priority safety and regulatory issues currently under development. The preliminary assessment was completed in November 2005, with revisions in January 2006.

4. Was the concern about the tsunami hazard potential at OCPP related to the December 2004 earthquake and tsunami In Sumatra and the Indian Ocean?

No. The study of the potential tsunami hazard was performed during the licensing of the proposed ISFSI at the DCPP site, prior to the 2004 event m the Indian Ocean. In response to the tsunami in Sumatra and the Indian Ocean, PG&E initiated its own study of the tsunami threat to DCPP. A 2011 staff overview of Diablo Canyon (http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML111290158 )

includes reference to a 2010 PG&E report on updated tsunami hazards (http://peer.lberkeley.edu/tsunami/tasks/task* 1 *tsunami*hazard-analysis/ ), part of an academic review of California tsunami hazard.

Followlng the earthquake and tsunami in Japan on March 11, 2011, the NRC issued a demand for information letter (also referred to as a 50.54(f) letter) in March 2012 requesting information from each nuclear power plant regarding the current flooding hazard at the site, using the most u~to--date methodologies. DCPP's response to this letter is due March 12, 2015. DCPP was given three years to complete this re*evaJuation due to the technical Page 38 err1e1AL tJ9E eNL\\1 - 9EN91fl't1E IN'fERNAL INFORMMIOH

Ol'l'ICltct t,Sf ONLY - Sl!N3Ffl't1: INTeftN>'ct 1Nf'6RM>'<Tl6N complexities involved at their site.

5. Are coastal nuclear faclllties safe today from the tsunami threat?

Yes, the coastal nuclear facilities are safe from the threat of tsunamis. The NRC has llcensed a number of nuclear facilities on the US Pacific, Atlantic, and Gulf coasts. These facllltles include commercial nuclear reactors. ISFSl's. and research and test reactors (RTR's). The NRC has determined that public health and safety continue to be maintained for these facilities.

The NRC design philosophy for natural phenomena hazards, such as tsunamis, is based on consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area with sufficient margin for limited accuracy, quantity, and period of time for which the historical data have been accumulated. Existing nuclear facilities were licensed consistent wtth this design philosophy.

In general, facilities located along the Pacific coastline are more likely to be impacted by tsunamis due to the more frequent occurrence of large earthquakes along the margins of the Pacific Ocean. Deep ocean trenches off the coasts of Alaska, the Kuril Islands, Japan, and South America are well known for their large earthquakes and as potential sources for Pacific-wide tsunamis. The most recent damaging tsunami along the Pacific coast was caused by the 1964 magnitude 9.2 Alaskan earthquake with a wave height of 21 ft recorded in Crescent City, far from DCPP. Tsunamis generated by local sources, such as submarine landslides, also have the potential to impact coastal sites. The design of nuclear facilities along the Pacific coast was based on historical tsunami information and considered both local and distant tsunami sources as well as local onshore and offshore topography. Hence the facilities have been designed for the largest recorded tsunami effect with additional safety margins.

Therefore the NRC staff believes that there continues to be adequate protection of public health and safety from the tsunami threat to nuclear facilities on the Pacific coastline.

The design basis tsunami for DCPP considers distantly-generated tsunamis and locally-generated tsunamis. The design basis tsunami is the greater of these tsunamis and 34.6 ft.

Additionally, DCPP sits atop a coastal bluff, 85 ft above sea level, decreasing its vulnerability to a tsunami hazard. DCPP's ability to withstand large waves and the maximum wave height at the intake structure were determined through extensive and detailed scaled model wave testing. The only safety-related components within the project sea wave zone (auxiliary salt water system) are protected from tsunami effects.

6. Has NRC assessed the potential Impact of a tsunami, as predicted by Dr. Sewell, on the DCPP and public safety?

The NRC's assessment of potential tsunami hazard is ongoing and the DCPP response to the 50.54(f) letter is due March 2015. However, the NRC has concluded that the tsunami scenarios described by Dr. Sewell in the report are based on preliminary data and analysis and should not be used as a basis for any licensing action. NRC continues to evaluate the potential tsunami hazard for coastal nuclear facilities to ensure the most up to date scientific information is assessed and properly considered.

Page 39 6fFlelAL t:19E eNt¥ - S!NSITl'l'E INTl!ftNAL INl'ORMATION

6FF1e11ct l19E eNLY - !l!NSllft'I! INl'!ftNAt INl'OftMATl6N

7. What Is the NRC doing to address any generic Implications for coastal sites otherr than DCPP?

Following the March 11, 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami.

The NRC used criteria to prioritize each site's response due date, ranging from 2013 to 2015. Once the NRC receives the response, experts will evaluate the data to determine if additional action is required.

8. Has NRC discussed the results of their review of the report with Dr. SeweU and has he responded to NRC's comments?

The NRC has discussed the findings with the NRC's contractor CNWRA, who subcontracted the study to Dr. Sewell.

9. If the NRC was dissatisfied with the draft report It received from Dr. Sewell, why didn't It return the report to him and require he make the changes necessary to address the statrs concerns?

After the SITAG's findings that the report's conclusions were based on limited data and methods, the NRC determined that it would be more effective to spend rts resources participating in several ongoing initiatives to reassess tsunami hazards sponsored by NOAA, USGS, and the White House Office of Science and Technology Policy, rather than further reviewing or revising Dr. Sewell's report.

Following the March 11, 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami.

The NRC used criteria to prioritize each site's response due date, ranging from 2013 to 2015. Once the NRC receives the response, experts will evaluate the data to determine if additional action is required.

10. What actions has the NRC taken to ensure it is correct In addressing the areas it used to discount Dr. Sewall's report?

A 2011 staff overview of Diablo Canyon (http://adamswebsearch2. nrc.qov/webSea rch2/main.jsp? AccessionNumber=ML.111290158 )

includes reference to a 2010 PG&E report on updated tsunami hazards (http://peer.berkeley.edu/tsunami/tasksltask-1-tsunaml-hazard-analysis/ ), part of an academic review of California tsunami hazard.

Following the March 11, 2011 earthquake and tsunami in Japan. the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami.

This re-evaluation must be completed using current methodologies and data. Therefore. the re-evaluation, when received in March 2015, will address these areas. The NRC will then review and,evaluate this response and determine what, if any, actions are needed.

11. How has the tsunami hazard been changed based on the identification of the Shoreline fault?

After identification of the Shoreline fault in 2008, PG&E determined that the tsunami hazard threat from Shoreline is relatively small since it is a strike-slip fault rather than a reverse fault Page 40 6Ffle1AL l19E eNL'f - 31!N911'1't't: ltffEffNAL INfi6ftMA1'16N

eFFlelAL t:19E eNLY - !ENS1Trt1e INT!:RNAL INF6RMAT16N and there is not expected to exceed the design basis. The NRC performed an evaluation of the tsunami hazard and an Independent deterministic seismic hazard analysis of the fault based on information provided by the licensee to confirm DCPP's conclusions regarding safe operation.

12. Why hasn't anything been done with this report post-Fukushima?

After the SIT AG's findings that the report's conclusions were based on limited data and methods, the NRC determined that the report should not be used as a basis for any licensing action.

However, following the March 11, 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami. This re-evaluation must be completed using current methodologies and data.

Therefore, the re-evaluation, when received in March 2015, will address these areas. The NRC will then review and evaluate this response and determine what, if any, actions are needed.

Page 41 eflfllCIAL ~!e ONLY - eeN91l'ltt£ INTe"NAL INf 6ftMAl'l6N

6fifile1AL tJSe 6HLY - S!NSIT~! INl'!ftNAL INfi6ftMAllON Non-concurrence and DPO Questions Refer to *communications Plan - Diablo Canyon Power Plant Topics of Interest Differing Professional Opinion and Appeai-for most current information.

NOTE: General FAQs on the DPO Program are included on the DPO Web site (look under Employee Resources-Employee Concerns.

1. Was the fonner OCPP SRI reassigned because he filed two non-eoncurrencea?

No. The former DCPP SRI was not reassigned. He applied for an instructor position in his area of expertise at the NRC's technical training center in Chattanooga, TN, at about the time he submitted his non-concurrence in accordance with the Non-Concurrence Process described in MD 10. 158. He was competitively selected for this sought-after position, and reported to his new assignment in September 2012. Resident inspector assignments are limited to 7 years to ensure objectivity. It is common for resident inspectors to apply for their next job when a desirable position comes open.

2. When were the non-concurrences filed?

Two non-concurrences were filed by the DCPP SRI.

11/7/11. The DCPP SRI submitted NCP 2011-103, on inspection report 05000275; 323/201104.

1/26/12. The DCPP SRI submitted NCP 2012-01, on inspection report 05000275; 323/201105.

3. What were the non-concurrences?

Both non-concurrences involve the same subject; regulatory actions in response to the discovery of the Shoreline Fault.

NCP 2011-103 was filed by the DCPP SRI on the basis that no violation was issued (as he had submitted in the draft report) related to operability evaluation of the Shoreline fault in Report 2011-04. NCP 2011-103 was dispositioned finalizing the violation in IR 2011-05 issued on 2/14/12. (The employee requested that the NCP be non-public.)

NCP 2012-01 was filed by the DCPP SRI because the SRI believed the violation in NRC IR 2011-05 should be for an Inadequate operability evaluation of the Shoreline Fault rather than not doing an operability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault. NCP 2012-01 was discussed with NRC stakeholders representing NRR/DE, NRR/DORL, RIV, and RES. NCP 2012-01 was dispositioned as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005~020 immediate (interim) operability evaluation in June 2011. Additionally, the offices involved in NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the lime oJ Inspection Report 2011-05 issuance it was expected that the requirements and methods would be addressed in a License Amendment Request that was under consideration.

Page42 Ol'l'ICIAL t:191! 6ffLV - Sflf911'1'1'! IPff!ftNAL Uff'OftMAll6N

Oflf'ICIAL li9! ONLY - 9ENS1fl'IE IN'TERNAL INF8RMA'fl8N However. by 30 /2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the L TSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered.a lesser included case of the Hosgri event. (The employee supported public release of the NCP ADAMS ML121A173.)

4. When was the DPO filed?

July 18, 2013. The former DCPP SRI filed Differing Professional Opinion (DPO) 2013-02 associated with the regulatory response following the discovery of the Shoreline Fault.

NRC employees are encouraged to file a DPO if they believe an agency decision is in error The DPO process is in keeping with the agency's open and collaborative working environment.

5. What Is the DPO?

DPO 2013-02 restated the issues presented in NCP 2012-01 and added a concern that a license amendment was needed incorporate the shoreline fault into Diablo Canyon's FSAR as described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults.

6. What is the status of the DPO?

A decision on the DPO was issued by the Office Director for NRR on May 29, 2014 consistent with the NRC's process included in MD 10.159. The DPO submitter appealed this decision to the EDO on June 23, 2014, and the appeal was thoroughly evaluated by the EDO and decision on the appeal was rendered on September 9, 2014.

As part of the agency's open and collaborative work environment, the NRC has established the DPO program as a means for employees to have their concerns reviewed by high level managers. The DPO Program is a formal process that allows all employees and contractors to have their differing views on established, mission-related issues considered by the highest level managers in their organizations, i.e., Office Directors and Regional Administrators. The process also provides managers with an independent, three-person review of the Issue {one person chosen by the employee). After a decision is issued to an employee, he or she may appeal the decision to the Executive Director for Operations (or the Chairman for those offices reporting to the Commission).

7. WIii the decision regarding the DPO be made publlc?

The NRC supports openness and wilt inciude a summary of the disposition of the DPO in the Commission's Weekly Information Report included on the NRC Web site (see Commission Documents under the Document Collections in the NRC Library). The OPO submitter has been contacted regarding the EDO's decision on the OPO appeal and has communicated support for the public release of the DPO Case File (with appropriate redactions). The DPO Case File should be publicly available within a few days of the EDO's DPO appeal decision.

8. Was the SRI wrongfully reassigned after filing two non-concurrences and a DPO?

Page 43 eFFlelAL t:19E eNLV SEN91flVE INTERNAL INF6RMAT16N

Of'f'lCIAL t:191! 6NLY seNs1,ive INTl!~NAL INl'O~ATIOlf No. As noted in Q&A #1 above. the SRI appfied for and was selected to a highly sought instructor position at the NRC's Technical Training Center. The NRC does not tolerate retaliation for engaging in the NCP or the DPO Program and both MDs reiterate this policy and direct employees to resources in the event they believe that they have been retaliated against

9. Would the OPO panel's conclusions or the DPO appeal decision change based on the new seismic information found In the State of California report?

PG&E, the licensee for Oiablo Canyon, 1s providing a report to the State of California that includes the results of its most recent evaluation of the seismic hazards for the Diablo Canyon facility. The NRC understands that the report will be provided to the State of California on September 10, 2014, and that a copy will be provided to the NRC as well.

Prior to performing a detailed review of this report, the NRC is not able to ascertain whether the new seismic information contained in the report would change the DPO panel's conclusions or the DPO appeal decision. The NRC understands that PG&E plans to incorporate the findings from this report into their ongoing probabilistic seismic hazards analysis required by the NRC Post-Fukushima task force recommendations that are due in March 2015. The NRC believes this more rigorous analysis will provide the mos1 accurate assessment of faults affecting the DCPP. In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the ground motions resulting from the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event.

The NRC staff will review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new infonnation associated with the Faults around DCPP cause NRC to question PG&E's conclusions.

10. Tlmeline of Events aesociated with the NCPs and DPO:

11/7/11 11 /9/11 40/2011 DCPP SRI submits Non-Concurrence NCP 2011*103. The SRI non-concurs on Inspection Report 05000275; 323/2011004 because the proposed violation involving the Shoreline Fault operability evaluation was not Issued.

NCP 2011-103 is dis positioned by Region IV. The operability evaluation issue was documented as an UnresolVed Item in Inspection Report 05000275; 323/2011002 and dis positioned as a violation in lnspectlon Report 05000275; 323/2011005.

The DCPP SRI continues to question the enforcement action associated with the Shoreline Fault operabili1y evaluation. Several meetings between multiple NRC offices are conducted to discuss the Shoreline Fault.

Page 44 61'FtetAL t:J9E eNLY - 9EN91fl'f'E INTEltNJfct u*FeftM>'rfl6'4

6FFlel>lcl tJ9E 6NLY - 9EN91fflif: INfERN>lcL INF6RMMl6N 1/26/12 DCPP SRI submits NCP 2012-01, non.concurring on Inspection report 05000275; 323/201105. The SRI believed the violation in NRC Report 2011-05 should be for an inadequate operability evaluation of the Shoreline Fault rather than not doing an ope,rability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault. (ADAMS Accession Number Ml 12151A173).

Feb 2012 OCPP SRI applies for instructor position vacancy at the Technical Training Center (TIC).

Feb 13, 2012 Response to NCP 2012-01 lssued. NCP 2012-01 was discussed with NRC stakeholders representing NRR/DE, NRR/DORL, RIV, and RES. NCP 2012-01 was disposition.ed as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (interim) operability evaluation in June 2011. Additionally, the offices involved in NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the time of Report 2011-05 issuance it was expected that the requirements and methods would be addressed in a License Amendment Request that was under consideration. However, by 30/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event. (ADAMS Accession Number ML12151A173).

02/12-07/13 RIV management frequently encourages the DCPP SRI to submit a Differing Professional Opinion (DPO) during several discussions involving seismic issues.

May 2012 Sept 2012 7/18/13 8/2/13 9/3113 4/3/14 DCPP SRI is selected for instructor position at the Technical Training Center (TTC).

The (now fonner) DCPP SRI reports to the TTC as a training instructor.

Fonner SRI submits a DPO regarding the agency's regulatory actions associated with the Shoreline Fault.

DPO 2013-002 was assigned to NRR for an independent review.

Director, NRR establishes a DPO Ad Hoc Review Panel (OPO Panel) for DPO 2013-002 with three NRC staff members who have been independent of the initial concerns raised by the fonner OCPP SRI.

OPO Panel completes its review of DPO 2013-002 and submits its, report lo the Director, NRR.

Page 45 6t=fi1e1>1ct ~91: erftV 9f!H91TIV! INfl:ftN>lcL INf6ftM>lcTl6N

5/29/14 6/23/14 6/27/14 7/7/14 8/25/14 9/10/14 Director, NRR issues his decision on DPO 2013-002 by memo to the former DCPP SRI.

Employee submits DPO appeal.

Director, NRR provided Statement of Views on contested issues in appeal DPO appeal package provided to EOO for disposition and decision.

Associated Press article released discussing the OPO.

EDO renders final decision regarding DPO. DPO submitter agrees to pubfic release of DPO.

Page 46 6FF1e1At t:ISe 0NL¥ - 91!N91fltte INfl!"NAL INl'09'MATION

erfletAL t:t9f eNLV SfHSfffVf Ufff RNAL INfOftMAflON RIS 2005-20. 2013-005. and Operability Evaluation Questions

1. What is a RIS?

A RIS is a Regulatory Issue Summary. Regulatory issue summaries are used to {1) communicate and clarify NRC positions on regulatory matters, (2) inform the nuclear industry of opportunities for regulatory relief. (3) communicate NRC endorsement of industry guidance, (4) provide guidance on the scope of infonnation that should be provided in licensing applications, and (5) request the voluntary participation of the nuclear industry in NRC-sponsored pilot programs or the voluntary submittal of infonnation. ARIS does not communicate new or revised NRC requirements.

2. How does the RIS apply to failures to meet design requirements (e.g.; General Design Criteria (GDC))?

RIS 2013-005 restated the NRC's position regarding operability evaluations for nonconfonning conditions related to design and licensing requirements. The failure to meet GDC, as described in the licensing basis (e.g., nonconfonnance with the Currenit Licensing Basis (CLB) for protection against flooding, seismic events, tornadoes) should be treated as a nonconforming condition and is an entry point for an operability determination if the nonconforming condition calls into question the ability of SSCs to perform their specified safety function(s) or necessary and related support function(s). If the licensee determination concludes that the Technical Specification (TS) SSC is nonconforming but operable or the necessary and related support function is nonconforming but functional, it would be appropriate to address the nonconforming condition through the licensee's corrective action program.

If the licensee's evaluation concludes that the TS SSC is inoperable, then the licensee must enter its TS Action Statement and follow the applicable required actions.

3. Can the licensee have a nonconformance with requirements and still operate?

Yes. RIS 2005-20, Revision 1, "Revision to NRC Inspection Manual Part 9900 Technical Guidance, 'Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety,** describes the actions licensees must take to evaluate nonconforming conditions.

For the Shoreline fault, the NRC issued a violation for Diablo Canyon's failure to perform an operability evaluation. The licensee completed the evaluation and the NRC concluded that the guidance in RIS 2005-20 had been met. In particular:

The use of the L TSP was appropriate to characterize and bound the faults as part of the operability evaluation process. Additionally, the L TSP had already been reviewed by the NRC and is consistent with the Hosgri evaluation method which is included in the UFSAR. It is expected that final corrective actions will involve an update to the UFSAR that describes current seismic information and how new seismic information will be evaluated.

Page 47 eFFlelAL t,SE 8NL¥ - 9!NSFftY! INTf "NAt: 1Nf6RMATl6f4

OfPICIAL t:191! ONLY - SEN9tffie INff!ftNAL INflOftMNTION Enforcement Questions

1. Did the NRC issue any violations Involving the Shoreline Fault?

Yes. Inspection Report 2011-05 documented a violation for the failure to perform an operability evaluation of the Shoreline fault.

2. What corrective actions did Diablo Canyon take in response to the violation?

Diablo Canyon completed an operability evaluation for the Shoreline fa ult which met the guidance in RIS 2005-020. Diablo Canyon submitted a LAR to clarify the UFSAR; however, the LAR has since been withdrawn. Dlablo Canyon is currently performing seismic evaluations to support their response to the NRC's March 2012 50.54(f) letter.

Page 48 Ol'l'ICIAL t:191! 6NLV - SENSlfl'tl! 114Tl!ftNAL INl'OftMATler*

6FF1e1>1ct l:JSE 6NLY - SEN91l'IW: INTERNJld. 1Nf6RMA'TION Current Licensing Questions

1. What are the Current Seismic Qualification OesJgn Basis requirements at DCPP?

Appe,ndix A to Part 50, General Design Criteria for Nuclear Power Plants, Criterion 2,

• oesign bases for protection against natural phenomena." Criterion 2 required that structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena, such as earthquakes, without loss of capability to perform their safety functions. Criterion 2 also stated that design bases for these structures, systems, and components shall reflect:

Appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and sunrounding area. with sufficient margin for the limited accuracy, quantity, and period of time in which the historical data have been accumulated, Appropriate combinations of the effects of normal and accident conditions with the effects of the natural phenomena and the importance of the safety functions to be performed.

10 CFR 100, Appendix A, USeismic and Geologic Siting Criteria for Nuclear Power Plants."

for establishing the three DCPP design basis earthquakes:

Design earthquake (Operating Basis Earthquake) - That earthquake which could reasonably be expected to affect the plant site during the operating life of the plant; it is that earthquake which produces the vibratory ground motion for which those features of the nuclear power plant necessary for continued operation without undue risk to the health and safety of the public are designed to remain functional.

Double design earthquake (Safe Shutdown Earthquake) - That earthquake based upon an evaluation of the maximum earthquake potential which produces the maximum vibratory ground motion for which certain structures, systems, and components are designed to remain functional.

Hosgri Event - a special postulated earthquake applicable only to DCPP.

[See Q&As for *oesignllnilial Llc9nsing Basis Questions" for additional background}

2. Did Oiablo Canyon submit a license amendment request for the Shoreline Fault?

Yes. Diablo Canyon submitted a license amendment request (LAR) on October 11, 2011.

PG&E wanted the NRC to approve using the Hosgri/l TSP method as the only method for evaluating new seismic infonnation (Including the Shoreline fault) and for approval of a method to combine LOCA and seismic loads.

In December 201 1, the licensee discussed the LAR with the Region IV Branch C h1ef for Diablo Canyon. PG&E stated that the LAR was changed to ask for the Hosgri event to become the safe shutdown earthquake. PG&E believed that the NRC had previously decided this point because the NRC had concluded that Hosgri was the SSE. NRR/DORL Page 49 e,,ietAL l:JSE 6f4LY - 9ENSFFltfE IP4TERH>ltl 1Nf8RM>ltfl8N

6ffle11ct l19E 6NL'I - 9EN9ffl'iE INTi:RNAL lt~F6RMATl6N subsequently confirmed that pre-application meetings in mid-2011 had not included discussion of the HE as the SSE.

3. Did the NRC accept PG&E's amendment request for the Shoreline Fault?

PG&E withdrew the amendment request on October 25. 2012.

During the NRC acceptance review the NRC noted that PG&E had not submitted all of the information needed to review the Hosgri method against the Standard Review Plan (SRP) requirements.

4. Why was the LAR withdrawn?

White the NRC evaluated how the operability evaluation for the Shoreline fault should be performed, PG&E concluded that gaining NRC approval for a LAR was the best resolution.

Parts of PG&E's October 201 1 LAR were intended to clarify the licensing basis by revising safe shutdown earthquake. PG&E requested that the NRC designate the Hosgri event as the safe shutdown earthquake at Diablo Canyon.

During the NRC review of the LAR, the NRC required that the Hosgri fault be assessed against the acceptance criteria for the DOE. Since PG&E had not performed or submitted such an evaluation, the LAR was not accepted and Diablo Canyon withdrew the LAR.

On March 12, 2012, the NRC issued a 50.54(f) letter to all power reactor licensees requiring a seismic hazard re-evaluation. The NRC specifically required PG&E to compare the results of this re-evaluation to the DOE. The NRC expects that the seismic re-evaluation at Diablo Canyon will yield results very similar to the L TSP results, because the methods and data are similar.

5. Did the NRC allow PG&E to bypass Olablo Canyon seismic licensing requirements?

No. All seismic hazard information collected to date has been evaluated by the NRC. The NRC concluded that the Hosgri analysis completed in 1973 (as part of the initial station FSAR) bounds all of the seismic information involving the Shoreline, Los Osos, and San Luis Bay f au Its

6. I heard NRC's Cliff Munsen say to the California Energy Commission that the NRC expects Oiablo will exceed its DOE once it completes this ongoing seismic review.

What does it mean when the NRC says they will exceed their DOE? What changes will the plant be required to make? If none, why not?

The Hosgri and DOE are separate methods for evaluating seismic information. As a result of the 50.54(f) letter review the NRC expects that Diablo Canyon will select a single method consistent with the already NRC reviewed L TSP for evaluating new seismic information.

The change to a single method for evaluating seismic information will need to be reflected in the UFSAR..

Page 50 6fflle1At t19E eHLY 9fN9f'ffl'f INffRffAL INF6RMATl6N

Of'f'ICIAL tJS! ONLY - 9ENSl'fltt1f INl£ftNAL INF6ftMAl'ION

7. When wlll Dlablo Canyon's FSAR reflect the correct seismic infonnatlon?

The NRC expects the UFSAR will be revised following completion of the 50.54(1) fetter reviews. Oiablo Canyon's initial response is due by March 2015. Diablo Canyon's risk assessment, if assigned a high priority, will be due no later than April 2018.

8. When does the FSAR need to be updated with new seismic Information?

Per the requirements of 10 CFR 50.71(e), all reactor licensees are required to periodically update the FSAR to reflect, in part, all safety analyses and evaluations performed by the licensee in support of approved LARs or in support of conclusions that changes did not require a license amendment in accordance with 10 CFR 50.59(c){2). FSAR is irequired to be evaluated for updates approximately every 24 months, depending on the station specific refueling cycles.

As such, if subsequent seismic analyses, Including PG&E's response to the 50.54(() seismic re-evaluation, results in the licensee submitting an LAR (and assuming it is approved by the NRC), then the evaluation would be required to be included as an FSAR update per 50.71(e).

Page 51 Ol'l'ICIAL t19! ONLY - 9!N91'frt'E lf4T!"NAL INFORMATION

Of'l'ICIAL tfS! ONLY - S!..SITl'f'! INT!IU*At INl"O"MA'ftON 50.54(0 Questions

1. When was the 50.54(f) letter issued?

March 2012.

2. What is the purpose of the seismic 50.S4(f) letter?

Diablo Canyon is being required to reevaluate the seismic hazards at their site. This reevaluation uses both modem methods and updated information. Additionally, Diablo Canyon is required to provide an assessment of the plant's ability to cope with the reevaluated hazard. The NRC will use this information to determine if additional regulatory action is appropriate.

3. When is Diablo required to provide a response?

No later than March 2015.

4. What actions will be required following the NRC's review of Diablo's response?

For facilities in the Western United States, within approximately 30 days of receipt of the last submittal, the NRC will determine the acceptability of the licensee's propased risk evaluation approach and priority for completion. At the latest this would be April 2015.

If the NRC assigns a high priority Diablo Canyon will need to complete their risk evaluation over a period not to exceed 3 years from the date of the prioritization. At the latest this would be April 2018. If assigned a lower priority, the risk evaluation would need to be completed by April 2019.

5. Doesn't Oiablo Canyon already have a Seismic PRA? If so, why is their completion date April 2018?

The March 12, 2012 orders (http://pbadupws.nrc.gov/docs/ML 1205/ML12053A340.pd0 state that "Within 3 years of the date of this information request, each WUS addressee is requested to submit a written response consistent with the requested information, seismic hazard evaluation, items 1 through 7 above.*

Therefore by March 2015, DCPP must submit a written response documenting their seismic hazard evaluation up to selecting of a risk evaluation approach. The two approaches that could be used are Seismic Margin Analysis (SMA) or Seismic PRA (SPRA). DCPP has committed to performing a SPRA using the new ground motion spectra. later in the March 2012 order, it states, "For hazard reevaluations that the NRC detennines demonstrate the need for a higher priority, addressees are requested to complete the risk evaluation... over a period not to exceed 3 years from the date of the prioritization ~ Since DCPP will be completing the SPRA, this statement in the order applies, and thus DCPP's due date for completion rn early 2018.

Page 52

eFFlelAL tJ9E 6NLY - 9EN91fl't11! INfl!ftNAL INl'OftMATION

6. Why is It expected to take several years to complete the review?

The expectation that the seismic issues will take some years to resolve at DCPP is not a safety concern. The NRC has followed the seismic re-evaluation process since the beginning at DCPP. The NRC will continue to evaluate seismic data to ensure our understanding of the seismic hazard Is informed and that there is no new challenge to safety.

By f o11owing the rigorous NRC-approved pirocess, which will take several years It is expected that PG&E will produce a single seismic hazard analysis for NRC review using the latest available methods. If approved by the NRC, these results can then be used to clarify the Diablo Canyon seismic licensing basis.

7. What is SSHAC? What is SSHAC Level 3?

10 CFR 100.23, paragraphs (c) and (d) require that the geological, seismological, and engineering characteristics of a site and its environs be investigated in sufficient scope and detail to permit an adequate evaluation of the Safe Shutdown Earthquake (SSE) Ground Motion for the site. In addition, 10 CFR 100.23, paragraph (d)(1 ), "Determination of the Safe Shutdown Earthquake Ground Motion,* requires that uncertainty inherent in estimates of the SSE be addressed through an appropriate analysis such as a probabilistic seismic hazard analysis (PSHA).

In response to these requirements, in 1997, the NRC published NUREG/CR-6372, "Recommendations for Probabilistic Seismic Hazard Analysis: Guidance on Uncertainty and the Use of Experts.n Written by the Senior Seismic Hazard Analysis Committee (SSHAC),

the NUREG provides guidance regarding the manner in which the uncertainties in PSHA should be addressed using expert judgment.

The SSHAC Level 3 process uses a panel of independent experts to study all available seismic data, identify the need for new data, and use the latest seismic analysis tools to develop a Seismic Source Characterization (SSC) and Ground Motion Characterization (GMC) in creating a risk-informed seismic hazard estimate (i.e. the PSHA). The NRC was intimately involved in the development of this formal methodology. This Is a new method that did not exist at the time of licensing for the current generation of nuclear power plants, but is now required for applicants seeking a new reactor license.

8. Why is the NRC giving the Western U.S. plants more time (than the Central and Eastern U.S.) to complete their seismic reevaluation when the seismic riska In the Western U.S. are greater?

A typical SSHAC Level 3 study (which is the process being used by all of the plants In the U.S. to perform a seismic hazard reevaluation) takes 3 - 4 years.

The SSHAC study produces the seismic hazard models that are needed to perform the seismic reevaluation. When Fukushima occurred, the Central and Eastern US plants (CEUS) were in the middle of conducting a SSHAC Level 3 study sponsored by the NRC, DOE, and EPRI, so when the 50.54(f) letters went out the CEUS already had the models they needed. to perform the seismic reevaluation, which is why we gave them a shorter period of time to respond to the 50.54(f) letter.

Page 53 OfftelAL tJ9! 6NL'f - 9!N91'fl'f'E INft:ftNAL INF6RMAfl6N

OFFIOlitcl tl9E ONLY 9EN911'1¥E ltffEffNitcL INFORMATION The Western U.S. does not have a regional model like the CEUS - so the NRC required all Western U.S. plants to complete a SSHAC Level 3 study in order to develop site-specific seismic hazard models. The Western U.S. plants were given three years to complete the SSHAC study and their seismic reevaluations. This is a significant amount of work to complete in three years and is realistically the fastest timeline that the Western U.S. plants would be able to adhere to while still following the rigorous requirements of a SSHAC Level 3 study.

9. Why does the NRC believe rt is ok to wait until 2016 or later for safety improvements to be in place?

The NRC has established reasonable schedules for nuclear power plants to comply with the Orders and requests for information. We expect many nuclear power plants will achieve compliance ahead of the established schedules and will closely monitor each plant's progress through the required six-month status updates.

The Near Term Task Force (NTTF) report concluded that with the current regulatory approach and the current plant capabilities, the sequence of events which occurred at the Fukushima accident are unlikely to occur in the United States. While the NRC concluded that the NTTF recommendations would enhance safety, the staff determined that none of the NTTF report findings identified an imminent hazard to the public health and safety. As such, continued safe operation of nuclear power plants is warranted while the safety improvements required by the orders are implemented.

10. Why did the NRC approve Industry's request for a six month extension in submitting the Central and Eastern U.S. seismic reevaluations?

The seismic hazard reevaluations for the Central and Eastern U.S. (CEUS) were originally due iin September 2013. The NRC approved a six month extension in order for industry to update the ground motion model, as this effort incorporates a significant amount of new information and data for CEUS seismic hazards. The CEUS ground motion model was developed from 2002-2004 with updates in 2006 and now updates in 2013. (The seismic source characterization model was developed from 2008-201 1 ). The updated ground motion model should ultimately yield more accurate results. The reevaluations for the CEUS are now due in March 2014.

11. Why Is PG&E conducting new seismic studies?

The ongoing seismic studies that PG&E is conducting right now are being conducted as a new chapter In their Long Term Seismic Program as well as In response to the California Energy Commission's AB 1632 Report, which specifically recommended enhanced 2-0 and 3-D seismic studies. With the NRC's issuance of the 50.54(f) letter, which in part requires re-evaluation of seismic hazard using current NRC guidance, the technical integration team of the SSHAC study has been empowered to take all of the information from these seismic studies, analyze it, and evaluate it in terms of the seismic hazard assessment. So the data collected from the various seismic studies and surveys will be fed into the SSHAC study and hazard re-evaluation as part of PG&E's response to the 50.54(f) letter.

Page 54 el'l'lelitct t:J!f OHL¥ - !EH!l'fl'iE IH'f~NAL INFORMATION

o.. 111e1At t19! ONLY - SEN91TI¥£ IPffEftNAL INfi6ftMATION

12. In an October 12, 2012, letter to Diablo Canyon, the NRC states that "The NRC recognizes that using the DOE as the basis of comparison will most likely result In the Shoreline fault and the Hosgri earthquake being reported as having greater ground motion than the SSE."

Is it accurate to state that this means that the licensee has not shown that it meets the requirements in its license that the reactor and its safety systems be capable of withstanding the ground shaking associate'4L INFORMAllON

eFFlelAL tf9E eNLY - 9ENS1ft't'E U4ff:RNAL INFeRMAfleN Uon-Re,;pons111e Record Page 57 OFFtelAL tJSE ONLY - Sf!ff91TM INTf!P04At U4fOftMATIOH

eFFlelAL tJSE 6NLY 9EN91fl¥E INTERNAL INF6RM,tffi6N Page 58 OP'lll'ICIM: t:191! eNLY - 91:N91fl¥E IN:r-ERN,ct INfieRM.trrleN

Of'flCIAL tl9E ONL'f - 9EN91Tl't1! INT!"NAL INf'Ol'tMNflON Non-Respons1vP Reaml Page 59 e....,e,At t19! eNLY - 9EN91l1¥E INTERNAL INF6RMATl6N

Purpose e,.,.,e,At t:,Sf 8P4L\\' set.91Tl't'f IHff!fU,AL INPOftMlcTION DCPP Licensing Basis Verification Proiect (LBVP)

(From Licensee Status Briefing in August 2012,

& Updated in Sept. 2013 for new RA briefing)

The primary purpose of the Licensing Basis Verification Project (LBVP) Is to perform an objective evaluation to determine if the DCPP licensing basis has been adequately maintained, and to correct any ldent!fled deficiencies. Additional goals are to provide an enhanced FSAR with clear current licensing basis (CLB) defined for plant personnel, and to enhance knowledge transfer of the Dlablo Canyon Power Plant Current Licensing Basis.

Objectives

1. Evaluate facility and analysis changes since completion of Amendment 85 of the original FSAR in 1980 through the current revision of the FSAR update

2. Evaluate the adequacy of the 1 O CFR 50.59 evaluations

3. Determine and document DCPP's committed compliance with 1 O CFR 50, Appendix A, *General Design Cnteria and Division I Regulatory Guides for Power Reactors.

4. Correct any licensing basis deficiencies discovered.

5. Correct any deficiencies in the licensing basis searchable document databases.

6. Improve the current licensing basis full-text search capabilities.

7. Perform component design basis reviews of eight selected systems, after the completion of the licensing basis verification and correction of any deficiencies in these systems.

8. Provide an updated tool to aid in operability determinations.

Who Is Involved with the LBVP?

PG&E Oversight with work done by Chicago Bridge and Iron (CB&I - formerly Shaw, Stone & Webster), partnered with Westinghouse (DCPP NSSS Supplier). CB&I has the lead. Westinghouse is responsible for various FSAR sections includlng Accident Analysis Chapter 15, RCS, RHR, Reactor, and others.

Phase I (February-October 2010)

Phase I of the LBVP reviewed and evaluated design and analysis changes to the Component Cooling Water (CCW) and Auxiliary Feedwater (APN) systems.

Phase II (September 2010- 2015)

Phase fl of the LBVP is evaluating all the remaining licensing basis changes. The methodology of Phase II will be to adjust to the revised scope based on the Phase I Page60 eFFlelAI use 8NLV -- 9t!N91fft1e IN!ERN~t lNF6RM.ti\\fl9U

8FFlel>>ttL liSE 8NLV S!NSl'fff'i: IN1f!"NAL INl'ORMATION findings, lessons learned, and recommendations, all of which was addressed in the Phase I summary Report.

Licensing Basks Reviews (signed off by PG&E):

Establish the licensing basis requirements (e.g., General Design Criteria, Reg. Guides, Generic Letters, etc.) along with the source documents (PG&E specific commitments in letters, etc.). Draft FSAR revision with licensing basis requirements. LBR reviewed internally by PG&E and by an Independent Review Board.

System Reviews Following the LBR, validate the licensing basis requirements and FSAR implementation into plant documents (desjgn documents, procedures, WCAPs, drawings. calculations).

Finalize IFSAR/DCM revisions. FSAR r,evislons will include identification of the source and implementing documents. System Review reviewed internally by PG&E and by an Independent Review Board.

Component Design Basis Reviews: (8 systems chosen):

Status Component Cooling Water

• complete 230-kV System

• complete 500-kV System

• complete Emergency Diesel Generator - in progress Auxiliary Feedwater System

• finished following the LBR and System Review Auxiliary Salt Water System - finished following the LBR and System Review SSPS System

• finished following the LBR and System Review Residual Heat Removal

• finished following the LBR and System Review Corrective Action Program Update Over 1000 SAP Notifications have been initiated to date. Six potential LARs being reviewed by PG&E staff.

Enhanced FSAR Update The FSARU Enhancement ls a synthesis of three other licensing bases document sets:

The Safety Evaluation Report and its supplements NRC letters to PG&E And PG&E letters to the NRC.

Current schedule DCPP committed to the NRC to complete the LBVP by 12/31/2015. Completion clarified in document DCL-12-003 as follows: Completion of LBVP Phase II includes completion of applicable licensing basis reviews. system reviews, component design basis report reviews, electronic database upgrades, implementation of new current licensing basis search tools, and correction of licensing basis deficiencies that do not require prior NRC approval. In addition, completion of LBVP Phase II includes submittal of License Page 61 8fFlet1'L tJSe et*tv seNSff1¥E 1Nl'ERN1'L 1Nfl6RM1'fleN

OfiFietAL t:19E ONLY - 9ENSl'f1'f't: IN'fERNAL 1Nf'ORMkll614 Amendment Requests (lARs) and initiating design changes. The completion of the design changes and the receipt of approved lARs will extend beyond the completion date of December 31, 2015.

NRC Conclusions (as of Sept 2013)

1. The licensee is performing a good review of their Licensing Basis.

2. They are identifying and correcting errors.

3. They continue to evaluate and improve the LBVP process

4. The process is not perfect. The NRC is still identifying problems with Licensing Basis Documents and how the licensee implements their licensing basis.

5. The Summer 2013 Component Design Basis Inspection (Inspection Report 2013-007) noted a significant improvement in Licensing Basis Documents at the site.

Page 62 6fiFlelAL ~SE 6Nt¥ - 9l!NS1f1VE INTERNf<L INl'O"Mf<TION

6FFl81AL l::19E 6NLY 9EN91ff'f'E INfl:~HAL lf4f'O~MAT10N

/on-Responsive Recore Page 63 6fflelAL tl9e 6NLY - 9eN91fl'le INleRNAL INF6RMAfl6N

6fifle1Al lj31: 6NLV 9!N9Jfl'w'! INTeftNAL INflOfltMATION Public Cancer Risks Refer to MCommunications Plan: Analysis of Cancer Risks in Populations Living Near Nuclear Facilities - Phase 2 Pilot Studies" (ML13274A664). maintained by RES, for the most current information.

The following Q&As noted are likely to be of particular Interest to OCPP stakeholders (page number in RES communication plan indicated):

Page 9:

01. Why has the U.S. Nuclear Regulatory Commission (NRC) asked the National Academy of Sciences (NAS) to conduct this study now?

03. Which seven sites will be included In the pilot study?

04. Which additional nuclear facilities could be lnciuded in the study?

Page 10:

06. Does the NRC suspect that cancer mortality rates are elevated around nuclear power plants?

07. How can I be sure that the nuclear power plant is not causing cancer? If I lived near a power plant, how might I be exposed to radiation? For example, if my house is 2 miles away from a reactor, am I being exposed whenever I am at my house?

Page 11:

011. I live near a nuclear power plant and my husband died of cancer. Will this study prove that living near the plant caused the cancer?

Q14. Why do some local cancer studies around some nuclear plants show increased cancer rates and some show no increase?

Page 12:

017. What will the NRC do if the results indicate an increase in cancer risk in some populations that live near a specific nuclear facility?

Page 13:

Q21. How does the NRC ensure the validity of the licensee's reporting of off-site doses and environmental monitoring results?

Page 15:

023. Where can the public find more information on the study?

Page 64 Ol'f&ICIAL lj9E 8NLY 9EN91flltJfl: INTERNAL INF8RMATl8N

Ol'l'ICIAL tlSI! OHLY - Sl!NSITl't! INT!:ftNAL INl'OftMATION Emergency Preparedness Concerns

.... NOTE - The following is predecisional. noni-public information, with the exception of the Unresolved Item that was included in the 40/2013 Resident Inspector Report which initially described this potential issue.

Background

In November 2005, Diablo Canyon Power Plant revised its emergency plan without prior NRC approval. This change removed a table used t,o assist in making protective action recommendations to the offs1te authorities during an emergency event. The change resulted in developing protective action recommendations directly from specific protective action zones, which did not explicitly identify the ocean areas. Therefore, this change to the emergency plan reduced the effectiveness of the plan and required NRC approval prior to implementation. This issue is currently being evaluated using our significance detennination process and through traditional enforcement.

Key Messages - Predecisional/nonpublic The licensee made a change to an emergency plan procedure that inadvertently removed the ocean from a table that provided guidance on making protective action recommendations.

The individuals responsible for making protective action recommendations are highly trained and qualified individuals (they are senior reactor operators) so they have to go through a rigorous training and evaluation process to obtain a license and must undergo continuing training and periodic evaluation to maintain the license.

The licensee recommends protective actions to the state and local officials, who make the actual call about what protective actions to take.

The county had procedures in place that included evaluating the ocean for evacuation.

Therefore, at no time was the public going to be allowed to stay in an area that had the potential for radioactivity if an event had occurred.

This is a preliminary determination, is still undergoing evaluation through our processes, and is subject to change upon further review Questions and Answers

• • UNDER DEVELOPMENT-Page 65 Ol'l'lelAt. t:IS! 6NLY - 9!N9ffl'II! INTERNAL INl'OftMATl6N

From:

To:

Cc:

Subject:

Date:

To all.

Sebrosky, Joseph Madslev MidJael; Munson, Qdford: Stovall Scott; Kock, Andrea; Williams Megan:.1.1....Ywl.; Oestene Eric weu. Jenny: Mao<>IY, Kamai: Lynd Loutse: Dudek. MJchaet: case. Mfchaet; Burnell, Scott; Hay. Mlchae!:

f@QOYicb, Mrke; Whaley. Sl)eena; Bowman. Greoo,v; Bo'!fen, Jererw: Moreno. Aoos:l; Ba!azik. Michael* SWgaJ.

~

Famholtz. Tognas* Kanatas (ilU!eooe* Hipg:hman Jbomas; 8C'i095A John; ~

folk Key,o; PIEcancesco. Nicholas; Balazik. Michael: Bexoo:;o, JohQ; Hfll. Bntta*n; Waflser, wayne: usefdJno. Lara:

Buchanan. Jl>ettsa: Keegan Ba,oc:; Jad\\sQQ PLw:* Wtids enan; Harris Brian: BQthCOGCl, David: ~

catbeaoe; PKme, Nell RE: Info: cover letter transmitting diablo canyon state of califomla report

• link to report Wednesday, September 10, 2011 3:19:00 PM The State of California report can be found on PG&E's website at:

http*/IWNW,pge,com/en/safety/systemworks/dcpp/seismicsafety/report page From: Sebrosky, Joseph Sent: Wednesday, September 10, 2014 1:48 PM To: Markley, Michael; Munson, Oifford; Stovall, Scott; Kock, Andrea; Williams, Megan; LI, Yong; Oesterle, Eric Cc: Weil, Jenny; Manoty, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Hay, Michael; Franovlch, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, Michael; Singal, Balwant; Famholtz, Thomas; Kanatas, catherine; Hipschman, Thomas; Reynoso, John; Ake, Jon; Folk, Kevin; DiFrancesco, Nicholas; Balazlk, Michael; Reynoso, John; Hill, Brittain; Walker, Wayne; UseJding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittick, Brian; Harris, Brian; Roth(OGC), David; Kanatas, catherine; OKeefe, Neil

Subject:

info: cover letter transmitting diablo canyon state of califomia report To all.

The purpose of this email is to provide you with the cover letter transmitting the diablo canyon state of California report to the NRC. The report is with the document control desk. It will take several days for it to be processed. I will send a separate email with a link to PG&E's website when the report is available there Let me know if you have any questions.

Thanks, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation josepb sebrosky@nrc gov 301-415-1132

From:

To:

Subject:

Date:

Thanks - Joe Sebrosky, Joseph "Soeoea PbiliPPC R" RE: NRC Submittal DCL-14-081, "Central Coastal Cahfornla Seismic Imaging Project, Shoreline Fault Commitment" Wednesday, September 10, 2014 3:05:00 PM

---

Original Message-----

From: Soenen, Phlllppe R (manto:PNS3@pge.com]

Sent: Wednesday, September 10, 2014 2:51 PM To: Sebrosky, Joseph

Subject:

FW: NRC Submittal DCL-14-081, "Central Coastal califomia Seismic Imaging Project, Shoreline Fault Commitment"

Joe, Per your reQuest.

Phlllppe Soenen Supervisor, Licensing Regulatory Services - DCPP Office - 805.545.6984 Cell -I (b)(6}

I From: Mackey, O,uck Sent: Wednesday, September 10, 2014 9:56 AM To: DCPP BASES DD; 'fred.madden@lumlnant.com'; kefredr@wcnoc.oom; Scott Bauer; Keith Mills; Jim Becker; Larry Parker (Larry.parker@starsalliance.oom); Steve Meyer; Tom Weber;

'timothy.hope@luminant.oom'; david.heckman@aps.com; 'daJpdate@certrec.com' Cc: 'Janeslo@kcbx.net' (janeslo@kcbx.net); 'dsneed@thetribunenews.com'

( dsneed@thetribunenews.com)

Subject:

NRC Submittal DCL-14-081, "Central Coastal California Seismic Jmaging Project. Shoreline Fault Commitment" The electronic file of the following CDVef letter that wa:s recently sent to the Nuclear Re,gulatory Commission Is attached to this e-mail and is being routed for your infonnation.

NRC Submittal OCL-14-081, "Central Coastal califomia Seismic Imaging ProJect, Shoreline Fault Commitment" Signed by: Edward D. Halpin

• Senior Vice President and Chief Nudear Offic.er Chuck Mackey Diablo canyon Power Plant Regulat()f'f Services ~lor Administrator - Nudear 104/5/536A P.O. Box 56 Avila Beach, CA 93424 Internal

• 8-691 *4444 External - (805) 545-4444 PG&E Is committed to protecting our customers' privacy.

To learn more, please visit ht;tp://www,D{le,com/about/company/privacy/customer/

Note: This letter is publicly available in ADAMS as ML14253A491.

From:

To:

Cc:

Subject:

Date:

Attachm*nts:

Sebrosky, Joseph WJlllaros Megan: Munson. Qiffo{d: Oesterle Erle: Mar1dey. Michael Vscldlng Lara: wa1ker Wayne: HIDS(broao ThQmas FW: SCOttJJoe ; review of blOO prior to sending to Eliot Wednesday, September 10, 2014 11:59:00 AM SEP2014bf0QAB1632 srb.docx Megan, Cliff, Eric, and Mike, Attached is the latest version of the blog that includes Scott's comments that removes some language that had me concerned. I still have one issue:

fhe blog indicated that the staff will "independently verify the calculations." I don't believe this is correct. Can we say the staff will "independently assess the information in the report.* I do not believe we are going to do a complete independent verification of all the calculations which, in my opinion the sentence implies.

Lara, Is someone from OGC looking at the language given the FOE petition?

Joe From: Burnell, Scott Sent: Wednesday, September 10, 2014 11:47 AM To: Uselding, Lara; Sebrosky, Joseph SUbject: RE: Scott/Joe ; review of blog prior to sending to Eliot provides confidence the plant can keep the public safe after a seismic event" instead?

From: Uselding, Lara Sent: Wednesday, September 10, 2014 11:45 AM To: Burnell, Scott; Sebrosky, Joseph subject: RE: Scott/Joe ; review of blog prior to sending to Eliot All fine with the exception of reasonable assurance. The public in CA hates this term and

~e have been lambasted for using it so we need an alternative From: Burnell, Scott Sent: Wednesday, September 10, 2014 10:39 AM To: Uselding, Lara; Sebrosky, Joseph

Subject:

RE: Scott/Joe ; review of blog prior to sending to Eliot Here are my edits.

From: Useldlng, Lara Sent: Wednesday, September 10, 2014 11:03 AM To: Burnell, Scott; Sebrosky, Joseph

Subject:

Scott/Joe ; review of blog prior to sending to Eliot Importance: High

Diablo Canyon In the News Today PG&E issued a report to the state as required by California Assembly Bill 1632 and has also shared a copy with the NRC. In 2006, the bill required the California Energy Commission to assess the vulnerability of the state's nuclear power plants to seismic hazards and plant aging among other things. As part of the assessment, PG&E performed state-of-the-art seismic studies on and offshore the area near the plant.

The methodology used for the state report is different than was used lo assess the Shoreline fault after it was discovered in 2008. New seismic information in the state-required report indicates that the Shoreline fault is both longer than previously thought and able to produce a stronger earthquake. Along with the report, PG&E provided Region IV with an operability evaluation after entering the new information in their corrective action program to assess its impact on plant operations.

NRC Resident Inspectors and Region IV staff have looked at the liceAsee\\;PG&E*s assessment and so far the information indicates reasonable assurance of public health and safcl, after a seismic cventthere is AO Aew iRformation teat w0t1IEI leaa Ule NRC te eoRell:IEle thal eonlinl:led safe opemtion of Dieblo Ca:Ayon is ehalleAgetl. n,is is eeeal:lseWhile the new seismic information gathered by PG&E adds detail about the Shoreline fault" s length and strcl'lbrth.BM the companv'sif evaluation reaffirms that the Shoreline fault is a lesser iAell:ltl~a fal:lll still bo1:1nded bynot as powerful as the Hosgri earthquake Diablo Canvon must withstand.

Howe..,.er. j.J.ust as Wtl5 aoAethe NRC wil,h the reviewed ef.the Shoreline fault information in 2009 and 20 I 2;w..H-, the ag,encvNRG will ae a mere thorough.ly review &f.the new information through our inspection process. The 1.000-pag~ seismic report is 1.000 J:>ages anel contains new technical information that will be reviewed by staff to independently verify the calculations.

Previo1:1sly. ~IRC provitletl its assess,aeHl ef l:ke ShereliAe fa1:11l seisAlie hatartl in the Resea:reh lnfom1atieA Letter (RTL) 12 QI **cenfiRHatery AAalysis ef Seismie M~ra at the Diat>lo Coo~on Power Plant froA1 the Shoreline Fel:llt ZoAe." I,~ the RJb. NRC staff eetermiAeEI that the

maxinnim grmmd motioA expeeted at Diablo from a seismie event along the Shoreline fault would be bowided by expected grouRd motioA for seismic e*.-ents along the Hosgri fault. E,*es lhm:1gh the shoreli-Re falill is eiifJable of pf0dlieieg a bigger earthqlittlle lhan pre,.*iolisly ealelilal~<l.

it is still bolinded by the Mosgri for whieh the pl0:11l is able to safely shutdown and proteet the publie and the eAviron1fleAt.

+hl5-PG&E will also use this new seismie information will also be 1:1sed to respofl:d loin providing an overnll seismic hazard re-analysis to the NRC's request for every U.8. nuclear power plant to re analy~e their earthEf\\:lake ha:z:arEis fellowiRg.JapaR

• s as part of the agency* s response to the 2011 Fukushima nuclear accident. PG&E's response re-analysis is due to the NRC in March 2015.

Prom:

To:

Cc:

SUbJect:

D1te:

Attachments:

Lara, Sebrosky, Joseph useldlng Lara wunam5 Megan* Munm Clifford; Qestedc, Enc; Maddey. M chacl RE: Scotti.Joe ; review d blog pnor to sending to Eliot Wednesday, Scprember 10, 20141 11:38:00 AM SEP2Ql4btogDf0AB1632.dooc You note that the document is 1000 pages Can you ask Megan to give you an accurate page count. I would also feel more comfortable if Megan. Cliff, Eric, and Mike were given an opportunity to comment before the blog went live.

Joe From: Useldlng, Lara Sent: Wednesday, September 10, 2014 11:03 AM To: Burnell, Scott; Sebrosky, Joseph

Subject:

Scott/Joe ; review of blog prior to sending to Eliot Importance: High

From:

To:

Subject:

Date:

Att1chment:1:

Oesterle, Eric Pruett. Troy FW: Comm Plan for OPO & Appeal Wednesday, September 10, 2011 12:JJ'.00 PM prart ro101-comm Piao oo QCPP opo Cinat dog

,roaaeQ03.png FYI... wanted to make sure we kept you in the loop.

Eric From: Oesterle, Eric Sent: Wednesday, September 10, 2014 12:32 PM To: Sebrosky, Joseph; Marl<ley, Michael; Munson, Oifford; Stovall, Scott; Kock, Andrea; Williams, Megan; Li, Yong Cc: Well, Jenny; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovlch, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazlk, Michael; Singal, Balwant; Famholtz, Thomas; Kanatas, Catherine; Hlpschman, Thomas; Reynoso, John; Ake, Jon; Folk, Kevin; Difrancesco, Nicholas; Balazjk, Michael; Reynoso, John; Hill, Brittain; Walker, Wayne; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittick, Brian; Harris, Brian; Roth(OGC), David; Kanatas, Catherine; OKeefe, Neil

Subject:

Comm Plan for DPO & Appeal Importance: High

Everyone, Attached for your use and for Region to fold into their "living DCPP Comm Plan" is the DPO & Appeal Comm Plan. It has been extensively coordinated with the Comm Plan for the PG&E Seismic Report {AB 1632) that is being issued today. The EDO has provided his decision on the DPO Appeal and the DPO Case File has been made public. As a result of these actions, we are issuing this DPO Comm Plan for timely use. If you have any questions please contact me. Thanks.

Er-£.o'R. O~lh Acting Branch Chief NRR/D0RL/LPL4* 1 301 *415-1014 From: Sebrosky, Joseph Sent: Wednesday, September 10, 2014 10:44 AM To: Markley, Michael; Munson, Clifford; Stovall, Scott; Kock, Andrea; Williams, Megan; Li, Yong; Oesterle, Eric Cc: Weil, Jenny; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovlch, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, Michael; Slngal, Balwant; Famholtz, Thomas; Kanatas, Cathenne; Hlpschman, Thomas; Reynoso, John; The rest of this email string ma1* be found as document G/12 in interim response #3 in FOINPA-2014-0488 (ML15033A280)

From:

To:

Cc:

Subject:

Date:

Attac:tlments:

To all, 5ebrosky, Joseph Madsfex HfdJaet: Munson, O,lford: Stovall, scott: Kods. Andrea* W!lhams Megan* ~

Oestedc Ecx; Weil Jeooy: Mangfy l<NNI. Lund I Q\\/:SC' Ot/dtk MtdJaet* case Mtd)aef: Burnell SCgtt: Hay Mjd)aeJ:

E@noyjch Mjke: Whaley. stcma: Bowman. Greooa: Bowco Jeremy: MofCJJO Anget: BalazIJs. M,chael: SUmL flil.l.w.act; Famholtz Thomas* Kj)OjlfilS catherioe* HiPSdJmao Thomas: Reynosa John:~

Eofk. Keym:

O,Francesco NidJOlas: Batallk. Hk;bael: Reynoso John. H11. BQttaio: WalJset, Wayne: Vsekllno. Lara:

Buchanan Jberesa

• Keegan EJm:* JadcsoQ Ptane* W1Uldl Brian: Harns, Brian: BothfOGCJ. paytd: Ka.oiltas..

cathe,;ine: PKeete, Neil RE: Info: status of diablo canyon state of califomla report recJardino seismic Issues Wednesday, September 10, 201411:18:00AM oc cant ztsmtc mt cprnm ofao 9-10-11 Ooal rev 1.docx I apologize, I previously sent you the wrong version. Attached is the correct version of the communication plan.

Joe Sebrosky X1132 From: Sebrosky, Joseph Sent: Wednesday, 5eptember 10, 2014 10:44 AM To: Markley, Michael; Munson, Olfford; Stovall, Srott; Kock, Andrea; Williams, Megan; Li, Yong; Oesterle, Eric Cc: Well, Jenny; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazlk, Michael; Singal, Balwant; Famholtz, Thomas; Kanatas, Catherine; Hipschman, Thomas; Reynoso, John; Ake, Jon; Folk, Kevin; DIFrancesco, Nicholas; Balazik, Michael; Reynoso, John; HIii, Brittain; Walker, Wayne; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittlck, Brian; Harris, Brian; Roth(OGC), David; Kanatas, catherlne; OKeefe, Neil

Subject:

info: status of diablo canyon state of califomia report regarding seismic issues To all.

PG&E is still scheduled to release their State of California report at 11 :00 am pacific, 2:00 pm eastern. Attached is the communication plan that is associated with this effort. Please note that it indicates that an NRC blog is possible OPA 1s working on developing the blog language separately from the attached communication plan.

Other items Eric Oesterle is leading the effort to finalize a communication plan associated with the OPO given that the OPO, the DPO response and the OPO appeal decision will likely be made publicly available in the short term. A draft has been provided to a smaller audience for their comment.

Let me or Eric know 1f there are any questions.

Thanks, Joe Sebrosky 301-415-1132

DRAFT - Ol't'ICl,CL t'J!! ONLY SEN91'f1VE INTE"N1'tl INl'OftM~T16N - NOT fi6ft,1:1et1e ftEU!:A!E

Background

UPDATED: 9/10/1410:30 eastern Communi1cations Plan -

Diablo Canyon Power Plant Topics of Interest State of California Seismic Report (ABN-1632)

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 2D and 3D mapping to compile this report. This is a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.

The purpose of this communication plan is to provide key messages associated with the public release of this report.

Key Messages

1. NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event.

PG&E's evaluation of the new seismic information, as documented in the report, concludes that the ground motions resulting from the faults discussed in the report (i.e.,

Shoreline, Hosgri, San Simeon. Los Osos. and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant

2. The NRC staff will review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.

3. PG&E will incorporate the findings from Bill 1632 report into their upcoming March 2015 probabilistic seismic hazard analysis as part of the NRC's post-Fukushima activities.

The NRC believes this more rigorous analysis will provide the most accurat:e assessment of faults affecting the DCPP.

1

DRAFT - 6f'flelAL t:19! ONLY S!N91Tl't1E INTEfitNAL 1NflOfitMM16N - N6T f'Oft flt:J8Ue ftE~A9E Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.

Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/ORPlRPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195 Thomas Hipschman Sr. Resident Inspector -

R-JV/DRP/RPB-A 805-595-2354 DCPP John Reynoso Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 DCPP Jon Ake Senior Seismologist RES/DE/SGS EB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Elaine Keegan License Renewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DiFrancesco Japan Lessons Learned JLD 301-415-1115 Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Diablo Canyon, should be used to accomplish these actions. The table below is based on a target public release date of the report on September 10, 2014.

Timeframe Action Responsible Party(ies)

Sept 8 PG&E provides a draft of the report in the PG&E electronic reading room for initial staff assessment Sept 9 PG&E notifies NRC of seismic report submittal to PG&E the state of California 2

DRAFT - 61'151CIAL ttSI! ONLY Sl!Nsrr,~ INTl!lltNAt INl'611tMATION - NOT FOR Pt:IBUe RELEASE Timeframe Action Responsible Party(ies)

Sept 10 PG&E/Diablo Canyon Power Plant submit seismic PG&E report to the state of California and issue a press release Promptly Region IV notifies the Communications T earn of R-IV/RPB-A (within Sept PG&E's actions as currently understood and 10+1 buslness implements the Communications Plan day)

Entirety of Communications Team notifies R-IV; NRR/DORL; applicable Senior Managers in their respective NRR/DLR; NRR/JLD reporting chain OPA; OCA: OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. Blog possible Oct3 JLO/NRO/RES completes preliminary assessment JLD/NRO/RES/RIV of published report and ma111agement decision is made if any additional actions should be taken prior to the submittal of the seismic reevaluation in March 2015. Updates to communication plan as appropriate As requested Complete a Commissioners Assistants Brief R-IV; NRR

1. Questions and Answers What is the Impact of this new infonnation on seismic design and licensing of DCPP?

Has the licensee entered this new information into the corrective action program and perfonned an operability evaluation?

In accordance with the guidance in the October 12, 2012, letter transmitting Rll 2012-001, PG&E has entered the new preliminary seismic information into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.

In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:

"If during PG&E's ongoing collection of seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information (Reference 2).

• Reference 2 is NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status,

• Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident.* March 12, 2012.

NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an immediate threat to public health and safety nor did it call into question the ability of SSCs to 3

DRAFT - 6f filel>>tct t:tse 6Nt¥ S!NSl,,\\T! INT!llltNM.: INl'Ollltllh\\,,ON - N6f Feft fit:J8Ue ft!l!A9!!

perform their specified safety functions or flecessary and related support functions.

In addition. the NRC staffs review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

The NRC iMll review the new information provided in the report to the State of California including the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRC staff will lake additional regulatory action as appropriate tf the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit the cx>nclusions in the RIL

2. Has DCPP provided the seismic report to the NRC?

Yes, in accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has provided the information to the NRC. In addition, the report was also provided to address license renewal issues (see question 8).

3. What does the new report state?

The new report includes information obtained from 2-dimensional and 3-dimensional high energy and low-energy seismic surveys both onshore and offshore of the DCPP site. The report provides more details on the regional faults, including more precise readings and additional data points where previously there were gaps. While a lot of the information from the previous Shoreline Fault report of 2011 was confirmed, some of the new data suggests the following:

Reduced slip rate on the Hosgri Fault Zone and the Shoreline Fault Zone Postulated connection of the Hosgri and the San Simeon faults which could result in a longer, larger, but more infrequent earthquake The unique geometry involved with intersecting the Hosgri Fault and the Shoreline Fault Zone results in an extension of a few kilometers, but with a lower frequency of occurrence Extension of the Shoreline Fault zone southern segment The new data does not alter the assessment of the closest approach of the Shoreline fault to DCPP which is 600 meters from the power block and 300 meters from the intake structure. Because the Shoreline fault is considered to be somewhat longer, potential earthquakes could also occur farther from the plant.

Updated analysis for the San Luis Bay, and Los Osos faults The report concludes that the ground motions for the Hosgri and L TSP evaluations continue to bound potential ground motions from the regional faults, including the Shoreline Fault, San Luis Bay, Los Osos, San Simeon and Hosgri. The DCPP continues to operate safely within the seismic margin they were designed to withstand.

4

DRAFT - 6ffle1Al tJS! ONLY S!NSITIVI! INT!RNAL INl'OftMl<TION - NOT "Oft,t:1et1c ftl!U!ASI!!

4. How will the AB 1632 seismic report be coordinated with the 50.54(f) required submittal in March 2015?

PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the OCPP.

(If pushed on any *unknowns* in the report: If necessary. actions could include orders to halt operations if new infonnatlon suggests there Is an immediate safety concern. The NRC will fulfill its mandate to protect public health and safety).

(If asked what things the plant has done since Fukushima: It is important to note that OCPP is an Industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).

5. Why is the report "final" for the state but "preliminary" for the NRC?

For the State, the report is final. For the NRC, this infonnation is expected to be incorporated into the more comprehensive 50.54f analysis due to the NRC in March 2015.

However, because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is safe to continue to operate. PG&E's evaluation of the new seismic infonnation, as documented in the report. concludes that the ground motions resulting from the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgrl analysis that was used during licensing of the plant.

6. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault in 2011 prior to issuing the Rll?

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Stat1ion. to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 report.

The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analyses which is due for OCPP in March 2015.

7. What is the impact of this new information on seismic design and licensing of DCPP?

Based on the preliminary results of the studies that are under review, PG&E detennined that 5

DRAFT - Ol'l'ICIAL tlS! ONLY Sl!NSITIYI! INTl!"NM: INl'O"MATt6N - Ne=r reR Pt:IBLJe RELEASE the Shoreline Fault Zone may be capable <>f producing somewhat larger earthquakes than cons,dered in the January 2011 Shorehne ireport. The NRC staff is independently assessing PG&E's determination. The process outlined in the 50.54(f) letter includes a detailed analysis of new seismic information (including shoreline faults and other faults around the plant). PG&E is scheduled to provide this assessment in the March 2015 time frame. The staff will continue to review the information in the new CA 1632 report and the final results of the new data from the more rigorous analysis to be completed by March 2015. The NRC staff will take appropriate regulatory action up to and including issuing Orders to ensure safe operation of the planl

8. Will the Report be considered in the Ucense Renewal Process Yes. In addition to the report being developed to address California Assembly Bill 16321 PG&E is providing the report to the State of California as part of the State of California coastal zone consistency certification associated with the license renewal for DCPP. The State of California coastal zone consistency certification is considered by the NRC during the license renewal environmental review process. In addition, the Staff will be reviewing the report to see how, if at all, it is relevant to the Staff's license renewal review. There is a contention related to the Shoreline fault and its consideration in the facility's severe accident mitigation alternatives analysis that is admitted in the license renewal proceeding (see ML14224A320; See CLl-11-11).

6

DRAFT - Ol'PICIAL t:IS! ONLY 91:NSITl'f'I! IN'fl:"NAL INF6RMA'fl6N NOT l'OPt llt19LtC Pt!L!AS!

Background

UPDATED:

09/25/2014 3:13 PM Communications Plan -

Diablo Canyon Power Plant Topics of Interest State of California Seismic Report (ABN-1632)

California Assembly Bill 1632 (Blakeslee. Chapter 722. Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of Cafifomia's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report. This is a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.

The purpose of this communication plan is to provide key messages associated with the public release of this repo.rt.

Key Messages

1. NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions.

In addition, the NRC staffs review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

2. The NRC staff will continue to review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.

3. PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015.

The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

1

DRAFT - e l'ftelAL tJ9! eHLV 9EN91Tf'f'! INfl!ftl'tAL tr~fiOftM*'16N NeT FeR Pl:IBLle RELEASE Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.

Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/ORP/RPB-A 817-200-1195 Thomas Hipschman Sr. Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 OCPP John Reynoso Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 OCPP Jon Ake Senior Seismologist RES/DE/SGS EB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal OCPP Project Manager NRR/OORU LPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Elaine Keegan License aenewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DiFrancesco Japan Lessons Learned JLD 301-415-1115 Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Diablo Canyon, should be used to accomplish these actions. The table below is based on a target public release date of the report on September 10, 2014.

Timeframe Action Responsible Party(ies)

Septa PG&E provides a draft of the report in the PG&E electronic reading room for initial staff assessment Sept9 PG&E notifies NRC of seismic report submittal to PG&E the state of California 2

DRAFT - 6FF1e1M: ljSE eNtV 8EN91fff'E INfEffNl<L 1Nf6RM1cfl6N - NeT "e" ptjetle "l!!t!AS~

Timeframe Action Responsible Party(ies)

Sept 10 PG&E/Oiablo Canyon Power Plant submit seismic PG&E report to the state of Calif omia and issue a press release Promptly Region IV notifies the Communications Team of R-IV/RPB-A (within Sept PG&E's actions as currently understood and 10+1 business implements the Communications Plan day)

Entirety of Communications Team notifies R-IV: NRR/DORL; applicable Senior Managers in their respective NRR/OLR; NRR/JLO reporting chain OPA; OCA; OGC OPA available to use Communications Plan to R-IV: OPA answer media inquiries. NO blog OR press release planned.

Oct 3 JLD/NRO/RES completes preliminary assessment JLO/NRO/RES/RIV of published report and management decision is made if any additional actions should be taken prior to the submittal of the seismic reevaluation in March 2015. Updates to communication plan as appropriate As requested Complete a Commissioners Assistants Brief R-IV; NRR

1. Questions and Answers What is the impact of this new lnfonnation on seismic design and licensing of OCPP?

Has the llcensee entered this new information into the corrective action program and performed an operability evaluation?

In accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001,

PG&E has entered the new preliminary seismic information into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.

In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:

"If during PG&E's ongoing collection of seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information (Reference 2).

• Reference 2 is NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," March 12, 2012.

NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an 3

DRAFT - Ofll'ICblll t:JSI! OIRY

!l!N!fflWI! INTl!"NAL INl'O"MATION - Ne, fi6R JatJ8Ue fU:Ll!"A91!

immediate threat to public health and safety nor did it call into question the ab1hty of SSCs to perform their specified safety functions or necessary and related support functions.

In addition, the NRC staffs review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

The NRC will review the new information provided in the report to the State of California including the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit the conctus1ons in the RIL.

2. Has DCPP provided the se~smlc report to the NRC?

Yes, in accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has provided the information to the NRC. In addition, the report was also provided to address license renewal issues (see question 8).

3. What does the new report state?

The new report includes information obtained from 2-dimensional and 3-dimensional high eneirgy and low-energy seismic surveys both onshore and offshore of the DCPP site. The report provides more details on the regional faults, including more precise readings and additional data points where previously there were gaps. While a lot of the information from the previous Shoreline Fault report of 2011 was confirmed, some of the new data suggests the following:

Reduced slip rate on the Hosgri Fault Zone and the Shoreline Fault Zone Postulated connecting the Hosgri and the San Simeon faults which could result in a longer, larger, but more infrequent earthquake The unique geometry involved with intersecting the Hosgri Fault and the Shoreline Fault Zone results in an extension of a few kilometers, but with a lower frequency of occurrence Extension of the Shoreline Fault zone southern segment The new data does not alter the assessment of the closest approach of the Shoreline fault to DCPP which is 600 meters from the power block and 300 meters from the intake structure. Because the Shoreline fault is considered to be somewhat longer, potential earthquakes could also occur farther from the plant.

Updated analysis for the San Luis Bay, and Los Osos faults The report concludes that the ground motions for the Hosgri and L TSP evaluations continue to bound potential ground motions from the regional faults, including the Shoreline Fault, San Luis Bay, Los Osos, San Simeon and Hosgri. The DCPP continues to operate safely within the seismic margin they were designed to withstand.

4

DRAFT - 6fflel>lcl t:19E e,~tY 9f!!NSlfl¥~ IN'!!"N>fct INl'eMIATlet4 - N6T f6R l't:18tle "flfA9f

4. How will the AB 1632 seismic report be coordinated with the 50.54{f) required submittal in March 2015?

PG&E plans to incorporate the findings from 8111 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

(If pushed on any "unknowns" in the repoct: If necessary, actions could include orders to halt operations if new information suggests there is an immediate safety concern. The NRC will fulfill its: mandate to protect public health and safety).

(If asked what things the plant has done since Fukushima: It is important to not,e that DCPP is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).

5. Why is the report final" for the state but "preliminary" for the NRC?

For the State, the report is final. For the NRC, this information is expected to be incorporated into the more comprehensive 50.54f analysis due to the NRC in March 2015.

However, because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is safe to continue to operate. The NRC has looked at the information in the report and its preliminary assessment is that based on the information presented by PG&E the new information associated with Faults near DCPP does not result in ground motions above those from the previously considered seismic hazard.

6. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault in 2011 prior to lssu ing the RIL?

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station, to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 report.

The NRC has requested licensees of opell"ating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analyses which is due for DCPP in March 2015.

7. What is the Impact of this new information on seismic design and licensing of OCPP?

Based on the preliminary results of the studies that are under review, PG&E determined that 5

DRAFT - 6fifilCIAL 1:19!! 6NLV 9EN91llVE IN'fEfUtAL INfi6RMiA'fl6N - N6'f Feft Pt:JBtte RELEASE the Shoreline Fault Zone may be capable of producing somewhat larger earthquakes than considered in the January 2011 Shoreline report. The NRC staff is independently assessing PG&E's determination. The process outlined in the 50.54(f) letter includes a detailed analysis of new seismic information (including shoreline faults and other faults around the plant). PG&E is scheduled to provide lhis assessment in the March 2015 time frame. The staff will continue to review the information In the new CA 1632 report and the final results of the new data from the more rigorous analysis to be completed by March 2015. The NRC staff will take appropriate regulatory action up to and including issuing Orders to ensure safe operation of the plant.

8. WIii the Report be considered In the license Renewal Proce-Ss Yes. In addition to the report being developed to address California Assembly Bill 1632, PG&E is providing the report to the State of California as part of the Stale of California coastal zone consistency certification associated with the license renewal for OCPP. The State of California coastal zone consistency certification is considered by the NRC during the license renewal environmental review process. In addition, the Atomic Safety and Licensing Board (ASLB} has expressed interest in the report because it is associated with a contention that is under consideration by the ASLB in the license renewal process (see ML14224A320}.

6

From:

To:

Cc:

Subject:

D*t.:

Atbdlments:

Cliff, Sebrosky. Joseph Munson Qrfford wunams, Megan: Oestede Erle: Ugkt,oo Lara: walker, Wayne: HIQSchmao Thomas FW: oc_ca11t_seism~ rpt comm plan 9-10-14_nnal(2).docx Wednesday, September 10, 2014 10:08:00 AM oc cant :;e;srn;c mt comm Piao g.10-14 tnaKZ> dog Thanks for the quick feedback, I have no issues with your suggested changes.

Lara, Wayne, Megan, Eric, and Tom, Please verify you have no issues with Cliff's changes. I will then accept all changes and send it out to the broader audience.

Thanks.

Joe From: Munson, Olfford Sent: Wednesday, September 10, 2014 10:04 AM To: Sebrosky, Joseph subject: oc_calif_seismic_rpt comm plan 9-10-14_final(2).docx I have a couple of suggested changes.

Thanks, Cliff

From:

To:

Cc:

SUbject:

Attachments:

Cliff, 5et>rosky, Joseph NYOS9o Chfford Usefding Lara* walker Wayne; wm,a,ns Megan; HfQSChman Jbomas; Pestede Enc OC_Calif_selsmic_rpt comm plan 9*10-14_flnal.d0Cx Wednesday, september' 10, 2011 9:50:00 AM pc Calif se;sm1c rot comm Piao 2-10:11 final docx Per our discussion could you please review the attached final version of the communication plan and let me and Megan Williams know if you have any concerns. Also per our discussion Lara will work with Megan on any followon technical questions that she might lhave. If Megan needs help she will contact you, otherwise, we are leavin,g it up to Megan to advise Lara.

Lara, Wayne and Megan, I made changes consistent with what was discussed in the meeting. The yellow highlighted stuff was changed based on a comment from Eric after the meeting. Once Cliff gives his comments/approval I will send the document to a broader audience.

Thanks, Joe

DRAFT - 6ffle1AL tf Sf 6NL\\'

SENSl'fr11f IN'ffRNAL INfeRMAl16N - NOT PeR Pt:J8tle Rl!L!ASI!

Background

UPDATED: 9/10/14 9:30 eastern Communications Plan -

Diablo Canyon Power Plant Topics of Interest State of California Seismic Report (ABN-1632)

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the, California Energy Commission to assess the potential vulnerability of California's largest basel!oad power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report. This is a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.

The purpose of this communication plan is to provide key messages associated with the public release of this report.

Key Messages

1. NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance, of public health and safety after a seismic event.

PG&E's evaluation of the new seismic information, as documented in the report, concludes that the ground motions resulting from the faults discussed in the report (i.e.,

Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

2. The NRC staff will continue to review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.

3. PG&E plans to incorporate the findings from Bill 1632 report into their upcoming March 2015 seismic hazard re-analysis as part of the NRC's post-Fukushima activities. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the OCPP.

1

DRAFT - OPl'ICIAt t:ISl! ONLY S!NSITl'tl! INTl!PtN,CL tN,OPtMATION - NeT FeR P~Blle RELE>tc9E Communication Team The primary responsibility of the communica,tion team is to ensure that It conveys a consistent.

accurate, and timely message to all stakeholders. The team consists of the project management. technical. and communication staff named below.

Team !Member Position Organization Telephone Wayne Walker Branch Chief R-IV/DRP/RPB-A 8 17-200-1148 Ryan Alexander Sr. Project Engineer R-IV/ORP/RPB-A 817-200-1 195 Thomas Hipschman Sr. Resident Inspector -

R-IV/DRP/RPB-A 805-595-2354 DCPP John Reynoso Resident Inspector -

R-IV/DRP/RPB-A 805-595-2354 DCPP Jon Ake Senior Seismologist RES/DE/SGSEB 301-251-7695 Eric Oesterte Acting Branch Chief NRR/OORU LPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Offilcer RIV 817-200-1519 Bill Maier State liaison Officer RIV 817-200-1267 Elaine Keegan license Renewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DiFrancesco Japan Lessons Learned JLD 301-415-1115 Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Diablo Canyon, should be used to accomplish these actions. The table below is based on a target public release date of the report on September 10, 2014.

Timeframe Action Responsible Party(ies)

Sept 8 PG&E provides a draft of 1he report in the PG&E electronic reading room for initial staff assessment Sept9 PG&E notifies NRC of seismic report submittal to PG&E the state of California 2

DRAFT - Ofl'lel1ct tJSI: ONLY 8EN91flVE INTl:RNA1::: INfORMNPl6N - NOT FeR PtJ8tle RELEASE Timeframe Action Responsible Party(ies)

Sept 10 PG&E/Oiablo Canyon Power Plant submit seismic PG&E report to the state of California and issue a press release Promptly Region IV notifies the Communications Team of R-IV/RPB-A (within Sept PG&E's actions as currently understood and 1 O+ 1 business implements the Communications Plan day)

Entirety of Communications T earn notifies R-IV; NRR/DORL; applicable Senior Managers in their respective NRR/DLR; NRR/JLD reporting chain OPA; OCA; OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. NO blog OR press release planned.

Oct3 JLD/NRO/RES completes preliminary assessment JLD/NRO/RES/RIV of published report and management decision Is made if any additional actions should be taken prior to the submittal of the seismic reevaluation in March 2015. Updates to communication plan as appropriate As requested Complete a Commissioners Assistants Brief R-IV; NRR

1. Questions and Answers What is the impact of this new information on seismic design and licensing of DCPP?

Has the licensee entered this new Information into the corrective action program and performed an operability evaluation?

In accordance with the guidance in the October 12, 2012, letter transmitting RI L 2012-001, PG&E has entered the new preliminary seismic information into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.

In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:

"If during PG&E's ongoing collection of seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staff's March 12, 2012, request for information (Reference 2).

• Reference 2 is NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," March 12, 2012.

NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an 3

DRAFT - 61'f lehtit tt3! eNtY 3ENS1f1V! 1Nf£RNAL 1Nfl6Rflllilffl6N - H6T F6R Ptt8Ue "ELEA9e immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions.

In addition, the NRC staffs review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant The NRC will review the new information provided in the report to the State of California including the Shoreline Fault characteristics. and the updated characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit the conclusions in the RIL.

2. Has DCPP provided the seismic report to the NRC?

Yes, in accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has provided the information to the NRC. In addition, the report was also provided to address license renewal issues (see question 8).

3. What does the new report state?

The new report includes information obtained from 2-dimensional and 3-dimensional high energy and low-energy seismic surveys both onshore and offshore of the DCPP site. The report provides more details on the regional faults, including more precise readings and additional data points where previously there were gaps. While a lot of the information from the previous Shoreline Fault report of 2011 was confirmed, some of the new data suggests the following:

Reduced slip rate on the Hosgri Fault Zone and the Shoreline Fault Zone Postulated connection of the Hosgri and the San Simeon faults which could result in a longer, larger, but more infrequent earthquake The unique geometry involved with intersecting the Hosgri Fault and the Shoreline Fault Zone results in an extension of a few kilometers, but with a lower frequency of occurrence Extension of the Shoreline Fault zone southern segment The new data does not alter the assessment of the closest approach of the Shoreline fault to DCPP which is 600 meters from the power block and 300 meters from the intake structure. Because the Shoreline fault is considered to be somewhat longer, potential earthquakes could also occur farther from the plant.

Updated analysis for the San Luis Bay, and Los Osos faults The report concludes that the ground motions for the Hosgri and L TSP evaluations continue to bound potential ground motions from the regional faults, including the Shoreline Fault, San Luis Bay, Los Osos, San Simeon and Hosgri. The DCPP continues to operate safely within the seismic margin they were designed to withstand.

4

DRAFT - 0Ffle1AL tl91! 0NLY 9EN91Tl'f'I! INTl!~NAL INl'eft:MATleN - NOT FOR PtJBUe RELEASE

4. How will the AB 1632 seismic report be coordinated with the 50.54{f) required submittal in March 2015?

PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the OCPP.

(If pushed on any "unknowns" in the report: If necessary, actions could include,orders to halt operations if new infonnation suggests there is an immediate safety concern. The NRC will fulfill its mandate to protect public health and safety).

(If asked what things the plant has done since Fukushima: It is important to note that DCPP is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).

5. Why Is the report "final" for the state but "preliminary" for the NRC?

For the State, the report is final. For the NRC, this information is expected to be incorporated into the more comprehensive 50.54f analysis due to the NRC in March 2015.

However, because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is safe to continue to operate. PG&E's evaluation of the new seismic information, as documented in the report, concludes that the ground motions resultiJ1g from the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

6. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault In 2011 prior to issuing the RIL?

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station, to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 report.

The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analyses which is due for OCPP in March 2015.

7. What is the impact of this new infonnation on seismic design and licensing of DCPP?

Based on the preliminary results of the studies that are under review, PG&E determined that 5

DRAFT - 6 ffilelAL t:ISE 6f4LY 91!N91Tl'f'I! INT!"NAL 1Nf6RMATl6N - NeT F6R Pt:18Ue RELEASE the Shoreline Fault Zone may be capabte of producing somewhat larger earthquakes than considered in the January 2011 Shoreline report. The NRC staff ls independently assessing PG&E's determination. The process outlined in the 50.54(f} letter includes a detailed analysis of new seismic information (including shorenne faults and other faults around the plant). PG&E is scheduled to provide this assessment in the March 2015 time frame. The staff will continue to review the information in the new CA 1632 report and the final results of the new data from the more rigorous analysis to be completed by March 2015. The NRC staff will take appropriate regulatory action up to and including issuing Orders lo ensure safe operation of the plant.

8. Will the Report be considered in the License Renewal Process Yes. In addition to the report being developed to address California Assembly Bill 1632, PG&E Is providing the report to the State of California as part of the State of Caiifomia coastal zone consistency certification associated with the license renewal for DCPP The State of California coastal zone consistency certification is considered by the NRC during the license renewal environmental review process. In addition, the Staff will be reviewing the report to see how, if at all, it is relevant to the Staff's license renewal review. There is a contention related to the Shoreline fault and its consideration in the facility's severe accident mitigation alternatives analysis that is admitted in the license renewal proceeding (see ML14224A320; See CLl-11-11).

6

from; To:

Cc SUbJect:

Start End:

Location:

Attadlmients:

Sebrosky. Joseoh St(MU. Scott' Munson, CJ,ffon;l: WlHWD,S. MeQan:.LJ....lggg.; Hips;hman Thpma.: Y{,11kg,:. Wayrne: ~

ft:lt; Siroal aatwaat: Marklex Mtd>aef: lad§on l)jane: o,Franceyp HIChQfas: YIJl,aJey Sl)eena * ~

Lm; Bt/roen Scptt: OKffle Nd* faro[Pltz, Thomas* Kanatu CatheQne: RrxN~l PaxJd: Manoty, Kamal:

bv::;,~c*

tjjllBtltta,n* Dudek. M/ctli>d; Buchanan, Theresa. Kro,. AQdrea: weayer. Thomas:

~-~~ l ~c &11; !<fflJJD &me

~::::.:.:.:.-:.:.:.-.. -.... -.... -: *@- IQSkl. Jom: Weer:sAAocr,, 5yn11 Internal meetlno to finalize diablo c:ommunlc3tlon plan Wednesday, Seplenl)er 10. 2014 8:30:00 AM Wednesday, September 10, 2014 9:30:00 AM HQ* lWFN-10C01-15p OC eanr ffilDlt mtmmm Qfao 9::10-11 srti,docl Nott: CDITVllUOlc:atlon plan updated to lrldude Saltt &lml!lt's amments In redlile/miteout Bridge#: B88*6n-0690 Passcode:I (b)(61 I

Purpose:

To finalize the draft a:immunicabon plan OUtcome: CommunicatiOn plan associated wlttl Diablo Canyon State d Californa seismic report finahzed Agenda:

DISOJssiOIII of changes Incorporated inputs from Tom Hlpschman. Lara llseldlng, and ~

Williams (thris for the Insights)

First key messaoe bullet changed based on Tom and Lara's input Other changes made based on direction during the 9/9 meetlng and additional Input from Megan II. Comments and resolution III. Next steps

'N. Wrapup

Project Plan for NRC Staff Review of PG&E's Report to the State of California Regarding Seismic Faults Near the Diablo Canyon Power Plant 9/12/14 Version NOTE: This Is a living document and wlll be updated as necessary. Please note the date on the cover.

Document Point of Contacts:

Joseph.Sebrosky@nrc.gov Nick.D1Francesco@nrc.gov Japan Lessons Learned

TABLE OF CONTENTS Purpose of the Review of the State of California Report................................................................................ 2 Background..................................................................................................................................................... 2 Products to be Reviewed................................................................................................................................ 4 Review Process................................................................................................................................................ 4 Review Team................................................................................................................................................... 6 Communication Plan....................................................................................................................................... 6

PURPOSE OF THE REVIEW OF THE STATE OF CALIFORNI A REPORT This project plan documents steps necessary for NRC staff to quickly assess the information found in the report provided by Pacific Gas and Electric (PG&E) to the State of California related to Seismic Faults near the Diablo Canyon Power Plant (DCPP). The assessment will be used to support the Region's inspection of the operability determination associated with the information in the report.

A second expected outcome of the assessment is a recommendation to NRR. and NRO management as to whether or not the NRC's processes associated with new seismic information as it relates to Diablo Canyon and which are described m NRC letters dated March 12, 2012 1

October 12, 20122, and February 20, 20143 should continue to be followed or if there is new Information that suggests there Is an immediate safety concern that would require action In accordance with established regulatory processes (e.g., Order).

BACKGROUND California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste, accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art seismic evaluation methodologies included 20 and 30 mapping to compile this report. This is a different and more extensive data set than what was used for PG&E's 2011 Shoreline Fault evaluation (ADAMS Accession No. ML110140431 ).

Based on information that PG&E verbally provided to the NRC in late August 2014, PG&E indicated that the length, and magnitude of the Shoreline fault is greater than that assumed in a 2011 PG&E report provided to the NRC. PG&E has also indicated that the soil properties found in the 2011 report have also been updated based on new information. The report was subsequently provided to the staff and in addrtion to providing changes to the Shoreline fault characteristics new information Is provided In the State of California report relative to other faults in the area (e.g.. Los Osos, and San Luis Bay).

PG&E's operability evaluation, which is available to the staff, states the following:

Based on the preliminary results of the studies that are under review, it has been determined that the Shoreline Fault Zone may be more capable than summarized in the January 2011 report, but the deterministic response spectra are still bounded by those for the Hosgri and L TSP earthquakes.

The staff previous evaluation of the Shoreline Fault can be found in Research Information Letter (RIL) 12-01 "Confirmatory Analysis of Seismic Hazard at the Oiablo Canyon Power Plant: from the Shoreline Fault Zone" (ADAMS Accession No.ML121230035). The staffs deterministic evaluation includes several scenarios and resulted in the conclusion that the Shoreline Fault is bounded by the Hosgri and L TSP spectrum. The graph below is from the RI L.

1 The March 12, 2012, request for information is available under ADAMS Accession No. ML12053A340 2 The October 12, 2012, letter is available under ADAMS Accession No. ML120730106 3 The February 20, 2014, letter is available under ADAMS Accession No.. ML14030A046 Z I P age

As can be seen in the graph from the RIL the staffs magnitude 6. 7 earthquake scenario is essentially equal to the Hosgn spectrum in the 20 to 40 Hz range PG&E's assessment in the 2011 report was based on a magnitude 6.5 earthquake. Based on the information in the report to the State of California the Shoreline Fault Is capable of generating a 6 7 magnitude earthquake.

There are several differences in PG&E's assessment of the Shoreline Fault found in their 2011 report and the staffs assessment found in the RIL. As stated in the report to the State of California as well as the cover letter transmitting the report to the NRC, PG&E believes that based on new information relative to the Shoreline Fault and soil properties in the area the Shoreline Fault deterministic ground motion response spectrum is still bounded by the Hosgri and L TSP spectrum.

The purpose of the headquarters staffs review is to do the following*

C) -

C i Cl>

8 c(

I Cl) provide technical assistance to the Region to support their inspection associated with the licensee's operability determination, and provide an assessment to NRR and NRO management on whether or not the process outlined in the March 2012 50.54(f) letter should continue to be followed or if there is new Information that suggests there 1s an immediate safety concern that would require action in accordance with established regulatory processes (e.g., Order).

2.6 Ho*~ lpecWum LTSP ~

Wl'IC Ml 7

• a.,

2.0 w.-e Mst -a.,

us 1.0 0.5 0.0 0.1 1

10 100 Frequency (Hz)

In addition, in the NRC's October 12, 2012, letter) transmitting NRC's review of the Shoreline Fault Report to PG&E (ADAMS Accession No. ML120730106), the NRC placed,ts assessment of the Shoreline Fault in context with the process outlined in the March 12, 2012, 50.54(f) letter.

The October 12, 2012 letter contained the following guidance relative to the discovery of new seismic information:

The NRC staff understands that the seismic evaluations described in the March 12, 2012, request for information are currently in progress at DCPP, and PG&E plans to acquire new off shore and onshore two-and three-dimensional seismic reflection data to identify and characterize faults in the vicinity of DCPP. If during the collection of the data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, the staff expects that the licensee will provide the NRC with an interim evaluation that describes actions taken or planned to address the 3 I P c1 g e

higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information. The staff will use this information to independently assess whether the new fault or new information related to the Shoreline fault challenges or changes the staffs cuffent position that the motions associated with the Shoreline fault are at or below those levels of the HE and L TSP ground motions.

PG&E was informed prior to submitting the report that based on what PG&E verbally indicated would be in the report, the NRC staff expected PG&E to provide an interim evaluation that describes actions taken or planned to address the higher seismic evaluation In the September 10, 2014, letter transmitting the report to the NRC PG&E provided the interim evaluation concluding that the Shoreline fault remains bounded by the Hosgri analysis.

In performing this assessment the staff will also consider the supplemental Information related to the March 12, 2012, request for information provided in an NRC letter dated February 20, 2014 (ADAMS Accession No. ML14030A046). The February 20, 2014, letter includes guidance regarding operability and reportability. As stated in the February 20, 2014, letter.

"as always, the safety of the operating plants is of paramount importance. The NRC will follow established regulatory processes, including the backfit rule, in determining whether additional requirements are warranted:

Other Faults The PG&E 2011 Shoreline Fault report and the staffs RIL also discuss other seismic faults near Diablo Canyon including the Los Osos and San Luis Bay faults PG&E's report to the State of California also includes new information relative to these faults.

PRODUCTS TO BE REVIEWED PG&E report to the State of California relative to Seismic Faults near Diablo Canyon (until the document is available in ADAMS please see the following PG&E link:

http://www.pge.com/en/safety/systemworks/dcpp/se1smicsafety/report.page)

PG&E's interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis REVIEW PROCESS Review time for this process should be charged to the following tac numbers:

MF4750, DIABLO CANYON 1 - Review Oiablo Canyon Seismic Report Submitted to the State and Other Associated Activities MF4751, OIABLO CANYON 2 - Review Diablo Canyon Seismic Report Submitted to the State and Other Associated Activities As of September 10, 2014, the staff has access to the report Prior to being provided access to the report, the staff took the following steps:

Based on PG&E's preliminary description of the information in the State of California report, the staff originally considered assessing the new information in accordance with the process that has recently been used for Central and Eastern u.s_ (CEUS) plants that is found in a March 11, 2014, letter from EPRI (ADAMS Accession No. ML14083A586).

The NRC staff provided a list of information needs to PG&E on September 3, 2014, in

order to calculate a seismic core damage frequency consistent with the approach in the EPRI report. The NRC staff requested feedback from PG&E on whether or not the information could be provided to the staff in the September 2014 time frame. PG&E informed the staff In a September 8, 2014, phone call that PG&E would not be able to provide all of the necessary information to calculate a new seismic core damage frequency until March of 2015.

The staff also considered performing a qualitative assessment of changes to the seismic core damage frequency based on a sensitivity analysis found in the State of California report that compares the new information to the PG&E's 2011 Shoreline Fault evaluation (ADAMS Accession No. ML110140431). Although a seismic core damage frequency cannot be calculated, a qualitative assessment of changes to the seismic core damage frequency discussed in PG&E's shoreline fault report was thought to be possible and useful. However, based on a preliminary review of the report as of September 11, 2014, such a qualitative analysis may not be possible. The information comparing the new information in the report to that found in the 2011 PG&E Shoreline fault report is not sufficiently detailed to make such a qualitative analysis possible.

The staff is therefore considering the following approach to review the new seismic information:

Perform a focused deterministic calculation using PG&E's new seismic information (including seismic fault and soil property changes) as inputs into a staff developed model.

The calculation could provide a limited updated ground motion response spectrum to be compared against the Hosgri spectrum. This calculation is limited in that it would not be a complete revision to the staffs deterministic evaluation captured in RIL 12-01, but it is thought the information the calculation could provide could be useful in developing a recommendation to management on how to proceed.

Determine whether or not an update to an assessment discussed in a May 29, 2014, NRC memorandum, "Differing Professional Opinion Involving Seismic Issues at Diablo Canyon (DP0-2013-002)." (ADAMS Accession Nos. ML14153A658, and ML14163A673) is appropriate. Section 4.2.1, *Technical Assessment of the Potential for Seismic Loads on SSCs to Exceed Previously Analyzed Conditions." includes a discussion that PG&E calculated in-structure acceleration response spectra as the basis for comparison between the ground motions in the 2011 PG&E Shoreline report to the ground motions used in the updated final safety analysis report. The staff will inquire as to whether PG&E has updated this calculation based on the new seismic information in the State of California report.

The proposed milestones and timeframes for reviewing PG&E's report are as follows:

Tlmeframe Action Res pons Ible Status Party(ies)

Sept 3 NRC staff identifies information that it will quickly NRC review complete need from PG&E to support a possible review in team accordance with the process found in the CEUS study above PG&E will be asked to provide feedback on whether or not it cam provide information by Sept 22.

Sept 8 PG&E provides feedback to the staff on whether or PG&E complete not it can provide information to the staff by Sept 22 to calculate a seismic core damage frequency. On September 8 PG&E informed the staff that this information would not be available until March 2015.

SI P age

Timeframe Action Responsible Status Party(les)

Sept 8 Key NRC review team members review the State of NRC review complete California report prior to its public release.

team Changes to the project plan and communication plan are identified Sept 10 PG&E provides report and interim evaluation to the PG&E complete NRC Sept 15 NRC review team initial meeting to discuss NRC review preliminary observations and assessment of team information in the report. Determines that information it may need to support RIV's Inspection and the independent analysis that may be needed to support a recommendation to NRR and NRO management relative to the 50.54(f) process Sept22 RIV coordinates with PG&E documents to be RIV provided in electronic reading room to support inspection efforts based on outcome of September 15, 2014, meeting Sept29 NRC review team completes it preliminary NRC review assessment of new Shoreline fault information.

team Information provided to Region IV to support inspection and recommendation to management on how to proceed provided October 3 NRC management makes dec1s1on on how to NRC proceed management October 10 As appropriate, based on outcome of October 3 NRC decision, NRC provides letter documenting interim assessment to NRR manageme11t Consideration made for public release of the assessment through the inspection report process and/or a letter back to the licensee REVIEW TEAM The following are the proposed members of the review team subject to management approval NRR Projects: Enc Oesterle, Balwant Smgal, Joe Sebrosky, Nick DiFrancesco NRR technical: Kamal Manoly, Yong Li NRO t,echnlcal: Cliff Munson, Britt Hill, John Staimatakos (contractor)

RES: Jon Ake, Scott Stovall, Thomas Weaver Region IV: Wayne Walker, Theresa Buchanan, Megan Williams, Tom Hipschman COMMUNICATION PLAN A communication plan has been developed for the PG&E report. The NRC review team will update the communication plan based on its assessment of the new information.

GI Pag e

DRAFT - Ofll'ICIAL t:IS! ONLY 8EN81fl~! lt4fEIU4AL INf'OftMATION - NOT FOR flt:IBtle ~LEAS!:

UPDATED:

09/25/2014 3:26 PM09/1012014 8:07 AM09J10/2014 7:0G.AM

Background

Communications Plan -

Diablo Canyon Power Plant Topics of Interest State of California Seismic Report {ABN-1632)

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report. This is a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.

The purpose of this communication plan is to provide key messages as.sociated with the public release of this report.

Kev Messages

1. NIRC Resident Inspectors and Region IV staff looked at the licensee's documentation in

~corrective action process assessmentiA9 of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an immediate threat toindicates reasonable assurance of public health and safety nor did it call into q1::1estion through the ability of SSCs to perform their specified safety functions or necessary and related support functions after a seismic event.

In addition, the NRC staff's review of the PG&E report's new seismic information i-R--tM report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

2. The NRC staff will continue to review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRG to question PG&E's conclusions.

3. PG&E plans to incorporate the findings from Bill 1632 report into their upcoming March 2015 seismic hazard re ongoing analysis req1:1ired byas part of the NRC'..§. post-Fukushima task force recommendationsactivities due in March 2015. The NRC believes 1

DRAFT - 6ffllelAL tl91! 6NLY 9Ef~91Tl'f'I! ltffl!f'NAL INF6f'MAfl6N - N6T F6R Ptl8tle RELEA9E this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

Communication Team The primary responsibility of the communication team is to ensure that it conveys a,consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.

Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195 Thomas Hipschman Sr. Resident Inspector -

R-IV/DRP/RPB-A 805-595-2354 DCPP John Reynoso Resident Inspector -

R-IV/DRP/RPB-A 805-595-2354 OCPP Jon Ake Senior Seismologist RES/DE/SGS EB 301 -251-7695 Eric Oesterle Acting Branch Chief NRR/DORL/LPLIV 301-415-1014 Batwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Dricks Public Affairs Officer RIV 81 7-200-1 128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Elaine K,eegan License Renewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DiFrancesco Japan Lessons Learned JLD 301-415-1115 Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Diablo Canyon, should be used to accomplish these actions. The table below is based on a target public release date of the report on September 10, 2014.

Timeframe Action Responsible Party(ies)

Sept 8 PG&E provides a draft of the report in the PG&E electronic reading room for initial staff assessment 2

DRAFT - Ol'P'ICl'1ct t:JS! ONLY 8EN91fl't1E INl'ERN>>t<L INF6RMA'fl6N - NOT l'Oft l't:J8Ue ftfl!ASe Timeframe Action Responsible Partv(ies)

Sept 9 PG&E notifies NRC of seismic report submittal to PG&E the state of California Sept 10 PG&E/Dlablo Canyon Power Plant submit seismic PG&E report to the state of California and issue a press release Promptly Region IV notifies the Communications Team of R-IV/RPB-A

{within Sept PG&E's actions as currently understood and 10+1 business implements the Communications Plan day)

Entirety of Communications Team notifies R-IV; NRR/DORL; applicable Senior Managers in their respective NRR/DLR; NRR/JLD reporting chain OPA; OCA; OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. NO blog OR press release planned.

Oct 3 JLD/NRO/RES completes preliminary assessment JLD/NRO/RES/RIV of published report and management decision is made if any additional actions should be taken prior to the submittal of the seismic reevaluation in March 2015. Updates to communication plan as appropriate As requested Complete a Commissioners Assistants Brief R-IV; NRR

1. Questions and Answers What is the impact of this new information on seismic design and licensing of OCPP?

Has the licensee entered this new information into the corrective action program and performed an operability evaluation?

In accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has entered the new preliminary seismic information into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.

In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:

"If during PG&E's ongoing collection of seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staff's March 12, 2012, request for information (Reference 2).

• Reference 2 is NRG letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident,* March 12, 2012.

NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in 3

DRAFT - 6 f'f'le1At tf91: 6NLY 9!N91l l'f'E INl'ERNAL INf'6ftMtcf"16N - N6f F6R PtfBtle RELf!A:9E their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's 1nfonnation did not indicate there is an immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or mecessary and related support functions.

In addition, the NRC staff's review of the new seismic infonnation in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shorefine, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

The NRC will review the new information provided in the report to the State of Califomia1 including the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRC staff wlll take additional regulatory action as appropriate if the NRC staff concludes that the new infonnation associated with the Shoreline Fault causes the NRC to revisit the conclusions in the Rll.

2. Has DCPP provided the seismic report to the NRC?

Yes, in accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has provided the information to the NRC. In addition, the report was also provided to address license renewal issues (see question 8).

3. What does the new report state?

The new report includes infonnation obtained from 2-dimensional and 3-dimensional high energy and low-energy seismic surveys both onshore and offshore of the DCPP site. The report provides more details on the regional faults, including more precise readings and additional data points where previously there were gaps. While a lot of the information from the previous Shoreline Fault report of 201 1 was confirmed, some of the new data suggests the following:

Reduced slip rate on the Hosgri Fault Zone and the Shoreline Fault Zone Postulated connecting the Hosgri and the San Simeon faults which could result in a longer, larger, but more infrequent earthquake The unique geometry involved with intersecting the Hosgri Fault and the Shoreline Fault Zone results in an extension of a few kilometers, but with a lower frequency of occurrence Extension of the Shoreline Fault zone southern segment The new data does not alter the assessment of the closest approach of the Shoreline fault to OCPP which is 600 meters from the power block and 300 meters from the intake structure. Because the Shoreline fault is considered to be somewhat longer, potential earthquakes could also occur farther from the plant.

Updated analysis for the San Luis Bay, and Los Osos faults The report concludes that the ground motions for the Hosgri and L TSP evaluations continue to bound potential ground motions from the regional faults, including the Shoreline Fault, San Luis Bay, Los Osos, San Simeon and Hosgri. The DCPP continues to operate safely within the seismic margin they were designed to withstand.

4

DRAFT - 6fll91CIAL tJSI! ONLY Sl!NSITl'II! IN,l!ftN>ltt INfl0ftMfcTl6N - NM FOR fll:JBUe RttEASE 4

How will the AB 1632 seismic report be coordinated with the 60.S4(f) required submittal in March 2015?

PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

(If pushed on any "unknowns* In the report'. If necessary, actions could include orders to halt operations if new information suggests there is an immediate safety concern. The NRC will fulfill its mandate to protect public health and safety).

(If asked what things the plant has done since Fukushima: It is important to note that DCPP is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).

5. Why is the report "final" for the state but "preliminary" for the NRC?

For the State, the report is final. For the NRC, this information is expected to be incorporated into the more comprehensive 50.54f analysis due to the NRG in March 2015.

However, because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is safe to continue to operate. The NRC has looked at the information in the report and its preliminary assessment is that based on the information presented by PG&E the new information associated with Faults near DCPP does not result in ground motions above those from the previously considered seismic hazard.

6. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault in 2011 prior to issuing the RIL?

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station, to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 report.

The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazal'd reevaluation using up-to-date methodologies and analyses which is due for DCPP in March 2015.

7. What Is the impact of this new information on seismic design and licensing of OCPP?

Based on the preliminary results of the studies that are under review, PG&E determined that 5

DRAFT - efllilCllct tlSf: 6NLY Sl!N91Tl't11! INff:"Nld: INl'e"MATleN - NOf FOR PtJ8Lle RELEASE the Shoreline Fault Zone may be capable of producing somewhat larger earthquakes than considered In the January 2011 Shoreline report. The NRC staff is independently assessing PG&E's determination. The process outlined in the 50.54(1) letter includes a detailed analysis of new seismic information (including shoreline faults and other faults around the plant). PG&E is scheduled to provide this assessment in the March 2015 time frame. The staff will continue to review the information in the new CA 1632 report and the final results of the new data from the more rigorous analysis to be completed by March 2015. The NRC staff will take appropriate regulatory action up to and including issuing Orders to ensure safe operation of the plant

8. Will the Report be considered In the License Renewal Process Yes. In addition to the report being developed to address California Assembly Bill 1632, PG&E Is providing the report to the State of Calif omia as part of the State of California coastal zone consistency certification associated with the license renewal for OCPP. The State of California coastal zone consistency certification is considered by the NRC during the license renewal environmental review process. In addition, the Atomic Safety and Licensing Board (ASLB) has expressed interest in the report because it is associated with a contention that is under consideration by the ASLB in the license renewal process (see ML14224A320).

6

from:

To:

Subject:

Date:

Attachments:

Megan, Sebrosky,Joseph w111,ams Megan* Famholtz. Thomas: walker wavnc FW: ~

language Wednesday, 5eptembef 10, 2014 6:'18:00 AM DC CaHf $ffiJ)jc mt oomm Qfao 2-2-11 rev rottt dog DC cant se;sm;c mt comm Piao 2-10-11 am cexisi>o 1 dooc I found your comments extremely helpful. I did not inoorporate all of them. Based on diSOJssions with Tom Hipschman last night the first bullet for key messages was changed back to something closer to the original. I am including Tom and Wayne on the email so they are aware of the basis for some of the changes in the communication plan which are a direct result of your comments.

Thanks for the help. If I screwed something up and you have time to call me before the 8:30 am call please do so, so I can attempt to address it right off the bat

Thanks, Joe

---

Original Message-----

From: Williams, Megan Sent: Tuesday, September 09, 2014 3:46 PM To: Sebrosky, Joseph

Subject:

RE: suggested language

Joe, I have suggested to some edits to the Q&As. I don°t think the answer to #6 Is very good (as written),

but not a great answer In of itself, so not sure about Improvements to that one.

Sure I am your favorite person right now, but thanks for lettering me offer my comments.

Thanks for your hard work.

r/,

megan From: WIiiiams, Megan Sent: Tuesday, September 09, 2014 2:52 PM To: Sebrosky, Joseph subject: suggested language Proposed language for key points of comm plan:

NRC staff is intimately familiar with the seismic hazards at Dlablo canyon and our seismic experts have been looking at this in detail for many years.

Based on a preliminary review of PG&Es seismic report by NRC staff, there is no new information to suggest that there is an immediate safety cone.em. This preliminary review included assessment of the licensee's current actions in accordance with Inspection guidance for having reasonable assurance of operability, pending further evaluation. The information does not indicate there is an immediate threat to public health and safety nor call into quesnon the ability of SSCs to perform their specified safety functions or necessary and related support functions.

The NRC staff will continue to review the technical details of the report to independently evaluate

the new information regarding seismic hazard for DQ>P and take additional regulatory actioo as appropriate if the new information associated with the Shoreline Fault changes the results of the preliminary evaluation.

PG&E will incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due In March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

thanks,.)Oe.

r/,

megan From: Sebrosky, Joseph Sent: Tuesday, September 09, 2014 12:18 PM To: Markley, Michael; Munson, Olfford; Stovall, Scott; Kock, Andrea; Williams, Megan; Li, Yong; Oesterle, Eric Cc: Weil, Jenny; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, Michael; Singal, Balwant; Famholtz, Thomas; Kanatas, Catherine; Hipschman, Thomas; Reynoso, John; Ake, Jon; Folk, Kevin; DiFrancesco, Nicholas; Balazik, Michael; Reynoso, John; Hill, Brittain; Walker, Wayne; Useldlng, Lara; Buchanan, Theresa; Keegan, Elaine; Jack.son, Diane; Wittick, Brian; Harris, Brian; Roth(OGC), David; Kanatas, catherine; OKeefe, Neil; Uhle, Jennifer; Lund, Louise

Subject:

info: status of public release of Diablo canyon State of califomia report To all, Based on my disrussions with Philippe Soenen of PG&E, PG&E IS targeting the public release of the State of callfomla report for 11:00 am Pacific time (2:00 pm eastern) on 9/10/14. PG&E intends to do the following:

Issue an announcement Issue a press release Make the document publicly available on their website Provide a hard copy to the County Walk a copy of the report to us to be provided to the document control desk in accordance with 10 CFR 50.4 requirements On a different note, Mike Markley, Eric Oesterle, and I briefed Jennifer Uhle on the status of Diablo seismic Issues using the attached briefing sheet.

No action required on your part. Thought you should know.

Let me know if you have any Questions.

Thanks, Joe Sebrosky 301-415-1132

DRAFT - Ol'l'ICIAL US! ONl:t' 91!NSITI\\'! INf l!ftNAL INl'OftMA'TION - N6f reR flt:J8LIC ft!tl!A31!

Background

UPDATED:

09/25/201* 3:27 PM Communications Plan -

Diablo Canyon Power Plant Topics of Interest State of California Seismic Report (ABN-1632)

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerabmty of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts f'rom nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report. This is a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.

The purpose of this communication plan is to provide key messages associated wijh the public release o,f this report.

Kev Messages

1. NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions.

In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report {i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

2. The NRC staff will continue to review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around OCPP cause NRC to question PG&E's conclusions.

3. PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015.

The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

1

DRAFT - 6Ffle1At tJSE eNL'I 9EN91TIW: IPffERNAL INFORMMION - Ne, f8R fltJ8Lle RELE'JlcSE Communication Team The primary responsibility of the communication team 1s to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.

Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/ORP/RPB-A 817-200-1195 Thomas Hipschman Sr. Resident Inspector -

R-JV/DRP/RP8-A 805-595-2354 DCPP John Reynoso Resident Inspector -

R-IV/DRP/RPB-A 805-595-2354 DCPP Jon Ake Senior Seismologist RES/DE/SGSEB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Elaine Keegan License Renewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DiFrancesco Japan Lessons Learned JLD 301-41 5-1115 Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Diablo Canyon, should be used to accomplish these actions. The table below is based on a target public release date of the report on September 10, 2014.

Timeframe Action Responsible Party(ies)

Sept 8 PG&E provides a draft of the report in the PG&E electronic reading room for initial staff assessment Sept 9 PG&E notifies NRC of seismic report submittal to PG&E the state of California 2

DRAFT - 6fl!IIC~L tlSI! 6NLY Sl:N91'fl¥1!! ltffl!IUOcL INf16ftMA'f1er* - NeT f6ft l'tl!UC ft:!Ll!1cSI!

Timeframe Action Responsible Party(les)

Sept 10 PG&E/Diablo Canyon Power Plant submit seismic PG&E report to the state of California and issue a press release Promptly Region IV notifies the Communications Team of R-IV/RPB-A (within Sept PG&E's actions as currently understood and 10+1 business implements the Communications Plan day)

Entirety of Communications Team notifies R-IV; NRR/DORL; applicable Senior Managers in their respective NRR/DLR; NRR/JLD reporting chain OPA: OCA; OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. NO blog OR press release planned.

Oct3 JLD/NRO/RES completes preliminary assessment JLD/NRO/RES/RIV of published report and management decision is made if any additional actions should be taken prior to the submittal of the seismic reevaluation in March 2015. Updates to communication plan as appropriate As requested Complete a Commissioners Assistants Brief R-IV; NRR

1. Questions and Answers What Is the impact of this new information on seismic design and licensing of OCPP?

Has the licensee entered this new information Into the corrective action program and performed an operability evaluation?

In accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has entered the new preliminary seismic information into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.

In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:

"If during PG&E's ongoing collection of seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staff's March 12, 2012, request for information (Reference 2)." Reference 2 is NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," March 12, 2012.

NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an 3

DRAFT - Ol'l"ICIAL t:ISf ONLY SENSlfl'tf IN'fEM~AL INPORMM'ION - NOT f'Oft l't:U!LIC ft!l~Sf immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions.

In addition. the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

The NRC wilt review the new information provided in the report to the State of California including the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit the conclusions In the RIL.

2. Has OCPP provided the seismic report to the NRC?

Yes, in accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has provided the information to the NRC. In addition, the report was also provided to address license renewal issues (see question 8).

3. What does the new report state?

The new report includes information obtained from 2-dimensional and 3-dimensional high energy and low-energy seismic surveys both onshore and offshore of the DCPP site. The report provides more details on the regional faults, including more precise readings and additional data points where previously there were gaps. While a lot of the information from the previous Shoreline Fault report of 2011 was confirmed, some of the new data suggests the following:

Reduced slip rate on the Hosgri Fault Zone and the Shoreline Fault Zone Postulated connecting the Hosgri and the San Simeon faults which could result In a longer, larger, but more infrequent earthquake The unique geometry involved with intersecting the Hosgri Fault and the Shoreline Fault Zone results in an extension of a few kilometers, but with a lower frequency of occurrence Extension of the Shoreline Fault zone southern segment The new data does not alter the assessment of the closest approach of the Shoreline fault to DCPP which is 600 meters from the power block and 300 meters from the intake structure. Because the Shoreline fault is considered to be somewhat longer, potential earthquakes could also occur farther from the plant.

Updated analysis for the San Luis Bay, and Los Osos faults The report concludes that the ground motions for the Hosgri and L TSP evaluations continue to bound potential ground motions from the regional faults, including the Shoreline Fault, San Luis Bay, Los Osos, San Simeon and Hosgri. The DCPP continues to operate safely within the seismic margin they were designed to withstand.

4

DRAFT - Ol'l'ICIAL t:191! ONLY 8Ef4Slfl't'E INfEftNAL INfi6ftMA'f10**

NOT l'Oft flt:Jl!ILIC ftl!Ll!ASI!

4. How will the AB 1632 seismic report be coordinated with the 50.54(f) required submittal In March 2015?

PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the OCPP.

(If pushed on any "unknowns*,n the report: If necessary, actions could include orders to halt operations if new information suggests there is an immediate safety concern The NRC will fulfill its mandate to protect public healtlrl and safety).

(If asked what things the plant has done since Fukushima: It is Important to note that OCPP is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).

5. Why is the report "final" for the state but 11preliminary" for the NRC?

For the State, the report is final. For the NRC, this information is expected to be incorporated into the more comprehensive 50.54f analysis due to the NRC in March 2015.

However, because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is safe to continue to operate. The NRC has looked at the information in the report and its preliminary assessment is that based on the information presented by PG&E the new information associated with Faults near OCPP does not result in ground motions above those from the previously considered seismic hazard.

6. Why didn't the NRC discover the length,of the faults when It did its seismic review of the Shoreline fault in 2011 prior to Issuing the RIL?

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station. to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of -the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 1report.

The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analyses which is due for OCPP in March 2015.

7. What is the impact of this new infonnation on seismic design and licensing of DCPP?

Based on the preliminary results of the studies that are under review, PG&E determined that 5

DRAFT - eFFlelAL t:JSE et~LY S!!f.!ITl"I!! INTEftN>'cl INl'OftM'A'Tt6N - NeT '56ft,~elle RELE>'c91:

the Shoreline Fault Zone may be capable of producing somewhat larger earthquakes than considered in the January 2011 Shoreline report. The NRC staff is independently assessing PG&E's determination. The process outlined in the 50.54(f) letter includes a detailed analysis of new seismic information (including shoreline faults and other faults around the plant). PG&E is scheduled to provide this assessment in the March 2015 time frame. The staff will continue to review the information in the new CA 1632 report and the final results of the new data from the more rigorous analysis to be completed by March 2015. The NRC staff will take appropriate regulatory action up to and including issuing Orders to ensure safe operation of the plant.

8. Will the Report be considered In the License Renewal Process Yes. In addition to the report being developed to address California Assembly Bill 1632, PG&E is providing the report to the State of California as part of the State of California coastal zone consistency certification associated with the license renewal for DCPP. The State of California coastal zone consistency certification is considered by the NRC during the license renewal environmental review process. In addition, the Atomic Safety and Licensing Board (ASLB) has expressed interest in the report because it is associated with a contention that is under consideration by the ASLB in the license renewal process (see ML14224A320).

6

From:

To:

Cc:

Subject:

Date:

Attachments:

Cathy, Sebrosky, Joseph Kanat.as Cathenne RothfOGC) pay1d: Keegan Efame; Witttek Bnan: Ysd<I ng Lara action: quick look at question In Olablo ccmm plan assodited with ranse renewai Wednesday, September 10, 2014' 6:40:00 AM QC caw :;efsmic mt comm clan 9-10-11 am revis,on 1 doos Can you please look at question 8 in the attached communication plan associated with the Oiablo Canyon State of California report and its impact on license renewal and let me know if you have any comments on the proposed answer. I am hoping to finalize comments this morning in support of an expected release of the State of California report at 2:00 pm eastern time today.

Any insights would be appreciated.

Thanks, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office o*f Nuclear Reactor Regulation joseph.sebrosky@nrc.gov 301-415-1132

DRAFT - 6fflelAL tl9E ONLY 8EN91'fl'IE INTERNAL 1Nf6RMATl6N - NOT P:OR ll't:t8LIC ftl!!Ll!!A!!!

Background

UPDATED:

09/25/2014 3:28 PM Communications Plan -

Diablo Canyon Power Plant Topics of Interest State of California. Seismic Report (ABN-1632)

California Assembly Bill 1632 {Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclea waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants In the state's energy portfolio. The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report. This is a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.

The purpose of this communication plan is to provide key messages associated with the public release of this report.

Key Messages

1. NIRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary information concerning OCPP seismic and licensing bases. The licensee's information did not indicate there is an immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions.

In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgrl analysis that was used during licensing of the plant.

2. The NRC staff will continue to review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around OCPP cause NRC to question PG&E's conclusions.

3. PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015.

The NRG believes this more rigorous analysis will provide the most accurate assessment of faults affecting the OCPP.

1

DRAFT - 6Fflebfct tJSE 6NLV S!NS1TJ¥1! INTl!IU4,CL 1141'0"MJltTION - NOT fOI' l'tJeue ft!Ll!1<S~

Communication Team The primary responsibility of the communication team is to ensure that 1t conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.

Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/ORP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/ORP/RPB-A 817-200-1 195 Thomas Hipschman Sr. Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 OCPP John Reynoso Resident Inspector -

R-IV/ORP/RPB-A 805-595-2354 DCPP Jon Ake Senior Seismologist RES/OE/SGSEB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/OORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Oricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Elaine Keegan License Renewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DiFrancesco Japan Lessons Learned JLD 301-415-1115 Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Diablo Canyon, should be used to accomplish these actions. The table below is based on a target public release date of the report on September 10, 2014.

Timeframe Action Responsible Party(ies)

Sept 8 PG&E provides a draft of the report in the PG&E electronic reading room for initial staff assessment Sept 9 PG&E notifies NRC of seismic report submittal to PG&E the state of California 2

DRAFT - Ol'l'ICIA'.L tJS! ONL't 9ENS1fl'IE IN=fERNAL INFORMATION - Nf*,fllllo..

o*~........

tJ..

eM-t..,,e... "a.ea4t""'8~ s-l!

Timeframe Action Responsible Partv(les)

Sept 10 PG&E/Diablo Canyon Power Plant submit seismic PG&E report to the state of California and issue a press retease Promptly Region IV notifies the Communications Team of R-IV/RPB-A (within Sept PG&E's actions as currently understood and 10+1 business implements the Communications Plan day}

Entirety of Communications T earn notifies R-IV; NRR/DORL; applicable Senior Managers in their respective NRR/DLR; NRR/JLO reporting chain OPA; OCA; OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. NO blog OR press release planned.

Oct 3 JLD/NRO/RES completes preliminary assessment JLD/NRO/RES/RIV of published report and management decision is made if any additional actions should be taken prior to the submittal of the seismic reevaluation in March 2015. Updates to communication plan as appropriate As requested Complete a Commissioners Assistants Brief R-IV; NRR

1. Questions and Answers What Is the impact of this new information on seismic design and licensing of DCPP?

Has the licensee entered this new Information into the corrective action program and perfonned an operability evaluation?

In accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has entered the new preliminary seismic information into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.

In res.ponse to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:

"If during PG&E's ongoing collection of seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actiorns taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staff's March 12, 2012, request for information (Reference 2).

• Reference 2 is NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, wRequest for Information Pursuant to Title 1 O of the Code of Federal Regulations 50.54(f)

Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-I chi Accident,* March 12, 2012.

NRC !Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an 3

DRAFT - Ofl'ICIAL tlS! ONLY Sl!N91TIVI! n*Tl!IUML IN.. OftMATlON HOT l'Oft i-t1eue ftl!L!1<S!!

immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functionis.

In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay} continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

The NRC will review the new information provided in the report to the State of California including the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit the conclusions in the RIL.

2. Has OCPP provided the seismic report to the NRC?

Yes, in accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001, PG&E has provided the information to the NRC. In addition, the report was also provided to address license renewal issues (see question 8).

3. What does the new report state?

The new report includes information obtained from 2-dimensional and 3-dimensional high energy and low-energy seismic surveys both onshore and offshore of the OCPP site. The report provides more details on the regional faults, including more precise readings and additional data points where previously there were gaps. While a lot of the information from the previous Shoreline Fault report of 2011 was confirmed, some of the new data suggests the following:

Reduced slip rate on the Hosgri Fault Zone and the Shoreline Fault Zone Postulated connecting the Hosgri and the San Simeon faults which could result in a longer, larger, but more infrequent earthquake The unique geometry involved with intersecting the Hosgri Fault and the Shoreline Fault Zone results in an extension of a few kilometers, but with a lower frequency of occurrence Extension of the Shoreline Fault zone southern segment The new data does not alter the assessment of the closest approach of the Shoreline fault to OCPP which is 600 meters from the power block and 300 meters from the Intake structure. Because the Shoreline fault is considered to be somewhat longer, potential earthquakes could also occur farther from the plant.

Updated analysis for the San Luis 8,ay, and Los Osos faults The report concludes that the ground motions for the Hosgri and L TSP evaluations continue to bound potential ground motions from the regional faults, including the Shoreline Fault, San Luis Bay, Los Osos, San Simeon and f-iosgri. The DCPP continues to operate safely within the seismic margin they were designed to withstand.

4

DRAFT - Ol'l'telAL t:ISI! ONLY Sl!NSITl'J'I! lf4Tl!IU4AL 1141'09'MAT10N - N8T F8ft f'tl8tle ftftfA9!:

4. How wlll the AB 1632 seismic report be coordinated with the 50.S4(f) required submittal tn March 2015?

PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the OCPP.

{If pushed on any "unknowns" In the report: If necessary, actions could include orders to halt operations if new information suggests there is an immediate safety concern. The NRC will fulfill its mandate to protect public health and safety).

(If asked what things the plant has done since Fukushima: It is important to note that OCPP is an industry leader In implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).

5. Why is the report "final" for the state but "preliminary" for the NRC?

For the State, the report is final. For the NRC. this information is expected to be incorporated into the more comprehensive 50.54f analysis due to the NRC in March 2015.

However, because the licensee must notify the NRC of any new seismic info. they have shared this report and an initial operability evaluation showing why the plant is safe to continue to operate. The NRC has looked at the information in the report and its preliminary assessment is that based on the information presented by PG&E the new information associated with Faults near OCPP does not result in ground motions above those from the previously considered seismic hazard.

6. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault in 2011 prior to Issuing the RIL?

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station. to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 report.

The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analyses which is due for OCPP in March 2015.

7. What Is the impact of this new information on seismic design and licensing of OCPP?

Based on the preliminary results of the studies that are under review, PG&E determined that 5

DRAFT - Ofl*ICIAL tJ9! ONLY 9ENS1fPIE INff:RNAL INF0RMA'ifl0N _,.e, 1'6ft f'tJBUe ft!t!)Pc!E the Shoreline Fault Zone may be capable of producing somewhat larger earthquakes than considered in the January 2011 Shoreline report. The NRC staff is independently assessing PG&E's determination. The process outlined in the 50.54(f) letter includes a detailed analysis of new seismic information (including shoreline faults and other faults arour,d the plant). PG&E is scheduled to provide this assessment m the March 2015 time frame. The staff will continue to review the information in the new CA 1632 report and the final riesults of the new data from the more rigorous analysis to be completed by March 2015. The NRC staff will take appropriate regulatory action up to and including issuing Orders to ensure safe operation of the plant

8. Will the Report be considered In the License Renewal Process Yes. In addition to the report being developed to address California Assembly Bill 1632, PG&E is providing the report to the State of California as part of the State of California coastal zone consistency certification associated with the license renewal for OCPP. The State of California coastal zone consistency certification is considered by the NRC during the license renewal environmental review process. In addition, the Atomic Safety and Licensing Board (ASLB) has expressed interest in the report because it is associated with a contention that is under consideration by the ASLB in the license renewal process (see ML14224A320).

6

from:

To:

Subject:

Date:

Philippe, 5dWl'iY, Jogpn

• ,oenen, PbiltPPe R" Info: basis for June 2017 SPRA date Tuesday, September 09, 2014 1:45:00 PM The basis for the June 2017 SPRA date can be found in the letter at the following link:

bttp* //pbadupws,nrc,goy/docs/ML131O/ML13101A345 html Specifically if you look at attachment 3 of the above link it gives you various time frames based on the results of the seismic reevaluation. Based on prioritization the SPRA submittal schedule could be as early as June 2017. As noted in the table there is a range of possible submittal dates.

Sorry for asking the question without first checking with the folks here. Let me know if you have any questions or if I am missing something.

Sincerely, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph.sebrosky@nrc.gov 301-415-1132

From:

To:

Cc:

Subject:

Date:

Atbchmentl:

Jennifer, Sgbrosky J05eph Vble, Jeno,fet:

Markley H!Ctw:I; PeSede Ertc: Lung, Louise Info: electronic version of draft project plan Tuesday, September 09, 201'4 12:21:00 PM PJablo State or Cahrorwa 5flsroic ceoort review Qtan tfYJ519D 1 docx Attached is the draft project plan that we discussed with you. It has links to ADAMS documents that are referenced. It is a work in progress and is continuously being revised.

Please let me know if you have any questions.

Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph.sebrosky@nrc.gov 301-415-1132

Project Plan for NRC Staff Review of PG&E's Report to the State of California Regarding Seismic Faults Near the Diablo Canyon Power Plant 9/9/14 Version NOTE: This Is a living document and will be updated as necessary. Please note the date on the cover.

Document Point of Contacts:

Joseph.Sebrosky@nrc.gov Nick.Olfrancesco@nrc.gov Japan Lessons Learned

TABLE OF CONTENTS Purpose of the Review of the State of California Report................................................................................ 2 Background................................................................................................................................................... 2 Products to be Reviewed................................................................................................................................ 4 Review Process................................................................................................................................................ 4 Review Team................................................................................................................................................... 6 Communication Plan....................................................................................................................................... 6 ll Page

PURPOSE OF THE REVIEW OF THE STATE OF CALIFORNIA REPORT This project plan documents steps necessary for NRC staff to quickly assess the information found in the report provided by Pacific Gas and Electric (PG&E) to the State of California related to Seismic Faults near the Diablo Canyon Power Plant (DCPP). The expected outcome of the assessment is a recommendation to management as to whether or not the NRC's processes associated with new seismic information as rt relates to Diablo Canyon and which are described in NR.C letters dated March 12, 20121. October 12, 20122, and February 20, 20143 should continue to be followed or if there is new information that suggests there is an immediate safety concern that would require action in accordance with established regulatory processes (e.g.,

Order).

BACKGROUND California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a maj,or disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future rote of these plants in the state's energy portfolio. The licensee has used the most state of the art seismic evaluation methodologies included 20 and 30 mapping to compile this report. This is a different and more extensive data set than what was used for PG&E's 2011 Shoreline Fault evaluation (ADAMS Accession No. MU 10140431).

Based on information that PG&E has verbally provided to the NRC, PG&E has indicated that the length, and magnitude of the Shoreline fault is greater than that assumed in a 2011 PG&E report provided to the NRC. PG&E has also indicated that the soil properties found in the 2011 report have also been updated based on new information It is the staffs prefiminary understanding that in addition to providing changes to the Shoreline fault characteristics that new information is provided in the State of California report relative to other faults in the area (e g., Los Osos, and San Luis Bay).

PG&E's operability evaluation, which is available to the staff, states the following:

Based on the preliminary results of the studies that are under review, it has been determined that the Shoreline Fault Zone may be more capable than summarized in the January 2011 report, but the deterministic response spectra are still bounded by those for the Hosgri and L TSP earthquakes.

The staff previous evaluation of the Shoreline Fault can be found in Research Information Letter (RIL) 12-01 "Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone" (ADAMS Accession No.ML121230035). The staffs deterministic evaluation includes several scenarios and resulted in the conclusion that the Shoreline Fault is bounded by the Hosgri and LTSP spectrum. The graph below is from the RIL.

As can be seen in the graph from the RIL the staffs magnitude 6.7 earthquake scenario is essentially equal to the Hosgri spectrum in the 20 to 40 Hz range. PG&E's assessment in the 2011 report was based on a magnitude 6.5 earthquake. Based on recent conversations with 1 The March 12, 2012, request for information is available under ADAMS Accession No. ML12053A340 2 The October 12, 2012, letter is available under ADAMS Accession No. ML120730106 3 The February 20, 2014, letter is available under ADAMS Accession No.. ML14030A046 ZI Page

PG&E they now believe that the Shoreline Fault is capable of generating a 6.7 magnitude earthquake. There are several differences in PG&E's assessment of the Shoreline Fault found In their 2011 report and the staffs assessment found in the RIL. The staff understands that PG&E believes that based on new information relative to the Shoreline Fault and soil properties in the area that Shoreline Fault deterministic ground motion response spectrum is still bounded by the Hosgri and L TSP spectrum.

The issue is the staffs review of the new information and whether the staffs deterministic evaluation in the RIL will be updated based on the new information or if an alternate approach will be used to assess the new information pending expected receipt in March 2015 of an assessment of new seismic information in accordance with the senior seismic hazard analysis committee (SSHAC) process outlined in the March 12, 2012, 50.54(f) letter.

2.!5 Hoec,I~

LTSPS.--

§ 2.0 NltC~7 * ""'

NltC~9-8'-,.

C

8 I.!

1.!5 j

1.0

~

0.5 u,

0.0 0.1 1

10 100 Frequency (Hz)

In addition, in the NRC's October 12, 2012, letter) transmitting NRC's review of the Shoreline Fault Report to PG&E (ADAMS Accession No. Mll20730106), the NRC placed its assessment of the Shoreline Fault in contex1 with the process outlined in the March 12, 2012 50.54(f) letter. The October 12, 2012 letter contained the following guidance relative to the discovery of new seismic information:

The NRC staff understands that the seismic evaluations described in the March 12, 2012, request for information are cuffently in progress at DCPP. and PG&E plans to acquire new offshore and onshore two-and three-dimensional seismic reflection data to identify and characterize faults In the vicinity of DCPP. If during the collection of the data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than cuffently believed, the staff expects that the licensee will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to compfetion of the evaluations requested in the NRC staff's March 12, 2012, request for information. The staff will use this information to independently assess whether the new fault or new information related to the Shoreline fault challenges or changes the staff's current position that the motions associated with the Shoreline fault are at or below those levels of the HE and L TSP ground motions.

PG&E has been informed that based on the NRC staffs understanding that the State of California report will contain new information relative to the Shoreline Fault, the NRC staff expects PG&E to 3I Page

provide an interim evaluation that describes actions taken or planned to address the higher seismic evaluation.

In performing this assessment the staff will also consider the supplemental information related to the March 12, 2012, request for information provided in an NRC letter dated February 20, 2014 (ADAMS Accession No. ML 14030AQ46). The February 20, 2014, letter includes guidance regarding operability and reportability. As stated in the February 20, 2014, letter:

• as always, the safety of the operating plants is of paramount importance. The NRC will follow established regulatory processes, including the backfit rule, in determining whether additional requirements are warranted."

Other Faults The PG&E 2011 Shoreline Fault report and the staffs RIL also discuss other seismic faults near Diablo Canyon including the Los Osos and San Luis Bay faults. It is the staffs preliminary understanding that PG&E's report to the State of California will also include new Information relative to these faults.

PRODUCTS TO BE REVIEWED PG&E report to the State of California relative to Seismic Faults near Oiablo Canyon PG&E's interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis REVIEW PROCESS Review time for this process should be charged to the following tac numbers:

MF4750, OIABLO CANYON 1 - Review Olablo Canyon Seismic Report Submitted to the State and Other Associated Activities MF4 751, DIABLO CANYON 2

• Review Oiablo Canyon Seismic Report Submitted to the State and Other Associated Activities The staff will review the new seismic information when it is provided the opportunity. Based on PG&E's preliminary description of the information 1n the State of California report, the staff originally considered assessing the new information in accordance with the process that has recently been used for Central and Eastern U.S. (CEUS) plants that ls found in a March 11, 2014, letter from EPRI (ADAMS Accession No. ML14083A586). The NRC staff provided a list of information needs to PG&E on September 3, 2014, in order to calculate a seismic core damage frequency consistent with the approach in the EPRI report. The NRC staff requested feedback from PG&E on whether or not the information could be provided to the staff in the September 2014 time frame. PG&E informed the staff in a September 8, 2014, phone call that PG&E would not be able to provide all of the necessary information to calculate a new seismic core damage frequency until March of 2015. The staff is therefore considering the following approach to review the new seismic information:

Perform a qualitative assessment of changes to the seismic core damage frequency based on a sensitivity analysis found in the State of California report that compares the new information to the PG&E's 2011 Shoreline Fault evaluation (ADAMS Accession No. ML110140431 ). Although a seismic core damage frequency cannot be calculated, a qualitative assessment of changes to the seismic core damage frequency discussed in PG&E's shoreline fault report maybe useful.

4 1P a g e

Perform a focused deterministic calculation using PG&E's new seismic information (including seismic fault and soil property changes) as inputs into a staff developed model.

The calculation could provide a limited updated ground motion response spectrum to be compared against the Hosgri spectrum. This calculation is limited in that it would not be a complete revision to the staffs deterministic evaluation captured in RIL 12-01, but it is thought the information the calculation could provide could be useful in developing a recommendation to management on how to proceed.

Determine whether or not an update to an assessment discussed in a May 29, 2014, NRC memorandum, "Differing Professional Opinion Involving Seismic Issues at Diablo Canyon (DP0-2013-002)," (ADAMS Accession Nos. ML14153A658, and ML14163A673) is appropriate. Section 4.2.1, "Technical Assessment of the Potential for Seismic Loads on SSCs to Exceed Previously Analyzed Conditions,* includes a discussion that PG&E calculated in-structure acceleration response spectra as the basis for comparison between the ground motions in the 2011 PG&E Shoreline report to the ground motions used in the updated final safety analysis report. The staff will inquire as to whether PG&E has updated this calculation based on the new seismic information in the State of California report.

The proposed milestones and timeframes for reviewing PG&E's report are as follows based on the assumption that the report will be publicly released on September 10, 2014.

Tlmeframe Action Responsible Status Party(les)

Sept 3 NRC staff identifies information that 1t will quickly NRC review complete need from PG&E to support a possible review In team accordance with the process found in the CEUS study above. PG&E will be asked to provide feedback on whether or not it can provide information by Sept 22.

Sept 8 PG&E provides feedback to the staff on whether or PG&E complete not it can provide information to the staff by Sept 22 to calculate a seismic core damage frequency. On September 8 PG&E informed the staff that this information would not be available until March 2015.

Sept 8 Key NRC review team members review the State of NRC review California report prior to its public release.

team Changes to the project plan and communication plan are identified Sept 10 PG&E provides report and interim evaluation to the PG&E NRC Sept 15 NRC identifies any additional information needs that NRC review it has to complete its preliminary evaluation team Sept 22 PG&E completes providing NRC staff with PG&E information necessary for the staff to complete its preliminary evaluation Sept 23 Publicly noticed phone call to discuss seismic NRC/PG&E issues Sept 29 NRC review team completes it preliminary NRC review assessment of new Shoreline fault information and team makes recommendation to management on how to proceed

Timeframe Action Responsible Status Party(les)

October 3 NRC management makes decision on how to NRC proceed management October 10 As appropriate, based on outcome of October 3 NRC decision, NRC provides letter documenting interim assessment of new seismic information in State of California report REVIEW TEAM The following are the proposed members of the review team subject to management approval NRR Projects: Eric Oesterle, Balwant Singal, Joe Sebrosky, Nick DiFrancesco NRR technical: Kamal Manoly, Yong Li NRO technical: Cliff Munson, Britt Hill, John Stamatakos (contractor)

RES: Jon Ake, Scott Stovall, Thomas Weaver Region IV: Wayne Walker, Theresa Buchanan. Megan Williams, Tom Hipschman COMMUNICATION PLAN A communication plan has been developed for the PG&E report. The NRC review team will update the communication plan based on its assessment of the new information.

6I Pagc

From:

To:

Cc:

Subject:

Start:

End:

Location:

Attachments:

setx osky Joseph stayafl Scott; Mup5an, Q1ttorg; w,111ams, Mroan; LU'.PllQI H1o::,cbmao, Thomas; wa1~er, wavoe; ~

~

Smgal, Balwant; Markley. N1d]aet*,lacksqn P@oe* Plfraoresco N1cho!as* Whaley Sheena: ~

LM1i Burnell Scptt, OKeete. Ned; FarQholtz. Thomas: Manotv. Kamal, Reynoso. John. H1 L BntWm; ~

MlalilCI; Buchanan. IlM:cesa: KQdt. MOcea

• wea:xer Jbomas Kanatas. catbeoru:: Rott(OGC>, Por*O internal meeting to determine if changes to the communication plan fOf' the Olablo Canyon State of California rePort need to be made based on a preliminary assessment of the report {Tac MF4750, MF47Sl)

Tuesday, September 09, 2014 2:00:00 PM Tuesday, September 09, 2014 3:00:00 PM HQ*TWFJf-07C02*20p pc Co11C seismic wt cqnm Plilo 2*2 11 rey1Sj0(] gpcx Qlablo State at Cali{orrna se,sro,c report cmew Qian cevtS120 1.oooc Note: SCheduler updated to Include latest revised version of the a>mmlKllc.atlon plan and project plan Prevtous update to sdleduler made to correct tac numbers In subjffl btle (I.e., please use MF4750, and MF4751 for review) and to change the agenda to add a discussiOn about whether or not II publldy notked phone call wUI be needed and changes to the project plan due to Information to calculate a seismic COl'e damaoe freQuency not being available In the short term.

Bridge, : 888-6n-09JO Pa~:! (b)(6) I

Purpose:

F°' a1rr ML11son, Megan wunams, Scott Sll>vall, and YOf\\O u, IX> i,r<M1e a a>lleclM! assessment on whedler or not changes to the draft a,mmunlc:atlon plan and dral'l project plan a$$OOaled l'liCl the Dlablo Call'fC)n Slllll! ot ~

repo,t neetJ lo be made based on their Q\\Jld\\ kl<* ll the report Outcome: IDeclslon made on whethtr or not c:nanges to communkallOn plan and project plan need to be made alff, Megen, Soott, and Yono. brief the team on their a~

of trie lnrorTna!Joo 1n U'le State of Oil ft>mla ~

Oeds1on made on whether or not d\\llngcs to the Cl)ffllllUlllCcon plan need tn be ma*

OISGUSsiOn of v.tiether or not a pubO(fy noticed phone all with PG&E Wfl be needed In "" September time frame

m. Dlsrusslon of c11anoes to project plan based on 1nf01mation needed II) ala.llate a selsmk an damage frequency not being available In the short term Olanges to pro,ea plain made to: 1) condense l)Ul1IC)Se, 2) change review Pf0Cle$$ sedlOn reoogntung the that se!Smk c:ort dlll'T\\8!lf' freQi.lellC( camot be calculated tn tile st10ft berm, 3) add Ole possibiltty of a ~

nodced phone a.II IW1>und mlO* 5eptember, and 4) other mtscdaneous <flanges

DRAFl - el'l'telAL ~91!! eNLY 9EN91l,V'I!! n*,r:~HAL 1r.,e~MA"f let* - f111Nlfl01"1T"1f'lll0"1t"IHll'fi~~8ttt'tflC'!-tt~

...... l!!~A*'9"'1!!~

UPDATED:

09/25/2014 3;29 PMOf,'Q@fiQ14 8:&4 AMQ8f98'c014fi4f Al109!08/ic>14 8;0 AM

Background

Communications Plan -

Oia1bto Canyon Power Plant Topics of Interest State of California Seismic Report fABN-1632}

California Assembly Bill 1632 (Blakeslee, Chapter 722, StaMes of 2006) directs the California Energy Commission to assess the potential vulnerability of Callfom1a's largest baseload power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event 0< plant agmg, to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants, and to evaluate other major issues related to the future role of these plants in the state's energy portfolio The licensee has used the most state of the art methodologies using 20 and 30 mapping to compde this report This 1s a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.

The purpose of this communication plan is to provide key messages associated with the public release of this report.

Key Messages NRC staff ts lotimately famiHar with the seismic hazaros at Diablo Canyon and our seismic experts have been looking at this in detail tor many years

_* _The resident lnspectOnceming DCPP seismic and licensing bases that the Shorefine fault may be more capable than previously determined. The information did not indicate there is an immediate threat to public health and safety nor did It call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions The licensee's current actions meet the Manual Chapter 0326 guidance for having reasonable assurance of operability, pending further evaluation.

• Based on a preliminary review of PG&Es seismic reoort by NRC staff. there II no new information to suggest that there 1s an immediate safety concern The seismic report does contain a iot of new mrormation that the NBC oeedS to look at in more detail and put through our analytical models to more auantitatrvely refine our understanding of the seismic hazards

DRAFT - 01',tCblct tl!e OMLI 9!!NSITI\\'!! lrff!!IU4AL INl'OIU¥11'1el* - Het re" l"~et1e ft!!L!!A!!

The NRC w~I continue lo review the new information in the report and will take add1t1ona1 regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit its preliminary evaluation.

-Diablo Canyo1 will incorporate the Bill 1632 report's information,nto its March 2015 seismic hazard re-analysis submittal to the NRC.

Communication Team The primary responsibility of the communication team 1s to ensure tnat it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/ORP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195 Thomas Hlpschman Sr. Resident Inspector -

R-IV/DRP/RPB-A 805-595-2354 DCPP John Reynoso Resident Inspector -

R-IV/DRP/RPB-A 805-595-2354 OCPP Jon Ake Senior Seismologist RES/DE/SGS EB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Slngal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Dricks, Public Affairs Officer RIV 817-200-1128 Lara Useldlng Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Elaine Keegan License Renewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DiFrancesco Japan Lessons Learned JLD 301-415-1115 Planned Communls:atlon Actlyltltt 2

DRAFT

• o,,.elillt. t,S! C,Nt:'l' 9!f.191TII! IN,!IU4AL INl'O,.,MMIC,14 -,.e, l'e" l't,ISLIC ftl!t!AS!

The contents on this communication plan, supplemented by information provided by PG&E/Oiablo Canyon. should be used to accomplish these actions The table below is based on a target public release date of the report on September 10, 2014.

Tlmeframe Action Rnponaible Party(iea)

Septa PG&E provides a draft of the report In the PG!..E electronic reading room for inibal $lafl assessment Sept9 PG&E notifies NRC of seismic report submittal to PG&E the stale of Califomia Sept 10 PG&E/Diablo Canyon Power Plant submit seismic PG&E report to the slclte of California arid issue a Pf8$$

release Promptly Region IV notifies the Communications Team of R-tv/RPB-A (within Sept PG&E's actions as currently understood and 10+1 business implements the Communications Plan day)

Entirety of Communications Team nobfies R-IV; NRR/DORL; applicable Senior Managers in lhetr respectrve NRR/OLR; NRR/JLO rePOrtina chain OPA* OCA; OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. NO blog OR press release planned.

Oct 3 JLD/NRO/RES completes preliminary assessment JLO/NRO/RES/RIV of published report and management decision Is made if any additional actions should be taken prior to the submittal of the seismic reevaluation in March 2015 Updates to communication plan as appropriate As requested Complete a Commissioners Assistants Brief R-IV; NRR

1. Qu91tlon1 and An1w11J What Is the Impact of this new informaUon on Hlsmlc dHlgn and llcenslng of DCPP?

Haa the llc.enaff enwred thla new Information Into the correcUve action program and perfonned an operability evaluation?

As required by the NRC. as documented 1n RIL 2012-001, PG&E has entered the new preliminary seismic information Into their correctJve action program The results of the study are used to assess the impact on the current design and licensing basss of DCPP.

In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC*

• u during PG&E's ongoing collection of seismic data, rew faults are discovered or information Is uncovered that would suggest the Shoreline fault,s more capable than currently believed, PG&E will provide the NRC with an intenm evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information (Reference 2)." Reference 2 1s NRC letter to All Power 3

DRAFT - Ol'l'ICIAL tlS!! eNL'f 9EN9ff ri1E IHfEIUf.-t lNF8RM,C"8N - t111N~c..

,...,.lf0""...

""""'B11-LWIC~ft'""I! l%~M,

~ 1!~

Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request tor Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(0 Regarding Reoommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accidenl" March 12, 2012.

The resident inspectors and regional staff reviewed the 6censee's documentation in their corrective action process of new preliminary Information concerning OCPP seismic and licensing bases that the Shore!ine fault may be more capable than previously determined. The information did not indicate there is an Immediate threat to public health and safety nor did 11 can into question the abllity of SSCs to perform their speeffied safety functions or necessary and related s-upport functions Toe licensee's current actions meet the Manual Chapter 0326 guidance for having reasonable assurance of operabilrty, pending further evaluation.

The NRC will review the new information provided in the report to the State of California including the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit the conclusions In the RIL

2. Hae OCPP provided the seismic report to the NRC?

The new information, required by the state of CA AB 1632, has been provided to the NRC and shows that some previously separated segments of the Shoreline fault system may be connected. These connections indicate that if the Shoreline Fa ult slips in the future, the earthquake magnitude from that slip might be somewhat higher than previously considered possible for the Shoreline Fault. However, the new data does not alter the assessment of the closest approach of the Shoreline fault to the DCPP. Because the Shoreline Fault is somewhat longer, potential earthquakes could also occur farther from the plant. For these reasons, PG&E continues to believe that the ground motions for the Hosgri and L TSP evaluations continues to bound potential ground motions from the Shoreline Fault

3. How will the AB 1632 seismic report be coordinated with the 50.S4(f) required submittal In March 2015?

The 1000-page document has also been given to the NRC (Japan Lessons Learned Directorate) to be considered in the 50.54(f) review. The new preliminary information regarding regional seismic source characterization (I.e. fault capability) and potential site ground motion will be evaluated in accordance wrth the process defined by the NRC in their Fukushima 50.54(f) letter. This requires an NRC-endorsed formal structured process to evaluate alternative interpretations when developing the final seismic hazard and Ground Motion Response Spectra (GMRS) that will be submitted to the NRC by March 2015. The updated seismic hazards will be used as an input to any Seismic Probabilistic Risk Assessment (SPRA) Diablo Canyon might have to submit to the NRC by June 2017.

(If pushed on any *unknowns* in the report: If necessary, actions could include orders to halt operations If new information suggests there is an immediate safety concern. The NRC will fulfill its mandate to protect public health and safety).

(If asked wtrat things the plant has done since Fukushima: It is important to note that 4

eo.-t [Jmd]: 50.&4(1) lellel-QIYN 3 )'9ffl lo do tlda w!*:11 would be Msdl 2018. Whal ii h be,11 for th9 J.,,. 2017 data?

DRAFT - or, ICIAL t,S! Olft I 91!N~m*tv! lfff!"NAL lf4P'e"MA'fleN - lfeT ~

rt,19LJC ~t!!AS!

OCPP is an Industry leader in lmplemenbng FLEX which was a post-Fukushima indus.t,y lnltlatiVe to have extra e(lulpmenl available remocely In the event cl a beyond design basis event),

4. Why la the report "ftnaf' for 1he state but "preliminary'" for the NRC?

For the state. the rel)Oft 1s final. For the NRC. this information is e,cpected to be incorporated Into the more comprehensive 50.54r anatys1s due to the NRC In March 2015. However, because the licensee must notify the NRC or any new seismic 1nro, they have shared tt11s report and an initial operabihty evaluation showing why the plant Is safe Ix> operate The NRC has looked at this evaluatton and its prehmmary assessment,s that based on the infoml3tion presented by PG&E the Shoreline Fa~t does not exceed prevlou$ty considered seismic hazards.

6. Why didn't the NRC diacover the i.ngth of the faults when It did Im aelamlc 1'9Vlew of the Shorellne fault In 2011 prior to Issuing the RIL?

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerabdity of California's largest base-load power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station, to a major disruption due to a seismic event or plant aging, to assess the impacts of such a disruption on system reliability, pl.bllc safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio The licensee has used the most state-of-the-art 20 and 30 geophysical mapping technrques, which are commonly used In offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault 1n the 2011 report.

The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analysis which is due ror OCPP in March 2015.

6. What It tlhe impact of thlt new lnfonnation on aelamlc dealgn and llcen1lng of OCPP?

Based on the prelrminary results of the studies that are under review, PG&E determined that the Shoreline Fault Zone may be capable of producing somewhat larger earthquakes than considered in the January 2011 PG&E report. The staff 1s independently assessing PG&E's determination. The process outlined in the 50.54(1) letter includes a detailed analysis of new seismic information (including shoreline raurts and other faults around the plant) PG&E is scheduled to provide this assessment in the March 2015 tune frame. The staff Is currently reviewing the Information in the Shoreline fault report and will assess the more complete assessment of new seismic information scheduled to be provided in the March 2015 time frame. The NRC staff WIii take appropriate regulatory action up to and including issuing Orders to ensure safe operation of the plant

7. WIii the Report be considered in the License Renewal Process Yes. In addition to the report being developed to address California Assembly Bill 1632.

PG&E IS providing the report to the State of Cabfomla as part of the State of Cahfom1a coastal zone consistency certification associated with the license renewal for OCPP. The 5

DRAFT - Of'l'telAL t:131! eNL'I sr.m,i,,ve llffl!fUIAt,,,,.e,.M1cT1e1* - """ reR l't18Ue ft!L!Ase State of California coastal zone consistency certJfication Is c:onS!dered by lt-e NRC dut'lng lhe license renewal environmental rev,ew process.- In addition, the Atomic Safety and Licensing Board (ASLB) hu expressed interest tn lhe report because rt 1s a"ooated with a contention that is under consideration by the ASLB in the Ucense renewal process (see ML14224A320}.

8. The AP wire Hr.lice recentty reported that there 11 a Differing ProfeHlonal Opinion

{DPO) 1noclated with NRC'1 evaluaUon of the Shoreline Faull Why h.. the Histence of thl1 DPO only now bMn made pubflc?

The OPO process Is a strictly controlled and formahzed process wrth1n the agency that allows differing professional opinion$ to be thoroughly considered by the agency while at the same time protecting the privacy of the DPO submitter A DPO was submitted and is still undergoing internal NRC review In accordance with this process. Unbl the NRC completes its internal review process for this DPO, the agency is unable to comment on any potential DPO resolution or documentation. Once the review Is completed the agency will have a final decision on the DPO and associated documentation 6

From:

To:

Subject:

Date:

Joe, Sococc Pblliaae B Sellfos~x JQ5CQh PG&E attendees on phone call Monday, September 08, 2014 1:08:30 PM Below is a list of individuals from PG&E who participated on the phone call:

Rich Kllmczak Nozar Jahangir Norm Abrahamson Philippe* Soenen Phthppe Soenen Supervisor, L1cens1ng Regulatory Services

• DCPP Office - 805.545 6984 Cell 1 (b1(6l

From:

To:

Subject:

Date:

Sebroslcy, Josef>h Munson. Chfford FW: Access requests Monday, September 08, 201" 2:.. 7:00 PM

---

Original Message-----

From: Soenen, Philippe R [majlto:PNS3@pge.com]

Sent: Monday, September 08, 2014 2:15 PM To: Sebrosky, Joseph

Subject:

Fwd: Access requests

Joe, Cliff should have received the new login information.

Philippe Soenen Sent from my iPhone Begin forwarded message:

From: Dale Lawson <dale.lawson@certrec.com < rnaUto:dale.lawson@certrec.com > >

Date: September 8, 2014 at 11:04:32 AM POT To: Philippe R Soenen <pns3@pge.com<ma11to;pns3@pge.com>>

Subject:

Access requests I have sent Munson a new verification code email as well as an email to Stoval regarding his access.

Stoval already had a Certrec account and he should be able to access your site with his credentials. I have asked him to oontact: me if he's having any difficulties doing that.

As soon as Munson receives his verification email and logs in he will have access as well. Please let me know If there Is anything else I can help you with. Thank you and thanks for using Certrec for your regulatory needs.

Dale Lawson Customer Support Specialist II Certrec Corporation 4150 International Plaza, Suite 820 Fort Worth, TX 76109 P: 817-738-7661 F: 866-635-1869 support@certrec.com< ma1lto*1tm>ct@certrec.com >

PG&E is committed to protecting our customers' privacy.

To learn more, please visit http://www.pge,com/about/company/onyacv/custorner/

From:

To:

Cc:

Subje<t:

Date:

Megan, Sebrosky, Joseph wm,aros Megan

\\YAlket, Wayne FW: DCPP EledTonlc Readi119 Room Monday, September 08, 2014 1:04:00 PM Cliff and Scott are having troubles accessing the site. I will keep you informed of the resolution for them. In the interim, please let me know if you are experiencing problems accessing the site through certrec.

Thanks, Joe From: Soenen, Philippe R [mai1to:PNS3@pge.com]

Sent: Monday, September 08, 2014 12:59 PM To: Sebrosky, Josept,; Munson, Clifford

Subject:

FW: DCPP Electronic Reading Room Philippe Soeneo Supervisor, Llce11sing Regulatory Services - OCPP Office - 805 545 6984 eeu -I (b)(6)

I From: Dale Lawson [ma11to:dafe,lawsoncem:ec.mm]

Sent: Friday, September 05, 2014 7:22 AM To: Soenen, Philippe R subject: Re: DCPP Electronic Reading Room Good morning Philippe, Sorry for the delay in responding to your request. The 4 NRC individuals below now have access to the PG&E ERR site and all but Scon StovaJI have been notified via our system of their new access or account that was set up.

Scott Stovall -Already had access to Certrec and the PG&E site has been added.

Cliff Munson -Already had an account but never used his verification code to activate it. He's been sent another verification email.

Megan Williams - Did not have access but has now been sent the verification email.

Yong Li - Did not have access either but the email has been sent.

I will be sending Scott an email shortly to let him know. We are also working on ensuring they only have access to the Diablo Canyon library. At the moment they will have restricted