ML20141L710

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

ML20141L710
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: ML20141L710 (188)

Text

{{#Wiki_filter:access to both libraries but I have IT working on it to limit their access accordingly. For some reason the system is not allowing the capability like it should. I will keep you infonned of the progress on this. Thank you. 'DaCe Lawson Customer Support Specialist II Certrec Corporation P: 817-738-7661 support ~,,certrec.com From: "Philippe R Soenen" <PNS3@pge.com> To: "dale lawson" <dale,lawson@certrec,com> Sent: Thursday, September 4, 2014 10:12:18 AM

Subject:

DCPP Electronic Reading Room

Dale, Please provide access for the following NRC members to the DCPP Electronic Reading Room*.

Scott Stovall - scott,stovall (Znrc i:m Cliff Munson - c)ifford,munson(ci'nrc iilov Megan Williams - meiilan,wiHjamsr@lrc,i:ov Yong Li - YPOi: ,!Vi; nrc,i.:ov How are these individuals notified of their access? EspeciaJJy if these individuals already have Certrec access from through other sites (don't know if this is the case).

Thanks, Philippe Soenen Supervisor, Licensing Regulatory Services - DCPP Office - 805.545.6984 Cell - I (Dl1BJ l PG&E ~s committed to protecting our customers' privacy.

To learn more. please visit http://wwwpge.com/about/company/privacy/cusmmer/

From: Sebroslcy, Joseph To: "Soeaeo Pb1112oe R": "Baldwlo Jboroas coceer CTRBt<<rooc,com> Cc: Qesterte. Enc

Subject:

RE: phone call with PG&E to discuss their ability to pr<Mde seismic lnfonnatiOn in the Sept 2014 time frame Date: Monday, Sept.ember 08, 2014 12:40:00 PM Attlchments: Request to provide feedbadc on ab hty to PIC>'dde Ptablo Canyon sessm,c 1nformahon by September 22 2014 rosa Philippe and Tom, Per PG&E's request the time for the call this afternoon has changed to 4:00 pm eastern (1 :00 pm pacific). Let me know if you have any questions.

Thanks, Joe

---

Original Appointment*----

From: Sebrosky, Joseph Sent: Monday, September 08, 2014 6:21 AM To: Sebrosky, Joseph; Munson, Clifford; Stovall, Soott; LI, Yong; Williams, Megan; Manoly, Kamal; Oesterle, Eric; Markley, Michael; Jackson, Diane; Kock, Andrea; Hipschman, Thomas; Walker, Wayne; Buchanan, Theresa; DiFrancesc:o, Nicholas

Subject:

phone call with PG&E to discuss their ability to provide seismic information In the Sept 2014 time frame When: Monday, September 08, 2014 4:00 PM-4:30 PM (UTC*OS:00) Eastern Time (US & Canada). Where: headquarters staff meeting In cliff munson's office (T

• 7D9)

Note: Scheduler updated to change time of call due to PG&E availability. The room location has also changed. Cliff and Scott will most like support the call from Cliff's office. The rest of the NRC headquarters staff will be calling in. Note that bridge number and passcode remain the same. If you are not one of the people listed below please let me know that you plan to participate. Currently, I believe the following will participate in the call: Cliff Munson (NRO), Scott Stovall (RES), Wayne Walker (RIV}, Megan Williams (RIV), Eric Oesterle (DORL), and Joe Sebrosky (DORL). Tom Hipschman (SRI) may also participate. If you wish to participate and you are not on the list please let me know - Thanks, Joe A bridge line has been established. Bridge # : 888-677-0690 Passcode: j tbJ(6l

Purpose:

Phone call with PG&E to discuss PG&E's ability to provide additional

seismic information in the September 2014 time frame Outcome: Staff has a clear understanding of what information PG&E can provide in the short term and what information can be provided in the longer term Agenda: I. Background

a. Staff provided following email identifying 6 possible information needs in the short term II. PG&E to discuss which information can be provided in the near term and which items are longer term items Ill. Next steps IV. Wrapup

l'rom: Sebroskv, Joseph T OI Myn50n Cl!f{ord* stoyau Scou

• L....1Qog; Wdhams Megan* Haoolv, K,ama1; Oesterle Enc; MarklCY, M1rnac1; Jackson. oaoe; Kock, Aodu:,; N*QSChrNo, Thoma:;; Walker, wavnc; Buchanan, Jb<:resa* PtE@ocesco, N,ct1oias

Subject:

phone call with PG&E to disa,ss their ibillty to provide selsmiC inform,t,on In the Sept 201'4 time frame Start: Monday, September 08, 201'4 '4:00:00 PM

!nd:                       Monday, Set)tember 08, 201'4 4:30:00 PM Location:                  headquarters staff meeting In drff munson*s o~ (T* 709)

Attachment.: Reaves to proy,de f<:edback on ab,ny to woy,ae 01ab1o Canyon seisrnK: mtoanabQQ by September 22 2011 msa Note: Scheduler updated to change timed cal due to PG&E avallabillty. The room location has also changed. a,ff and Scott will most llke support the can from Oiff's office. The rest of the NRC headquarters staff wlH be calling In. Note that bnclge runber and passcodc remain the same. If you are not one of the people hsted below please let me know that vou plan to participate. Currently, I belleve the foUowtng will participate In the call: Clff Munson (NRO), Scott Stovall (RES), Wayne Walker (RIV), Megan WIiiiams (RIV), Eric Oesterle (DORL}, and Joe Sebrosky (DORL). Tom Hlp.schman (SRI) may also participate. If you wish to participate and you are not on the list please let me know - Thanks, Joe A bridge One has been establlShed, ltrldge * : 888*677*0690 l>*sscode=I ,b)(6) I PIJrpose: Phone call With PG&E to d1SCUS$ PG&es abllltV to Ol'Ql.'-'e addibooa. seismic Information In the September 201'4 bme rra,,.,e OUta>me: Staff rias a dear understandlno d what 10formMJOn PG&E on pttMde In lhe short tA!tffl and what lnfofmat:lon can be l)rOVlded In the loogt, term Agenda: O&ckground Staff prc,,.,ld<<! follo.vlno emaB ldentttymq 6 PoSslble 1rtolfflltlon rieed's 1n the short twrn II. PG&E to dlsruss which Information c.an be providecJ In tl'le near ll!fm and whdl items are loog!r term items

m. Ne>rt: steps IV. Wrapup

From: Sebrosky. Joseph Sent: Wednesday. September 03, 2014 10:43 AM To: 'Soenen, Philippe R'; 'Baldwin, Thomas (OCPP)' Cc: Walker, Wayne; Hipschman, Thomas; Oesterle, Eric; Singal, Balwant

Subject:

Request to provide feedback on ability to provide Oiablo Canyon seismic information by September 22, 2014 Categories: non hearing material Philippe, and Tom, The purpose of this email to request whether or not you will be able to provide potential Information needs to assess new Diablo Canyon seismic information by September 22, 2014. Please note this is not a formal information request. The NRC intends to review new seismic information when it becomes available. After review of the new information the questions will be revised as appropriate and formally sent to you. In order t_o plan NRC's review, the staff needs to understand your ability to provide the information below in a timely manner.

1) As part of PG&E's report to the State of California, have updated control point (where the main power block is founded) seismic hazard curves been developed for DCNPP that reflect the new information concerning the Shoreline Fault as well as other faults in the region?

2) What is the slip rate of the Shoreline Fault based on the latest studies?

3) Is the lncrea*se in maximum magnitude estimate for the Shoreline fault based solely on a longer length estimate or on .a change in seismogenic depth as well?

4) The IPEEE results for DCNPP indicate a PGA HCLPF value of 1.56 g. Provide the spectral shape used in the estimate of the plant-level HCLPF capacity.

5) What combination of spectral frequencies were used to compute the seismic core damage frequency (SCDF) estimates cited in Section 6.9 of the Shoreline report?

6) Provide shear wave velocity profiles, shear modulus and damping curves, and small strain damping values (kappa) used for the development of Site Amplification Factors.

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

From: Sebrosky, Joseph To: *5penen. Ph1hppe R": "Bafdw,a. Thomas (QCPPJ" CTBBl(tooe cpml Sub~ 1 Info: phone call with PG&E to discuss their ability to provide setsmlc information In the Sept 2014' time frame Date: Monday, September 08, 2014 7:14:00 AM Altllc:timentl: Rgoucst 10 oroy,dc fl:1:dbacJs on ab14y to PCPYJd<: 01ab1g (anyoo seismic 1nrormauoo bv seatcmbec 22 2011.msa Philippe and Tom. Below are the details for the subject call today. The proposed time for the call is 2:00 pm eastern. 11 :00 am pacific. Please let me know if this time is acceptable . Sincerely, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph.sebrosky@nrc.gov 301 -415-1132

• • • • • Original Appointment** ***

From: Sebrosky, Joseph

Subject:

phone call with PG&E to discuss their ability to provide seismic information in the Sept 2014 time frame When: Monday, September 08, 2014 2:00 PM-2:30 PM (UTC*OS:00) eastem Tlme (US & Canada). Where: HQ*1WFN* 10C01*1Sp A bridge line has been established. Bridge #: 55483 Passcode~,__~_i_ui_ t~~~-'

Purpose:

Phone call with PG&E to discuss PG&E's ability to provide additional seismic information in the September 2014 time frame Outcome: Staff has a clear understanding of what information PG&E can provide in the short term and what Information can be provided in the longer term Agenda: I. Background

a. Staff provided following email identifying 6 possible information needs in the

short term II. PG&E to discuss which information can be provided in the near term and which items are longer term items 111. Next steps IV. Wrapup

From: Sebrosky, Joseph To: Manoly. Kamal Cc: .Ll....)'.gag_; <>estedc Er c

Subject:

FW: Into: A re<iuest has been made to PG&E tnat vou be provided to the State of caliromia reJ)ort on 9/8/14 Date: Monday, September 08, 2014 7:07:00 AM Attachments: oc caht seismic rot comm otaa B-22* M CIM$!90,docx 01an10 sr.ate or cahrom1a se1srotc ceooa review 01an cev@ol ,QQCX Kamal, Can you give me a call when you get a chance. I just received an out of office reply indicating Yong is out this week. As long as Cliff, Scott and Megan are taking a quick look at the report I think we are OK. You need to tell me ASAP if DE needs to look at the report and if so who it should be. Any insights would be appreciated. Thanks, Joe From: Sebrosky, Joseph Sent: Thursday, September 04, 2014 10:35 AM To: Stovall, Scott; Munson, Oifford; Williams, Megan; LI, Yong Cc: Hlpschman, Thomas; Walker, Wayne; Oesterle, Eric; Singal, Balwant; Markley, Michael; Jackson, Diane; OKeefe, Nell; Useldlng, Lara; DIFrancesco, Nicholas; Whaley, Sheena

Subject:

info: A request has been made to PG&E that you be provided to the State of califomia report on 9/8/ 14 Scott, Cliff, Megan and Yong, The purpose of this email is to inform you that the process has begun to get you access to the State of California report on 9/8/14 and to identify near term steps in the process. PG&E has been requested to provide you access to the State of California report on 9/8/14 through the certrec electronic reading room (ERR). You will be able to view the document but will be unable to print or download the information. The following is information relative to the review:

• The tac to charge to this effort is MF4720, and MF4721 , Diablo 1 and 2, *Review Diablo Canyon Seismic Report Submitted to State of California and Other Associated Activities."
• The purpose of the preliminary review is to identify changes that need to be made to the attached draft communication plan and project plan ahead of the public release of the document on 9/10/14
• You will be notified via email when the information is available in the certrec ERR by Philippe Soenen of PG&E o PG&E is not sure what time of day the information will be made available (I hope to get clarity on this) o PG&E is making arrangements for the State of California to also be granted access around the same time we are granted access

o PG&E is still targeting public release of the document on 9/10/14 (again they are not sure what time of day this will be done)

• I will send you a scheduler for a meeting on the afternoon of 9/9/14 so that you can collectively provide your preliminary assessment to key NRC personnel of the information and provide a recommendation on whether or not changes to the communication plan are needed (Note: I am fundamentally assuming that if you need to confer with each other you will pick up the phone and talk to each other prior to this meeting)
• I will send you a scheduler for a meeting on 9/15/14 to discuss our more detailed (still preliminary) assessment of the report. In accordance with the attached project plan confirmation of the information that we need from PG&E in order to provide a recommendation to management is to be done on 9/15/14. Cliff suggested that the technical staff meet on 9/15 to collectively discuss their assessment of the report.

Please let me know if you have any questions about the above.

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

DRAFT - eir'1elAL tf9! eM:\ 91!H91TIVI! INn:,ufAL IN..OIUMTION - NOT l"eft ..~eue PU!~! UPOATEC>: 09125/201* 3:32 PM Communications Plam-Dfablo Canyon Power Plant Topics of Interest State of California Seismic Report (ABN-1632)

Background

California Assembly 81111632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerabihty 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, pubttc, safety, and the economy; to assess the costs and impacts from nuclear waste accunulatlng at these plants. and to evaluate other ma)OI' issues related to the Mure 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 1s a different and more extensive data set than what was used for the 201 1 Shoreline Fault evaluation. The purpose of this communication plan 1s to provide key messages associated wrth the public release of this report. Key Messages

• The resident Inspectors and regional staff reviewed the licensee's documentation In their corrective action process of new preliminary infamabon concerning OCPP seismic and licensing bases that the Shoreline fault may be more capable than previously determined. The information did not indicate there 1s an immediate threat to public healtln 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 clXt'ent actions meet the Manual Chapter 0326 guidance for having reasonable assurance of operability, pending further evaluation
• The NRC wdl contmue to review the neN lnformatiOn In the report and w,11 take addrtlonal regulatory action as appropriate 1f the NRC staff concludes that the new infonnation associated with the Shoreline Fault causes the NRC to revisit Its preliminary evaluation.
• Diablo Canyon wlll lncorporato the Bill 1632 report's Information Into its March 2015 seismic hazard re-analysis submittal to the NRC.

DRAFT - Ol'l'ICllltl t,SI!! ONL I S!NS"rt'I! llfTl!PUf>IIL IHl'O"MJlcTION - HOT re" l'tlBtle "!1.891! Communication Team The primary responsibility of ttle communication team 1s to ensure that 1t conveys a consistent, accurate, and timely message to all stakeholders. The team conSlsts or lhe prqed management, technical, and commun1catJon staff named below Team Member Position Organtutlon TelephorMt Wayne Walker Branch Chief R-IV/ORP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/ORP/RPB-A 817-200-1195 Sr. Resident Inspector - Thomas Hipschman R-IV/ORP/RPB-A 805-595-2354 DCPP Resident Inspector - John Reynoso R-IV/DRP/RPB-A ~595-2354 OCPP Jon Ake Senior Seismologist RESIDE/SGS EB 301 -251-7695 Eric Oesterle Acting Branch Chief NRR/IDORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/IDORULPLIV 301-415-3016 Scott Burnell Pubhc 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 BIii Maler State Liaison Officer RIV 817-200-1267 Elaine Keegan License Renewal NRR/OLR 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 mformabon provided by PG&E/Diablo Canyon. should be used to acx:ompbsh 1hese actions. The table below is based on a target public release date of the report on September 10, 2014. Tlmeframe Action RHponalble Party(ln) Sept8 PG&E provides a draft of the report In the PG&E electronic reeding room for Initial staff assessment 2

DRAFT - M"l'!Cb\L t19! ONLt 9!1491Tl't'l! 114T!IUOcL 1141'0ftM>\TION - 140f .-Oft l'tjl!LIC ft!te119! Tlmeframe Action Re&ponsible Party(les) Sept9 PG&E notifies NRC of &e1smic report submittal to PG&E -Sept 10 the state of Califorma PG&E/D,ablo Canyon Power Plant submit se1smlc PG&E tePort to the state of Callfomia and tssue a press release Promptly Region IV notifies the Commun,callons 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 Commun,cat,ons Team notlfies R-IV; NRR/DORl; applicable Senior Managers in their respect,ve NRR/DLR, NRR/JLO reoortinQ 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 reevaluabon ,n March 2015. Updates to communication plan as appropnate As reQuested Complete a Comm1Ssioners Assistants Brief R-IV; NRR

1. auestlonund Answers What It the Impact of 1h11 new Information on Mltmlc dttlgn ind llcentlng of DCPP?

HH lhe llcen1N entered this new Information into lh* comctJve action pl'09ram and performed 1n operability ev1lu1tlon? As required by the NRC, as documented in RIL 2012-001, PG&E has e!lered 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 collect,on of se,sm,c data. neN1 faults are discovered°' information is uncovered that would suggest the Shorebne fault is more capable than currently believed, PG&E will provide the NRC with an interim evalua1ion 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 1s NRC letter to All Power Reactor Licensees and Holders of Construction Permits 1n Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulaltons 50 54(f) Regarding Recommendations 2. 1, 2.3, and 9.3 of the Near-Term Task Force ReVl8W of Insights from the Fukushima Dai-lch1Accident; March 12, 2012. The resident Inspectors and regional staff reviewed the licensee's documentation In their corrective action process of new preliminary information concerning DCPP seismic and 3

DRAFT - el'l'tetAL t:191! eNLt 91!H9rrr.-i! llfTl!9'1fAt 1N,e9'MA?te1* - **e, ,e,.. ,t1at1e M!t:eASI! ficensing bases that the Shore~ne fault may be more capable ~n preV10usly determined The tnformatlon did not indicate there Is an unmedaate threat to public health and safe,y nor dld It call into question the abttlty of SSCs 10 perform their specified safety functions or nec:.essary and related suppcrt runcuons The 1rcensee's current aeuoos meet the Manual Chapter 0326 guidance for haV1ng reasonable assurance of operabtli!Y, pending further evaluatlon The NRC wm review the new information provided in the report to the State of Cahfo,nia lndudlng the Shoreline Fault characteristlCS, and the updated charactenstics asaoaated wi1h the soll properties near the site. The NRC staff WIU take aoditlonal regula\OfY ICtlOn as appropriate if the NRC staff ooocludes that the new Information associated with the Shoreline Fault causes the NRC to revisit the oonclusions in the RIL

2. Has DCPP provided th* Hl1mlc report to th* 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 Sh0reline Fault 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, potentJal earthquakes could also <>CCIX farther from the planl For these reasons. PG&E continues to believe that the ground motx>ns for the Hosgri and LTSP evaluations continues to bound potential ground motions from the Shoreline Fault

3. How will the AB 1632 sel*mlc report be coordinated with the 50.54(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 with 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 Respoose 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 submrt to the NRC by~ 2011t . _- ~ (jllld]: 50 54(1) ....r glvtl 3 Y'N IDdolllle-wouldl>e....,,20111. WIWII the beM br the JIM 2017 dale? (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 concem The NRC will fulfill its mandate to protect public health and safety) (If asked what things the plant has done since Fukushima* It 1s 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 11 the report "final" for the 1tate but "preliminary" for the NRC?

For the state, the report is final. For the NRC, this information is expected to be incorporated 4

DRAFT - el'l"ICI~ tl!II! eHt I S1!f.9tfl'W'I! n*T!IU.,tct IHl'eftMA?leH - HeT P'eflt l'tll5UC ftl!l!'A91! into the more COl'T'lprehensive 50.54f analysis due to the JNRC in Mardi 2015 However, because the licensee must notify the NRC of any new se1sm,c 1nfo, they have shared this report and an inlbal operab1l,ty evaluation showlllJ why the plant 1s safe to operate,. The NRC has looked at th s evatuauon and Its prelmtnary assessment is ttlal based on the informabon presented by PG&E the Shorehne Fault does,. not exoeeo previousfy considered se,smic hazards.

6. Why didn't the NRC discover the length of the faults when It did Its seismic ,-view of the Shoreline fault In 2011 prtor to l11ulng the RIL 7 California Assembly Bill 1632 (Blakeslee. Chaptei 722, Stat~.es of 2006) d irects the California Energy Commission to assess the potential vu1nerab1hty of carlfomia'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 tmpacts 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 maior issues related to the Mure role of these plants in the state's energy portfolio. The licensee has used the most stale-of-the-art 20 and 30 geophysical mapping techniques. whteh are commonly used in offshore petroleum resource exploration These techniques provide higher-resolution data than what was available to Charactenze the Shoreline Fautt 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 analysis whieh is due for OCPP in March 2015.

6. What ia the impact of this new Information on seismic design and licensi ng of OCPP?

Based on the prelminary results of the studies that are under review, PG&E detemuned that the Shoreline Fault Zone may be capable of produong somewhat larger earthquakes than considered in the January 2011 PG&E report The staff 1s independently assesS1ng PG&E's determination. The process outlined 1n the 50 54(f) letter mdudes a detailed analysis of new seismic information (including shoreline faults and other faults around the plant). PG&E Is scheduled to provide thtS assessment in the Mareh 2015 ltme 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 1n the Mareh 2015 time frame. The NRC staff wil take appropriate regulatory action up to and including Issuing Orders to ensure safe operation of the plant

7. WIii the Report be considered in th* License Renewal ProcNs Yes. In addition to the report being developed to address California Assembly Bin 1632, PG&E is providing the report to the State of California as part of the State of California coastal zone consistency certif1C&t10n associated with the hcense renewal for DCPP. The State of California coastal zone consistency certification 1s 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 1s under consideration by the ASLB in the hcense renewal process (see ML14224A320).

5

DRAFT - OPmtl'Ct t:l!e ONli 91!!NS"r.'I! llfff1U4"L INPeRW.fleH - 14M reft ftt:119Lte M!tr"S!

8. The AP wire service recentty reported that there fs a Dfffering Professi onal Opinion (DPO) a,oclated wfth NRC's evaluation of the Shoreline Fault. Why has the exl1tenoe of this DPO only now been made pubttc?

The DPO process is a sttlctly controlled and fo,maliz.ed prooess wtth,n the agency that allows dlffenng professional opinions to be thoroughly consid<<ed by the agenq while at the same time protecting the privacy of the DPO submitter. A OPO was submitted and 1s slJII undergoing internal NRC review in accordance with this proce.ss Unbl the NRC completes Its Internal review process for this OPO. the agency is unable 10 comment on any potential OPO resolution or documentebon Once the M'lliew IS com!)leted tt,e agency will have a final decision on the OPO and associated documentationi. 6

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/ ~ / 14 Version NOT£: Thh Is I ltv1n1 document and will be updated as necesury. Please note the date on the cow,. OocumeM Point of Contacts: Joseph,5ebrosky@nrc.gov Nkk.Dlfrancesco@occ 1oy Japan Lessons Learned

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PURPO~E OF THE REVIEW OF THE STATE OF CALIFORNI A REPORT This project plan documents steps necessary for NRC staff to quickly assess the infonnation found in the report provided by Paclic Gas and Electric (PG&E) to the State of California related to Seismic Faults near the Dlablo Canyon Power Plant (DCPP). The purpose of the assessment Is to determine what, if any, changes need to be made to the approach outlined in 1.tM-March 12, 2012, request for Information Issued pursuant IQ 10 CFR 50,51(0 <see ADAMS Accession No, ML12053A340l The March 12 2012 request for mfonnalion proylCles a process for perfom,ing a seismic hazard reevaluat,on and to proytde the re,utts of this reeva1u111on to the sJaff Tbe staff w111 use this information to determine whether a ltcense should be mod1f,ed. suspended. or revoked In perrormmg 1h11 assessment !be staff w111 a1so consider the supp1ementa1,otormat100 related to the March 12, 2012. reauesl for infonnation provided ,nan NRC letter dated February 20. 2014 a&SeG1eled wilt! Rew &ei&mie 1Alo,mati811 (eoe Jl,DAMS AGr.e1&1e11 Ne.. Mb12Q§JA340l' Accession No ML14030AQ46l The February 20 2014, letter ,ncJudes guidance regarding operab111ty and reoortabditv. As stated in me February 20. 2014 tc;ter

         *as always. the safety of the operaling Plants IS of paramount importance 1onow established regulatory processes. including the beckf,t rule The NRC w1U *
                                                                                ,n determining whether i FonMttad: lndlnt: left: OS additionaJ requirements are warranted

• The expected outcome of the review IS a recommendation to management as to whether or not the Maren 12 2012 reauest for w,lormauon process should cont,nue to bt 10 owed or ,1 there ,s new 1nform11,on that suggests thore 1$ an tmmediate safety coocem Jhal would require act1Q11 1n accordance w,Jh established reguJatory oroqsses ce a
• Order)

OACKGROUNO California Assembly Bill 1632 {Blakeslee, Chapter 722, Statutes of 2006) directs the Cahfomla Energy Commission to assess the potential vulnerablity of C811fomla's largest baseload power plants, D,ablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impads of such a disruption on system reliability, public, safety, and the economy, to a"ess 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*, energy portfolio. The licensee has used the most atate of the art se1sm1c eyaJuaoon methodologies ~~ 2D and 30 mappcng to compile this report. This is a different and more e>Ctensive data set than what was used for ~PG&E's 2011 Shoreline Faull evaluation (ADAMS Accession No. ML110140431). Ba,ed on information that PG&E has verbally provided to the NRC. PG&E has indicated that tll§ length. and magnitude of the Shoreline fault is greater than that assumed in a 2011 ~report provided to the NRC. PG&E has also lnd1catttd that the soil properties found In the 2011 report have also been updated based on new infom11tion. It is the :staff's prefiminary understanding that in addition to providing changes to the Shoreline fault characteristics that new information is provided in the State ol California report relative to other faults in the area (e.g., Los Osos, and San Luis Bay). PG&E's operabllity evaluation, which is available to the staff, states the following Bes<<J on the preliminary results of the studies thet are under review, h hes been determined that the Shoreline Fault Zone may be more capable then summanzed in the January 2011 reporl, but the deterministic response sp<<;tra are still boilnc>>d by those for the Hosgrl and LTSP 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 ML121230035l . The staffs deterministic evaluation lnciudes several scenarios and resulted In the conclusion that the Shore'ine 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 essentlatly equal to the Hosgrl spectrum in the 20 to 40 Hz range. PG&E's assessment In the 2011 report w11 based on a magnitude 6.5 earthquake. Based on recent conversations with PG&E they now believe that the Shorekne Faun 1s capable of generat,ng a 6 7 magnitude earthquake. There are several differences m PG&E':s assessment of the Shore~ne Faun 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 sod praperties in the area that' Shoreline Fault deterministic ground motion response spectrum is still bounded by the Hosgri and LTSP spectrum. The Issue Is the staffs review of the new information and whether the staff's determinlsbc evaluation In the RIL will be updated based on the new information or ff an alemate approach win be used lo assess the new lnformatton pending expected receipt in March 2015 of an assessment of new seismic Information in accordance with llile senior seismic hazard analysis committee (SSHACl process outlined in the March 12, 2012, 50.5"4(1) letter.

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{I) 0 .15 o.o 0.1 10 100 Frequency (Hz) In addition, in the NRC's October 12. 2012, let1erl transmitting NRC's review of the Shoreline Fault ~ t o PG&E (ADAMS Access,on No ML120730106). the NRC placed b auessment of the Shoreline Fault in context with the process outlined in the March 12, 2012 50 54(1) le11er. The October 12, 2012 letter contained the following gUldanee relative to lhe discovery of new seismic information: The NRC staff understands that Irie seismic evalual,ons descnbed in the Mardi 12, 2012, request for Information are CUrT9rltfy In progress st DCPP, end PG&E plans to acquire new offshore and onJhore two-.end th,.,.*dimenslonal seismic reflection deta to identify and charecterfze faults in the Viclnfty of DCPP. If dunng the collection of the data, new faults ,,. discovered or information ,, uncovered that would sugge$1 /he Shorofne fault 1s more capable than ctrr&ntly be6eved, the staff expect, that the licensee will provide the NRC with an mtenm evaluation that de,cnbes actions taken or planned to address the higher seismic hazard relative to the deSJgn basis, as appropriate, prior to completion of the ,valuations requested in Irie NRC stafrs March 12, 2012, request for Information. The

staff will UM this lnfonnation to Independently e!MS.S whether the new faulf or new information related to the ShoreHne fault chllllflnges or changes the statrs current position thet the motions associated with the Shoreline faun in at or t>e/OW 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 provide an Interim evaluation that describes actions taken or planned to address the higher seismic evaluation Other fa,utts The PG&E 2011 Shoreline Fault report and the staffs RIL also discuss other seismic faults near Oiablo Canyon including the Los Oaos and San Luss Bay fa1tfts It 11 the staffs prellninary understanding that PG&E's report to the Stale of Cahfornia will also include new information relative to these faults

PRODUCTS TO BE REVIEWED

• PG&E report to the State of California relative to Se1sm1c Fau,s near D1ablo Canyon
• PG&E's interim evaluation that describes acbons taken or planned to address the higher seismic hazard relative to the design basis REVIEW PROCESS The staff win review the new seismic information when it is provided the opportunity Based on the new information the staff may assess 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. Ml14083A586l.

The proposed milestones and timeframes for reviewing PG&E's report are as follows based on the assumption that the report wlll be pubhcly released on September 10. 2014 Tlmeframe Action Rnponslble Party(ies) Sept 3 NRC staff identifies information that it wi .l quickly NRG review team need from PG&E to suppor1 a possible review 11 accordance with the process found in the CEUS study above PG&E WIii 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 PG&E or not it can provide information to the staff by Sept 22 SePt 8 Key NRG review team members review the State NRC review team of California report prior to its public release Changes to the project plan and conununication plan are identified Sept 10 PG&E provides report and interim evaluation to PG&E the NRC Sept 15 NRC identifies any add1honal information needs NRC review team that it has to complete its preliminarv evaluation Sept 22 PG&E completes providing NRC staff ¥Ith PG&E information nete$sary for the staff to complete rts preliminary evaluation Sept 29 NRC review team completes it preliminary NRC review team assessment of new Shoreline fault Information and makes recommendation to management on how to proceed October 3 NRC management makes deas1on on how to NRC management proceed

REVIEW TEAM The following are the proposed members of the review team subject to management approval NRR Projects: Eric Oesterle, Balwant Slngal, Joe Sebrosky, Nick DIFrancesco NRR technical: Kamal Manoty, Yong LI NRO technical: Cliff Munson, Bntt Hill, John Stamatakos (cortracto,) RES. Jon Ake Region IV: Wayne Walker, Theresa Buchanan, Megan Wiliams. Tom Hipschman COMMUNICATION PLAN A communication plan has been developed for the PG&E report. The NRC review team w,11 update the communication plan based on Its assessment of the new information

rrom: Sebrosty, Joseph To: Kods Andrea Cc: Mynsgn Cktfoal

Subject:

Rf: Info and action: status ~ dlablo canyon state of calfornia report reoardlng seismic issues Date: Monday, September 08, 201'4 6:51:00 AM I just sent you the scheduler. Joe From: Kock, Andrea Sent: Monday, September 08, 2014 6:35 AM To: Sebrosky, Joseph Cc: Munson, Clifford

Subject:

Re: Info and action: status of diablo canyon state of califomia report regarding seismic Issues Joe- thanks so much for the update. Can you either invite me to the meeting tomorrow to discu5s early insights on the report or send a summary of where we are after the meeting? I'm interested In any early rssuc*s we may identify and whether the 1nformat,an that the licensee can provide will ::>e sufficient for us to make a safety conclus1on .1 ha"e an all day meeting tomorrow, but dependln@on the time, 1 rnay be able lo step out Thanks I Sent from NRC blackberry Andrea Kock I (b)(6) From: Sebrosky, Joseph Sent: Monday, September 08, 2014 05:47 AM To: Markley, Michael; Munson, Oifford; StovalJ, SCott; Kock, Andrea; WIiiiams, 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; Balat1k, Michael; Singal, Balwant; Farnholtz, Thomas; Kanatas, Catherine; Hipschman, Thomas; Reynoso, John; Ake, Jon; Folk, Kevin; Difrancesco, Nicholas; Balazik, Michael; Reynoso, John; Hill, Brittain; Walker, Wayne; Useldlng, Lara; Buchanan, llleresa; Keegan, Elaine; Jackson, Diane; Wittlck, Brian; Harris, Brian; Roth(OGC), David; Kanatas, cathertne; OKeefe, Neil

Subject:

info and action: status of diablo canyon state of califomla report regarding seismic Issues Cliff, Scott, Yong, and Megan, The purpose of this email is to:

1) inform you when you can expect to receive access to the Oiablo Canyon State of California seismic report,

2) inform you that I will be sending you a scheduler for a phone call this afternoon with PG&E to discuss their feedback on whether or not they will be able to provide responses to the 6 questions we developed in the September time frame, and

3) Provide a general status of other items related to the Status of Diablo Canyon seismic issues

I am copying several other folks on this email for their awareness. Access to Report PG&E informed me over the weekend that the four of you (i.e., Cliff, Scott, Yong , and Megan) can expect to receive access to the report today (9/8) at 11 :00 am eastern time (8:00 am Pacific). PG&E is still targeting the public release of the information on 9/10. DORL has changed the tac to which you should charge your review time. The new tacs are MF4750, and MF4751 . You will be receiving an email from Philippe Soenen of PG&E that will explain how to get access through certrec. You will not be able to download or print the material. PG&E is also making arrangements for some State of California officials to review a hard copy of the report around the same time we get access. PG&E's Ability to Proyjde Response to 6 Ouestjons io the September lime Frame PG&E also informed me over the weekend that they will not be able to provide a response to all of the 6 questions in the attached email in the September time frame. They would like to have a phone call this afternoon to discuss which items they maybe to answer in the short term and which items may not be available until March of 2014. I will send the four of you a separate scheduler for this call In addition to you, I will include the following individuals on the scheduler (Eric Oesterle, Mike Markley, Diane Jackson, Andrea Kock, Tom Hipschman, Wayne Walker. and Theresa Buchanan). Status of Other Items

• You should have a scheduler for an internal meeting tomorrow to discuss your insights based on a quick look at the report on whether or not changes to the communication plan or draft project plan are needed.
• There is a possibility that the DPO, the DPO recommendation. and the DPO appeal, will be made publicly available this week. DORL is working on coordinating updating the DPO communication plan based on the public availability of this information.

Let me know if you have any questions.

Thanks, Joe Sebrosky

From: 5ebrosky, Joseph To: Burnell, Scott

Subject:

RE: Info and idlon: status o( dlablo canyon stata of cakfornt1 report regarding seismic issues Date: Monday, 5eptember ~ . 20116:05:00 AM Yes - sorry for the confusion - joe From: Burnell, Scott Sent: Monday, September 08, 2014 6:01 AM To: Sebrosky, Joseph

Subject:

Re: info and action: status of diablo canyon state of califomia report regarding seismic Issues Morning Joe; Typo below? I think you meant PG&E said March 2015 for some replies? Scott Sent from an NRC Blackberry Scott Burnell I (b)(6) from: Sebrosky, Joseph Sent: Monday, September 08, 2014 05:47 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; Franovtch, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazlk, Michael; Singal, Balwant; Farnholtz, Thomas; Kanatas, Catherine; Hipschman, Thomas; Reynoso, John; Ake, Jon; Folk, Kevin; Difrancesco, Nlc.holas; Balazik, Michael; Reynoso, John; HIii, Brtttaln; Walker, Wayne; Useldi111g, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wlttick1 Brian; Harris, Brian; Roth(OGC), David; Kanatas, Catherine; OKeefe, Neil

Subject:

info and action: status of d1ablo canyon state of califomia report regarding seismic Issues Cliff Scott, Y.ong, and Megan. The purpose of this email ls to

1) inform you when you can expect to receive access to the o ,ablo Canyon State of California seismic report,

2) inform you that I will be sending you a scheduler for a phone call this afternoon with PG&E to discuss their feedback on whether or not they will be able to provide responses to the 6 questions we de,vetoped in the September time frame, and

3) Provide a general status of other items related to the Status of Diablo Canyon seismic issues I am copying several other folks on this email for their awareness.

Access to Report PG&E informed me over the weekend that the four of you (1 e . Cliff, Scott. Yong and The entire email string is found as document G/25 in interim response #3 in FOIA/PA-2014-0488 (ML15033A280).

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Cc;: IStADilta>, C4UJcuoe: RottiOGC1. QaYffl Subjeclt: Internal meeting to detelT!llne ff cllanges to l!'le communlaltlon plan for the Olabto canyon Stat,e of Callfomla

                      ~ort need to be made based on a prellmfnary assessment of the "90lt (Tac Mf020, MF4721) start:                Tuesday, 5el)tember 09, 2014 2:00:00 PM
!nd:                  Tuesday, September 09, 2014 3:00:00 PM Location:             HQ-TWfN-07C02-20p Atbd11.-ents:          QbtQto S!at:>> ot ca ,ma se1sm1e a::,,ort m ::vi Plio CMW : gocg QC   ca   f zon*c rnt @rrm plan a-2:2::1* r:ttS:oo doQt 8ndgc # : 888-677-0690 Passaxle:1 (bl(6)    I

Purpose:

For Olff Munson. Megan wm1ams, Scott Stovall, and Yorio U. to prav1de a cd1edlve assessment on whether or not dlanges to the draft communication plan and draft project plan assodated with the Dlablo <:anyoo State of Cattforna report need to be made based on their quick look at the repart Outcome: Decision made on whethef or not changes to communication plan and project plan need to be made Agenda: Clff. Megan, Scctt. and Yong. brief the team on their assessment of the infonnabon In the State r:J Califomla repart o<<lslon made on whether or not changes to the attached comminc:atton plan or profect plan need to be made Ill. Next steps N . Wrapup

DRAFT - 61"FlelAL t19f 614LV 9!1491Tl't! 114T!ftl4AL 114P'eftMATlel4 - 14M reft P't19Lle ft!L!A9! UPDATED: 09/2512014 3:~ PM Communications Pla111 - Dia'blo Canyon Power Plant Topics of Interest State of California Seismic Report {ABN-1632)

Background

California Assembly 81111632 (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 asse,s the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the Mure 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 Shorehne Fault evaluation. The purpose of this communication plan 1s to provide key messages assooated with the public release of this report. KeyMea,age,

• The resident inspectors and regional staff reviewed the licensee's documentabOn in their corrective action process of new preliminary informabon concerning OCPP seismic and licensing bases that the Shoreline fault may be more capable than preVJOusly determined. The information did not indicate there 1s an immediate threat to public health and safety nor did it call Into quesuon the ability of SSCs to perform thetr specified safety functions or necessary and related support functions The licensee's cooent actions meet the Manual Chapter 0326 guidance for having reasonable assurance of operability, pending further evaluation.
• The NRC wm continue to review the new information ,n the report and will take additional regulatory action as appropriate If the NRC staff condudes that the new information associated with the Shoreline Fault causes the NRC to revisit its preliminary evaluation
• Diablo Canyon will incorporate the BiU 1632 report's information into its Marcil 2015 seismuc hazard re-analysis submittal to the NRC

DRAFT - eP11'1e1At t:IS! eHt I Sl!!f4SIT1f! llff!ftl4AL 114reftMA'1'1014 - He, l"eft l't:ll!tle ft!~i>l!Sl!! Communication Team The primary responsibility of me commun1cat1on team Is lo ensure that it cooveys a conSJStent. aCGUrate, and timely message to all stakeholders The team cons1Sts ot the ~ management, technical, and communication staff named below T.amMember Position Organlutlon Telephone Wayne Walker Branch Chief R-IV/ORP/RPB-A 817-200-1148 Ryan Alexander Sr. Pr()J8Ct Engineer R-IV/ORP/RPB-A 817-200-1 195 Sr. Resident Inspector - Thomas Hipsctrnan R-IV/ORP/RPB-A SOS-595-2354 DCPP Resident Inspector - John Reynoso R-IV/ORP/RPB-A 805-595-2354 DCPP Jon Ake Senior Seismologist RESIDE/SGSEB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPUV 301-415-1014 Balwant Singal DCPP Project Manager NRR/OORULPLIV 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-S517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DiFrancesco Japan Les.sons Learned JLO 301-415-1115 Planntd Communication ActlvltlH The contents on this communication plan, supplemented by mformabon provided by PG&E/Olablo Canyon, should be used to accomplish these actions. The table be <:IN IS based on a target publtc release date of the report on September 10, 2014. Timeframe Action Responsible Party(lea) Septa PG&E provides a draft of the report in the PG&E electronic reading room for initial staff assessment 2

DRAFT - OPP'ICl"L t,S! ONL, S !mH,IY! IH,EfU.AL 114pie1111.-.1"10t* - NHlfl!O_..,...,..,. C"llll""P'~t,1'449111L"41f'! C"'ftNl!!l..,L"' l!!"Jlc IIIoS~

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Tlmeframe Action Responsible Party(les) Sept9 PG&E notifies NRC of se,smlc repon submittal to PG&E the state of California Sept 10 PO&EfOiablo Canyon Power Plant submit seismic PG&E report to the state of Callfotnla arid 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 ,molements the Communications Plan day) Entirety of Communications Team nobfies R-IV; NRRIDORL; applicable Senior Managers m their respective NRRIOLR; NRR/JLD reoortma chain OPA. OCA: OGC OPA available to use Communications Plan to R-IV; OPA answer media Inquiries. NO blog OR press release olanned Oct 3 JLO/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 subm1tta.l of the se1sm1c reeva uabon in March 2015. Updates to communication plan as apJ)(ooriate As requested Complete a Commissioners Assistants Bnef R-IV; NRR

1. Question* and An1wera What la the Impact of this new Information on Niamic design and llcenaing of DCPP?

Has the licensN entered this new Information into tt.. corrective action program and performed an operability evaluation? As required by the NRC, as documented in RIL 2012-001 , PG&E has entered the new preliminary seismic information into their corrective action J)f'ogram. 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 "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 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 is NRC letter to All Power Reactor licensees and Holders of Construction Perm ts in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50 54(1) Regarding Recommendat.ions 2.1, 2.3, and 9.3 of the Near-Tenn Task Force Review of Insights from the Fukushima Oal-lch1Acadent: March 12 , 2012 The resident inspectors and regional staff reviewed the licensee's documentation in their corrective action process of new preliminary information concerning DCPP seismic and 3

DRAFT - O,.l'telAL t,S! 01'4L I S!ffsi,tV! llf,!ftltAL lffl'Of\MATION - NOT ,.Oft Ptn,ue l'eteac:SI! licensing bases that the Shoreline fault may be more capable than previously determined The infoonabon did not indicate there 1s an 1mmed1a1e threat to pubhc health and safety nor did It call into question the ability of SSCs to perfonn their specified safety functions, or necessary and related support functions The 11censee*s cu,rent actions meet the Manual Chapter 0326 guidance tor having reasonable assurance of operability, pendillJ further evaluatton The NRC will review the new Information provided in the report to the State of Cahfomra including the Shoreline Fault characterlsllcs. and the updated charactenstics associated with the soil properties near the site. The NRC staff wiD take additional regulatory action as appropriate If the NRC staff conolude.s that the new information auoc:iated with the Shoreline Fault causes the NRC to revisit the conclusions ln the RIL.

2. Has DCPP 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 Fault 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 Shore~ne fault to the OCPP. Because the Shoreline Fault 1s 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 LTSP evaluations continues to bound potential ground motions from the Shoreline Fault

3. How will the AB 1632 seismic report be coordinated with the 50.5.c(f) required 1ubmlttal In March 20157 The 1000-page document has also been given to the NRC (Japan Lessons Learned Directorate) to be considered in the 50.54(1) review. The neN preliminary ,nformabon regarding regional seismic source charactenzation (I.e. fault capability) and potenbal site ground motion will be evaluated in accordanc:e with 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 µune 2017l - ~ ()1111.): so.54(1)..., glww 3 }'191 ID clO N I ~ - be Man:fl 2011. Whatll

                                                                                                     . .._.. at.JI.Ill 2011 d*7 (If pushed on any *unknowns* in the report If necessary, ac.tions 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 implemenbng FLEX which was a post-Fukushima industry 1nibative lo have extra equipment available remotely in the event of a beyond design basis event)

4. 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 1s expected to be incorporated 4

DRAFT - epprfelM. 1:19! et4t't 3£149"1\1! llffEIU4Jt<t INl'e"Mit<fleN - 14eT l'e" l't:IBue "Et.£1'4:Sl! Into the more oompretiensive 50.54f analysis due to the NRC In March 2015. However, because the licensee must notify lhe NRC of any new se1s1T11C Info. they have shared this report and an inrtial operability evaluation showing Why Iha plant 1s safe to operate. The NRC has IOOked at this eveluauon and its prehmln.iry aSS8$$ment 1s that based on the inrormatloo presented by PG&E the Shoreline Faull does. nol e:Kceed previously considered seismic hazards. &. Why didn't the NRC diacover the length of the faults when It did its sefamlc review or the Shoreline fault ln 2011 p,tor to Issuing the RIL? California Assembly BHI 1632 (Blakeslee, Chapter 722, Statut~ of 2006) directs the California Energy Commission to assess the potential vulnerability of Cahfom1a't largest base-load power plants, Diablo Canyon Power Plant and San Onofre Nudear Generating Station, to a major disruptioo due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, pubhc 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 portfofio. 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 201 1 report The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-<late methodologies and analysis which is due for DCPP in March 2015.

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 ShoreNne Fault Zone may be capable of producing somewhat larger earthquakes than considered m the January 2011 PG&E report The staff is independently assessing PG&E's determination. The process ouUined In the 50.54(f) letter lndudes a detailed analysis of new seismic Information (including shOl'eline faults and other faults around the plant). PG&E Is scheduled to provide this assessment 1n the March 2015 bme frame The staff is currently reviewing the information in the Shoreline fault report and will Hsess the more complete assessment of new seismic infonnation scheduled to be provided m the March 2015 time frame. The NRC staff will take appropriate regulatory action up to and including Issuing Orders to ensure safe operation of the plant

7. Will the Report be conaidered In the UcenH Renewal Process Yes. In add lion to the report being developed to address Cahfornia Assembly Bin 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 Mbl 422~A320).

5

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8. The AP win, tervloe recently ,..porud that tl'le,. Is a Dif'9r'lng Professlonal Opinion (DPO) nsoclated with HRC'* evaluation of the Shoreline F1uh. Why has the u ltten~*

of this OPO only now been made public? The OPO process ls a strictly controlled and formalized process wrthtn the agency that allows dlffenng professional opinions to be thoroughly considef9d by the ll98ncy while at the same time protecting the pnvacy of the OPO submitter A DPO was sut>mrtted and is still underg01ng internal NRC ,eview in accordance w,th ltllS process Until the NRC cx,mpletes 11s Internal rev'lew process for this OPO, the agency tS unable to oornment on any potential DPO resolution or documentation Once the review 1s completed the agency will have a final decision on the OPO and associated documontationi 6

From: Vbk:, 1eoQtfer To: GIiies Nanette: pygek Mt<;hae! Cc: Johnson. H1rnae1: Setimsllv Jaseob* Lynd Louise; Dapas Marc; Jackson 01aoe; Munson, ChffQrd; YcahQrctls

                 ~

Subjed: RE: Chairman bneflng tomorrow on Diablo canyon Date: 'Thursday, 5eptember 04, 2014 8:46:03 AM Nan. Okay only Cliff will attend and no one will call m. Thanks, Jennifer From: Gilles, Nanette Sent: Thursday, September 04, 2014 8:34 AM To: Uhle, Jennifer; Dudek, Michael Cc: Johnson, Michael; Sebrosky, Joseph; Lund, Louise; Dapas, Marc; Jackson, Diane; Munson, Oifford; Vrahoretls, Susan

Subject:

RE: Chainnan briefing tomorrow on Diablo Canyon Importance: High Regarding this morning's briefing, the Chairman has relayed that she does NOT want to discuss the DPO. She only wants to talk to the seismologists about the new State-commissioned seismic report so that she can understand, technically, the resu lts and implications. She has requested a meeting with the seismologists only.

Thanks, Nan From: Uhle, Jennifer Sent: Wednesday, September 03, 2014 3:20 PM To: GIiies, Nanette Cc: Johnson, Michael; Sebrosky, Joseph; Lund, Louise; Dapas, Marc; Jackson, Diane; Munson, Clifford subject: Chairman briefing tomorrow on Diabio Canyon

Nan, Mike Johnson and Roy Zimmerman informed me that the Chairman meeting tomorrow at 9: 15 on Diab lo Canyon seismic issues will be focused on technical issues associated with the recent findings on the Shoreline fault and how it impacts safety and the licensing basis. As such, we have cut down the attendance to Neil O'Keefe, Joe Sebrosky and Cliff Munson. Jon Ake is on vacation and is not able to call in. We think this is more of a question and answer session. We have some slides if needed.

Thanks, Jennifer

from: Dudek.. Michael Sent: Wednesday. Septerober 03, 2014 1:11 PM To: Oesterle, Eric

Subject:

RE: info: status of actions associated with with Diablo Canyon shoreline fault Thanks Eric! Can I give this to the Commission? Michael I . Oude:k I OEDO Executive Technical Assistant I U.S. NRC M1chael.Dudek@nrc.gov I 11: {301} 415-6500 I BB :j a 6 j From: Qesterte, Eric Sent: Wednesday, September 03, 2014 1:09 PM To: Sebrosky, Joseph; Hipschman, Thomas; Mark.ley, Mldlael; Kanatas, catherine; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Oifford; OKeefe, Neil; Folk, Kevin; Difrancesco, Nicholas; Balazik, Michael; Reynoso, John; Singal, Balwant; HIii, Brittain; Walker, Wayne; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittick, Brian; Stovall, Scott Cc: Weil, Jenny; U, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michaef; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, Michael; Williams, Megan; Famholtz, Thomas; Kanatas, catherine; Pedersen, Renee

Subject:

RE: info: status of actions associated with with Diablo canyon shoreline fault To all, Attached are the updated Key Messages. They incorporate comments from OPA and Mike Hay. And they retain bullets on the expected submittal date of PG& Seismic Report to CA and to NRC as we'll need these key messages up to and following those dates (i.e., 9/10). Eric From: Sebrosky, Joseph Sent: Wednesday, September 03, 2014 11:35 AM To: Hipschman, Thomas; Markley, Michael; Oesterle, Eric; Kanatas, Catherine; Reynoso, John; Mamoly, Kamal; Ake, Jon; Munson, Clifford; OKeefe, Neil; Folk, Kevin; Difrancesco, Nicholas; Balazik, Michael; Reynoso, John; Slngal, Balwant; HIii, Brittain; Walker, Wayne; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wlttlck, Brian; Stovall, Scott Cc: Weil, Jenny; Li, Yong; Manoty, Kamal; Lund, Louise; Dudek, Michael; case, Michael; 8umell, Scott; Hay, Michael; f ranovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, MIChael; Williams, Megan; Famholtz, Thomas; Kanatas, Cathefine; Pedersen, Renee

Subject:

Info: status of actions associated with with Oiablo Canyon shoreline fault To all, The purpose of this email is to provide you with a status of items associated with the Diablo Canyon seismic review related to status of the project plan to review new seismic information and the latest information regarding a Chairman briefing. Prolect Plan for Reviewing New Seismic Information Attached is the revised project plan for reviewing new seismic information. The document shows the changes made from the last revision (you can accept an changes if you are not interested in the changes). The major changes from the lasI version are: This entire email string is document G/29 in interim response #3 in FOIA/PA-2014-0488 (ML15033A280).

From: Oesterle, Eric Sent: Wednesday, September 03, 2014 1:09 PM To: Sebrosky, Joseph; Hipschman, Thomas; Markley, Michael; Kanatas, Catherine; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Clifford; OKeefe, Neil; Folk, Kevin; Di Francesco, Nicholas; Balazik, Michael; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittick, Brian; Stovall, Scott Cc: Weil, Jenny; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, Michael; Williams, Megan; Farnholtz, Thomas; Kanatas, Catherine; Pedersen, Renee Subject RE: info: status of actions associated with with Diablo Canyon shoreline fault Attachments: Diablo seismic process key messages_srb+ero.docx To all, Attached are the updated Key Messages. They incorporate comments from OPA and Mike Hay. And they retain bullets on the expected submittal date of PG& Seismic Report to CA and to NRG as we'll need these key messages up to and following those dates (i.e., 9/ 10). Eric From: Sebrosky, Joseph Sent: Wednesd'ay, September 03, 2014 11:35 AM To: Hipschman,. Thomas; Markley, Michael; Oesterle, Eric; Kanatas, Catherine; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Oifford; OKeefe, Neil; Folk, Kevin; DiFrancesco, Nicholas; Balazik, Michael; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittick, Brian; Stovall, Scott Cc: Weil, Jennyi LI, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, Michael; Williams, Megan; Famholtz, Thomas; Kanatas, Catherine; Pedersen, Renee

Subject:

info: status of actions associated with with Diablo Canyon shoreline fault To all. The purpose of this email is to provide you with a status of items associated with the Oiablo Canyon seismic review related to status of I.he pro1ect plan to review new seismic information and the latest information regarding a Chairman briefing. Project Plan tor Reviewing New Seismic Information Attached is the revised proiect plan for reviewing new seismic information The document shows the changes made from the last revision (you can accept all changes 1f you are not interested 1n the changes). The major changes from the last version are:

• Changes made to include expectations that in addition to changes in Shoreline Fault information the State of California report will also include new information relative to the San Luis Bay and Los Osos faults.
• Recognition that today {9/3) PG&E has been provided with expected information needs for the staff to perform a prelimjna,y assessment of the new sersmic information and request to PG&E that they intorm This entire email string is document G/29 in interim response #3 in FOIA/PA-201 4-0488

From: Oesterle. Eric Sent: Wednesday, September 03, 2014 12:09 PM To: Sebrosky, Joseph; Hipschman, Thomas; Markley, Michael; Kanatas, Catherine; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Clifford; OKeefe, Neil; Folk, Kevin; DiFrancesco, Nicholas; Balazik, Michael; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Buchanan. Theresa; Keegan, Elaine; Jackson, Diane; Wittick, Brian; Stovall, Scott Cc: Weil, Jenny; Li, Vong; Manoty, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel'; Balazik, Michael; Williams, Megan; Farnholtz, Thomas; Kanatas, Catherine; Pedersen, Renee

Subject:

RE: info: status of actions associated with with Diablo Canyon shoreline fa ult Attachments: Diablo State of California seismic report review plan revision l _ero.docx

Joe, Some minor edits and a couple of comments that could be addressed during briefing.

Eric From: Sebrosky, Joseph Sent: Wednesday, September 03, 2014 11:35 AM To: Hipschman, Thomas; Markley, Michael; Oesterle, Eric; Kanatas, Catherine; Reynoso, John; Maooly, Kamal; Ake, Jon; Munson, Oifford; OKeefe, Neil; Folk, Kevin; Difrancesco, Nicholas; Balazik, Michael; Reynoso, John; Slngal, Balwant; Hill, Brittain; Walker, Wayne; Usetding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wlttick, Brian; Stovall, Scott Cc: Weil, Jenny; LI, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, Michael; Williams, Megan; Farnholtz, Thomas; Kanatas, Catherine; Pedersen, Renee

Subject:

info: status of actions associated with with Diablo Canyon shoreline fault To all, The purpose of this email is to provide you with a status of items associated with the Diablo Canyon seismic review related to status of the project plan to review new seismic information and the latest information regarding a Chairman briefing. Project Plan for Reviewing New Seismic Information Attached Is the revised project plan for reviewing new seismic information. The document shows the changes made from the last revision (you can accept all changes if you are not interested in the changes). The major changes from the last version are:

• Changes made to include expectations that in adchhon to changes in Shoreline Fault information the State of California repor1 will also include new information relative to the San Luis Bay and Los Osos faults.
• Recognition that today (9/3) PG&E has been provided with expected information needs for the staff to perform a preliminary assessment of the new seismic information and request to PG&E that they inform the staff on whether or not they will be able to provide the information by 9/22 (see attache,d email to PG&E)

During discussions I had wtth PG&E about the attached email they Indicated that they could support a public meeting in the September time frame if the NRC behaved such a meeting was necessary to discuss the State l This entire email string is document G/29 in interim response #3 in FOIA/PA-2014-0488 (ML15033A280).

From: Dapas, Marc To: Martctey, Michael: 5ebcoslsx, Joseob Cc: Dorman, pan: wa tw wavne: Qf<eefc Ne.1

Subject:

FW: Into regarding Chalrmitll Brief on Olitblo canyon seismic issues Date: Wednesday, September 03, 201'4 12:5":5" PM Atuchments: Djabto Stats: of Catt[orrna seismic report rey,cw 01an Ct:Yl$IOO 1.doQ Request to oroy1ae tee<Jback on abtl:tY ro oroy,ae o,ab!A canyon se,sm1c 1nrormatioo bv sememt>er 22 2019,msg Mike/Joe, I just learned this morning of the subject briefing request by the Chairman. I presume NRR is taking the lead for the briefing given the subject matter being related to the DPO and AB 1632 report. From: Dapas, Marc Sent: Wednesday, September 03, 2014 11:52 AM Toi Walker, Wayne; OKeefe, Neil

Subject:

FW: Info regarding Chairman Brief on Diablo canyon seismic issues Who is leading the briefing, NRR? From: Bowers, Anthony Sent: Wednesday, September 03, 2014 10:57 AM To: Dapas, Marc Subjea: Info regarding O'lalrman Brief on Diablo canyon seismic issues Marc. For your awareness ... I heard your line of questioning during the events brief today at 11 :00. I did not speak up since I felt 1t was appropriate for your staff to brief you first However. with that said I will give you a heads up on what I know and what to expect during the brief. The below language is a quote from the Chairman's staff (Nanette Gilles), which provides perspective on her specific interests to be addressed during the brief.

         "The Chairman wants to understand exactly what Mr. Peck was taking issue with in his DPO. We've heard over and over that he did not have a safety concern, yet that isn't how it is being presented in (most of) the media. She also wants to understand, from a technical standpoint, what the State-commissioned study did differently that resulted in the conclusion that the Shoreline Fault is more capable than previously thought and why we can still say that ,t is bounded by Hosgri.

I suggest staff also be ready to address the current licensing basis and our basis for saying that the Shoreline Fault was bounded by the Hosgri fault, 1f asked. For example, the draft Comm Plan says: 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 LTSP/Hosgri method.

This makes it sound like, because we don't think the Shoreline fault was really ever active, we can "therefore* bound it by the Hosgri method. I suspect there's more to it." In addition , attendees for the brief are listed in the below e-mail from Joseph Sebrosky. Please let me know if you need anything additional. Tony From: Dudek, Michael Sent: Wednesday, September 03, 2014 11:39 AM To: Bowers, Anthony Subjed:: FYI: Info: status of actions associated with with Diablo Canyon shoreline fault FYI Mlchael I . Dudek I OEDO Executive Technical Assistant I U.S. N RC l!l: MJchaeLDudek@nrc.aoy I * : (301) 415-6500 I ee : j j From: Sebrosky, Joseph Sent: Wednesday, September 03, 2014 11:35 AM To: Hlpschman, Thomas; Markley, Michael; Oester1e, Eric; Kanatas, catherine; Reynoso, John; Marioly, Kamal; Ake, Jon; Munson, Olfford; OKeefe, Nell; Folk, Kevin; OIFrancesco, Nicholas; Balazlk, Michael; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Useldlng, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittick, Brian; Stovall, Scott Cc: Weil, Jenny; Li, Yong; Manely, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovlch, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazlk, Mlchael; WIiiiams, Megan; Farnholtz, Thomas; Kanatas, Catherine; Pedersen, Renee Subjed:: Info: status of actions associated with with Dlablo canyon shoreHne fault To all, The purpose of this email is to provide you with a status of Items associated with the Diablo Canyon seismic review related to status of the project plan to review new seismic information and the latest information regarding a Chairman briefing. Project Piao for Reviewing New Seismic Information Attached is the revised project plan for reviewing new seismic information. The document shows the changes made from the last revision (you can accept all changes if you are not interested in the changes). The major changes from the last version are:

• Changes made to include expectations that in addition to changes in Shoreline Fault information the State of California report will also include new information relative to the San Luis Bay and Los Osos faults.
• Recognition that today (9/3) PG&E has been provided with expected information needs for the staff to perform a preliminary assessment of the new seismic

information and request to PG&E that they inform the staff on whether or not they will be able to provide the information by 9/22 (see attached email to PG&E) During discussions I had with PG&E about the attached email they indicated that they could support a public meeting in the September time frame if the NRC believed such a meeting was necessary to discuss the State of California report DORL senior management does not currently believe such a public meeting is necessary, therefore, a public meeting is not currently reflected in the attached project plan. In addition, PG&E has confirmed that they will be providing electronic reading room access to the State of California and key NRC reviewers on 9/8/14, ahead of the tentative public release of the report on 9/10. The NRC individuals for which will be requesting access are: Cliff Munson. Scott Stovall, Yong Li, and Megan Williams. The purpose of the electronic reading room review is to identify changes to the communication plan and project plan ahead of the public release of the State of Cahforn1a report on 9/10/14. Chairman Briefing -At her request a briefing of the Chairman has been scheduled from 9:15 (eastern time) to 10:00 am tomorrow (9/4) to answer her questions relative to the DPO and how the NRC will review the new seismic information.

• The participants in the briefing are: - Neil O'Keefe (RIV), Cathy Kanatas (OGC),

Cliff Munson (NRO), Kamal Manely (N RR/DE), Mike Markley (DORL), Scott Stovall (RES), and Renee Pedersen (OE).

• A draft copy of the slides will be provided to all on distribution for this email around 1:00 pm eastern today Key staff will be requested to provide their comments on the draft slides by COB today so that the slides can be revised early tomorrow morning in time for the 9:15 briefing and a quick review by the EDO's office prior to the 9: 15 eastern time briefing.

Please let me know if you have any questions about the above. Thanks, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph,sebrosky@nrc gov 301-415-1132

Project Plan for NRG Staff Review of PG&E's Report to the State of California Regarding the Shoreline FaultProject Plan for NRC Staff Review of PG&E's Report to the State of California Regarding Seismic Faults Near the Diablo Canyon Power Plant NOTE: This Is I llvln1 document and wlll be updated II necessary. Please note the d1te on the cover. Document Point of Cont1ets: Jpseph.Sebrosky@nrc.goy Nick DIFrancescolll>nrc.goy

Japan Lessons Learned TABLE OF CONTENTS Purpose of the Review of the State of California Report ....,......................,..,.,.........,.,..,.....,.........,........,..*.*3c Background ......... I . . . . .. ... . . . . ..... ., * * . ., ......... ... I'll ' fl " I . .,.,,........ ............,. .... ,.. .... .,., .......,. , ........ 3-Products to be Reviewed ..........................................................................................,................................... 54 Review Pr oce~s..............................................................................................................................................54 ReviewTeam ,................................................, ............................................,.................." ............. "...." ...........s Communication Plan ...................... ,.,.... ......................... ................ ,....... - ........,.......,...................,..,.. 7i f1e1rees!! el_t~e_l!_e,,eiew of t~e S_tat~ el Gal~er~i~ ~~p_a!'.' !"!".:""::'!.":' :"!'::".:*::m""m.:".:*::*::*::*.::""*!".:'::*::*.::*::*~_ _ ' fonNttecl: Default Paragraph Font. 01eck spel~ng and grammar I Formatted: Defa1At Paragraph Font, Check i!._E~fl!l!W_!I~ ~ '-"-"!"-' __ *::*:. *__,.:* _. _._ ,_._ *- *-* .:*.:* _*!. ._ ! ". '!_* .;*_ *.:* -"!."- '!""'.'""!.m".:"":.'m""""""m"*"""'";! spelling and grammar fonNtted: Oefault Paragraph Font, Check

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PURPOSE OF THE REVIEW OF THE STATE OF CALIFORNIA REPORT This project plan documents steps necessary for NRC staff to qu1ddy assess the information found in lhe report provided by Pacific: Gas and Eledric: (PG&E) to the State of California relalld to Seismic: faultslhe ShoreliAe Fawlt near the 01ablo Canyon Power Plant (DCPP). The purpose of the assessment Is to detennine what, if any changes need to be made to the approach outlined in the March 12, 2012, request for information assOC11ted wrth new seismic: Information (see ADAMS Accession No,. MLJ 2053A3401 BACKGROUND I California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the Caltfomia Energy Commission to assess the potential vulnerabil~y of California's largest baseload power plants, Oiablo Canyon Power Plant and San Onofre Nudear Generating Station to a major disruption due to a seismic: event or plant aging; to assen the impacts of suc:h a disruption on system reliability, pubhc:, safety, and the economy, to assess the costs and impacis from nuclear waste acoumulatlng at these plants; and to evaluate other major Issues related to the Mure rote of these plants in the state's energy portfolio. The licensee haa 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 in PG&E's 2011 Shoreline Fault evaluation (ADAMS Accession No ML110140431). Based on information that PG&E has verbally provided, PG&E has indicated tha t length, and magnitude of the Shoreline fault 1s greater than that assumed in a 2011 report provided to the NRC. PG&E has also indtc:ated that the soil properties found In the 2011 report have also been updated based on new information. It 1s the stairs preliminary understanding that in addition to providing charges to the Shoreline fault characteristics that new lnformauon iS orovldeg ID Jbe State of Cahforn1a report relative to other fau1t1 in the area ce.g Los Osos, and San LufS Bay) PG&E's operability evaluation, which Is available to the staff, states the following. Based on the preliminary results of the studies that ate under review. it has bHn detenmned that the Shoreline Fault Zone may be more capable than summarized in the January 2011 report, but the deterministic: response .spectra a,e still bounded by those for the Hosgr/ and LTSP t1arfhquakos. The staff previous evaluation of the Shoreline Fault c:an 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 Ac:oess1on No ML121230035) The staff's deterministic: evaluation includes several scenarios and resulted in the conclusion that the Shoreline Faun 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 staff's magnitude 6.7 earthquake 1c:enario 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 magnHude 6.5 earthquake. Based on recent conversations wrth PG&E they now believe that the Shoreline Fault is capable of generating a 6.7 magnitude earthquake. There are several drfferenoes In PG&E', aut&ament of the Shoreline Fault found in their 2011 repor1 and the staff's assessment found in the RIL. The staff understands that PG&E believes 1hat based on new information relative to the Shoreline Fault and soil properties in the area that Shore,ne Fault deterministic: ground mobon response spectrum IS still bounded by the Hosgrl and LTSP spectrum. The issue Is the staff's review of the new information and whether the staff's determinisbc: evaluation In the RIL will be updated based on the new information or 1f an alternate approach will be used to assess the new information pending expected receipt in March 2015 of an

assessment of new aelsmic information in accordance with the senior seismic hazard analysis committee (SSHAC) process outlined in the March 12, 2012, 50 54{1) letter 2 .5

                -       Holen~
                        \Tl,0--

a 2.0 g ~ 1 .5 1 C 1,0 i (I) O.lli 0.0 0 .1 10 100 Frequency (Hz) In addition, In the NRC's October 12, 2012. letter) transmitting the Shorehne Fault to PG&E (ADAMS Acceaalon No. ML120730106), the NRC placed its .assessment of the Shoreline Fault In context with the process outlined In the March 12. 2012 50.54(1) letter. The October 12, 2012 letter contained the followrtg guidance relative to the discovery of new seismic information

         ..~ l'jRC staff.UIJ<!.e.rstands !~! t~ _seis'!'~ _eya}f!s_tio(!s_d_e1£ri~ ip the_ M!fPI! 1?, 20!2.,

request for Information are currently ,n progress et OCPP, end PG&E plans to ecquira

                                                                                                             *- i for'INttllcl: Fonc: 10 p1 new offshore and onshOre two-end lhfff-dimensional ~smic reflection data to identify and characterize faults In the vicinity of DCPP. ff dunng the col/ectJon of the data, new faults are discovered or information is uncovered that would suggest the Shorellne feult is more capaola than currently O.lieved. the staff axpects that the licensee w/11 provide the NRC wfth an interim ,valuation that de:scrit,es aclion:s teken or planned lo eddres:s the higher :seismic hazard relat,ve to the design basis. as appropriate. prior lo completion of the eva/uabons requested ,n the NRC staff's March f 2, 2012, request for informelJon. The staff will use this information to Independently esse.s.s ~ther the new feult or new Information relat9d to Iha Shore/me fault cha&engos or chenge:s the stafr:s r;urrenl position that the motions assoaated with the Shore/,ne fault ere al or below tho,e levels of the HE and L TSP ground motions.

PG&E has been Informed that beaed on the NRC staffs understanding that the State of Califom1a report will contain new information relative to the Shoreline Fault, the NRC staff expects PG&E to provide an Interim evaluation that describes actions taken or planned to address the higher seismic evaluation. Other Fauns -{ 1-atW: Foot: 10 pt. Undtltne The PG&E 2011 Shorehne Fault rw rt and the staffs RIL also d1SOJSS other setSm,c faults near -- 1fQnnat:tad: Font: (Default> Arial P1abto canyon including lbe Los 010s and San Luis Bay 1au11s 11 ,, the sta[s pret,m,narv understanding that PG&E s report to the State of California will also mctude new mlormatlon reiatiye to these faults

I* --------- - { l'onnllttad: Font: (Default) Ariel PRODUCTS TO BE REVIEWED

• PG&E report to the State of California relative to ~ ~-Fau~

Diablo Canyon

• PG&E's Interim evaluation that descobes actJons taken or planned to address the higher seismic hazard relative to the design bas~

REVIEW PROCESS The staff will review the new seismic information when it is provided the opportunity Based on the new Information the staff may assess the new lnfonnatlon In accordance with the process that has recently been used ror Central and Eastern U.S. (CEUS) plants that is found in a March 11 , 2014, letter from EPRI (ADAMS Accession No. ML14083A586l The proposed milestones and tlmeframes for reviewing PG&E's report are as follows based on the assumption that the report win be publicly released on September 10, 2014. I Timeframe les ~  : Font* 10 pt l'or!Mned: Font 10 pt Formntad: Font: 10 pt

 ~                                                                           PG&E                    { format:tlld: Foot: 10 pt
 .Septa                Key NRC review team members review the State of California report prior to its public release.

NRC r;view team 1fonnKtad: Font: 10 pt Changes to the project plan and convnunicatlon Ian are lclentlfted j .Sept_19 PG&E provides report and lntemi evaluation to theNRC PG&_E_ 1Forwat:tlld: Font: 10 pt 1.sept 15 NRC identifies any addrtion.aJ information needs that rt has to com lete ,ts hmina evaluation NRC review team 1"°'1natted: Font: l Opt 1.s~~t 22 _ - - PG&E ~mplete! p~yii!i_!lg NRC staff with __ Information necessary for the staff to complete Its NRG f8\'l8W team~ -i Fonutted: Font: 10 pt prellmina evaluation

 ~Sept 29              NRC review team completes it preliminary              NRC review team        *( fonNtted: Font: 10 pt assessment of new Shoreline fault information and makes recommendation to management on how to proceed NRC management !!lakes decision on how to roceed
                                                                             ~C management          1~ : Font: 10 pc

The following are the proposed members of the review team sub1ect to management approval * - - - -{ fonnilttlld: Line spaong: single NRR Proj ects. Eric Oesterle, Ba~an1 Singal, Joe Sebrosky, Nidc DiFrancesco NRR lechnical: Kamal Manoly, Yong LI NRO technical: Cliff Munson, Brkt Hill. John Stamatakos (contractor) RES: Jon Ake Region IV: Wayne Walker, Theresa Buchanan, Megan W~liams, Tom H1pschman

COMMUNICATION PLAN A communication plan has been developed for the PG&E report. The NRC reV1ew team will update the communication plan baaed on its assessment of the new information.

From: Setrosky Joseph To: "Soeoeo. PtJHtope R"

Subject:

RE: question: do you know w~e a 9/10(14 letter from Olablo is In the process O.te: Friday, Septembcf 12, 2014 11:00:00 AM

Philippe, Thanks for the prompt response.

Joe

• • • • -Original Message--***

From: Soenen, Philippe R (maHto: PNS3@pge.com] Sent: Friday, September 12, 2014 11:00 AM To: Sebrosky, Joseph Cc: Nguyen, Kenny; Slngal, Balwant

Subject:

Re: question: do you know where a 9/10/14 letter from Dlablo is in the process

Joe, The DVD is a copy the of the hardcopy report. It is provided for ease of getting into ADAMS.

Philippe Soenen Sent from my iPhone On Sep 12, 2014, at 7:36 AM, Sebrosky, Joseph" <Joseph.Sebrosky@nrc.gov< maj!to:Joseoh.Sebrosky@nrc.gov >> wrote: I do not know. I will check with the licensee.

Philippe, can yoo confirm whether or not the CDs that the courier delivered on Friday are in addition to or are copies of the 1400 pages that were printed out. Any insights would be appreciated.

Thanks, Joe From: Nguyen, Kenny Sent: Friday, September 12, 2014 10:32 AM To: Sebrosky, Joseph Cc: Singal, Balwant SUbject: RE: question: do you know where a 9/110/14 letter from Oiablo is in the process

Joe, There Is also a CD submitted. Are the flies on the CO the same as the hard copies?

Thanks, Kenny Nguyen Project Officer/IT Specialist Office: 301* 287-0786 Mailstop: 3WFN-04C64M Alternate location on Thursdays I (bJ(G,1 I

From: Sebrosky, Joseph Sent: Friday, September 12, 2014 9:53 AM To: Nguyen, Kenny Cc: Singal, Balwant

Subject:

question: do you know where a 9/ 10/ 14 letter from Diablo is in the process

Kenny, I hand carried a 1400 page plus report to the doa..ment processing center on Wednesday afternoon.

The cover letter Is attached. Any insights on when I can expect it to be in ADAMS would be helpful.

Thanks, Joe PG&E is committed to protecting our customers' privacy.

To team more, please visit bttp://www.pge.com/about/company/prjyacy/customer/

l'rom: Sebrnsky. Joseph To: Markfex. M,d}aeJ; Oests:d<:, Erfc

Subject:

FW: Info: technical support needs r<< Olablo Canyon seismic Issues Date: Friday, August 29, 201'1 10:51:00 AM FYI - joe From: Hill, Brittain Sent: Friday, August 29, 2014 10:45 AM To: Sebrosky, Joseph; Jackson, Diane Cc: Case, Michael

Subject:

Re: info: technical support needs for Diablo Canyon seismic issues For the DPO Panel report, i can tell you that we wrote the report text with publi info, with the exception of new calcs that PGE did at our request For these calcs, we cited the damping values PGt used in the calcs for Shoreline ground motions. While these are not public, I doubt PGE would consider them proprietary. ""his info, however. 1s key to deMonscratmg chat DCPP design basis already acounts for potential effects of Shoreline in Catl SSCs. So its mportant to have these v.;lues available, or there will likely be an endless loop over ground motion vs des1gr Although we reviewed about a dozen nonoubl1c docs. they are listed separa ely from public docs in panel report. Not cited in text, either Simple to redact these refs Am n CA thru at least next week - fam ly emergency

• but have b,ackberry access Thanks-Britt Sent from Brittain Hill's PDA (b)(6)

From : Sebrosky, Joseph Sent: Friday, August 29, 2014 06:14 AM Eastern Standard Time To: Jackson, Diane Cc: Difrancesco, Nicholas; Oesterte, Eric; Markley, Michael; Whaley, Sheena; Markley, Michael; Munson, Oifford; Ake, Jon; LI, Yong; Manoty, Kamal; OKeefe, Neil; Walker, Wayne; Hipschman, Thomas; Hill, Brittain; Slngal, Balwant; Buchanan, Theresa; Balazfk, Michael; Uselding, Lara SUbject: info: technical support needs for Diablo canyon seismic issues Diane, The purpose of this email is to provide you with my opinion on the technical support needs for Diablo Canyon seismic issues. I know your question below was limited to the electronic reading room issue, but I believe there are additional non-trivial seismic review support needs. Perhaps 1t would be worthwhile to get the key branch chiefs together (i.e .. Eric Oesterle (DORL}, Sheena Whaley (NRO). Wayne Walker (RIV, DRP} and you} to discuss the near term Diablo Canyon seismic resource needs Below are the current issues that I believe require NRO technical support

• There is a Differing Professional Opinion that Britt Hill was involved with. OE is asking for help in reviewing the document for sensitive information We will likely need NRO support for this review
• The new information associated with the shoreline fault o The plan is outlined in the email below. The original plan to ask for immediate access to the document through the ERR process has been scrapped, however. we may take PG&E up on its offer to review the document through the ERR process two days prior to its scheduled release on 9/10/14. Regardless, Jennifer Uhle has made the decision that we should review the report in a timely manner (30 days was mentioned as being reasonable subject to change) after its public release to determine what changes, if any, need to be made to the approach to review new seismic information in accordance with the 50 54(f) process.

o The folks that have been mentioned for review of the report (both prior to and after its release) include:

• Yong Li, Jon Ake, Cliff Munson, Britt Hill, and potentially John Stamatakos (if we can get him through the existing NRO contract).

o It has been communicated to PG&E by both me and RIV that we expect PG&E to submit what interim actions they have taken or plan to take based on the new shoreline fault information in accordance with guidance provided to them in an October 12. 2012, letter (see ML120730106). We will likely need NRO help in reviewing this information

• Friends of the Earth petition o The attached request from OGC includes technical assistance in reviewing the petition and the response that is under development. Currently the list includes me, Kamal, and Yong. I believe it should also include Cliff and/or Jon Ake, and potentially Britt Hill. I would also like to include Neil O'Keefe from Region IV on the review. I understand it is management's call on who should help OGC with the review, but I would feel much more comfortable ii we had additional eyes on this work item
• c ommunication plans o For now a revised communication plan for the new shorehne fault report is being used as the vehicle to lay out the plan for reviewing the document.

NRO's help in reviewing the communication plan 1s needed, and as appropriate to help develop/review project plans As I indicated In another email._I am working from home this morn,.,g q I (b)(BJ

             <bl(61              f  My cell number 1s I       h, ,:       I ------

Eric, Sheena, Mike and Wayne. Please let me know ,f I am missing something as far as near term Diablo Canyon seismic support needs go. Thanks, Joe Sebrosky

From: Hipschman, Thomas Sent: Thursday, August 28, 2014 6:31 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; Balazlk, Michael; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Useldlng, Lara; Lyon, Fred; Buchanan, Theresa; Keegan, Elaine Cc: Weil, Jenny; LI, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael; Uhle, Jennifer; Franovlch, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy

Subject:

RE: info: updates to Diablo canyon shoreline fault seismic communication plan -update to 1st Item Additional update. The licensee will make the report available in San Francisco, or via electronic reading room two days prior to its release. tentatively set for September 10th. Please contact Philippe Soenen for details. From: Hlpschman, Thomas Sent: Thursday, August 28, 2014 1:32 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; Balazlk, Michael; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Lyon, Fred; Buchanan, Theresa; Keegan, Elaine Cc: Well, Jenny; LI, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael; Uhle, Jennifer; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy

Subject:

RE: Info: updates to Diablo canyon shoreline fault seismic oommunlcatlon plan -update to 1st Item The licensee informed me that the anticipated release date 1s September 10, and they will allow the draft to be reviewed up to two days in advance, or on September ath . The specific details whether this would require an in-person review or electronic reading room access is still being determined. Tom From: Sebrosky, Joseph Sent: Thursday, August 28, 2014 12:17 PM 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; Uselding, Lara; Lyon, Fred; Buchanan, Theresa; Keegan, Elaine Cc: Weil, Jenny; LI, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael; Uhle, Jennifer; Franovlch, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy

Subject:

Info: updates to Dlablo Canyon shoreline fault seismic communication plan To all, The purpose of this email is to provide you a summary of the current status of activities associated with the development of the communication plan to support the issuance of the Diablo Canyon State of California report associated with the shoreline fault. The list below

From: Sebrosky, Joseph To: Htoschman, Thomas; Mart,iev. MIChael: Qestcne. Enc; Kanatas, cathem,e* Reynoso John: Manofv K,ama1: Al!£. Jim; M\l]sqt. Ol!{ord: O!Cffle, Neff; Folk, Keyl(); P:Ecaf9'SP, NICholas: Bataz,k Mid)agl: Rc:YD9SQ, John: s,naa1, Batwant* H11 enttam* walker wavce: Useld,ng Lara: LYOQ. frgd; Buchanan Jheresa: Kwan Elawe* Jaoooo. Diane; wttrt ertan Cc: we,f. Jenny; ~ Monot,, K,amat; Lund Louse; Dud~k M,dlaet; Case M1chas:t* Burnell. S<ott: 11lll'... MJ.cba.gJ; E@ogvjch Mike; Wbillev Shfeoa: Bowman Grs:oorv; Bowen, l<:cerov; Mareno. Angel: Ba1uLls..

                  ~ w,marns, Meoao; Eorohottz, Thomas

Subject:

action: request for feedback on documents associated wfth Dtablo canyon shoreline fault Date: Friday, August 29, 2014 10:28:00 AM AtUc:hments: one page P@bfo se,sm1c qocos key CUfSSills:s dgcx oc cahf !jffilJ'llc mt comm Qian s 22-11 cev,s,on dOQl Pfabfo state ot cat fomja wisro:c ceoort r:mew Qian.dog To all, The purpose of this email is to request your review and comment on the following documents associated with the Diablo Canyon State of California seismic report that will include new information related to the Shoreline Fault: 1) an updated draft communication plan, 2) a draft project plan. and 3) a one page briefing sheet developed by DORL on the topic. The email also provides you with a listing of other Diablo Canyon seismic issues that will likely require resources from the headquarters and RIV to review. Communication Plan

• The communication plan has been updated to reflect that we will not have access to the report until two days prior to its public release scheduled for 9/10/14. It also includes an updated proposed key message from Tom Hipschman based on this approach.

Project Plan

• The attached draft project plan was developed to attempt to capture the expectations for review of the report including the review team, review documents.

and schedule. The project plan includes the assumption that PG&E will be providing an interim evaluation of actions taken or planned based on the new seismic information in accordance with the guidance found in the October 12, 2012, letter to PG&E. The expectation that PG&E will provide such an evaluatiion has been communicated to PG&E by both me and Wayne Walker.

• Eric Oesterle, Diane Jackson, Sheena Whaley, Wayne Walker, and Jon Ake, your feedback on the project plan is particularly important. Please let me know if I need to arrange a meeting on Tuesday to discuss the approach. Jon, I recognize that you are out of the office next week but any feedback before you leave would be greatly appreciated.
• Eric Oesterle, Balwant Singal, Nick DiFrancesco, Kamal Manely, Yong Li, Cliff Munson, Britt Hill, Jon Ake, Wayne Walker, Theresa Buchanan, Megan Williams, and Tom Hipschman, you are currently listed as supporting the review of the report. This was a guess on my part and subject to management revision.
• Diane Jackson and Cliff Munson, the project plan proposes the involvement of John Stamatokos (contractor) in the review because of his history and knowledge

associated with Diablo seismic issues. Any feedback on the proposal to have John involved would be appreciated. One Pager

• DORL developed the attached one-pager to be used as a communication tool for senior management. Your feedback on this document would also be appreciated.

Other Issues

• Friends of the Earth petition o OGC is coordinating the effort to respond to the recently received Friends of the Earth Petition relative to Diablo Canyon seismic issues.
• DPO o The Office of Enforcement will likely be asking for key people to r,eview the DPO decision, when it is available, for sensitive information so that it can be provided to the public.

Your comments on the attached documents are appreciated. 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

DRAFT - OfP'ICIAt. t,91! ONL I S1!l4S1Trt I! 114Tl!"f4,CL t1f P'e"w.T1e1f - 14e, re" ,1:18t..1e 9'1!L.1!,c91! UPDATED: 09/2512014 3:46 PM Communications Plan - Diablo Canyon Power Plant Top'i cs of Interest State of California Seismic Report {ABN*1632l

Background

Califomla Assembly 81111632 (Blakeslee, Chapter 722. Statutes of 2006) directs the Cahfom,a Energy Commission to assess the potenbal vulnerability of California's largest baseload power plants, 01ablo Canyon Power Plant and San Onofre Nuclear Generabng Station to a major disruption due to a seismic event or plant aging: to assess the mpacts 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 asSOCtated with the public release of this report. KevMttHR**

• The resident Inspectors and regional staff reviewed the licensee's documentation in their corrective action process of new preliminary information concerning OCPP seismic and licensing bases that the Shoreline fault may be more capable than previously determined. The information did not indicate there is an immediate threat to pubhc health and safety nor did it call into QU8Stion the ability of SSCs to perlorm their spec1fied 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.
• The NRC will continue to review the new information m the report and will take additional regulatory action as appropriate II the NRC staff concludes that the new Information associated with the Shoreline Fault causes the NRC to revisit its prefim1naJ)' evaluabon
• 0 1ablo Canyon will incorporate the 81111632 report's information into its March 2015 seismic hazard re-analysis submittal to the NRC.

DRAFT - err1e1M:. t:191! 6HLY S!l4S"rw ! Ufff!R Hat.L lf4f6RMNfl614 - tlllfl6lll... T..,lilellllR~,"4t:l

                                                                               ~a. - ,-e ..RNl!...

L!*! .. at.4 9*! Communication Team The primary responsibility of the commun1catton team Is to ensure that It conveys a consistent, accurate, and timely message to alt stakeholders The team consistB of lhe project management, technical, and commun,catlon staff named below Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1 148 Ryan Alexander Sr. Project Engineer R-fV/ORP/RPB-A 817-200-1195 Sr. ReStdent Inspector

• Thomas Hipschman R-IV/ORP/RPB-A 805-595-2354 OCPP Resident Inspector
• John Reynoso R-IV/ORP/RPB-A 805-595-2354 OCPP Jon Ake Senior Seismologist RES/OE/SGS EB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/OORULPLIV 301-415-1014 Balwant Singal OCPP Pro,ect Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-41 5-8204 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Cricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 BIii Maler State Liaison Officer RIV 817-200-1267 Elaine Keegan License Renewal NRR/OLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick OiFrancesco Japan Lessons Learned JLO 301-415-1 115 Planned Communication ActMtles The contents on this communtcabon plan, supplemented by information provided by PG&E/Olablo 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 RetD<>ntlble ParMIN ) Sept8 PG&E provides a draft of the report in the PG&E electronic reading room for initial staff ass.essment 2

DRAFT - err1e1.-: H!! e1*t, se1*s,,.1.-e 11*,e"r*~t n*re"M-..,..elf - t1114lefl..,...,..,e"""..."Ht:1..Bt.Mffe~1t*1t11JMtt~,-~s111eia Tlmeframe Action Rnponslble Party(ies) Sept 9 PG&E notifies NRC of seismic repOft submittal to PG&E the state of California Sept 10 PG&E/Dlablo Canyon Power Plant submit seismic PG&E repon to the state of Callfom1a 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 1O+ 1 busmess implements the Commumcattons Plan day) Entirety of Commun,cations Team nobfies R-4V; NRR/OORl. applicable Senior Managers in then respectJVe NRR/DLR, NRR/JLO reporting cham OPA. OCA. OGC OPA available to use Communications Plan to R-IV, OPA answer media inquiries. NO blog OR press release planned Oct3 JLO/NRO/RES completes preliminary assessment JLD/NRO/RES/RIV of published report and management decision is made ,t any additional actions should be taken prior to the submittal of the seismic reevaluation In March 2015. Updates to communtcabon plan as appropriate As reQuested Complete a Commissioners Assistants Brief R-IV; NRR

1. Quesuon, and An1wer1 What It 'the impact of thlt new infonnatlon on seitmlc design and llctntlng of DCPP?

HH the licensee entered this new lnfonnatlon Into the corrective action program and perfonned an operability ev1lu1tlon? As required by the NRC. as documented In 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 sei&mic data, new faults are discovered or information is uncovef'ed that would suggest the Shoreline fault is 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 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 Da1-lch1Accident.* March 12, 2012 The resident inspectors and regional staff reviewed the ficensee's documentat on 1n their corrective action process of new preliminary information concerning DCPP seismic and 3

ORAFT- Ol'Ple1*t t:.191!! 01.-Ci eEr*e"IVE 11*tEft..At lfff9ftMA'fler* - f4eT F8ft ,1::1eue Mt!:ASe licensing bases that the Shoreline tault may be more capable than preV10usly determined. The Information did not indicate there 1s an ll'IUT1ed1ate threat to public health end safety nor did it call into question the ability ot SSCs to perform their speafied safety functions or neoessary and related support functions The licensee's current actions meet the Manual Chapler 0326 guidance for having reasonable assurance of operability, pending further evaluation, The NRG wlll review the new informabon provided in the report to the State of Cahfomla Including the Shoreline Faull characteristics, and the u~ed charaeterlstJcs associated With the soil properties near the s11e Tile NRC staff ~ u take additional regulato,y act,on es appropriate 1f the NRC staff concludes that the new information associated WTth the Shoreline Fault causes the NRC to revisit the conclusions 1n the RIL

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

The new information, required by lhe 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 Fault 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 LTSP evaluations continues to bound potential ground motions from the Shoreline Fault

3. How wlll the AB 1632 seismic report be coordinated with the 50.54(f) requjred aubmlttal 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 with the process defined by the NRC in their Fukushima 50.54(f) letter. This requires an NRC~ndorsed formal structured process to evaluate alternative interpretations When developing the final seismic hazard and Ground Motion Response Spectra (GMRS) that will be submrtted to the NRC by March 2015. The updated seismic hazards will be used as an input to any Seismic Probabilfstic Risk Assessment (SPRA) Dlablo Canyon might have to submrt to the NRC by µune 2or7l * ~ U - 1 ):50.64{1),._,glw,3~ (If pushed on any *unknowns* tn the report: If neoessary, actions could include orders to flt lallO:ll' lie Jin 2017 -.1 lo do 1h11 whlc/l ...,.,CS 119 -Ch 2018. - 11 halt operations if new information sugge,ts there ~ an immediate safety conoem. The NRC will fulfill its mandate to protect public health and safety) (If asked what things the plant has done since Fukushima. It 1s 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 1n the event of a beyond design basis event).

4. Why 1, the report "flnal" for the state but " preliminary" for the NRC?

For the s.tate, the report is final. For the NRC, this information 1s expected to be incorporated 4

DRAFT - 61'1'te"'1: tlS! 6Ht:1 91!14Sl,rtt llffl!ftf4ili t: lf41'6ftMililfl614 - N f4fll6"'T"'fllf'6~ft!-tfl~tl"ftl!llllt...lel'!-tlft!fl!II-L£~A~SP! Into the more comprehensive 50.541 analysis due lo the NRC In March 2015. However, because the licensee must notjfy the NRC of any new seismic info, they have shared thtS report and an ln1tal operab,hty evaluaUon shoWtng why the plant ts safe to operate The NRC has looked at this evaluation and its praftminary assessment ts that based on the Information presented by PG&E the Shoreline Fal.At does not exceed previously oon&ldered seismic hazards.

5. Why didn't the NRC discover the length of the faults w hen It did Its seismic review of the Shoreline fault In 2011 prior to laaulng the Rll ?

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability or 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 Jmpacts of such a dJSrupbon on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste acan,ulating at these plants, and to evaluate other major issues related to the future role of these plants in the slate's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping tecmiques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to charactenze the Shoreline Fault In the 201 1 report. The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analysis whic:h is due fo, DCPP in March 2015.

6. What 11 the Impact of this new lnfonnatlon on set,mlc design and llcen,tng of DCPP?

Based on the prelminary resutts of the studies that are under review, PG&E determined that the ShoreHne Fault Zone may be capable of producing somewhat larger earthquakes than considened in the January 2011 PG&E report The staff 1s 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 JS scheduled to provide this assessment in the Marc:h 2015 bme frame The staff is currently reviewing the 1nfonnation in the Shoreline fault report and will assess the more complete assessment of new se1sm1c 1nfonnation scheduled to be provided ,n the March 2015 time frame. The NRC staff will take appropriate regulatory action up to and including Issuing Orders to ensure safe operation of the plant.

7. WIii the Report be con,ldered In the llcenH Renewal ProceH Yes. In addition to the report being developed to address California Assembly Bil 1632 PG&E is providing the report to the State of California as part of the State of Califorr11a coastal zone consistency certification associated with the license renewal for OCPP. The State of Califomia 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 ASLS in the license renewal process (see ML14224A320).

5

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8. The AP wire HMCe recently reported that there Is a Differing Profnslonal Opini on (DPO) aasoola18d with NRC'a evaluation of the Shoreline Fault. Why has th* exlatence of this OPO onty now been m_ad. public?

Tile OPO process ,s a strictly controlled and fomiallzed prooess Wlth,n the agency that allows differing professional opinions to be th0<oughly considered by the agency wtiile at the same time protecting the privacy of the DPO submitter. A OPO was submitted and is still undergoing internal NRC review In aocordanoewith this process Unul the NRC oompletes Its internal review process tor thls OPO, the agency ,s unabte to comment on any Potential DPO resolutJon 01 documentation. Ones the review ~ completed lhe agency will have a final clec.ision r:>n the OPO and associated documentation. 6

Project Plan for NRC Staff Review of PG&E's Report to the State of California Regarding the Shoreline Fault 8/2,/14 Version NOTE: This Is a Jiving document and will be updated as necessary. Please note the date on the cover. Document Point of Contacts: Joseph.Sebrosky@nrc.gov Nick.DiFrancesco@nrc.gov Japan Lessons Learned

TABLE OF CONTENTS Purpose of the Review of the State of California Report ................................................................................2 Background .....................................................................................................................................................2 Products t o be Reviewed ................................................................................................................................ 3 Review Process ................................................................................................................................................ 4 Review Team ........................................................................... .......................................................................4 Communication Plan ....................................................................................................................................... 5 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 the Shoreline Fault near the Oiablo Canyon Power Plant (DCPP). The purpose of the assessment is to determine what, if any, changes need to be made to the approach ou11ined in the March 12, 2012, request for information associated with new seismic information (see ADAMS Accession No,. Ml12053A340) 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, 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 rellablllty, public, safety, and the economy; to assess the costs and impacts from nuclear was,te 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 in PG&E's 2011 Shoreline Fault evaluation (ADAMS Accession No. ML110140431). Based on Information that PG&E has verbally provided, PG&E has indicated that length, and magnitude of the Shoreline fault is greater than that assumed in a 2011 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. 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 LTSP earthquakes. The staff previous evaluation of the Shoreline Fault can be found in Research Information letter (Rll ) 12-01 "Confirmatory Analysis of Seismic Hazard at the Oiablo Canyon Power Plant from the Shoreline Fault Zone" (ADAMS Accession No.ML121230035). The staff's deterministic evaluation includes several scenarios and resulted in the conclusion that the Shoreline Faull 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 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 relabve 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 staff's 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. ZI Page

2 .5

               -      Hoiopll_.,m
               -      lTSP.-
               - - NRC Mt f . ..,
~     2 .0     - - NRCM,t1 , . ."lo C

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en 0.5 0 .0 0 .1 1 10 100 Frequency (Hz) In addition, in the NRC's October 12, 2012, letter) transmitting the Shoreline Fault to PG&E (ADAMS Accession No. ML120730106), the NRC placed its 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 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 currently believed, the staff expects that the licensee will provide the NRC w;th an inten*m 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. 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 provide an interim evaluation that describes actions taken or planned to address the higher seismic evaluation. PRODUCTS TO BE REVIEWED

• PG&E report to the State of California relative to the Shoreline Fault
• PG&E's interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, 3I Pag e

REVIEW PROCESS The staff will review the new seismic information when it is provided the opportunity. Based on the new information the staff may assess 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 proposed milestones and t1meframes for reviewing PG&E's report are as follows based on the assumption that the report will be pubhdy released on September 10, 2014. Responsible Tlmeframe Action Party{ies) Sept2 NRC staff identifies information that it will NRC review team quickly need from PG&E to support a possible review in accordance with the process found In the CEUS study above Septa Key NRC review team members review the NRC review team State of California report prior to its public release. Changes to the project plan and communication plan are identified Sept10 PG&E provides report and interim evaluation PG&E to the NRC Sept15 NRC identifies any addition information NRC review team needs that it has to complete its preliminary evaluation Sept22 PG&E completes providing NRC staff with NRC review team information necessary for the staff to complete its preliminary evaluation Sept29 NRC review team completes it preliminary NRC review team assessment of new Shoreline fault information and makes recommendation to management on how to proceed October 3 NRC management makes decision on how NRC management to proceed 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 Region IV: Wayne Walker, Theresa Buchanan, Megan Williams, Tom Hipschman 41 Page

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. SI Page

PG&E Seismic Report (AB 1632) Key Messages:

• The licensee is always responsible for ensuring safe operation of its facilities
• Licensees perform operability determinations to ensure the structures, systems, and components (SSCs) remain operable as required by the plant Technical Specifications
• When new information is identified by the licensee, NRC, or a third party, the licensee performs an operability evaluation
• Licensees also perform evaluations to ensure the SSCs meet their intended safety functions

 , particular1y when a degraded or non-conforming condition exists.

• Licensees also use their probabilistic Risk assessments (PRAs) to assess the functional and operability of the plant and or/certain SSCs
• Licensees also enter this information and associated studies in its corrective action program (CAP)
• NRC performs regulatory oversight of the licensees decisions using the Reactor Oversight Process (ROP) including both the operability determinations and use of the CAP
• NRC Guidance Is provided in Inspection Manual Chapter 0326, MOperabllity Determinations and Functionality Assessments for Conditions Adverse to Quality or Safety"
• PG&E has performed additional seismic studies as required by California Coastal Commission and California Public Utility Commission with state-of-the-art methods in accordance with Assembly Bill 1632
• PG&E expected to submit Seismic Report to CA State on September 9 or 10, 2014
• PG&E has stated they will provide the Seismic Report to NRC at or about the same time
• PG&E has stated that the new Seismic Report will provide additional characterization of the Shoreline fault, has performed its operability and functional evaluations, and is entering it into its CAP.
• PG&E has stated that the Seismic Report concludes that the seismic risks are bounded by the Hosgri fault and that Diablo Canyon remains within its design and licensing basis
• NRC will independently verifying the operational/functional evaluations performed by PG&E when the report is available
• NRC actions will include:

o An initial evaluation of the licensee's operability and functional determinations by the resident inspectors, regional staff, and any needed Headquarters support o A more detailed evaluation by seismic and structural experts o An evaluation of the risk estimates relative to the Commission's Safety Goal Policy Statement o An evaluation of the Seismic Report and the information expected to be provided in response to the 10 CFR 50.54(f) letter on Fukushima actions

• At present, the NRC has no new information that would result in immediate regulatory acti on, however, the NRC does not preclude taking regulatory actions should the results of Its assessment warrant such actions
• NRC expects that the results of the seismic study will be considered as part of PG&E's response to the NRC that is due in March 2015 in response to the 50.54(f) letter requesting information on updated seismic hazards

From: Htpschman, Thomas To: sebrasky. Joseoh: Maddey. Michael: Qestede, Enc: Kanatas. Cathenne: Reynoso John: Manoty. Kamal: ~ m Munson. Chfford: QKecCe, NcJt: Fofk. xevm: wrona. payrd: P!Ecaarnc;o. Nicholas: Salazfis. Michael: Reynoso John: Sjngal Batwaat* Hill, BdtteiQ; watter. Wayne: Uscldtna Lara: Lyon. Fred; Buchanan. Iberesa: Keegan. E1a1oe Cc: we,1. Jennv; LJ....l'.Qn.g.; Manoly. Kamal: Lund. Lovtse; Dudek, Michael: case. Michael; BumeH. Scott; ~ Sheena; Hav. Md)ael: Yble Jcoaiter: franov,d]. Nike; Whalev. Sheena: Bowman. Greoory: Bowen. Jecerov

Subject:

RE: Info: updates to Oiablo Canyon shoreline fault seismic communication plan

• update to 1st Item Date: Thursday. August 28, 2014 6:31:22 PM Additional update.

The licensee will make the report available in San Francisco. or via electronic reading room two days prior to its release. tentativ,ely set for September 10th. Please contact Philippe Soenen for details. From: Hipschman, Thomas Sent: Thursday, August 28, 2014 1:32 PM To: Sebrosky, Joseph; Markley, Michael; Oesterle, Eric; Kanatas, catherine; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, d ifford; OKeefe, Neil; Folk, Kevin; Wrona, David; Difrancesco, Nicholas; Balazik, Michael; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Lyon, Fred; Buchanan, Theresa; Keegan, Elaine Cc: Weil, Jenny; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael; Uhle, Jennifer; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy

Subject:

RE: info: updates to Diablo canyon shoreline fault seismic communication plan -update to 1st item The licensee informed me that the anticipated release date is September 10. and they will allow the draft to be reviewed up to two days in advance, or on September ath. The specific details whether this would require an in-person review or electronic reading room access is still being determined. Tom From: Sebrosky, Joseph Sent: Thursday, August 28, 2014 12:17 PM To: Markley, Michael; Oesterle, Eric; Kanatas, Catherine; Hipschman, Thomas; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Clifford; OKeefe, Nell; Folk, Kevin; Wrona, David; DIFrancesco, Nicholas; Balazlk, Michael; Hlpschman, Thomas; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Useldlng, Lara; Lyon, Fred; Buchanan, Theresa; Keegan, Elaine Cc: Weil, Jenny; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael; Uhle, Jennifer; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy

Subject:

info: updates to Diablo canyon shoreline fault seismic communication plan To all., The purpose of this email is to provide you a summary of the current status of activities associated with the development of the communication plan to support the issuance of the Diablo Canyon State of California report associated with the shoreline fault. The list below includes action items. Wayne Walker, Eric Oesterle, Jon Ake, and Mike Markley. if I missed something please reply to all.

From: Roth(OGQ. David Sent: Thursday, August 28, 2014 1:21 PM To: Manoly, Kamal; Li. Yong; Sebroslcy, Joseph; Singal. Balwant Oeste,rle. Erk Cc: Lindell, Joseph; Young, Mitzi; Roth(OGq, David

Subject:

Attorney Client Privilege Categories: non hearing material Good afternoon Kamal, Yong and Joe, (b)(S) David Roth 5 NRC Blackberry ! (b)\ l HQ Office (301 ) 415*2749 Tliis message 111a1 eo"teh, awsili.o idle:: al i::f:rn re ,QR&idectid To be 9Hiieia1la111 Q* I; AU0P1 .eiy Glie~t P,iYilege er iA,t:te Ff:18Y 'A(Qdc Pcod11ct David Roth NRC Blackberry! lbH6l HQ Office (301 ) 41 5-2749 l liis 111essage 111ay contain saositive iiile11 ,al info1111atio11 ee"ei8eFeel te lie

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From: SebrQSkv, Joseph To: Buchanan Theresa Cc: MarkJev Michael Subject! RE: Info: updates to Diablo Canyon shoreline fault seismic communication plan D1te: Fr1day, August 29, 2014 9:04:00 AM Attachments: Piabl9 State of Cafi{oCD1a cms:w oJan.docx oc Cahf se,sm c mt mmm 01ao s-22-1, rev,s,on ooos Mike Markley has the lead. He is supposed to give me something so that I can update the communication plan. Attached is the revised comm plan that I will provide to the broader audience once l get Mike's input. l am also developing the attached review plan that I hope to complete in the next hour or two to give to the team. Joe From: Buchanan, Theresa Sent: Friday, August 29, 2014 9:03 AM To: Sebrosky, Joseph 5ubject: RE: info: updates to Diablo canyon shoreline fault seismic communication plan

Joe, I've gotten a request from RIV management to receive a copy of the 1 page communication tool/talking points NRR/DORL is developing/has developed Do you know who specifically has the lead on that?

Theresa Buchanan Senior Project Engineer RIV DRP Branch A 817-200-1503 From: Sebrosky, Joseph Sent: Thursday, August 28, 2014 2:17 PM To: Markley, Mlehael; Oesterle, Eric; Kanatas, catherlne; Htpschman, Thomas; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Clifford; OKeefe, Nell; Folk, Kevin; Wrona, David; DiFrancesco, Nicholas; Balazlk, Michael; Hlpschman, Thomas; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Useldlng, Lara; Lyon, Fred; Buchanan, Theresa; Keegan, Elaine Cc: Weil, Jenny; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael; Uhle, Jennifer; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy

Subject:

info: updates to Dlablo canyon shoreline fault seismic communication IJ@n To all, The purpose of this email is to provide you a summary of the current status of activities associated with the development of the communication plan to support the issuance of the Diablo Canyon State of California report associated with the shoreline fault. The list below includes action items. Wayne Walker, Eric Oesterle, Jon Ake, and Mike Markley, if I missed something please reply to all.

From: Seorostv, Jmon To: Maditex, Htcti:agt Ocao1c, Euc; "3wtiK, ~ ; H*QS<hmao IlMmi!S' BtYDos9 lPbo' MaooN Kam4!* & Jgo; MupsqJ C(iffQ<<I: OICl,'ffe, tie<<: F S !Scro; \'wrgna Olly d. QjfI4QCC'fU>i NCDQ!m i Bajaz1k,, MtdJact: tJ,pghman. Thomas: 8eynm, 2obo: s,nqat. aa1wi1m, tt11, so~m: wa1ka:, wavoe; Us¢At09 Lara: L.YoO, Ec<:d: Buchanan, Ibecesa; Keegan flame Cc: we,1. Jenny: u....nm.; Maoolr, ,s.,mat; Lund, Loo,e. 0ooe1c,, M/(:l)MI: case, M1ctm1: evme* Scott* ~

                    ~ Hax M11ia:#1 lRllc lmmfec E!M9Y?<!> t11he* ,Yl>>!!:Y Sbeer:A {ICW!'\an CireaQIY: BQwea, lft:cmx

Subject:

Info: ul)dates to Oiablo canyon sh<nllne taolt seismic communication plan Date: ThorsdaV, Augu!t 28, 201'4 3*16:00 PM Attachments: oc c.w S<:1$JK rot cgmm oiao s>1l ,aa cro pocx Note: ML14083A586 is FW comm f'lao,mso 03-12 11 NRC x/Sm1c RlSk Eyatuat)OQ$ fQ{ CEUS Pilots Mll1Ql13a58& aal publicly available in ADAMS. To all, The purpose of this email Is to provide you a summary or the current status of activities associated with the development of the communication plan to support the issuance of the Diablo Canyon State of California report associated with the shoreline fault. The 11st below includes action items. Wayne Walker, Eric Oesterle, Jon Ake, and Mike Markley, if I missed something please reply to all. Status

• PG&E (Philippe Soenen) informed me that PG&E management does not support the use of provide a draft copy of the report in an electronic reading room. Based on subsequent discussions with Jennifer Uhle, NRR will not pursue the issue further.
• The attached communication plan will have a major revision based on the NRC staff not being able to review a draft of the State of California report prior to its targeted issuance on 9/9 or 9/1O. I have an action to provide a revised revision to everyone tomorrow morning. The revision will include:

o The attached hi-level main message from Tom Hipschman o A t + 30 day time frame for the NRC to complete its initial assessment of the Shoreline Fault information

• The assessment will include whether or not the NRC staff will be able to say with confidence that the new information does not invalidate the 2012 RIL's conclusions that the Shoreline Fault continues to be bounded by Hosgri and LTSP
• If such a statement cannot be made then appropriate regulatory action will be taken, including possibly assessing the new seismic information in accordance with the process used for the central and eastern U.S. plants outlined In the attached pdf document
• I will work with Wayne Walker and Tom Hipschman to communicate to PG&E the NRC's expectations that PG&E will provide an interim evaluation of the new Shoreline fault information in a timely manner consistent with the following guidance in the October 12, 2012, letter to PG&E that transmitted the RIL:

                  *ff 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 NRG

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 infonnation."

• NRR/JLD will work with NRR/DROL, NRR/DE, NRO and RES to identify information that NRC will likely need to perform its preliminary assessment in the 30 day time frame after receipt of the State of California report. This information is likely to include that which is necessary to perform the type of analysis discussed in the attached CEUS pdf document.
• NRR/DORL will develop a one-page communication tool similar to what was developed for the DPO, highlighting the process the NRC uses for reviewing operability determinations.

Please let me know if you have any questions. of if I am missing something. I will keep you informed of developments as they progress.

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

DRAFT - OPl'lelAt t,31! ONLi Sl!1*ei,1,11! 114Tl!IU*At n*P~M"'Plet* - lfOT reft l"tn,ue ftl!tl!Jlt31! UPDATED: 0912512014 3:49 PMOflffiiOU ii14 Jifll919?519:l4 i ill Aa,!Ol!a§ll014 l :11 PM08~ila01 * ~;C7 PM Communications Plan - Diablo Canyon Power Plant Topics of Interest State of cautornia Seismic Report tABN-1632)

Background

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerabihty of California's largest baseload power plants, Diabl'o 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 evaluale 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 1s 1..d1fferent and more extensive data set mell~edeleg~ than what was used for the 2011 Shoreline Fault evaluation. i

                                                                                                  * * * ~ J: .J>~Modled                   1o be conN1en1 The purpose of this communication plan is to provide key messages associated with the public release of this report.

Kev Messages

• Based on a preliminary evaluation, NRC staff concludes the IIhe em 1632 report*s Information is consistent w1th Sl;lf>00$ the NRC's and PG&E's existing conclus1ons that D1ablo Canyon's seismic design basis already accounts for ground motions evakM larger than ~those&- postulated for a longer Shoreline faulk>af! eee,rate; Therefore _ -
• c:-..nt U2): :r;>"-N .tlen we can1 the NRC does not currenuv have a safety concern wsth the structures, systems, and IUppo,t .... blMII l'ln*IO problem lfflOng °'*

                                                                                                          " -* You canl AY 1h11 llefore we hlN9 -

components necessary to reach and maintain safe shutdown, being able to perform their leld-reaon.,.._,i--- wordint MUSI wll lo NY fu unlJ tec:t,niQI Intended tunctJon should the site expenence en earthquake from the Shoreline feult MIi - .. Ille VW'f _, clone

• replcl, cura<<y rud of h rei,o,1.
• The NRC will continue to review the new information in the report and will take additional regulatory action as appropriate it the NRC staff conciudes that the new intormatjon associated with the Shoreline fault causes the NRC to revisit its Q!elim,nary evaluation
• D1ablo Canyon will incorporate the s,11 1632 report's ,o[ormatron mto rts Marcil 2015 se1sm1c hazard re-analysis submrttal to the NRC

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                                                                                     ~t,~B"'L~lf'!

C"'ft"'l!"L'"' l!'IIIA~3P f! Communication Team The pnmary responsib lity of tt,e communication team ,s to ensure that ii conveys a oonststent, accurate, and timely message to all stakeholders The team consists of lhe pro,ect management technical, and communieauon staff named below Team Member Poaltlon Organfution Telephone Wayne Walker Branch Chief R-IV/ORP/RPB*A 817-200-1148 Ryan Alexander Sr. Project Engineer R-N/ORP/RPB-A 817-200-1195 Sr. Resident Inspector - Thomas Hlpschman R-N/DRP/RPB-A 8~595-2354 DCPP Resident Inspector - John Reynoso R-IV/DRP/RPB-A 8~595-2354 DCPP Jon Ake Senior Seismologist RES/OE/SGSEB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORL.n..PLIV 301-415-1014 Balwant Singal DCPP Proiect Manager NRR/DORL.n..PLIV 301-415-3016 Scott Bunnell 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 Useldlng Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 DaveW~Aa~ I Keeoan License Renewal NRR/DLR 3Q1-415-8517 I ~1111:n: ~l!OIIIH ~ OGC ~Ql-4l~,~,1 I Nick D1Francesco JiU2s!n LH!i!2Dli LH'DSI~ JLD JQl~l~ll1~ e1,nned Communication Actlvltle, The contents on this communication plan. supplemented by infonnabon provided by PG&E/D1ablo Canyon, should be used to accompfish these ~ction -- -- ...... ~ U , ]:JPl,r

                                                                                                                                         ~lnllll ........ doa -                 acluaty look Ill the report?

Tlmeframe les Lool{1 illlewltl*11 day we 00 !Mo twtll1n8 mode T- 7 days T- 1 2

DRAFT - el'l'ICl>'ll 1:191!! erftv S!l4!1flY! llfT!ftHAL llffeftMA,1e14 - HeT Feft l'HBlle 9'!L!A9! Timeframe Action ResponsibJe Party(ies} T=O 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 lhe Communicabons 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 respecwe 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. Within T+Z2 G0~8F aGtieR1~~LQ ~m12l!l!t!l!i 12r~lmin51!:)'. ~LQ/NRO business days i!H~Sm!nt of fini!I riQQ!1 l2 ~l~!!!Jine if i!n~ i!!:l!:li~QOi!I i!giQ~ ~hQ!,!I~ be li!k!l!n QrlQr IQ the

                    §!,!~mi!li!I Qf th!i! §~~mik rmi!l!,!i!tiQD iD Mi!C£l 2015 As requested         Complete a Commissioners Assistants Brief                R-IV; NRR

1. Questions and Anewe!J What le the Impact of this new lnfonnation on seismic design and llcenelng of DCPP?

Haa 1he licensee entered this new infonnatlon into the corrective action program and performed an operability evaluation? As required by the NRC, as document~ in 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 ShOf'eline 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 lnsig'hts from the Fukushima Oai-lchi Accident,' March 12, 2012 Region IV including the resident inspectors, have undertake" an initial ~e_Y~'!"-o_fp_G&E's I ----I Commait [J4J: JP~?Ok? assessment of this new information to verify that rt does not affect the plant's ability to operate safely and to be able to remain safely shutdown following an earthquake. NRC's 3

DRAFT - OflPICt*t t,SI! ONL, 9ff49fffVE lfffeftf#cL lf4f8ftMM'l81f - f48T 1'8ft l'tf8Lte iteLeit.9! preliminary review Is that the D1ablo Canyon Units are safe to continue to operate based on.

• ABa&ee M assertions made by PG&E that the Shoreline Fault response spectra are still bounded by those for the Hosgn and LTSP earthquakes for which the plant was pre\liously ~nalyz~ - COfflfflellt OJ.11W. eh0\11'1 andclpn
• ex!WMI querion he!HI M NRC retttng only
• The prelirninary assessment by PG&E of the data acguir~ for the CAABl632 OIi In. PG6£ -*11*.c?

report ind!cates that the Shorehne Fault ~+6-<:apable of generating a magnitude 6 7 earthquake. kJ documemed in the RIL the NRC staff has analrzed a scenario involving a Shoreline Faul1 or magnitude 6 7 and concluded that the response spectra developed by SUCh an earthquake 1s bounded by the Hosgrl and LTSP spectra The NRC will review the new information provided in the report to the State of Cahfomia indudmg the Shoreline Fault characterisbcs, and the updated charactenstJcs assooated with the sod properties near the site. The NRC staff wil take additional regulatory action as appropriate if the NRC staff condudes that the new information associated with the Shoreline Fault causes the NRC &laff.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 maffl a,e..connected These conneellons Indicate that If the Shoreline Fault shps in the future, the earthquake magnitude from that slip might be somewhatligAtly higher than previously considered possible for the Shoreline Fault. However. the new data does not alter the assessment of the ctosest approach of the Shorenne fau't to the DCPP. ~ u s e the Shoreline Fault is somewhat longer, potential earthquakes could also occur farther from the plant. For these reasons. PG&E conbnues to believe that the ground motions for the Hosgn and LTSP evaluations continues to bound potential ground motions from the Shoreline Fault.

3. How wllll the AS 1632 aelsmlc report be coordinated with the 50.5'(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 ground motions from the Shoreline fault remain& bounded by those from the Hosgrt fault for which the plant was designed and licensed to withstand. The staff will continue to review the new information associated With the Shoreline Fault and ~mess if it ~us~ the_f!~~ ~to ~~ _!.tle_~ I l l ! ~ i!)_ti)~ !3IL -*-*1 ~ mlulnglwe. (Jl]1.JP, . , _ .. , _ _.

  !The 1000-page document has also been given to the ~Japan Lessons Learned Directorate} to be considered in the 50.54(f) review. Consistent with the UFSAR, the new               Comment [Slla37]: This pt,raliig Implies the preliminary information regarding regional ~source characterization (i.e. fault                        JlD II pe,formlng the M11mlc ,._enalytlt. How llbo<II "l"t. JLO wll contkl.. 1"- A8 1632 ropo!t capability) and potential site ground motion will be evaluated in accordance with the process         Wilen a revtewa Diabk>Canyon't GMRS defined by the NRC in their Fukushima 50.54(f) letter.1This requires an NRC-endorsed                   IUblnllllN In Mllrch 2015' f rm I          red          t evalu             *

• when
• th IM:M:ltJ~~Hif'~olilf86El66--~Ht-final seismic hazard and Ground Motion ResJ:1'()nse _, -- 1 ~ [JIJ 1 R ~ ...... llle Spectra (GMRS) that will be submitted to the NRCfoy March 2015 The updaie<fsefsm1c 4

DRAFT - el'l'lelAL t:19! OHL I se:r*s1tl't'! Hff!"r*At 11*re"w."er* - r*et re" rtn,ue "!L!A!! h~Qrc;ts Se1sm1a MazaresJGMRS will wa1:1le will be used as m1np1.11 to a~ 1:1pdatoo Seismic ProbabHlsUc Risk Assessment (SPRA) D1ablo Canyon might have to, w~Gh will be submlttoo to the NRC ~~~~-2_0J?L _ _ _ _ _ - COfrl-.t (Jt]: GMRS Is not \lad M PAA-(If pustled on a11y *unkt'loWns* in the report* If neoessary. actiOns could 1nchde orde~ to . - ------------<

                                                                                                          ~ harard QJMlt f t c - i t [JIJlO): c... the J\.O Cl\tClc Ille June 2017 llnl. TIie :J/12112 ~ 54(1) IIW halt operations if new information suggests thel'9 is an immediate safety ooncem The NRC              Qll,fl up IO 31U't 'O ~ lie Mil/TIC will fulfill rts mandate to protect public health and safety).                                        PAA Iller lhe GMRS It fUOl'nltl9cl In Mll'l!I d 201!. 11 IPPNR 'Iha PG&E WOllld hew ri li!IIUI 2011 ln:. ..O d .Mll 2011.

(If asked wha~ ~ the plant has done since Fukushima* It is important to note that OCPP is an Industry leader in implementing FLEX wtueh was a post-Fukushima industry lnlt1atr.ie to heve extra equipment available remotely in the event of a beyond design b3s*s event)

4. 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 expociod to be incorporated 00Rs1dere(}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 evaluatt0n showing why the plant is safe to operate. The NRC has looked at this evaluation and its prehm1nary assessment 1s that based on the lnfOflllatlon presented by PG&E -the Shoreline Fault does not exceed previously considered seismic hazards. S. Why didn't the NRC dl1cover the length of the fault:a when it did Its ael1mlc review of the Shoreline fault In 2011 prior to issuing the RIL? CaHomia Assembly 8111 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the Cafifomia Energy Commission to assess the potential vulnerability of California's largest base;load power plants, Olablo Canyon Po.var Plant and San Onofre Nudear Generating Station, to a ma1or disruption due to a seismic event or plant ag'°g; to assess the Impacts of such a disruption on system rellabilrty, 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 hcensee has used the most state-of-the-art 2D and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide i higher-resolution data than what was available to characterize the Shoreline Fault In~ ____

• c - t auJ: KAI)' po1n1 2011 report.

The NRC has requested licensees of operating nudear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analysis which 1s due f0< OCPP m March 2015. (Lauren, JLLD. anything to add here?) I 6. What It the Impact of -this new Information on aelsmlc design and licensing of DCPP? Based on the preliminary results of the studies that are under review, -PG&E detenn1ned that the Shoreline Fault Zone may be capable of prOducing s ~ larger , Com!Mllt UU]: J P ~ to be dew Ille earthquakes than considered In the January 2011 f.Q.IDepofl However, the ground ,, megnllude lncrNM 11 l1IIIIMI lo Ille PG6E mellfflllide, the RU UMd 8.7. 5

CRAFT - el'l'lelAL tl3f 6f~LY er;14er,r11e lff'l'!ftffAL IHP'eftMATleN - HOT relit rt1Bt1e ft!L~3! motions from these larger earthquakes are S!JII bounded by the Hosgn and LTSP ground motions. Since tl'le seismic design of DCPP considered a range ot ground motions from both a :oouble design ~arthquak4( and a Hosgrl earthquake and tne new ground motions do not exceed the Hosgrt earthquake. lhe new information rs not expected to adversely

                                                                                               .-1 =--UUJ;P~--ll>dollntt Impact the seismic design ot DCPP As a resuh, the assessment assocaated wi1h tne January 2011 Shoreline Fault Report remains vahd.

7 WIii the Report be considered In the LlcenJt Renewal Process Yes, tn addition to the 19oort being developed to address cahfom1a Assembly Bill 1632. PG&E ,s providing the report to the State of California as part of the State ot California coasta11zone consistency certification associated with the license renewal tor DCPP The State of California coastal zone consistency certification is considered by the NRC dunng the license renewal environmental review process In addition. the Atomic Safety and Licensing Board <ASLB) has expressed interest in the report because 4is associated wjth a contention that is under consideration by the ASLB ,n tthe license renewal process <see ML14224A320l

s. The AP wire aeryice recenuy reported that there 1, a Plfftrlna Professtonar Opinion CQPO) associated wfth NRC'a evaluation of the Shoreline Fault. Why has the existence of this QPQ only now been made public?

The OPO process js a strictly controlled and formahzed process within the agency that allows differing professional opinions to be thoroughly considered by the agency while at the same time protecting the privacy of the DPO subrmtter A OPO was submitted and IS still undergoing intemal NRC revie::H in accordanoe wtth th s P!OQ8!S Until the NRC completes rts internal rev1tw process for this OPO. the agency is unable to comment on any potential DPO resolution or documentation once the rev ew 1s completed the aaencv w111 have afinal deQs,on on the QPQ and associated gocumentat,on 6

From: Hipschman, Thomas Sent: Thursday, August 28, 2014 12:22 PM To: Sebrosky, Joseph

Subject:

FW: Comm Plan Categories: non hearing material FYI From: Hlpschman, Thomas Sent: Thursday, August 28, 2014 8:59 AM To: Buchanan, Theresa; Walker, Wayne; Reynoso, John SUbject: RE: Comm Plan

Wayne, Here's my current thinking on how to state the operability call for the comm plan.

Tom The resident inspectors and regional staff reviewed the licensee's documentation in their corrective action process of new preliminary information concerning DCPP seismic and licensing bases that the Shoreline 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. From: Buchanan, Theresa Sent: Thursda,y, August 28, 2014 5:58 AM To: Hipschman, Thomas

Subject:

RE: Comm Plan The latest version I have is the one you sent Joe Sebrosky with your comments. From: Hipschman, Thomas Sent: Wednesday, August 27, 2014 5:33 PM To: Buchanan, Theresa SUbject: Comm Plan

Theresa, Can you please send me the latest section of the comm plan that discusses the resident inspector review of the seismic studies?

Thanks, Tom 1

From: Hlpschmao I hQmas To: SebCQsjr;y, Joseph: Madslev, Mdlaef; Qestcde, Enc* Kanatas Q;:henne: Reynoso John- Manotv Kamal* At.I:. JQn; HvoSAO C!1ffAC<1: OKeeCe Ned: EA'!s Kj!y)n: wrooa, Dav!d: PIE@oo:sro N1 ctPfas: BalazJk, H@o<:L Reynoso, John: Sfoaat. Bal'JYaot: HIit. Bntta,n: Yfalkec waype: Vseld,ng Lara: Lyoo fted Cc: wc:,1 Jenny: L!...)'.gng; Mang!y. Kamal: Lynd tg.,rsc* Dvdds. M,chaf'I* ease M,d)aet: surnen Scott: ~ Sl:Wim; Hay. Mtchaet

Subject:

RE: action: Review d updated commun.c:atlon plan and propoul to ask PG&E to provide draft ,copy of report In an electronic reading room Date: Wednesday, August 27, 2014 11:3'4:01 AM One correction to the tlmellne. Toe licensee is currently looking at releasing the report on either September 9th or 10th. Tom

---

Original Message-----

From: Sebrosky, Joseph Sent: Wednesday, August 27, 2014 3:33 AM To: Markley, Michael; Oesterle, Eric; Kanatas, Catherine; Hipsd,man, 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; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael

Subject:

action: Review of updated communication plan and proposal to ask PG&E to provide draft copy of report In an electronic reading room To all, Toe purpose of this email is to provide you with an updated Diablo Canyon seismic report communication plan and to include a proposal that we ask PG&E to provide a dra~ copy of the State of Califomla Report in an electronic reading room. Attached ls an updated Dlablo Canyon seismic report communication plan that Incorporates comments from several people (thanks to Jon Ake, Britt Hill, and Scott Burnell on their quick feedback). One of the problems that has been Identified Is OPA's need for the NRC to provide some type of preliminary assessment of the lnfonnatlon in the report and the frustration by the technical staff that basing a preliminary assessment on the Information provided in the dropin is problematic. To resolve the issue this email proposes to request PG&E provide a draft of the report in an electronic reading room so that the folks that were Involved In the RIL can quickly review the document and adjust the communication plan if needed. Elaine Keegan, and Cathy Kanatas - a question has been added to the communication plan associated with the report's tie to the license renewal process. Per my discussion with Cathy yesterday, I do believe that the status of this report is discussed In ASLB filings associated with the license renewal process. I will work with PG&E to conflnn this. Tom Hlpschrnan - thanks for the information yesterday that PG&E is now leaning towards releasing the report on 9/8 or 9/9. Based on this timeline, I think we have enough time to get the report loaded In an electronlc reading room so that the staff can review it and adjust the communication plan as appropriate prior to the release of the report. Please let me know if you have any comments on the electronic reading room proposal. In addition, any comments associated with the attached draft communication plan would also be appreciated. I am looking to determine whether or not to pursue the electronic reading room proposal by COB today. I will Inform you of the decision and the timeline for establishing the electronic reading room, If applicable, In another update to the plan.

From: N1asrnrnan, J])omd) To: 5ebcos"'., Joseph

Subject:

Re: update: request has been made to PG&E to grant access to draft COl>Y or State of Caliromla report associated with the electJOnk: reading room Thul1day, August 28, 201<1 8:32:3S AM Ed Halpin said he will let us know by noon PDT Sent via My Workspace for iOS On Wednesday, August 27, 2014 at 7:17:28 AM, "Sebrosky, Joseph"

<Joseph.Sebrosky@nrc.gov> wrote:

To all, The purpose of this email is to Inform you that based on NRR, and RIV management approval, I talked to Philippe Soenen (PG&E licensing engineer) this morning and requested electronic reading room access to a draft of the State of califomia report associated with the Shoreline fault I followed the discussion with the attached request via email for Jon Ake and Britt Hill to be granted access to the draft report. Philippe Indicated that he would discuss the issue with his management chain (lnduding Tom Baldwin) and quickly let me know if this presented a problem. Philippe indicated on the phone that he did not think that granting such access would be an Issue. I will let you know if and when Jon and Britt have been granted access. If PG&.E's response Is that they will not provide sud, access I will inform the 1 appropriate management and elevate the issue quickly. Jon and Britt, RIV has suggested that if the report is too complex to be able to quickly assess the differences between PG&E 2011 Shoreline fault report that we can request that PG&E develop a list of the deltas between the two reports to aid in your assessment. I understand that I am still waiting for confirmation from your management that they will support your review of the document, but assuming you get the green light to review the document, please consider RIV's advice and let me know if you want me to request such a product from the licensee. Please let me know if you have any questions. Sincerely, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph.sebrosky@nrc.gov 301-415-1132

*****Original Message-****

From: Sebrosky, Joseph Sent: Wednesday, August 27, 2014 6:33 AM To: Markley, Michael; Oesterle, Eric; Kanatas, catherine; Hipschman, Thomas; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Clifford; OKeefe, Nell; Folk, Kevin; Wrona, David; Difrancesco, Nicholas; Balazik, Michael; Hipschman, Thomas; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Lyon, Fred Cc: Weil, Jenny; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael

Subject:

action: Review of updated communication plan and proposal to ask PG&E to provide draft copy of report in an electronic reading room

To all, The purpose of this email is to provide you with an updated Diablo canyon seismic report communication plan and to Include a proposal that we ask PG&E to provide a draft copy of the State of Califomla Report In an electronic reading room. Attached Is an updated Dlablo Canyon seismic re.port communication plan that Incorporates comments from several people (thanks to Jon AAe, Britt Hill, and Scott Burnell on their quick feedback). One of the problems that has been Identified is OPA's need for the NRC to provide some type of preliminary assessment of the Information in the report and the frustration by the technical staff that basing a preliminary assessment on the Information provided In the dropln Is problematic. To resolve the issue this email proposes to request PG&E provide a draft of the report In an electronic reading room so that the folks that were Involved in the RIL can quickly review the document and adjust the communication plan if needed. Elaine Keegan, and Cathy Kanatas

• a question has been added to the communication plan associated with the report's tie to the license renewal process. Per my discussion with cathy yesterday, I do believe that the status of this report is discussed in ASLB filings associated with the license renewal process. I will work with PG&E to confirm this.

Tom Hipschman

• thanks for the information yesterday that PG&E is now leaning towards releasing the report on 9/8 or 9/9. Based on this timeline, I think we have enough time to get the report loaded in an electronlc reading room so that the staff can review It and adjust the communication plan as appropriate prior to the release of the report.

Please let me know If you have any comments. on the electronic reading room proposal. In addition, any comments associated with the attached draft communication plan would also be appreciated. I am looking to determine whether or not to pursue the electronic reading room proposal by COB today. I will Inform you of the decision and the timelrne for establishing the electronic reading room, if applicable, in another update to the plan.

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

From: SebrOSky, Joseph To: Munsen a1ttorg: &.JQo; Plfrancescp. N1ct,gtas: Qal,n:lt MKNef Cc: wc,1, Jannv; ~ Maootv Kamal* Lund Loyr..e: Dudek Mich.lei; ease M1d)ae1: aumeu, Scott;~

                   ~ Hay, M1maet: oestecte EtJc:* MartJex, ttoaeJ: !<aO'JW Cattx:rtoe; HiQSChmao Jbomas: ~

Jm MaQOlv, Kama!: Ql'ee!e ffdl* f;olk. E'.ma; l)u;ha040 Jbewa; Wrona Pavll Hmschman, Thomas; Ra00$0, ,John: S!@!ll 1.1a want, tl* l!otU*o; wo0ser wame; uw1og t.aca: LXOo, feed

Subject:

question: Does It make sense to perform an ~ e n t d tne changes in the shoreline fault loformallon to tne seismic a,re-datnaQe frequency Oat.: Thursday, August 28, 201-46:59:00 AM Note: ML14083A586 is publicly Attachments: 03 12-14 NBC SM:!),c &s!s Eyjlujff:lon:s {sx:C'EUS pt~nts ML140&'3a586 Pltl available in ADAMS. Cliff, Jon, Nick, and Mike, The purpose of this emall is to request your feedback on an approact, that Jon disrussed briefly with me yesterday related to assessing new shoreline fault Information for Oiablo using an approach slmllar to what was recently done for central and eastern U.S. (CEUS) plants as described In the attached document. The attached EPRI document Includes an analysis to provide perspective regarding the safety implications of new seismic hazard estimates for CEUS plants developed in accordance with the March 12, 2012, process, based on an analysis of the changes to the seismic core-damage frequency. Jon indicated that based on infonnation available in Dlablo's seismic PRA, the 2011 Shoreline fault report, and assuming we can get updated Information on the shoreline fault from the State of califomia report, an analysis similar to the attached could be done. Any insights you might have on pursuing such an analysis would be appreciated.

Thanks, Joe

From1: Sebrosky, Joseph To: *soeoeo, f'hll!Poe s* Cc: "Baldwm Thomas coceer: Ocsecle Enc: Lyon Eced: S1noat. aa1want: Walker. wayne: Htpschman. Thom4s: Reynoso John: &.J.gn; ml. llQtt,1,11: Manotx Kamal; ~

Subject:

RE: action: request fOf electronic rNdlng room access to draft Stat, of (abfomia report associated with the Shoreline fault Date: Wednesday, August 27, 2014 11:06:00 AM Philippe, In addition to providing access to Jon Ake, and Britain Hill can you also consider granting access to the report to the following individual: - Yong LI, email address: Yong.U@nrc.gov sincerely, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph.sebrosky@nrc.gov 301-415-1132

---

Original Message-----

From: Sebrosky, Joseph Sent: Wednesday, August 27, 2014 10:05 AM To: 'Soenen, Philippe R' Cc: 'Baldwin, Thomas (DCPP}'; Oesterle, Eric; Lyon, Fred; Singal, Balwant; Walker, Wayne; Hlpschman, Thomas; Reynoso, John; Ake, Jon; Hill, Brittain

Subject:

action: request for electronic reading room access to draft State of California report associated with the Shoreline Fault Philippe, Per our discussion this morning, the purpose of this email is to request that the following two individuals be granted electronic reading room access to the draft State of cauromia report associated with the Shoreline Fault:

- Jon Ake, email address: jon.ake@nrc.gov

- Brittain HIii, email address: Brlttaln.Hill@nrc.gov I understand that you will discuss the issue with your management and let me know if PG&E Is amenable to doing this with the understanding1that such access will only allow the individ.Jals to read the draft document and they will not be able to download or print the document. There Is a chance that in the future we may amend the request to include additional NRC personnel. Please let me know if you have any questions. Sincerely, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division

Office of Nuclear Reactor Regulation Joseph .sebrosky@nrc.gov 301 -415- 1132

From: 5ebf'0$1Cy, Joseph To: ManoJy Kamal Cc: HUaQd Pa\c!Ck: Bou Lee Marylanc: ~ Macklcv Micbacl; Pcstede, Eric: PJEcaocesco, Nicholas

Subject:

RE: update: request has been made to PG&E to grant access to draft copy<< State<< Cartfomia report associated with the electronic reading room o~te: Wednesday, August 27, 2014 11:09:00 AM

Kamal, You should have a copy of the email where the request has been made to also grant Yong access to the Information. As Indicated in the email below, I will inform you (as well as others) if and when the three Individuals that we have requested be granted access have been granted access.

Let me know if I am missing something.

Thanks, Joe

• • -*-Ori:ginal Message-----

From: Manoly, Kamal Sent: Wednesday, August 27, 2014 10:52 AM To: Sebrosky, Joseph Cc: HIiand, Patrick; Ross-Lee, MaryJane

Subject:

RE: update: request has been made to PG&E to grant access to draft copy of State of callfornla report associated with the electronic reading room

Joe, Yong Is, NRR's only senior seismologist. I suggest that he gets access to that report as well. It Is Incumbent that our staff specialist be equally Informed as staff from other offices.

Kamal -*--*Original Message---*- From: Sebrosky, Joseph Sent: Wednesday, August 27, 2014 10:17 AM To: Markley, Michael; Oesterle, Eric; Kanatas, Catherine; Hlpschman, Thomas; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Clifford; OKeefe, Neil; Folk, Kevin; Wrona, David; Difrancesco, Nicholas; Balazlk, Michael; Hlpschman, Thomas; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Lyon, Fred Cc: Weil, Jenny; LI, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, M1chael; Burnell, Scott; Whaley, Sheena; Hay, Michael

Subject:

update: request has been made to PG&E to grant access to draft copy of State of califomia report associated with the electronic reading room To all, The purpose of this emall is to inform you that based on NRR, and RIV management approval, I talked to Philippe Soenen (PG&E licensing engineer) this morning and requested electronic reading room access to a draft of the State of (alifomia report associated with the Shoreline fault. I followed the discussion with the attached request via email for Jon Ake and Britt HIii to be granted access to the draft report. Philippe indicated that he would discuss the issue with his management chain (including Tom Baldwln) and quickly let me know if this presented a problem. Philippe indicated on the phone that he did not thlnk that granting such access would be an issue. I will let you know if and when Jon and Britt have been granted access. lf PG&E's response is that they will not provide such access I will Inform the appropriate management and elevate the issue quldcly. The entire email string is document F/23 in interim response #3 in FOIA/PA-2014-0488 (ML15033279).

From: Ll..1Qll{l To: Sebroskv, Joseph Cc: Manotv. Kamal: HHand, pat:ndt

Subject:

RE: update: request has been made ID PGaf to grant aa:ess to dralt copy of State of ~11rom1a report assooated wl1h the ~ledronlc reading room D1te: Wednesday, August 27, 2014 10:27:02 AM

Joe, can I have access to the draft report too?

Thanks! Yong

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

From: Sebrosky, Joseph Sent: Wednesday, August 27, 2014 10:17 AM To: Markley, Michael; Oesterle, Eric; Kanatas, catherine; Hipschman, Thomas; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Olfford; OKeefe, Neil; Folk, Kevin; Wrona, David; DiFrancesco, Nicholas; Balazik, Michael; Hipschman, Thomas; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Lyon, Fred Cc: Weit, Jenny; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael

Subject:

update: request has been made to PG&E to grant aa:ess to draft copy of State of califomla report associated with the electronic reading room To all, The purpose of this email Is to Inform you that based on NRR, and RIV management approval, I talked to Philippe Soenen (PG&E licensing engineer) this morning and requested electronic reading room access to a draft of the State of callfom1a report associated with the Shoreline fault. I followed the discussion with the attached request via email for Jon Ake and Britt Hill to be granted access to the draft report. Philippe indicated that he would discuss the issue with his management chain (including Tom Baldwin) and quickly let me know if this presented a problem. Philippe indicated on the phone that he did not think *that granting such access would be an issue. I will let you know if and when Jon and Britt have been granted access. If PG&E's response is that they will not provide such aa:ess I will inform the appropriate management and elevate the issue quickly. Jon and Britt, RIV has suggested that if the report is too complex to be able to quickly assess the differences between PG&E 2011 Shoreline fault report that we can request that PG&E develop a list of the deltas between the two reports to aid in your assessment. I understand that I am still waiting for confirmation from your management that they will support your review of the document, but assuming you get the green light to review the document, please consider RIV's advice and let me know if you want me to request such a product from the licensee. Please let me know If you have any questions. Sincerely, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nudear Reactor Regulation Joseph.sebrosky@nrc.gov 301-4 1132

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

From: Sebrosky, Joseph Sent: Wednesday, August 27, 2014 6:33 AM To: Marl<Jey, Michael; Oesterle, Eric; Kanatas, catherine; Hlpschman, Thomas; Reynoso, John; Manoly, Kamal; Ake, Jon; Munson, Oifford; OKeefe, Nell; Folk, Kevin; Wrona, David; Difrancesco, Nicholas; Balazlk, Michael; Hipschman, Thomas; Reynoso, John; Singal, Balwant; HIii, Brittain; Walker, Wayne; Useldlng, Lara; Lyon, Fred Cc: Well, Jenny; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael

Subject:

action: Review of updated communication plan and proposal to ask PG&E to provide draft copy of report in an electronic reading room To all, The purpose of this email is to provide you with an updated Diablo Canyon seismic report communication plan and to include a proposal that we ask PG&E to provide a draft copy of the State of California Report In an electronic reading room. Attached is an updated Diablo Canyon seismic report communication plan that incorporates comments from several people (thanks to Jon Ake, Britt Hill, and SCX>tt Burnell on their quick feedback). One of the problems that has been identified is OPA's need for the NRC to provide some type of preliminary assessment of the information in the report and the frustration by the technical staff that basing a preliminary assessment on the information provided in the dropin is problematic. To resolve the Issue this email proposes to request PG&E provide a draft of the report In an electronic reading room so that the folks that were involved in the RIL can quickly review the document and adjust the communication plan if needed. Elaine Keegan, and Cathy Kanatas - a question has been added to the communication plan associated with the report's tie to the license renewal process. Per my discussion with Cathy yesterday, I do believe that the status of this report is disrussed in ASLB filings associated with the license renewal process. I will work with PG&E to confirm this. Tom Hlpschman - thanks for the Information yesterday that PG&E Is now leaning towards releasing the report on 9/8 or 9/ 9. Based on this timellne, I think we have enough time to get the report loaded In an electronic reading room so that the staff can review It and adjust the communication plan as appropriate prior to the release of the report. Please let me know if you have any comments on the electronic reading room proposal. In addition, any comments associated with the attached draft communication plan would also be appreciated. I am looking to determine whether or not to pursue the electronic reading room proposal by COB today. I will inform you of the decision and the timeline for establishing the electronic reading room, if applicable, in another update to the plan.

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

From: we11, Jenny To: Scbrosky Joseph Cc: Moreno M9ei

Subject:

RE: update: request has been made to PG&E to orant access to dralt copy of State of califomla report associated with the electronlc readil'lg room Date: Wednesday, August 27, 2014 10: 18:30 AM Thanks Joel

  -----Original Message---**

From: Sebrosky, Joseph Sent: Wednesday, August 27, 2014 10:17 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; Slngal, Balwant; Hill, Brittain; Walker, Wayne; Useldlng, Lara; Lyon, Fred Cc: Weil, Jenny; LI, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Whaley, Sheena; Hay, Michael

Subject:

update: request has been made to PG&E to grant access to draft copy of State of California report associated with the electronic reading room To all, Toe purpose of this email is to inform you that based on NRR, and RN management approval, I talked to Philippe Soenen (PG&E licensing engineer) this morning and requested electronic reading room access to a draft of the State of California report associated with the Shoreline fault. I followed the discussion with the attached request via email for Jon Ake and Britt Hill to be granted access to the draft report Philippe Indicated that he would discuss the issue with his management chain (Including Tom Baldwin) and quickly let me know If this presented a problem. Philippe Indicated on the phone that he did not think that granting such access would be an issue. I wlll let you know If and when Jon and Britt have been granted access. If PG&E's response is that they will not provide such access I will inform the appropriate management and elevate the issue quiddy. Jon and Britt, RIV has suggested that if the report is too complex to be able to quickly assess the differences between PG&E 2011 Shoreline fault report that we can request that PG&E develop a list of the deltas between the two reports to aid in your assessment. I understand that I am still waiting for confirmation from your management that they will support your review of the document, but assuming you get the green light to review the document, please consider RlVs advice and let me know if you want me to request such a product from the licensee. Please let me know Jf you have any questions. Sincerely, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nudear Reactor Regulation joseph.sebrosky@nrc.gov 301 -415-1132

 ****-Original Message**-*

From: Sebrosky, Joseph Sent: Wednesday, August 27, 2014 6:33 AM The entire email string is document F/23 in interim response #3 in FOIA/PA-2014-0488 (ML15033279).

From: Sebrosky, Joseph To: Budlanan, Ibs:u::;a Cc: Walkgr Wayne* H,U BrtttatQ; lJ<',t!dlQQ Lara; Ocstcr1e, Er(; P1f@QCCSCQ, N,s;ho!as

Subject:

quest!On: Updated Dlablo Canyon Canm Plan Date: Tuesday, August 26, 2011 10:58:00 AM Attachments: Piablo Commun;cabon f'lao

• Bev o ce-2s-i11 dog STAT!: REPQRJ MESSAGING,OOCX

Theresa, I am assuming that page 34 - 37 of the updated communication plan 1s what we are to review. Please confirm that the state messaging document (attached) in no longer applicable and has been included in the D1ablo comm plan. I just want to make sure that we are commenting on the correct product

Thanks, Joe From: Buchanan, Theresa Sent: Tuesday, August 26, 2014 10:07 AM To: Sebrosky, Joseph; Hill, Brittain

Subject:

Updated Diablo canyon Comm Plan

Hello, Attached is the most up-to-date revision to, the DC comm plan. Please note that there are other sections, beyond the ABN 1632 section, that are undergoing revision due to recent events. Let me know if you have any questions or problems with the attached file.

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

DRAFT - err1ebfct tJSE 6NLY SfNSITf'IE lf4'ffftHAt INF6ftMAll6N - f46'f Feft lltJBtle ftf teASf UPDATED: 09/25/2014 3:52 PM Communications Plan - Oiablo Canvon Power Plant Topics of Interest Purpose This communication plan describes the methods and resources that NRC staff will use to communicate with internal and external stakeholders regarding the Diablo 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 DCPP stakeholders, 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 continuous11y evaluated for the need to update key messages, and a full review/update will be evaluated approximately once per calendar quarter. Summary 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 accelera1ion 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 DCPP 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 units in 1984 and 1985. The OBE and SSE remained 0.2g and 0.4g, respectively. However, DCPP was required to have additional seismic protection that would automatically initiate reactor shutdown if ground acceleration during a seismic event exceeded the OBE and SSE. and PG&E was required to re.evaluate the seismic design basis for OCPP. PG&E was also required to evaluate the plant's response to ground motion of O.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 LTSP study. PG&E concluded that DCPP Units 1 and 2 could withstand ground motion up to 0.75 g. In 2006, PG&E notified the NRC about the newly discovered Shoreline fault zone. PG&E comple1ed characterization of the Shoreline and other local earthquake faults in January 2011. 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 Page 1 DRAFT - e,*,1etAt tJSE 6NLY SENSFfl't'E INl'ERH~l lNFeRMM l6N - NeT f'6R ,t:1et1e Rl!Ll:A!I:

DRAFT - Ol'l'ICIAt: t:ISI!! ONL't' 9EN91Tl'f1E INTERNAL 1Nfi6RMATl6N - NOT FOR p~eue RELEASE 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 the Shoreline fault is bounded by previous analyses of potential seismic events, including analyses of the Hosgri fault and the LTSP 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(1) 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, 201 1, 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 QBE 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 QBE 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 O 75g) from the Hosgri fault. o The NRC staff reviewed and accepted 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 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 Hosgn 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 run power without undue risk to the health and safety of the public.

• The NRC performed an independent deterministic analysis of new seismic information pro,vided by PG&E in 2011 relating to the Shoreline fault. NRC's conclusions are documented in Research Information letter (RIL) 12--01 , dated October 10, 2012 (publically available in ADAMS ML121230035) . NRC detelTTlined that the maximum ground motion Page 2 DRAFT - 6f filetAL t:ISE erRV

            !EN91TIYE INTERNM: INF6RMATl6N - f46'f Fe" Pt:1Btle RELEASE

DRAFT - 6fflCl>'d.: tJ9! e,~tv 9!N91'fl'f1! ltff!RNAL INf6ftMATl6N - N6T f6ft. ,t:Jeu e ftf t!!:A!E 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 DCPP 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 LTSP 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.' 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.
• California Assembly Bill 1632 (ABN 1632) 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 2D and 3D mapping. This is different methodology that what was used for the 2011 Shoreline Fault.

1 See NRC Jetter, dated March 12, 2012, Issued to all power reactor lfcensees "Request for Information Pursuant to Title 10 of the Code of Federal Regufations 50 54(() Regarding Recommendations 2 1. 2. 3. and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Da/./chl Accident.* (.http:llpbadupws.nrc, gov/docs/ML 1205/ML12053A340. QdQ Page3 DRAFT - 6f FICtM: t:J9! 6NLY 9!N91fl'l'E INTERNAL INP6RM:ATl6N - Ne, f6R fttl8Ue RELEASE

DRAFT - erftelAL tlSE 6'4LV SENSl'ffVf: IWFERNAL INF6RMA"f16N - NeT FeR PtJBUe RELcltSE

• Based on the preliminary results of he studies under eview, the Diabk> Canyon Power Plant has determined that the Shoreline Fault Zone may be more capab e than summarized in the January 2011 report, but the deterministic response spectra are still bounded by those for the Hosgri and LTSP earthquakes. Therefore, the conclusions remain the same and there is no adverse impact on the seismic design of Oiablo Canyon. As a result, the assessment associated with the January 2011 Shoreline Fault report remains valid .

Page 4 DRAFT - OFFlel~L tJSE ONLY SENSl'TII/E IN'fERNAL INFORMA"flON - NOT l'OR l'tll!LIC ft!L!ASE

DRAFT - OfflCIAL t:ISE ONLY 9EN9fll'IE INlERN>f<L INF6RMAll6t4 - Ne, feR flt:IBUe ftfl!*Sf 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 Ml110140400, January 7, 201 1 Task Interface Agreement (TJA) 201 1-010, *concurrence on Oiablo Canyon Seismic Qualification Current Licensing and Design Basis,* August 1, 2011 TIA 2012-012, "Revised Response to Task lnterfaoe Agreement -Oiablo Canyon Seismic Qualiflcation Current Licensing and Design Basis, IA 2011 -010 (TIA 2012-012) (TAC NOS. ME9840 and ME9841)," November 19, 2012 RI L 2012-01 , "Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone," September 19, 2012 {ML121230035) Page 5 DRAFT - eFFletAt t:ISE 6NLV SENSITlflE IHfERNAL INF6RMAll6N - Nel' FeR Pt:IBUC RELEASE

DRAFT - OfftCtAL tt91! ONL'I 91!N91'fl',t: INff!ftNAL lf4P'6ftMA-fl6N - N6T P'Oft 111:1eue ftaeA91! Non*Public Information Regarding Non-Concurrences & Differing Pr of essional Opinions [NOTE - this Informat ion is generally NON-PUBLIC, but is provided as background only, with additional information in t he associated Q&AJ

Background

The former SRI submitted non-concurrence papers {NCPs) In January 2011 and January 2012, followed by a Differing Professional Opinion {OPO) In July 2013 detailing a disagreement with the NRC about how the new seismic information should be compared to the plant's current seismic license requirements. Key Messages

• NCP 2011-103 was filed by the (now former) DCPP SRI on the basis that no violation was iss,ued (as he had submitted in the draft report) related to operability evaluation of the Shoreline fault in Inspection Report 2011-04. NCP 2011-103 was dispositioned finalizing the violation in Inspection Report 2011-05 issued on 2/14/12.
• NCP 2012-01 was filed by the (now former) OCPP SRI because he 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 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.
• The former OCPP SRI filed Differing Professional Opinion (DPO) 2013-02 associated with the regulatory response following the discovery of the Shoreline Fault. 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.
• The NRC is following the established DPO process as discussed in Management Directive 10 159 in reviewing the concern raised by the former DCPP SRI (petitioner). However, the DPO process for a specific review is an internal, non-public process. The OPO petitloner has rights, including the right to privacy over this issue. The OPO petitioner has a key role in determining whether or not the OPO and Director's decision become available publicly.
• The former OCPP SRI applied for and w.as selected for a highly sought after position within the agency. He was not reassigned.
• The NRC encourages and welcomes differing opinions and offers several paths for staff for officially document their differing views.

Background Documents [NON-PUBLIC] Non-concurrence NCP 2011 -103, dated November 7, 2011 Page 6 DRAFT - 6ffletAL tJ9E e,*tv 9EN91ll'f'E INlERNAL INF6RMA'f16N - NOT fOft l'tJet1e ftEL!'ll.9~

DRAFT - 61'1'1CIAL t,31! OfRY Sl!N!1'1..1 l! u*,e*u*itct u*11eftMitcT1ef4 - Ne, "e" 11t1eue ft!l:!itcse Non~concurrence NCP 2012-01 , dated January 26, 2012 (publically available in ADAMS] {NON-PUBLIC] Differing Professional Opinion 2013-02, dated July 18, 2013 Page 7 DRAFT - erne12':t tJ9E 6NL¥ Sl!NSlfff'! n*TERN1'cL INl'ORM1'c'10N - NeT 110ft 111:1eue REL!A!l!!

DRAFT - 6fflel>'cl t:19E 6NLV 911!N911'11/1! unl!RHM:: INf6RM>'cTl6t4 - Ne, f eR flt:18Lle RELEASE ATTACHMENTS Audience/Stakeholders ...............................................................................................................9 Communication Team ............................................................................................................... 10 Communications Tools ............................................................................................................ 11 List of Applicable Acronyms and Abbreviations ........................................................................ 14 Timeline of Seismic Issues at DCPP ......................................................................................... 15 Specific Topics Q&As: Design/Initial licensing Basis Questions (DE/DDE/Hosgri/Tsunami) ........................................ 22 Long Term Seismic Program (LTSP) Questions .......................................................................26 Shorelline Fault Questions ......................................................................................................... 28 State of California Seismic Report (ABN-1632) .........................................................................34 Los Osos and San Luis Bay Faults ...........................................................................................38 Research Information Letter (RIL) Questions ...........................................................................40 Non-concurrence and DPO Questions ...................................................................................... 42 RIS 2005-20, 2013-005, and Operability Evaluation Questions ................................................. 48 Enforcement Questions ......................................................................................... ................... 50 Current Licensing Questions ..................................... ................................................................ 52 50.54(f) Questions .................................................................................................................... 56 Tier 3 Expedited Transfer of Spent Fuel to Dry Cask Storage ................................................... 62 DCPP Licensing Basis Verification Project (LBVP) ..... ........................................... ................... 66 Waste Confidence .................................................................................................................... 70 Public Cancer Risks .............................................................. ................................ ................... 72 Emergency Preparedness Concerns ........................................................................................ 74 Page 8 DRAFT - ernet-.L l:J9E 6NLV 9l!NS1f1'f'E INlERN>'cl INF6RM>'cfl6N - NOl 1'6R flt:J8tle Rl:tl:ASE

DRAFT - OfFletAL 1::13!: OHLY 91!!N91Trte IN'fl!!ftNAL INl'OftMATION - NO'f l'O" 111::1eue ftl!t!A!! Audience/Stakeholders Internal Allegations Coordinator Office of Public Affairs (OPA) 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 (OEDO) Office of the Advisory Committee 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), Califomia Energy Commission, and California Coastal Commission. Industry groups (e g., Nuclear Energy Institute) Page 9 DRAFT - 6f1flel:AL t:19E ONLY 9Ef.91Trt1E INfl:"NAL INf6"MAfl6N - NOT 1'0" l't:16LJC "l!tl!AS!

DRAFT - 6fFlelM.. tf9E eNLY 9Ef.91ll't1E INTE~N)f(L INF8R~TleN - ,.e, reft l'tf8Lle ftfLf)f(9E 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 Branch Chief R-IV/DRP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195 Sr. Resident Inspector

• Thomas Hipschman R-IV/DRP/RPB-A 805-595-2354 DCPP Resident Inspector -

John Reynoso R-IV/DRP/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 301-415-101 4 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 Amy Powell Associate Director OCA 301-415-1673 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 8 17-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Page 10 DRAFT - efFtelAL tf9E eNLY 91!N91Tl't1E INTERNAL INF6RMATl6N - NOT flOft ,at:,eue RELl!ASE

DRAFT - Ol'l'lelAL l1S! Ot4LY 9fN91Tl't'E lt4'!ffNAL lf41'eftMATION - NOT P'eft l'tJl!9Lle ~LEA;SI! 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 infonned of activities and messages. Public Meetings In May 2009, a town hall public meeting was conducted in San Luis Obispo, California, to discuss the Shoreline Fault. tn 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 Lujs Obispo, California, 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 OCPP's actions to date in response to the post-Fukushima actions, including 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 OPA 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 / Report/ Document Title Lead Office Date (ADAMS/Reference number, as aoor,opriate) Submitted 50.72 notification with an operability 1 assessment to the NRC PG&E November 21 , 2008 (Event Number: 44675) 2 FAO developed Region IV November 26, 2008 Summary of tsunami hazard 3 RES December 8, 2008 (ML090820140 and ML083400496) Action Plan submitted to the NRC 4 PG&E December 17, 2008 (ML090720505) Page 11 DRAFT - OPl'leb'ct \1Sf Ot4LY 9EN91frte IN;peRNAL INF8RMMl8N - f46T '56R flt:18tle Rl:L!1<,3 f

DRAFT - OfflChtcL tJSE ONLY 9ENSITl'tE INll!RNAL INl'ORMNflOH - f40T ,oPt l't:H,LIC Ptl!tl!1<SI! Activicy / Report/ Document Title Lead Office Date (ADAMS/Reference number, as appropriate) The NRC concluded the Action Plan and schedule are reasonably complete and 5 comprehensive in scope for this study. NRR January 5, 2009 (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 Aprill 9, 2009 PG&E staff members plan to attend. Issue a safety evaluation regarding the, operability of DCPP based on a deterministic hazard NRR DE& 8 assessment and a preliminary review of the DORL April 30, 2009 tsunami hazard by RES. Complete an operability evaluation of potential 9 PG&E April30, 2009 around deformation Support a town-hall meeting, conducted by NRR, Region IV, in which the Shoreline Fault is 10 NRO, & May 28, 2009 ex pected to be discussed. RES 11 Meeting with PG&E to discuss status PG&E January 5, 2010 PG&E to submit Secondary Rupture Hazard 12 PG&E February 29, 2010 A nalysis 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 d iscuss User Need Request to determine future NRR March 29,2010 actions regarding the Shoreline Fault RES to provide confirmatory review of secondary 15 RES July 31 , 2010 rupture analysis RES to review Evaluation of Shear-Velocity at the 16 Independent Spent Fuel Storage Installation RES July 31 . 2010 (ISFSI) Brief the Chairman on the status of the Shoreline 17 NRR August 11 , 2010 Fault September 8 and 9, 18 Seismic Workshop in San Luis Obispo Region IV 2010 19 Complete seismicity studies PG&E December 2010 20 Complete geophysical studies PG&E December 20 10 21 Complete geologic studies PG&E December 201 O Complete Shoreline Fault source characterization 22 PG&E December 2010 for integration into final report Complete ground motion studies to be integrated 23 PG&E December 2010 into final reoort. Page 12 DRAFT - OPl'ICIAL t:191! ONLY 9EN91llttE INTERN~L INFORM>\TION - NOT FOR flt:IBLIC RELEASe

DRAFT - eFFlelAL t:f9E erRV 9!f4Slf1VI!!! lf4Tl!!!fU4At: mPeftMAll8H run f 8R ,~eue Rf:LEA8E Activity / Report I Document TiUe Lead Office Date (ADAMS/Reference number. as appropriate) NRR/ 24 Meeting on LTSP Amendment DORL December 9, 2010 Research Assistance Request for pre-application NRR/ 25 March 2011 discussions on LTSP Amendment DORL Research User Need Request to support review NRR/ 26 TBD of LTSP 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 stakeholders for review until all da1a are integrated into final report in December. 28 Complete final Shoreline report PG&E January 201 1 Research User Need Request to support review NRR/ 29 January 4, 2011 of Final Shoreline Report and update RIL 09-001 DORL Regional Meeting in California to discuss final 30 Region IV January 19, 2011 Shoreline Fault zone report NRR/ 31 Second Meeting on LTSP Amendment January 26, 2011 DORL NRR/ 32 Third Meeting on LTSP Amendment March 2011 DORL 33 LTSP Amendment submittal (LAR 11-05) PG&E October 20, 2011 The NRC held an annual assessment meeting 34 RIV June 201 1 and discussed seismic at Diablo 35 The NRC issued the RIL NRR October 10, 2012 Regional Meeting in California to discuss NRC's 36 Region IV November 28, 2012 review 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 meeting 10/16/2013) Written response to questions posed by U.S. NRR (w/ 38 Senate Environmental & Public Works Late January 2014 OCA) subcommittee staff R,egiona'I Meeting in San Luis Obispo to discuss 39 Region IV May 22, 2014 annual performance assessment for CY 2013 Diablo Canyon issued the ABN-1632 seismic 40 NRR/JLD August XX, 2014 report to the state of Califomia Page 13 DRAFT C,P:fl8titd.. ~9E 6P4LY 81W8Ff1Vli IPJTEZAUAL IUF8AMM18tt ue, f 6 R , __eue AEl!eA8E

DRAFT - 6PFletAL t:19! et*tv 9!N91f1Ye IHTEftN>>tcl lNf'6RM>>tcTl6N - Ne, 1'6ft l't:Jeue lllte..!A!! List of Applicable Acronyms and Abbreviations 2-0/3-0 Two-Dimensionalffhree-Dimensional (relative to seismic mapping studies) ACRS NRC's Advisory Committee on Reactor Safety ASLB NRC's Atomic Safety and Licensing Board ASW DCPP Auxiliary Salt Water System CLB Current Licensing Basis DCNPP or DCPP Diablo Canyon (Nuclear) Power Plant ODE Double Design Earthquake {DCPP specific term, equivalent to SSE) DE Design Earthquake (DCPP specific term, equivalent to OBE) DGEIS Draft Generic Environmental Impact Statement OPO Differing Professional Opinion GMC Ground Motion Characterization (relative to SSHAC process) HE Hosgri Event (i.e., seismic event occurring on the Hosgr1ifault) IPRP Independent Peer Review Panel (multi-agency panel of seismic hazard specialists established by the California Public Utilities Commission) LAR License Amendment Request LBVP DCPP's Licensing Basis Verification Project LTSP PG&E's 1991 Long Term Seismic Program NCP Non-Concurrence Paper NEPA National Environmental Policy Act NTTF NRC's Japan Lessons Learned Near Term Task Force OBE Operating Basis Earthquake PG&E Pacific Gas & Electric PGA Peak Ground Acceleration RG Regulatory Guide RIL Office of Research Information Letter RIS Regulatory Information Summary SER/ SSER Safety Evaluation Report / Supplement to Safety Evaluation Report SFZ Shoreline Fault Zone SMA Seismic Margin Analysis SPRA Seismic Probabilistic Risk Analysis SRI Senior Resident Inspector SRP Standard Review Plan SSC Systems, Structures, and/or Components SSC Seismic Source Characterization (relative to SSHAC process) SSE Safe Shutdown Ea1rthquake SSHAC Senior Seismic Hazard Analysis Committee TIA Task Interface Agreement TS Technical Specification U/FSAR Updated/Final Safety Analysis Report Page 14 DRAFT - 6FF1611cl tl9E 6t4t¥ 9!N91Tltt! n*T!ftNAL INl'6~MIAT16N - r.e, 1'6111t l't:Jl!ltle ft!t!A91!

DRAFT - 6FFl81ifcl tJSE 6NL¥ SENSll'l'IE INTERNitcl INF6RMATl6N - NeT FeR PtJBLle RELEASE 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 investigations 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 early 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 structures (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 ,

• oamping 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 DOE at Diablo Canyon. PG&E used the RG 1.61 values in the Hosgri evaluation and did not revise the DE or DDE.

1/ 10/77 Revision of Appendix A to 10 CFR 100 was issued 6/3/77 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 uwe [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 DRAFT - errielAL tJSE eNLV 1 9EN91Tl\ E INTERNAL INF6RMATl0N - NeT FeR Pt:t8Ll8 RELEASE

DRAFT - 6fif1Clf4l t:JSE eNLY S!Nsi,r,e IN,ERNf4l 1Nfl6RMf4Tl6N - N6f f6R fltJ9Ue R!ll!"A8! Timellne of Seismic Issues at DCPP (cont'd) 7/14/78 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.* 11/15/78 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.] 9/27/79 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 ....

• 11/2/84 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 DCPP, 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).

8/25/85 Operating license was issued for Unit 2. 1989 Diablo Canyon submits their LTSP Report. June 1991 The NRC reviewed and accepted the results of the LTSP, as documented in SSER-34. The SSER included the following statement in Section 1.4: "The staff notes that the seismic qualification basis for Diablo Canyon will continue to be the original design basis plus the Hosgri evaluation basis, along with the associated analytical methods, initial conditions, etc." 1992 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 DCPP and nearby region). 12/11/96 Revision of 10 CFR 100 was issued Page 16 DRAFT - efiflCl:At tJSE eNLY SEN91TII/E INTERN.At lf4fi6RMA"fl6N - ,,e, fieR PtJetle RELEASE

DRAFT - OP'l'ICIAL t:JS! ONLY S!NSl'fl'f't! INTEfU~AL 1Nf6RMA'fl6N - N6f f6R litJ8Ue fU:U:ASE Timeline o f 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 follO\l\led up on 11/21/08 with Event Notification No 44675. This line of epicenters became known as the Shoreline Fault Zone. Dec 2008 Using the LTSP 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 (Rll) 09-01 , *Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon NPP from Newly Identified Shoreline Fault." This independent study of potential impacts concluded adequate seismic margin exists for the Shoreline Fault. 1/2/10 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 201 O 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 2010 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 OCPP SRI questions PG&E on the capability/operability of SSCs to withstand the Shoreline Fault acceleration U'Sing 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 LTSP had contained new seismic information and the NRC had allowed PG&E to address it through a seismic margin assessment and seismic PRA. 1/7/ 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 ML110,140400}. This report included detenninistic evaluations for the Shoreline. Los Osos. and San Luis Bay earthquake faults, as well as probabilistic hazard calculations. The licensee concluded that each of these faults were bounded by *the existing LTSP. 6/3/11 Region IV submits Technical Interface Agreement (TIA) memorandum 201 1-010 posing questions needed to help resolve seismic operability evaluati1on issues Involving Oiablo Canyon's use of the Hosgri and LTSP methods as the only bounding design basis conditions for newly identified faults. Page 17 DRAFT- Ol'l'lelAL t:JS~ ONLY S1:!N9ll'tVE IN'fERN~L INFORMATION - N6T fe" lit:Jeue "ELEASE

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Timeline of Seismic Issues at DCPP (eonfd ) 8/1 /11 TIA 2011-010 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) 9/18/11 NRC issues Inspection Report 05000275;323/201104. 10/20/11 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. 11/23/11 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 10 CFR 50.54(f) letter. Once completed (anticipated March 2015), the PG&E SSHAC Level 3 study will update/replace the PG&E LTSP. 11/29/11 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. 12/15/11 The NRC's Branch Chief for DCPP discussed the LAR with PG&E. Feb 2012 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 ODE. 03/12/12 50.54(f) Request for Information 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). May 2012 Issuance of RIL 12-01 is delayed until assumptions concerning shear wave travel in generic vs. site-specific material are verified. 10/12/12 NRC issued RIL 2012-01 The cover letter stated that the NRC has concluded that the Shoreline fault was considered to be a lesser included case of the Hosgri event, and should be documented as such 1n the UFSAR. Sept-Page 18 DRAFT - Of FlelAL t19E eNLY S!N!ITl't'! ll~T!ftNtct INfOftMtcTION - NOT fOft flU8LIC "ft !AS!

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         !l!!!NSl.,.l..'E INlERHilcL lf4f6ftMM16N - N0'f F0R Pl:IBLle RELEASE Oct 2012       Internal NRC discussions occurred 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 review 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 U,e results of RIL 2012 and concluded that ground shaking from the Shoreline fault earthquake scenarios are less than the Hosgri and LTSP ground motions for which the plant was previously evaluated. 11/19/12 NRC issued TIA 2011-010, WRevised Response to Task Interface Agreement - Diablo Canyon Seismic Qualification Current Licensing and Design Basis, TIA 2011-010 (TIA 2012-012) (TAC NOS. ME9840 and ME9841 )" 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 workshop is open to the public and presentations are posted on the Southwestern US Ground Motiion Characterization Project website. NRC seismologists attend the workshop as observers. March 2014 PG&E conducts SSC SSHAC workshop #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 wor1<shop. Page 19 DRAFT - 6Ff'letAL t:19! eNLY 9!f431Tt'f'! INlEftNAL INfi6ftMlcTl6N - Ne,= fi6ft PtJ8Lle ftELl:A9E

CRAFT - 8FFl81AL li9E 8HLY S!f~SITl't'I! INT!RNAL INl'Of':MkllOf* - ,.o,  !'OR .. tJet,e Rl!L!ASI! Future Events: August 2014 PG&E expected to ubmil SEISMIC REPORT to Sta e 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 to March 2012 50.54(1) request. Current information from the SSHAC process supports he expected conclusion that the new ground motion response spectrum will be bounded by the original HE g ound motion response spec rum. June 2017 PG&E due to submit the results of the new Seismic P*RA to the NRC in response to 50.54(f) request. Page 20 CRAFT - Off le IAL tJSf OHL¥ SfNSfT1'11f INTEftNAL INfOftMATION - NOT fOft P'tt8Lle ftELE1cSf

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        !Eff!ITIVE INT!ftNAL INl'OR:MA1'10N - ff OT fOft flt::18LIC ft!ll!ASE Design/Initial Licensing Basis Questions (DE/DDE/Hosgri!Tsunami)

1. When was the Hosgri 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 OCPP Final Sa~ety 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 Hoagri fault addressed in the licensing and design of OCPP?

Ahhough 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 to 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 in 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 ODE 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 Page 22 DRAFT - Of'l'ICIAL tJ!E ONLY

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DRAFT - 6fFtelAL tJ31! 6NLY S!NSITft'! llnl!"NAL INF6ftMATleN - N6f 156ft ftt1et1e IU!L~e response spectra were developed as well as differences in the hypothetical earthquake that each design basis level ,s based on. Generally speaking, the response spectra were constructed based on modified versions of similar real earthquakes, nom,alized 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 to state that the DCPP operating license defines the DOE to be the SSE?

Yes. For the Diablo Canyon, the Double Design Earthquake (ODE) is equivalent to the Safe Shutdown Earthquake (SSE). During initial licensing of the Oiablo Canyon site. two design basis earthquakes (ground motion) were established. The operating basis earthquake (OE3E) represents the ground motion reasonably expected during the lifetime of the plant. At DCPP, this is called the Design Earthquake (OE), 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 permits 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 palrt 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 Diablo Canyon site (called the Hosgri 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 DOE seismic design bases, and provided additional margin. This aspect of the design and licensing basis is unique to Diablo Canyon.

5. Is It accurate to state that the SSE/ODE 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 safely shut the plant down and maintain a safe shutdown condition, must be able 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 compornents and supports were not mandated by 10CFR 50.55a until the mid-1980's, the acceptance criteria for OCPP rely on a combination of Page 23 DRAFT - 6f fitet-AL tJSE 6NLY SEN31flVE Uff!RNAL 1Nf6RMATl6N - N0f F0R Pl:JBL18 RELEASE

DRAFT - Ofiflelilcl 119f ONLY S!NSITIV! INTEfUftcL INf'eftMtc'fleN - Ne, f'OK f't::teue ft!L!)t.9! 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 10 CFR 50.55a. In addition, during the licensing of Diablo Canyon, PG&E demonstrated that all structures, systems and components that are required to remain functional following a DOE/SSE would also remain functional during a postulated HE event (0.75g). In most cases, following extensive 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 DCPP for the postulated Hosgri event and concluded that

  "... the staff's approach leads to an acceptable level of safety for DCPP." 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 withs,tand any earthquake that can reasonably be expected to occur on the Hosgri fault".

6. Is it accurate to state that meeting the SSE/ODE 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 SSE/DOE?

Yes, licensees are required to demonstrate through modeling, testing, and evaluation that specific structures, systems, and components are seismically qualified up to the ODE/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 i t accurate to state that NRC d id not require the licensee to meet all of the requirements of the SSE/DOE when it came to its Hosgrl 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 limi1ted 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 tsunam i is t he plant designed/bul tt to w ithstand?

The design basis tsunami is 35 feet. The OCPP 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 1he 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?

Page 24 DRAFT - OFFlelAL t'JSE eNLY 9EN91fl't'E INfERffAL INr-ertMAflON - NeT reR PtlBUe RELEASE

DRAFT - Ol'l'ICIAL t,SI!! ONLY 9Et491,1¥E IN,ERNAL 1Nf6RMATl6f4 - NOT "O" l't:J!LIC "l!!ll!!ASI!! (Answer under development.] Page 25 DRAFT - Ollf ICIAL t:JSI!! ONLY 9EN91f1VE INfERNAL INFORMA'90N - Ne, FOR ,at:teue RELEA!E

DRAFT - 6Ffl61AL t:J91: 6NLY 9EN9Fflt/l: INTERNAL IHF6RMA'fl6N - Ne'f F6R Pt:JBLle "!Ll!A9! Long Term Seismic Program (LTSP} Questions

1. Why Is there a LTSP?

In 1984 the NRC issued the operating license for Diablo 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 LTSP was developed by PG&E in response to this NRC mandated License Condition.

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

The LTSP is a "seismic margin anaJysis" included as an original plant license condition. The l TSP addressed concerns at the time the plant was licensed; 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 Oiablo Canyon?

In 1985 Diablo submitted the LTSP to the NRC. The LTSP 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 LTSP 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 LTSP used much more modern techniques than had been used for the DE and the DOE. The LTSP methods were consistent with the Hosgri event review method. Section 1.4 of SSER 34 stated, "The staff notes that the seismic qualification basis for Diablo 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 LTSP method?

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

5. Was Diablo Canyon's sole use of the LTSP appropriate for evaluating the Shoreline Fault?

No. 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 Page 26 DRAFT - 6f'FlelM: t:19! 6NLY SEN91'fl\'E INfl:RNAL INFORMATION N&T F6R PtlBLl6 RELEASE

DRAFT - eFFJelAL tl9E eNLY 9EN91fl'IE INTERNAL INF6RM>'lll6N - NOT FOR Pt:18Ue RELEA9! safety si9nificance 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 LTSP/Hosgri method. Page 27 DRAFT - e,.F,el>'IL t:19E ONLY 8EN81ll'IE INTERN>'ct INFORM>'ITION - N6T f6R ,.t:18LIC RELE>\S!

DRAFT - erfiet>'ct tJ9e eNLY 9Ef~91ll'f'! INleRN>'cL INP6RM,trJ16f4 - NOT 116ft fltJ9LIC ftl:LfA9! Shoreline Fault Questions

1. When 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 No 44675. This line of epicenters became known as the Shoreline Fault Zone.

2. Where 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. Wha1 are the characteristics of the Shoreline fault?

Studies conducted in 2009 and 201 0 concluded that the Shoreline fault is a right-lateral strike slip fault, approximately 23 kilometers (1 4.3 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 licensee 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 LTSP 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/DOE 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 LTSP/Hosgri, this case was bounded by the LTSP/Hosgri evaluation. This was because the Shoreline fault frequency and peak ground acceleration at the plant were shown to be less than what LTSP/Hosgri would produce at the plant.

5. Has '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 Oiablo 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 critena as was used for the LTSP/Hosgri to evaluate the Shoreline fault This was because the Page 28 DRAFT - eFFlel>'cL tl9E eNLY 9EN91fl'IE INTERN~l lNFORM~'flON - NOT FOR PtJBLle RELEASE

DRAFT - 6Ffte1J1rt t:t9E eNLV 9EN91fl'f1E INTERNAL INFeRMA'TleN - NOT FOR Pt:JBL18 RELEASE Shoreline Fault frequency and peak ground acceleration at the plant were below what LTSP/Hosgri would produce at the plant.

6. Was Olablo Canyon's sole use of tihe LTSP appropriate for evaluating the Shoreline Fault?

No. The design and licensing basis for Oiablo 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 event 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 LTSP 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 LTSP/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 capacity to cause rapid vertical displacement of the sea floor.

8. Why are they safe to operate?

Oiablo Canyon has completed an operational evaluation to show the plant is safe to operate. The NRC reviewed and agrreed the evaluation indicates the plant is safe to withstand earthquake hazards. Based on what the NRC has independently verified and detailed In RIL 2012-01, Diablo Canyon has an operational assessment in place to show that the plant is built to withstand the most severe expected ground motion at the site. If new information suggests the facility js not safe the NRC would take immediate action to resolve the issue. Page 29 DRAFT - efiflel>>tct t:t9E er~LY 9EN91'fl'te INTERNAL INFORMAflON Ne, reR PtJBLle RELEASE

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

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 shaking1at 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 fault 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 Diablo Canyon Power Plant. The former NRC senior resident inspector has questioned how the Shoreline Fault fits within the seismic design and licensing basis of Diablo 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 evaluated and licensed for the Hosgri ground motions; therefore the facmty does meet NRC's license requirements.

10. ls 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 alter the requirements of the license?

The options listed are vatid approaches that could be used to address a licensee'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 Page 30 DRAFT - eFF101AL t:JSE ONLY 9EN91fl\1E INTERNAL INFORMM=ION - NOT FOR Pl:18L18 RELEASE

DRAFT - OFAetAL l:JSE ONLY 9!N91fl\'! lf'fff!ftf.AL INfi6RMAflef* - HeT fi6R tat:f 8lle R!L!AS! 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 built into nuclear power plants. 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 licensee must take, including shutting the reactor down tf the issue cannot be resolved quickly, while others provide flexibility to identify and consider possible options. Depending on the situation and its significance. the NRC also has a number of enforcement options available (such as issuing violations, civil penalties, and Orrlers) 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 properly 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 when 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 DCPP 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 OCPP to determine if an immediate safety concern existed. The NRC continued to review new data and information on the Shoreline fault resulting 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 Page 31 DRAFT - OFFlelAL tJSE ONLV 9ENS1Th'E IN'fERNAL INFORMATION - NOT fieR f't:f8Ue RELEASE

DRAFT - Ofi,.ICIAL t:ISI! ONLY S!NStfl'f'! lf4T!ftN,t(L INl'e~M,tcTleN - NeT Fe9' .-~eue "ELE,tc9! existing design basis for the plant is sufficient to withstand ground motions from the Shoreline fault. Page 32 DRAFT - 6 FF1e1,ct t::t9E eNt\' 91!N91fl'f'f IN'ff PU4,tct 1Nf6"M,tcTl6N - N6T 1'61' P't:18LIC ftl!Ll!')f(91!

DRAFT - eFFlelitcL l1SE 6f~LV 9!NSfflVI! INTE~N1'<L INl'C~M>\TICN - Ne'f FeR Pl18Lle fU!L£ASE [THIS PAGE WAS INTENTIONALLY LEFT BLANK] Page 33 DRAFT - 6f Flebf<t t1SE eNLV 9t:NS1f1YI! INTl!fU*itct 1Nfil6RM1'cfl6N - ,.e, FeR Pl18Ue RELEASE

DRAFT - OFF181AL l:ISE Ot4LV 9!N91TIVI! llffl!ftNAL INf'OKMA'flOP* - NOT FOR Pl:IBLIO RELEASE State of California Seismic Report (ABN-1632)

Background

California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs 1he 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 lfcensee has used the most state of the art methodologies using 20 and 30 mapping to complie this report. This is different methodology than what was used for the 2011 Shoreline Fault. 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. Timeframe Action Responsible Partv(ies) 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/DIRS; OPA; OCA; reporting chain OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. NO blog OR press release planned. Within T+2 Other actions??  ??? business days As requested Complete a Commissioners Assistants Brief R-IV; NRR Questions and Answers

1. What is the Impact of this new infonnation on seismic design and licensing of OCPP? Has the licensee entered this new infonnation into the corrective action program and perfonned an operability evaluation?

As required by the NRC, as document in 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. Page 34 DRAFT OFf'tetAL tJ!! ONLV SENSl=fl'iE IN'fERHAL INFORMATION - NOT FOR PtJBLIO RELEASE

DRAFT - eFFletlcl tJSE 6NLY 9Ef~91flt/E INTERNAL INF6RM>llfl6N - t40T F0R P~BLie RELEASE 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 tor Information (Reference 2).fl 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 Dal-lchi Accident," March 12, 2012.

Region IV. including the resident inspectors, have taken an initial review 1of 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. The initial evaluation of this new information does not invalidate the NRC's standing assessment that the plant is built to withstand a 7.5 magnitude earthquake, or 0.75 ground motion on the Hosgri. The RIL documents the NRC's assessment of the seismic hazard at DCPP. The Hosgri fault, which was reviewed by the NRC, still bounds the Shoreline Fault even though it appears the shoreline fault may be more capable. Further analysis on-site by PG&E has determined that OCPP is still within its design to withstand the longer, more capable shoreline fault. (It produces more energy but over a wider area, which is why the PG&E states that it is still bounded by the Hosgri).

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

This new information, required by the state of California ABN 1632, has been presented to the NRC as a condition of the RIL and shows that the Shoreline fault may be longer and more capable. (Simply put, it produces more energy but over a wider area, which is why PG&E states that it is still bounded by Hosgri).

3. How will the AB 1632 seismic report be coordinated with the 50.54(f) required submittal In March 201 S?

The NRC has reviewed the ptant's corrective action program documentatiion 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. This new information does not negate or invalidate the NRC's assessment laid out in the RIL and therefore the plant remains safe to operate. The 1000-page document has also been given to the Japan Lessons Learned Directorate to be incorporated into 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) will be submitted ot the NRC by March 2015. The updated Seismic Hazards/GMRS will be Page 35 DRAFT - Offlet>IIL l19E eNL¥ 9EN91Tl'tE INfERNAL INF0RMATl0N - N0f F0R Pt-JBLI8 RELEASE

DRAFT - eFFlelAL t:J3E eNtY 9ENS1'f1YE INTERNAL INF6RMATl6N - N6f P6R ,1::1eue RELEASE 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 "final" for the state but "preliminary1' for the NRC?

For the state, the report is final. However, for the NRC, this information will be incorporated in the more comprehensive 50.54(f) analysis due to the NRC in March 2015. Because the licensee must notify the NRC of any new seismic information, they have shared this report with the NRC and entered this information into their corrective action program. The NRC has reviewed the corrective action program evaluation and agrees based on the information provided that the Hosgri is still bounding. Page 36 DRAFT - 6FFlelAL t:JSE et~LV S!NSITrf'! INT!PtNAL IN ..eRMA'TleN - NeT Feft ,t:1et1e RELEASE

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DRAFT - 6ffle1AL use eNtV SEN9ITl\1E ltffERNAL INFORMATION - N6T feR flt18tle ffl:L~!e Los Osos and San Luis Bay Faults

1. Did 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 LTSP. These faults were mentioned in PG&E's January 2011 Shoreline Report for comparison, though no new data on these f auIts was presented. The NRC reviewed these faults under its review of the LTSP, and concluded they were bounded by the Hosgri event and there was no specific need to discuss them in the Updated Final Safety Analysis Report. Page 38 DRAFT - 6ffiltetAL ti!! ONLY 9!N91'fl~1E INfERNAL lf4FORMAflON - NOT f'Oft flt18tle ftl!t!,1(91!

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DRAFT - 6fifile1Al t:ISE 6NLY 9ENS1fl't'E INfEftNl<L 1Nfi6ftMAfl6N - N6l fi6ft l't:18ltC ftEL~9l! Research Information Letter (RIL) Questions

1. What is a RIL?

RILs 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 1n regulatory activities. RIL's allow NRC Regulatory Offices or Regional Offices to readily understand what new information has been obtained, and the significance of that infomiation for current and future licensing reviews or other regulatory activities.

2. What is the purpose of RIL 2009-801 ?

Research lnfom,ation Letter (RIL) 2,009-001 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 2012-81?

Research Information Letter 2012-01 was issued on September 19, 2012. RIL 2012-01 was initiated for RES to complete ain independent analysis of seismic hazard at the Oiablo 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 LTSP/Hosgri method.

4. Now that the RI Ls have been Issued, is PG&E done with its studies?

No. PG&E has performed additional studies including thr~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 characterization of those seismic sources and ground motions most important to the OCPP: the Hosgri, Shoreline, Los Osos, and San Luis Bay fault zones and other faults within the Southwestern Boundary zone. PG&E are performing seismic and flooding watkdowns per the March 2012 50.54(f) request from the NRC. The results from PG&E's actions will be due in March 2015. Page 40 DRAFT - eFFlelAt tJ9! 6NLV 9EN91'flttE IN'fERN>'cl 1Nfi6RM>'c'fl6N - Nef f6fit Pt:18Lie RELEASE

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Background

In March of 2004, as part of the review for the Oiablo 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, Or 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 the Oiablo Canyon power plant. CNWRA did not endorse Dr. Sewell's work, but did transmit the report to the NRC so that he NRC could stay informed 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. Page 42 DRAFT - OFFl01,td: t:ISE ONLY 91:N91frtE INTERNAL lf~f6RMATl6N - NOf FOR Pt:1BU8 RELEASE

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DRAFT - 6fifitelAL t19E et4LY 9!N91fl't'! INf!ftNAL INfi6RMAl16f4 - N6T 1'6R ,t1et1e RELcfc9E Non-concurrence and DPO Questions (NOTE - this information is generally NON-PUBLIC, but is provided as background only]

1. Was the former DCPP 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 wrote his Non-Concurrence Paper (NCP). He was competitively selected for this sought-after position, and reported to his new assignment in September 2012. Resident Inspector assignments are limited to17 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. 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 2012-01was 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 operabihty evaluation from January 201110 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 operabmty 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 Rll 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. Page 44 DRAFT - OflflCl/ct USE ONLY 8 ff4SITl\1E INTERNAL INF6RMATION - N6T fi6R ~t18Lle RELEASE

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4. When was the DPO flied?

July 18, 2013. The for-mer DCPP SRI filed Diffenng 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?

On August 2, 2013, DPO 2013-002 was assigned to NRR for review. The DPO Panel was established on September 3, 2013. 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 public?

Maybe. The DPO process is discussed in Management Directive 10.159 (a publically available document). However, the DPO process for a specific review is an internal. non-public process. The DPO petitioner has rights, including the right to privacy over any issues rarsed in the process. The DPO petitioner has a key role In determining whether or not the OPO and Directo(s decision become available publicly.

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

No. The SRl's wording in the DPO c-0uld be viewed by some to mean he was reassigned following the filing of the non-concurrences against his will. 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 Page 45 DRAFT - 0FFl81AL t:ISE 0NL\1 S!l4SITl't! 114T!ftNAt IHl'OftMATIOH - HOf 1'6ft 1't:n,t1e l'U!U!A9!!

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9. Timellne of Events associated with the NCPs and DPO:

11n111 (NON-PUBLIC) OCPP SRI submits Non-Concurrence NCP 201 1-103. The SRI non-concurs, on Inspection Report 05000275; 323/2011004 because the proposed violation involving the Shoreline Fault operability evaluation was not issued. 11 /9/11 (NON-PUBLIC] NCP 2011-103 is dispositioned by Region IV. The operability evaluation issue was documented as an Unreso1lved ltern In Inspection Report 05000275; 323/201 1002 and dispositioned as a violation in Inspection Report 05000275; 323/2011005. 40/2011 [NON-PUBLIC] The DCPP SRI continues to question the enforcement action associated with the Shoreline Fault operability evaluation. Several meetings between multiple NRC offices are conducted to discuss the Shoreline Fault. 1/26/12 [NON-PUBLIC] 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 operability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault. Feb 2012 [NON-PUBLIC] DCPP SRI applies for instructor position vacancy at the Technical Training Center (TTC). 02/12-07/ 13 [NON-PUBLIC] RIV management frequently encourages the DCPP SRI to submit a Differing Professional Opinion (DPO) during several discussions involving seismic issues. May 2012 [NON-PUBLIC] OCPP SRI is selected for instructor position at the Technical Training Center (TTC). Sept 2012 [NON-PUBLIC] The (now former) DCPP SRI reports to the TTC as a training instructor. Oct. 1, 2012 [NON-PUBLIC] Response to NCP 2012-01 issued. NGP 201 2-01 was discussed with NRG 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 NRG 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 Page 46 DRAFT - OPl'ICIAL t:19! ONLY Sl!N9ffft1e INf!MNAL 1Nf6RMM'f6N - NOT ,e11t l'tJ!LIC ltl!t!Jilc9!

DRAFT - 6ffletAL tJSE eJRY S!NSll'ltt! INTERNAL INf6RMAfl6N - Nel' f6ft fttJBUe REL!ASE 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 7/18/13 [NON-PUBLIC) Former SRI submits a DPO regardmg the agency's regulatory actions associated with the Shoreline Fault. 8/2/13 [NON-PUBLIC] DPO 201 3-002 was assigned to NRR for an independent review. 9/3/13 [NON-PUBLIC] Director, NRR establishes a OPO Ad Hoc Review Panel (DPO Panel) for DPO 2013-002 with three NRC staff members who have been independent of the initial concerns raised by the former DCPP SRI. 4/3/14 [NON-PUBLIC] OPO Panel completes its review of DPO 2013-002 and submits its report to the Director, NRR. 5/29/ 14 [NON-PUBLIC) Director, NRR issues his decision on DPO 2013-002 by memo to the former OCPP SRI. 8/25/14 Associated Press article released discussing the DPO. Page 47 DRAFT - OfflelAL USE eNt\' 9EN91fl'tE IN=fERNAL INFORMA=flON - NOl' FOR fttJBL10 RELEASE

DRAFT - 6FFtetAt use 6f4LY 9ENSll'1¥E INl'!RNAL INf6RMAl'l6N - H6T f6R raueue Rfi:E)fcS! RtS 2005-20, 2013-005, and Operability Evaluation Questions

1. What is a RIS?

ARIS 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 information that should be provided in licensing applications, rund (5) request the voluntary participation of the nuclear industry In NRC-sponsored pilot programs or the voluntary submittal of information. A RI$ does not communicate new or revised NRC requirements.

2. How does the RIS apply to failures to mHt design requirements (e.g.; General Design Criteria (GDC))?

RIS 2013-005 restated the NRC's position regarding operability evaluations for nonconforming conditions related to design and licensing requirements. The failure to meet GDC, as described in the licensing basis (e.g., nonconformance with the Current 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 licensH 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 LTSP was appropriate to charactenze and bound the faults as part of the operability evaluation process. Addltionally, the LTSP 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 48 DRAFT - 6 f'flel>fl.t t19! 6NLY 1 9CN91'flYE IN'fERNAL INF8RMA'f18N - NM ,.09' ..tf l!9LIC 9'1!L!>\9!

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1. Did the NRC issue any violations invotving 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 fault which met the guidance in RIS 2005*020. Oiablo Canyon submitted a LAR to clarify the UFSAR; however, the LAR has since been withdrawn. Diablo Canyon is currently performing seismic evaluations to support their response to the NRC's March 2012 50.54(f) letter. Page 50 DRAFT - el'l'lebtct t:JSI! eNtY

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           !!!H!l'fl'f'!! INTt!ftNAL INl'6ftMAl16N - ,~eT FeFt PtJeue RELEASE Current Licensing Questions

1. What are the Current Seismic Qualification Design Basis requirements at DCPP?

Appendix A to Part 50, General Design Criteria for Nuclear Power Plants, Criterion 21 "Design 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 cap,ability 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 surrounding 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, "Seismic and Geologic Siting Criteria for Nuclear Power Plants,n for establishing the three DCPP design basis earthquakes:

• Design earthquake (Operating Basis Earlhquake) - 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 #Design/Initial Licensing Basis Questions" for additional background]

2. Did Diablo 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/LTSP method as the only method for evaluating new seismic information (including the Shoreline fault) and for approval of a method to combine LOCA and seismic loads. In December 2011, the licensee discussed the LAR with the Region IV Branch Chief 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. Page 52 DRAFT - OP'f'letAL tl9! 6NLY 9EN91Tl'fJE INTERNAL INF8RMAfl8N - N8T FOR PtJBUe RELEASE

DRAFT - 6f'flel111L tJ3!: et*LY 91:.N!ll"lttl! INTl!RNAL INl'O"Mic1'10N N6'f F6R fltJ!!Lle Rftl!ASI! NRR/OORL 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, 201 2. During the NRC aoceptanoe 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?

While 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 2011 LAR were intended to clanfy 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 ODE. 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(1) 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 ODE. The NRC expects that the seismic re-evaluation at Diablo Canyon will yield results very similar to the LTSP results, because the methods and data are similar.

5. Did the NRC allow PG&E to bypass Oiablo 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 faults

6. I heard NRC's Cliff Munsen say to the Callfomla Energy Commission that the NRC expects Dlablo will exceed its DOE once it completes this ongoing seismic review.

What does it mean when the NRC says they will exceed their ODE? What changes will the plant be required to make? If none, why not? The Hosgri and ODE are separate methods for evaluating seismic information. As .a result of the 50.54(1) letter review the NRC expects that Diablo Canyon wlll select a single method consistent with the alre,ady NRC reviewed LTSP for evaluating new seismic information. The change to a single method for evaluating seismic information will need to be reflected in the UFSAR. Page 53 DRAFT - 6f1flelAL tJ9! 6NLY S!NSlfftf'! INfE"NAt: INF6RMAfl6N - NeT F6R fitJBtle ft!LEA9E

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1. When will Oiablo Canyon's FSAR reflect the correct seismic information?

The NRC expects the UFSAR will be revised following completion of the .50.54(f) letter reviews. Diablo 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 required 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(f) 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 54 DRAFT - OFflelAL t:JSE ONLY S!NSITl'f'! INT!ft:NAL INfORM'lc'flON - NOT FOR Pt:IBLl8 RELEASE

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DRAFT - 6FFlel>>tcL t19E eNL'f 9!N91fl't1I: INfl!!RNAL INfORMAflON - NOT l'Oflt l'tll!!LIC IU!L!tcSI!! 50.54(f) Questions

1. When was the 50.54(f) letter issued?

March 2012.

2. What is the purpose of the seismic 50.54(f) letter?

Oiablo 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 Oiablo 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 proposed 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 Diab lo 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/ML1205/ML12053A340.pdf) 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 determines 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 in early 2018. Page 56 DRAFT - Ol'l'ICtAL tlSI! ONLY 9!N91TIYI! 1Nff1U4>>tcl U4f6ftM*Tl6H - NOT l'O" l'tJ!LIC ftl!Ll!A9!

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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 NRG has followed the seismic re-evaluation process since the beginning at DCPP. The NRG 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 following the rigorous NRC-appro,ved process, which will take several years. 11 is expected that PG&E will produce a s,ingle 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 ls SSHAC? What Is SSHAC Level 3?

10 GFR 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 NRG published NUREG/CR-6372, "Recommendations for Probabilistic Seismic Hazard Analysis: Guidance on Uncertainty and the Use of Experts.* Written by the Senior Seismic Hazard Analysis Committee (SSHAG), 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 compktte their seismic reevaluation when the seismic risks 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 perfonn a seismic hazard reevaluation} takes 3 - 4 years. The SSHAC study produces the seismic hazard models that are needed to perfonn the seismic reevaluation. When Fukushima occurred, the Central and Eastern US plants (CEUS) were ln 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 s.eismic reevaluation, Which is why we gave them a shorter period of time to respond to the 50.54(f) letter. Page 57 DRAFT - er,1e11ct HSI: eHt'( 9Ef~91flYE INTEffN>'cl INf6RMiltTl6N - Nef f6" ,1:n,ue MEL!>'c9E

DRAFT - 6 fflelAL t19E eNLY 9EN81'fl'IE IN'fEFtNallt 1Nf6FtM>'cll6N - NOT 110ft f't:1et1e ftELE>'cSE The Western U.S. does not have a regional model like the CEUS - so the NRC required all Western U.S. plants lo 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 signiftcant 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 it 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 (NTIF) report concluded that with the current ll'egulatory 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 NTIF recommendations would enhance safety, the staff determined that none of the NTIF 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 in 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 2008-2011 ). 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-D 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 w,11 be fed into the SSHAC study and hazard re-evaluation as part of PG&E's response to the 50.54(f) letter. Page 58 DRAFT - Of ftelAL lj9E ONLY 91!N91'fl'f'E lfffERNillt INF6RMillf l6N - ,~o, f'OR f't:18Ue RELel<Sf

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12. In an October 12, 2012, letter to Oiablo 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 associated with the ODE/SSE earthquake using the methods specified in the SSE/ODE? No. The quoted statement is referri,ng to a comparison the NRC requested licensees make ln a March 12, 2012 request for Information. The NRC's March 12, 2012 letter requested PG&E to perform a re.evaluation of the seismic hazards at the DCPP site, using the NRC-approved SSHAC Level 3 method. The request for information, issued in response to recommendations of the Near-Term Task Force review of the accident at the Fukushima Dai-ichi nuclear facility, requests the licensee to compare the results of its seismic re-evaluation using the latest methods to the current seismic design basis (the ODE for Diablo Canyon) and as-built design margins. The NRC specifically requested that licensees compare the results of their seismic re-evaluation to the DOE/SSE to ensure that the information received from every nuclear power plant was comparable across the industry. The March 12, 2012 letter specifically recognized that the new seismic data obtained through the NRC-specified process may result in higher ground motion when compared to the DOE/SSE, and lays out a process that licensees and NRC will follow in such situations. The quoted statement recognized that the DCPP seismic licensing and design basis is unique in that it includes the DE, the ODE, and the much larger HE ground motion. The NRC expects PG&E to include the Hosgri and Shoreline faults in its re*evaluation, and in its comparison of the new seismic information against the DOE. The October 12, 2012 letter continues by stating that *... it is appropriate to include these scenarios, along with any new seismic information that may be developed, in the risk-informed, performance-based (Ground Motion Response Spectra) GMRS and then follow the process set forth in the March 12, 2012, request for information, to determine whether any additional regulatory action is needed." It makes sense that including the much larger Hosgri fault and the Shoreline fault in the re-evaluation will likely result in a seismic hazard that exceeds the ODE, even after accounting for the low frequency of occurrence of such a large earthquake. The NRC's request in no way reflects negatively on the level of safety assurance provided by the current design basis and actual construction of US plants. The results will not invalidate the original analyses. Instead, they are intended to be used to assess the current level of seismic safety across the entire industry by taking advantage of advances In seismic evaluation techniques and much more seismic data. and to determine whether further regulatory action is needed. For example, if new information is uncovered that would suggest the Shoreline fault is more capable than currently believed, the NRC expects that the licensee will provide an evaluation that describes actions DCPP has taken or plans to take to address the higher seismic hazard relative to its design basis. The NRC staff will jndependently assess the new information and determine if it changes the staffs current position that ground motion associated with the Shoreline fault is at or below the HE. Page 59 DRAFT - 6ffle1Al t:ISE ONLY 9EN91fl'l'E INTERNAL INFORMATION - N8f FOR Pt:IBLle RELEASE

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13. What specific seismic studies is PG&E conducting?

In general there are two types of data. There is data that can help you better characterize the seismic sources (faults) and there is data that can help yo-.i better characterize the ground motions (shaking at the site). Specific new studies being conducted by PG&E for seismic source charact,erizat,on (most have already occurred):

• Onshore 2D/3D Seismic Reflection Surveys
• Onshore Geologic Mapping
• Onshore Light Detection and Ranging (UDAR) Mapping (topographic mapping)
• Offshore Multi Beam Echo Sounds (MBES) Mapping (of the sea floor)
• Offshore 20/3D Low Energy Seismic Reflection Surveys
• Potential Field Mapping (gravity and magnetic surveys)

Specific new studies being conducted by PG&E for ground motion characterization:

• Ocean Bottom Seismometers
• New seismic station near power block to record small earthquakes
• Finite Fault Simulations and Dynamic Rupture Models (working with various research groups including the Southern California Earthquake Center - SCEC and the Pacific Earthquake Engineering Research Center - PEER)

14. What is the status of the 30 mapping?

PG&E has completed low-energy two-dimensional (20) and three-dimensional (30) seismic mapping, along with high-energy 3D seismic on-shore mapping. The issue is with the offshore high-energy 30 mapping. In order to perform the offshore high-energy 30 testing, PG&E needed to obtain 12 permits from State and Federal agencies. In November 2012, the California Coastal Commission rejected the permit request for the high-energy 3D offshore mapping. PG&E is now considering whether to conclude that its obligation to the state has been met and pursue final certification (Coastal Consistency Certification).

15. Why did the Coastal Commission reject the permit?

The seismic surveys rely on the use of air guns to generate high energy acoustic pulses capable of passing through ocean waters and penetrating from six to nine miles into the seafloor. The key Coastal Commission issue of concern was the project's significant and unavoidable impacts to marine resouroes. Specifically, seismic surveys are among the very loudest anthropogenic underwater sound sources and can cause disturbance, injury, and loss of a large number of marine species due to air gun noise. The California Coastal Commission ultimately denied the permit application due to the potential detrimental effects to marine mammals and other wildlife in the area. Page 60 DRAFT - Ol'flCIAL t,Se ONLY 91!!f4SITl'WI!! IN'ft!ftNAL INF-6ftMATl6N - NOf l'Oft .. tJl!LIC ftl!Ll!!A!I!

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DRAFl - 6fF1e1>1ct ttse 6NLY 9!NSITl'f'I! INT!ftNAL INf6ftMATl6N - N6'f f6ft fltt8LIC ft!Le1<9! DCPP Licensing Basis Verification Proiect (LBVP) [From Licensee Status Bnefing in August 2012.

                          & Updated in Sept. 2013 for new RA briefing]

Purpose The primary purpose of the Licensing Basis Verification Project (LBVP) is to perform an obj ective evaluation to determine if the DCPP licensing basis has been adequately maintained, and to correct any identified 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 Diablo 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 10 CFR 50.59 evaluations

3. Determine and document DCPP' s committed compliance with 10 CFR 50, Appendix A, "General Design Criteria 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 defi ciencies in these systems.

8. Provide an updated tool to aid in o perability 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 including Accident Analysis Ch apter 15, RCS, RHR, Reactor, and others.

• Phase I (February - October 20*1O)

Phase I of the LBVP reviewed and evaluated design and analysis changes to the Component Cooling Water (CCW) and Auxiliary Feedwater (AFW) systems.

• Phase II (September 2010- 2015)

Phase II 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 Page 66 DRAFT - 6f ftetAL tt9! eNt't se:N91Tl't'! IN'f !RftAL INF8RMAll6f~ NOT FOR PijBL18 R£LEAt9E

DRAFT - 6FflelAL t19E eNLY S!NSffl't'! INT!ftN>'d: INfOftMAfleN - Ne,. f6ft flt19LIC "!L!AtS! findings, lessons learned, and recommendations, all of which was addressed in the Phase I summary Report. Licensi ng Basis 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 wi1h licensing basis requirements. LBR reviewed internally by PG&E and by an Independent Review Board. System Revfewa Following the LBR, validate the licensing basis requirements and FSAR implementation into plant documents (design documents. procedures, WCAPs, drawings. calculations). Finalize FSAR/DCM revisions. FSAR revisions 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 is 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 NRG.

Current schedule DCPP committed to the NRC to complete the LBVP by 12/31/2015. Completion clarified In document DCL-1 2-003 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 Page67 DRAFT - eFFlebtd.. t19f 6NLY

DRAFT - er,1e11ct t:J9E e,~tY SEN91fl'l'E IN'fERNAt: 1Nf6RMATl6N - NST fi6R flt:J8tle ftEt:!A9! 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 201 3)

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.

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DRAFT - ef p;telAL tJ9! 6NLY Sl!NSITl'f'! INT!"NAL IN"O"MATION - Ne;y: F6ft f'tJ8Ue R!LEltc,9 e Public Cancer Risks Refer to MCommunications Plan: Analysis of Cancer Risks in Populations living Near Nuclear Facilities - Phase 2 Pilot Studies" (Ml 13274A664), maintained by RES. for the most current Information. The following O&As noted are likely to be of particular interest to DCPP stakeholders {page number in RES communication plan Indicated): Page 9:

• 01 . Why has the U.S. Nuclear Regu,atory 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 included 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:

• 021 . 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?

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DRAFT - 6ffilCIAL tJSE 6Nl!t 9 EN91fl't'E INl'ERNAL INF0RMA'fl0N - N61' fie" flt:18Ue REteA9E Emergency Preparedness Concerns

Background

In November 2005, Oiablo Canyon Power Plant revised its emergency plan without prior NRC approval. This change removed a table used to assist in making protective action recommendations to the offsite 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 pnor to implementation. This issue is currently being evaluated using our significance determination process and through traditional enforcement. The preliminary determination is a Severity Level Ill with an associated White finding, but that is subject to change following further review. Key Messages

• 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). During drills and evaluations during the time period in question, these individuals did include the ocean appropriately.
• 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 Page 74 DRAFT - Ofll'ICtAL ttSE 6NLV 9EN91'fl'l'E INifERN~L INF0RMATl0N - N6'f f6ft fltn,ue M!tl!A!I!

DRAFT Talking Points: state Report 09/25/2014 3:52 PM

• As required by the NRC, as documented in the RIL, PG&E has entered the new preliminary seismic info 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 lo the NRC's review ofthe January 2011 Shoreline Fault Reporl, PG&E made /he following commitment 10 the NRC:

       "Ifduring PG&E 's ongoing co/lee/ion ofseismic data, new faults are discovered or information is uncovered thal would suggest the Shoreline fault is more capable Jhan currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address rhe higher seismic hazard relative to the design basis, as appropriate, prior to completion ofthe evaluations requested in the NRC staff's March /2, 2012, request for information (Reference 2)." Where Reference 2 is NRC letter to All Power Reactor Licensees and Holders ofConstruction Permits in Active or Deferred Status, "Request of Information Pursuant to Title IO ofthe Code of Federal Regulations 50.54(/) Regarding Recommendations 2.1, 2.3, and 9.3 ofthe Near-Term Task Force Review ofInsights from the Fukushima Dai-lchi Accident."

March 12, 2012

• The NRC perfonned an independent detenninistic analysis of new seismic information provided by PG&E in 201 1 relating to the Shoreline fault. NRC's conclusions are documented in Research Information Lener (RTL) 12-01, dated October 10, 2012 (publically available in ADAMS ML121230035). 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.
• Region IV, including the Resident Inspectors, have taken an initial review of PGE's initial operability evaluation of the new information to verify it does not affect the plant's ability to operate safely and be able to remain safely shutdown following an earthquake.
• The new information, required by the state of CA AB 1632, has been presented to the NRC as a condition of the RIL and shows that the Shoreline fault is longer and more capable. (Simply put, it produces more energy over a wider area which is why the NRC agrees that it is still bounded by the Hosgri.)
• The initial operability evaluation does not invalidate the NRC's standing assessment that the plant is built to withstand a 7.5 mag earthquake or .75 ground motion on the Hosgri.

The RJL documents the NRC's assessment of the seismic hazard al DCPP. The Hosgri fault which was reviewed by the NRC, still bounds the Shoreline Faull even now it

appears the shoreline fault is more capable. Further analysis on site by PG&E and has detennined that DCPP is still within its design to withstand the longer, more capable shoreline fault. (It produces more energy over a wider area which is why the NRC agrees that it is still bounded by the Hosgri.)

• Because this is a complex technical issue, there will be additional review by the seismic experts at HQ. This new information will also be evaluated by the Japan Lessons Learned Directorate and incorporated into the 50.54f review being conducted as part of the post-Fukushima actions and due in March 2015.
• In addition, a longer-term review is underway by the License renewal staff to determine whether an amendment to the 2011 issued Draft EIS (ML# .... ) is needed.

0 and A: What w ill the NRC do with this new information? The NRC has reviewed the plant's operability evaluation provided by PG&E. All indications are that the Shoreline fault remains bounded by the Hosgri fault for which the plant was built and licensed to withstand. This new information does not negate or invalidate the NRC's assessment laid out in the RJL and therefore the plant remains safe to operate. The 1000-page document has also been given to the Japan Lessons Learned Directorate to be incorporated into the 50.54f 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) will be submitted to the NRC by March 20 15. 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. (Ifpushed on any "unkowns" in the report : ff necessary, actions could include orders to halt operations ifthe 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 ofa beyond design basis event.) Why are you saying this report is preliminary? For the state, the report is final. For the NRC, this information will be incorporatedl 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 agrees based on the info that the Hosgri bounds all seismic events. 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 RJL? California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of2006) directs the California Energy Commission to assess the potential vuJnerability of California's largest bas,eload 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 2D and 3D mapping. This is different methodology than what was used for the 2011 Shoreline Fault. 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?) 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, it has been determined that the Shoreline Fault Zone may be more capable than summarized in the January 20 11 report, but the deterministic response spectra are still bounded by those for the Hosgri and LTSP earthquakes. Therefore, the conclusions remain the same and there is no adverse impact on the seismic design of DCPP. As a result, the assessment associated with the January 2011 Shoreline Fault Report remains valid.

From: Vse!dn IP Lara To: Ma,klev, l"'.icbac:I; Walker WlMl':, &x.nanafl, 111:::1:>il; Nwnaec Ryan cc: SebrQSliy. Jos.¢!!b: Case Mtmae!: O;fyl) Jn. S...1Qtt Soon. SUbject: someone has posted DPO online Date : Monday, AUVust 25, 201~ 2:15:27 PM Importance: High Qm someone verify if what Mothers for Peace Jane SWanson has sent out to media and the public is trie actual DPO? See her link to below: From: Jane SWanson [madtol b 61 b Sent: Monday, August 25, 20 4 12:Jo PM To: swanson Jane

Subject:

MORE on AP story Detailed Information about NRC Inspector Dr. Peck's Differ1ng Professional Opinion Is at http*//llbcloud s3 amazonaws com/93/Sa/8/4821/D1ablo Canyon Seismic PPQ,pdf It is at the heart of the AP story.

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Original Message*----

From: Markley, Michael Sent: Monday, August 25, 2014 11 :12 AM To: Uhle, Jennifer; Lund, Louise; Dudek, Michael Cc: Sebrosky, Joseph; Case, Michael; Davis, Jade; Uselding, Lara; Burnell, Scott

Subject:

FW: DPO story has run Importance: High

All, FYI, it appears that the DPO regarding Diablo Canyon is now running in the AP. As you know. the process Is stlll pending within the NRC. A final decision has not been made and the DPO process is a non-public process, in part, because the submitter has privacy rights. Only the submitter of the DPO can release the information to the public.

Mike

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Original Message-----

From: Useldlng, Lara Sent: Monday, August 25, 2014 11:52 AM To: Oesterle, Eric; Slngal, Balwant; Sebrosky, Joseph; Markley, Michael; Gibson, Lauren; Hlpschman, Thomas; Reynoso, John Cc: Walker, Wayne; Buchanan, Theresa Subj ect: FW: DPO story has run

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Original Message-----

From: Uselding, Lara Sent: Monday, August 25, 2014 10:47 AM To: Walker, Wayne; Buchanan, Theresa; Alexander, Ryan; Dapas, Marc; Kennedy, Kriss; Dricks, Victor; Brenner, Eliot; Burnell, Scott

Subject:

DPO story has run Just posted

AP Exclusive: Expert Calls for Nuke Plant Closure By Michael R. Blood Assoc,lated Press, August 25, 2014 LOS ANGELES (AP) - A senior federal nuclear expert Is urging regulators to shut down callfomla's last operating nuclear plant until they can determine whether the facility's twin reactors can withstand powerful shaking from any one of several nearby earthquake faults. Michael Peck, who for five years was Diablo Canyon's lead on-site Inspector, says in a 42- page, confidential report that the Nuclear Regulatory Commission Is not applying the safety rules it set out for the plant's operation. The document, which was obtained and verified by The Associated Press, does not say the plant itself Is unsafe. Instead, according to Peck's analysis, no one knows whether the facility's key equipment can withstand strong shaking from those faults - the potential for which was realized decades after the facility was built. Continuing to run the reactors, Peck writes, "challenges the presumption of nuclear safety." Peck's July 2013 filing is part of an agency review in which employees can appeal a supervisor's or agency ruling - a process that normally takes 60 to 120 days, but can be extended. The NRC, however, has not yet ruled. Spokeswoman Lara Uselding said In emails that the agency would have no comment on the document. The NRC, which oversees the nation's cornmerclal nuclear power Industry, and Diablo Canyon owner Pacific Gas and Electric Co., say the nearty three-decade-old reactors, which produce enough electricity for more than 3 million people annually, are safe and that the facility complies with its operating license, lnduding earthquake safety standards. PG&E spokesman Blair Jones said the NRC has exhaustively analyzed earthquake threats for Diablo Canyon and demonstrated that It "is seismically safe." Jones said in an email that the core issue involving earthquake ground motions was resolved In the late 1970s with seismic retrofitting of the plant. The disaster preparedness of the world's nuclear plants came into sharp focus In 2011, when the coastal Fukushima Dai-lchi plant in Japan suffered multiple meltdowns after an earthquake and tsunami destroyed Its power and cooling systems. The magnitude-9 earthquake was far larger than had been believed possible. The NRC has since directed U.S. nudear plants to reevaluate seismic risks, and those studies are due by March 2015.

The Important of such an analysis came Into sharp focus on Sunday when a magnitude 6.0-earthquake struck in Northern California's wine country, injuring scores of residents, knocking out power to thousands and toppling wine bottles at vineyards. Environmentalists have long depicted Diablo Canyon - the state's last nuclear plant after the 2013 closure of the San Onfore reactors in Southern California - as a nuclear catastrophe In waiting. In many ways, the history of the plant, located halfway between Los Angeles and San Francisco on the Pacific coast and within 50 miles of 500,000 people, has been a costly fight against nature, involving questions and repairs connected to its design and structural strength. What's striking about Peck's analysis Is that it comes from within the NRC Itself, and gives a rare look at a dispute within the agency. At Issue are whether the plant's mechanical guts could survive a big jolt, and what yardsticks should be used to measure the ability of the equipment to withstand the potentially strong vibrations that could result The conflict between Peck and his superiors stems from the 2008 discovery of the Shoreline fault, which snakes offshore about 650 yards from the reactors. A larger crack, the Hosgrl fault, had been discovered in the 1970s about 3 miles away, after the plant's construction permits had been issued and work was underway. Surveys have mapped a network of other faults north and south of the reactors. According to Peck's filing, PG&E research in 2011 determined that any of three nearby faults - the Shoreline, Los Osos and San Luis Bay- Is capable of producing significantly more ground motion during an earthquake than was accounted for in the design of Important plant equipment. In the case of San Luis Bay, It is as much as 75 percent more. Those findings Involve estimates of what's called peak ground acceleration, a measurement of how hard the earth could shake In a given location. The analysis says PG&E failed to demonstrate that the equipment would remain operable if exposed to the stronger shaking, violating Its operating license. Toe agency should shut the fadllty down until it is proven that piping, reactor cooling and other systems can meet higher stress levels, or approve exemptions that would allow the plant to continue to operate, according to Peck's analysis. Peck disagreed with his supervisors' decision to let the plant continue to operate without assessing the findings. Unable to resolve his concerns, Peck in 2012 filed a formal objection, calling for !PG&E to be cited for violating the safety standards, according to his filing. Within weeks, the NRC said the plant was being operated safely. In 2013 he flied another objection, triggering the current review. The NRC says the Hosgrl fault line presents the greatest earthquake risk and that Diablo canyon's reactors can withstand the largest projected quake on It. In his analysis, Peck wrote that after officials learned of the Hosgri fault's potential shaking power, the NRC never changed the requirements for the structural strength of many systems and components in the plant.

In 2012, the agency endorsed preliminary findings that found shaking from the Shoreline fault would not pose any additional risk for the reactors. Those greater ground motions were "at or below those for which the plant was evaluated previously," referring to the Hosgrl fault, it concluded. Peck, who holds a doctorate In nuclear engineering and Is now a senior instructor at the NRCs Technical Training Center In Tennessee, declined to comment on the filing. Earthquake faults and nuclear power plants have been uneasy neighbors In the state for decades. The Humboldt Bay plant in Northern California, which was within 3,000 yards of three faults, was shut down in 1976 to refuel and reinforce its ability to withstand possible earthquakes. Restarting it became more difficult and costly than projected - it never reopened.vgd

From: Sebrosky, Joseph To: G1bson, L,a1<eo: Difrancesco, N!Chofas Cc: s1naa1, Qalwant* Oeslede, Ede; Usefd1na Lara: Wha!ey, sns:eoa

Subject:

Info: past communieatlon plan on Olablo Canyon RIL Dabl: Monday, August 25, 2014 7 :34:00 AM Atbd'lments: commvo!GliPo Piao tor dcno weti @Yll zone 01 11-J.12 doQ Lauren . and Nick, The purpose of this email is to provide you with the past communication plan on the Oiablo Canyon RIL. Although old. it gives you some idea of the folks that were involved with the issuance of the RIL including OCA. In addition , based on discussions with Nick I understand that the PG&E mentioned on Friday that it considered the Shoreline fault to be capable of generating a magnitude 6.7 earthquake. As you know the 2012 RIL looked at the possibility of the Shoreline fault generating a magnitude 5.9 and a magnitude 6.7 earthquake. The RIL is available at: View ADAMS es Properties ML12123003S Open ADAMS ea Document {Research Inform at on Letter RIL-12 01 - Confirmatory Analysis of Seismic Hazard at the D,ablo Canyon Power Plant from the Shoreline Fau t Zone l As stated in the RIL the 6.7 magnitude earthquake is based on a scenario where the Shoreline fault is 23 kilometers long. There were longer faults that were considered in the RIL and the RIL states the following regarding these longer faults: Any fault length greater than 33 km, and thus capable of generating a larger earthquake, would have to extend onshore on the opposite side of the bay where evidence of faulting would be seen. These two lines of field evidence suggest that Mm," cannot exceed M6. 9. While this line of reasoning is informative and provides a clear upper boundary for Mmu, use of this scenario is not supported by the data, and the NRC staff determined that using M6.9 in a OSHA is speculative and not supported by the currently available observations. The bottom line is whatever PG&E told us on Friday I think needs to be reviewed against the RIL to see if the RIL is still applicable or if an update needs to be considered. Please recognize that at the 6.7 magnitude earthquake the statement we made in the RIL cover letteir that the deterministic evaluations were at or below those for which the plant is licensed was based on the graph below. The graph, which can be found in the RIL, shows that at the 20 Hz range the 6.7 magnitude earthquake spectrum and the Hosgri spectrum are essentially equal.

             - ~~

,S! C 2.0 1.TU>~

                    "-'AC~ 7 a.a...
             - - NRC USt M ...

0 =e 1.5 II> "i u u c( 1.0 i u, 0.5 0.0 '--~~~~~~~~~~~~~~~~~~~~~~----- 0.1 1 10 100 Frequency (Hz) More background information on the RIL that was used to support a November 2012 public meeting can be found at the following RIV sharepoint site: bttp*JJtusioo ore gov/regiooslciYLPublic%20Meetiogs/forms/Amtems aspx Please let me know if you have any questions.

Thanks, Joe

COMMUNICATION PLAN FOR ISSUANCE OF RESEARCH INFORMATION LETTER ASSOCIATED WITH SEISMIC HAZARD AT THE DIABLO CANYON POWER PLANT FROM THE SHORELINE FAULT ZONE SEPTEMBER, 2012 11-3-12 Version GOAL The goal of this communication plan is to outline the strategy the NRC will use to inform the public and interested stakeholders of the issuance of a Research Information Letter (RIL) 12-01 "Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone.* RIL 12-01 , documents the staff's near term assessment of the Shoreline Fault Zone. Pacific Gas and Electric is collecting information for a long term assessment in order to respond to a March 12, 2012, letter from the NRC, "Request for Information Pursuant to Title 1O of 1he 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 form the Fukushima Dai-lchi Accident." This communication plan associated w ith RIL 12-01 is to be used in conjunction with the communication plan dated March 2012 for the "Near-Term Task Force Tier 1 Recommendations and Orders & 50.54(f) Letters." The March 2012 communication plan is available at http://www.intemal.nrc.gov/communications/plans/act ive/Comm-Plan-0rders-and 54f-Letters. pdf KEY MESSAGES

• The RIL documents the staff's independent assessment t hat the recently discovered Shoreline fault peak ground motions are within the ground motions for which the plant was evaluated previously and demonstrated to have reasonable assurance of safety.
• The new information in the Shoreline Fault Report and the RIL continue to support the NRC's conclusion that Diablo Canyon Power Plant was designed and licensed to safely withstand the largest seismic ground motions expected at the site.
• The RIL documents a deterministic (scenario-based) analysis that allowed the staff to eliminate immediate safety concerns as a result of the identification of this new fault o Deterministic approaches focus only on the safety margin that exists for a specific earthquake scenario on the Shoreline fault. The deterministic approach is consistent w ith the current licensing basis method for DCPP.
• A more detailed assessment of potential risk impacts from the Shoreline fault is being performed by Pacific Gas and Electric (PG&E) for DCPP as part of the development of a regional model that will be used as the basis for PG&E's response to a March 12, 2012, letter from the NRC.

1

• High-energy seismic reflective profiling offshore is planned to supplement the low-energy testing and the many other studies that have already been completed to understand the seismic potential at the DCPP. This testing is voluntary.
• PG&E has worked cooperatively with the United States Geologic Survey (USGS) for years as part of the PG&E-USGSCooperative Research and Development Agreement (CRADA) to study seismic hazards that could impact Diablo Canyon.

The NRC has conducted more detailed seismic reviews of DCPP than any other plant in the country. The studies at DCPP have helped advance the state of the art.

• The NRC staff will continue to monitor PG&E's efforts in this area BACKGROUND On November 14, 2008, the Pacific Gas & Electric (PG&E) Company informed the U.S.

Nuclear Regulatory Commission (NRC) that it had identified a zone of seismicity that may indicate a previously unknown fault located offshore of the DCPP. This zone of seismicity is located approximately 600 meters offshore from DCPP. The potential fault was identified as a result of a collaborative research program between PG&E and the U.S. Geological Survey (USGS). This research program, called the PG&E-USGS Cooperative Research and Development Agreement (CRADA), focuses on increasing the understanding of tectonics in the region around the DCPP. The current phase of this long-standing program includes both new geophysical and geological field studies and the application of advanced seismological techniques to small-magnitude recorded earthquakes. Shortly after PG&E notified the NRC of the potential for a new fault, it provided the NRC with sets of initial scientific data and information related to the hypothesized fault (ML090690193, ML090690218), which PG&E subsequently named the "Shoreline fault." The licensee indicated that the hazard potential of the Shoreline fault is bounded by the ground motion spectrum used for the design and licensing of the facility, meaning that the plant has been designed to safely shutdown following a ground motion or shaking level larger than the Shoreline fault is capable of producing. Based on the initial information provided by PG&E and the USGS, NRC staff performed an immediate independent preliminary review of possible implications of the Shoreline fault to the DCPP to determine if an immediate safety concern existed for the facility. The Staff subsequently issued Research Information Letter 09-001 (RIL 09-001 ) entitled "Preliminary Deterministic Analysis of the Seismic Hazard at Diablo Canyon Nuclear Power Plant from Newly Discovered "Shoreline Fault"" (NRC, 2009). RIL 09-001 expanded on the Staff's initial preliminary review with a more thorough discussion of the data, the parameters used, and the basis for the Staff's initial conclusions. Over the next two years, the NRC reviewed information on an ongoing basis as the USGS and PG&E continued to obtain new data as a result of ongoing field work. In January 2011 , PG&E submitted to the NRC a report entitled "Report on the Analysis of the Shoreline Fault Zone, Central Coastal California: Report to the U.S. Nuclear Regulatory Commission" (ML110140431 ). This report (herein after called the "Shoreline Fault Report") provided new geological, geophysical, and seismological data to assess the potential seismic hazard of the Shoreline fault. This new information supplemented 2

or improved much of the geological, geophysical, and seismological information near the DCPP site that was documented in the PG&E Long-Term Seismic Program (LTSP). In reviewing the complete set of seismol ogical, geological. and geophysical data, the 1 NRC staff worked with external experts in the areas of paleoseismology, tectonics, and geology to assess the quality and reliability of the data, and to address the broader questions related to regional tectonics. NRC staff and their team of experts also visited the site in October 2011 to examine the geologic and tectonic features firsthand. Based on a review of the Shoreline Fault Report and the site visit, the NRC Review Team developed an independent assessment of the seismic source characteristics of the Shoreline fault and performed an independent Deterministic Seismic Hazard Assessment (OSHA). The NRC continues to compare the resulting deterministic seismic ground motions to those for which the plant has been previously analyzed, specifically the Hosgri Earthquake (HE) ground motion response spectrum as described in NUREG-0675, "Safety Evaluatipn Report Related to the Operation of Diablo Canyon Nuclear Power Plant, Units 1 and 2," Supplement No. 7 (US NRC, 1978) and the long term seismic program (LTSP) ground motion response spectrum as detailed in NUREG-0675 Supplement No. 34 (US NRC, 1991 ). The results indicate that deterministic seismic-loading levels predicted for all the Shoreline fault earthquake scenarios developed and analyzed by the NRC are at, or below, those levels for the HE ground motion and the LTSP ground motion. The HE ground motion and the LTSP ground motion are those for which the plant was evaluated previously and demonstrated to have reasonable assurance of safety The RIL presents results from a deterministic (scenario-based) viewpoint, which is the methodology used to license both units. However, current NRC guidance uses a more modern probabilistic seismic hazard assessment (PSHA) approach, as described in Regulatory Guide 1.208 (NRC, 2007), NUREG/CR-6372 (NRC, 1997), and NUREG-2117 (NRC, 2012).

• A deterministic approach is scenario-based and assesses safety margin. Only upper bound scenario earthquakes receive a detailed evaluation.

A probabilistic approach accounts for all seismic sources, addresses the likelihood and uncertainties for each source, and produces a quantitative assessment of seismic risk. PG&E updated their existing PSHA model and PG&E is also in the process of using this information to update their seismic probabilistic risk assessment (SPRA} model. The NRC did not perform a confirmatory ana'lysis of the PSHA due to the recent initiation of other seismic hazard assessment activities that will lead to the current PSHA model being superseded by a newer model in the near Mure. In 2011 , PG&E began development of a new PSHA model that includes a new seismic source characterization model and a new ground motion prediction model using the NRC's current regulatory guidance (RG 1.208). This project is being conducted using the Level 3 process from the Senior Seismic Hazard Analysis Committee (SSHAC) guidance as detailed NUREG/CR-6372 (NRC, 1997} and NUREG 2117 (NRC, 2012}. This process is more commonly known as a "SSHAC Level 3" process. PG&E's initial stated objective in conducting the SSHAC Level 3 project was to apply a state-of-the-art process to the full set of newly acquired data to develop a new PSHA model that is consistent with NRC requirements for new reactors. However, on March 12, 2012, the NRC issued "Request for Information Pursuant to Title 10 of the Code of Federal 3

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 Accideni-. The letter requests that updated seismic hazard information be submitted to the NRC. Once this updated information is available the NRC staff will determine whether additional regulatory actions are necessary {e.g., update the design basis and structures, systems, and components important to safety). AUDIENCE Internal stakeholders: Office of Public Affairs {OPA) Office of Congressional Affairs (OCA) Office of Federal and State Materials and Environmental Management Programs {FSME) Office of Nuclear Regulatory Research (RES) Office of General Counsel (OGC) Office of the Executive Director of Operations (EDO) Office of New Reactors {NRO) Office of Nuclear Reactor Regulation {NRR) including DORL, DE, JLD and DUR Region IV Commission External Stakeholders: Public California State Officials County and local officials Congress Industry groups {e.g., Nuclear Energy Institute) Pacific Gas and Electric 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. Name I Position 1 Organization f P hone l Dr. Annie . Senior Seismologist/Geophysicist - r ES/DEISGSEB 01-251-76951 Kammerer echnical lead on RIL J Joe Sebrosky Senior Project Manager DCPP iNRR/DORULPL-4 [301-415-11321 Mi_k:_Markley ~ C h i ef NRR/DORULPL-4 , - J 1 Neil O'Keefe : Region IV Branch Chief RIV/DRP/RPB-B jB17-200-11~ 4 Tom Farnholtz Region IV Engineering Branch RIV/DRS/EB1 817-200-1243 1Chief Chris Gratton Senior ProjectManager NRR/ JLO 1301-415-1055 4

Cliff Munson Senior technical advisor NRO/DSEA 301-415-69471 1 Trent Wertz. NRR Technical Assistant NRR 301-415-1568 Scott Burnell Headquarters Public Affairs Liaison OPA 301-415-8204, Dave McIntyre Headquarters Public Affairs Liaison OPA 301-415-82061 1 Victor Dricks Region IV Public Affairs Liason b PA/RIV 817-200-1128 Jenny Weil 1congressional Affairs Officer - :ocA 01-415-8492] June Cai ~SME - FSME 301-415-5192 Bill Maier 1 NRC State Liaison Officer RIV/ORA 81 7-8~0-12~ TIMELINE STEPI ACTION RESPONSIBLE - - j DATE '! ORGANIZATI~ _ ____j 1 2 f

      !issue draft RIL for peer review ssue draft transmittal letter for R-IL Kammerer, RES r=-- -    -

Sebrosky, NRR/DORL __!:~NRR/DE

                                                                              ,3/19/12 13/19/12 3      !Brief NRR office director                   Markley, NRR/DORL          '4112/12 Li, NRR/DE 4      ,Brief DEDO                                  Kammerer, RES               5/16/12 Markley, NRR/DORL Li, NRR/DE Munson, NRO/DSEA 5       Provide Commissioner Assistants Note Hogan, RES                         9/28/12 Markley, NRR/DORL 1

Li, NRR/DE Munson, NRO/DSEA l 6 Issue RIL and transmittal letter publicly Kammerer, RES, ;10112112 : 7 8 i

      !issue Press Release

[Issue EDO Daily --- Burnell, OPA _ --=- Sebrosky, NRR/DORL Sebrosky, NRR/DORL 10112/1~ 110112112 I 1 9 Communicate message to r o,12112 Congress ,Weil, OCA State of California Maier, RIV NEI Gratton, NRR/JLD OGC Sebrosky, NRR/DORL NRR/DLR Sebrosky, NRR/DORL 10 Public Stakeholder Meeting in California Famholtz/O'Keefe, R1v _ __.1_ 11_12a112

      ~o discuss RIL and 50.54(f)Jetter                                                  1 5

QUESTIONS AND ANSWERS

1. How was the Shoreline fault found?

The Shoreline fault was discovered while re-analyzing existing earthquake data gathered as part of a research pr,ogram being conducted by PG&E and the USGS to better understand the seismology of the central California coastal region. This effort is being conducted through a Collaborative Research and Development Agreement (CRADA).

2. How long has this research being ongoing?

The CRADA is a long-standing research program. The current phase of the CRADA was Initiated In 2007 and has been has been ongoing since then. Seismic research related to the Oiablo Canyon site has been ongoing since the late 1960s.

3. Where exactly is the fault?

It is mapped approximately 600 meters offshore west of the Diablo Canyon Power Plant (DCPP), trending NW-SE, nearly parallel to the coastline.

4. When was the NRC notified of the new fault?

The licensee notified onsite inspectors of the fault on November 14, 2008.

5. Has the fault been completely characterized?

PG&E and the USGS continue to evaluate the fault through both field investigations and analyses as part of the SSHAC Level 3 study. However, a characterization of the fault was provided by PG&E in January of 2011 . Both the staffs assessment of the analyses in the PG&E report and the NRC staff's own independent evaluation are provided in the RIL. A more detailed probabilistic assessment of all faults with the potential to impact the DCPP is currently being performed in accordance with a March 12, 2012, letter from the NRC. This more detailed assessment is expected to take 3 years to complete. PG&E is also working to complete a series of detailed two and three-dimensional seismic surveys to illuminate the faults in the subsurface beneath the DCPP.

6. What effect does the new fault have on seismic risk at DCPP?

Based on current information, the new fault has a minimal effect on the risk to DCPP. Although close to the DCPP, the Shoreline fault does not appear to be capable of generating ground motions that could damage the DCPP. l"he results of the evaluations by the licensee and the independent study by the NRC indicate that ground shaking at the plant site that could result from earthquakes on the Shoreline fault are bounded by the larger ground motions that could result at the plant site from earthquakes on the Hosgri fault. The plant has been evaluated previously and demonstrated to have reasonable assurance of safety under the ground motions that could be produced by the Hosgri fault. The micro-6

earthquakes that were used to identify the Shoreline fault were already part of the existing seismologic database. Because the Shoreline fault is approximately 600 meters from DCPP, and much closer to the DCPP than the Hosgri fault, PG&E and the NRC also evaluated the potential for surface fault displacements on the Shoreline fault to impact the structures, systems, and components (SSCs) of the DCPP. Although fault slip on the Shoreline fault itself cannot impact the DCPP, such fault displacements may cause secondary deformations in the near field of the fault trace. The potential impact of secondary ground deformation primarily involves the buried components, such as piping and conduits. Both the PG&E and NRC analyses indicate that the risk to the DCPP from secondary ground deformations is insignificant even when making highly conservative assumptions. The analyses performed by NRC staff are described in the RIL. There is no geologic evidence that the Shoreline fault has produced surface fault rupture on land. Based on these analyses of grou nd motions and fault displacements therefore, the Shoreline fault does not pose a new safety hazard to the DCPP.

7. What is the Hosgri Fault?

The Hosgri fault is a NW-SE trending strike-slip fault located offshore 5 km to the west of the DCPP. Based on the maximum magnitude earthquake that could occur on the Hosgri fault, seismologists determined that it is capable of generating ground motions up to 0.75g (peak ground acceleration) at the DCPP site. The level of ground shaking that the Hosgri fault could generate at the DCPP was the focus of considerable debate and study throughout the original licensing of the DCPP. During an extensive 10 year scientific study call the Long Term Seismic Program (LTSP) conducted after the DCPP was licensed by the NRC, PG&E confirmed the seismic adequacy of plant's original design, and showed that SSCs important to safety can withstand the effects of the 0.75g Hosgri ground motions. The LTSP also confirmed that the earlier 0.75g ground motion estimate for the Hosgri fault was still appropriate using the most up to date tools at the time. The current licensing basis for the DCPP is the original design basis ground motions (i.e., the Design Earthquake (DE) and Double Design Earthquake (ODE) ground motions) plus the Hosgri Earthquake (HE) ground motion.

8. Is it safe for DCPP to continue to operate given the discovery of the Shoreline fault?

Yes, both the licensee's evaluation and the NRC's independent evaluation In the RIL concluded that the ground shaking at the DCPP site from the maximum magnitude earthquake that could occur on the Shoreline fault are less than the 0.75g Hosgri ground motions, to which the plant has been evaluated previously and demonstrated to have reasonable assurance of safety. Additionally, to ensure public health and safety, DCPP has an automatic seismic reactor trip set point of 0.35g. If the ground acceleration at the DCPP from any earthquake exceeds this 0.35g set point, both reactors will automatically shut down to maintain plant safety and the health and safety of the public. 7

9. Is PG&E still assessing seismic information?

Yes, as discussed in the prior Q&As, PG&E continues to collect and assess new seismic information, Including work done within the CRADA as part of its long term seismic program. In addition to the field studies and data analyses, PG&E is also conducting a SSHAC Level 3 PSHA study. The updated seismic hazard results from the SSHAC study w ill be used to respond to the NRC staff's March 12, 2012, "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*.

10. What is the timeframe for PG&E to respond to the NRC's March 12. 2012, request for information?

The current time frames are as follows: ITEM Milestone Seismic Hazard Update Using Senior Seismic Hazard Process completed Analysis Committee (SSHAC) Level 3 Methodology in 2015 Risk evaluation in accordance with seismic margins Process completed assessment or seismic probabilistic risk assessment as in 2017 appropriate NRC determination of whether additional regulatory 2017 actions are necessary based on the results of the above 11 . Given that it may take 5 years for PG&E to completely respond to the NRC's March 12, 2012, letter. why is the plant safe to operate today? As described in the answer to question 8, the staff's independent evaluation of the data currently available indicates that the ground motion calculated for the Shoreline fault is bounded by the current Hosgri ground motion, to wh ich the plant has been evaluated previously and demonstrated to have reasonable assurance of safety. The data collected and reviewed to date do not indicate any significant changes to the overall hazard at the site. As outlined in the March 12, 2012, request for information. there is a process for PG&E to provide interim evaluations and actions may be taken if higher seismic hazards relative to the design basis are determined to exist based on the seismic hazard update currently being performed by PG&E. These evaluations are to be provided to the NRC prior to the risk evaluations being performed (i.e., within 3 years). Lastly, the NRC also continues to monitor the information that PG&E is collecting and will reassess the situation should new information suggests that the faults around Diablo Canyon Power Plant are capable of producing earthquakes and ground motions larger than the current ground motions for which the plant has been evaluated previously and demonstrated to have reasonable assurance of safety.

12. Why was the Shoreline fault referred to in some documents as a "potential fault"?

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When the zone of seismicity was first discovered in 2008 it was not clear at the time whether or not this zone was a fault and it was therefore characterized as a "potential" fault. Subsequent to its discovery the United States Geological Survey has described this zone of seismicity as a fault. Therefore, in current NRC documents when describing this zone of seismicity the NRC has removed the term "potential" and simply refers to this zone as the KShoreline fault."

13. Will outside experts be involved in assessing the probabilistic seismic hazards?

Yes, experts outside the NRC and PG&E will be involved in the probabilistic seismic hazard assessment. PG&E will use a range of experts to conduct its updated PSHA following the guidance in NUREG/CR-6372 (NRC, 1997) and NUREG 2117 (NRC, 2012). The external experts will be drawn from private consulting companies, State and US government agencies (including the USGS), and leading academic institutions. These experts will fill a variety of roles (described further in NUREG 211 7 and in Appendix A of the RIL). Some may act as formal members of the SSHAC Technical Integration (Tl) teams. Others may be tapped as Resource Experts, who act as unbiased experts on a particular database or topic, or as Proponent Experts, who are asked to provide their own judgments on the seismic sources or ground motion modeling that will constitute the updated PG&E PSHA. Still other outside experts will sit on the Participatory Peer Review Team, the formal peer review group for a SSHAC-based study. NRC experts and their consultants will act as observers to the program in the workshops and open meetings.

14. Did the NRC evaluate the impact of the Shoreline fault on the Diablo Canyon ISFSI?

Not directly, but by extension, because the licensing basis for the ISFSI was the same set of ground motions that constitute the current seismic qualification basis for the OCPP. In addition, the ISFSI site is under1ain by the same ground and soil conditions at the DCPP. Thus, because possible ground motions from a maximum earthquake on the Shoreline fault are less than the ground motions that make up the current seismic qualification basis for the DCPP and the ISFSI, the NRC staff concluded that the new information on the Shoreline fault does not challenge the existing licensing basis for the ISFSI. The NRC staff remain confident that the existing ISFSI is adequately protective of public health and safety and the environment.

15. Are the results of the SSHAC Level 3 process expected to show that the plant could be subjected to higher ground motion than it was designed to withstand?

Based on current information, NRC staff does not expect the updated PG&E PSHA to indicate higher ground motions than those to which the plant has been designed. This is because one of the key advancements in earthquake seismology in recent years has been the improved ground motion prediction equations (GMPEs, formerly called attenuation models) that were developed from the Pacific Earthquake and Engineering Research (PEER) Center's Next Generation Attenuation (NGA) project. For most earthquake scenarios. of interest to the DCPP, these new GMPEs predict lower amplitudes of ground motions at 9

the site than those used to develop the ground motions that constitute the current licensing basis. As noted in the answer to question 11 , the NRC is prepared to reassess the situation should it d iscover that the new information shows that the faults around Diablo Canyon Power Plant are capable of producing ground motions larger than the current ground motions for which the plant has been evaluated previously and demonstrated to have reasonable assurance of safety.

16. Why doesn't the RIL address the possibility that the Shoreline fault might rupture another close fault, creating a larger fault with higher ground motion?

The Rll does address this possibilrty. The Rll describes the NRC staff's assessment and proves the basis for the staff's findings. A multi-fault rupture would, necessarily, be a large magnitude earthquake, which would leave evidence in the landscape. However, the data available indicates that there has not been surface rupture at the location of the shoreline fault and there is no visible relative displacement across the fault. There is no geologic, geophysical, or seismological evidence that past earthquakes on the Shoreline fault or other faults around the DCPP have triggered rupture on any of the small faults near the DCPP. The exposed faults in the Discharge and Intake coves were examined by PG&E and the NIRC review team, and both reviews concluded that fault slip on these faults appear to be geologically older structures not related to the present seismo-tectonic stresses affecting the DCPP site. Additionally, both PG&E and the NRC performed probabilistic studies to assess the potential for secondary deformation resulting from a rupture on the Shoreline fault and found the risk to the DCPP to be negligible.

17. Why does the NRC use the 84111 percentile seismic loadini levels to review deterministic seismic evaluations instead of the 95th or 98 percentiles?

Use of the 84!11 percentile has been the state of practice for deterministic analyes for decades. Statistically, the 8411'1 percentile is the average value plus one standard deviation. NRC considers the 84th percentile to provide a reasonable level of conservatism in the analysis and one that has been applied over many years of NRC seismic hazards and seismic risk assessments. The 84th percentile ground motion is also consistent with the current licensing basis of the DCPP. Additional Questions Associated with the March 12, 2012, Request for Additional lnfonnation in Accordance with 10 CFR 50.54(f) and How It Relates to the Diablo Seismic Review - Site specific Supplement to 50.54(f) Generic Communication Plan

18. The recent 50.54f letters ask licensees to do a SSHAC level 3. External stakeholder question why not level 4?"

As noted in NUREG 2117, the NRC considers level 3 and level 4 SSHAC studies to be equally valid options from a regulatory perspective. Etther a SSHAC level 3 or 4 could be used to meet the 50.54(f) letter request. A level 4 study is not *better" than a level 3 study. Rather the appropriate choice of study 10

level is based on a variety of considerations, as discussed in Section 4.2 of NUREG 2117. In both cases the goal is to develop a model that represents the center, body and range of technically defensible interpretations; that is a model that provides both a best estimate ground motion and a robust estimate of the uncertainty. The main differences between level 3 and level 4 SSHAC study is the framework and composition of the team or teams that develop the PSHA logic tree. In a Level 3 process, the PSHA model is developed by one large Technical Integration (Tl) team, which is sometimes broken into source characterization and ground motion characterization sub-project teams. During the formal evaluation and integration processes (as described in NUREG 2117), Tl team members are expected to continually engage in challenge and discussion among team members such that a robust model that meets the goal is developed. In a Level 4 process, models in the form of logic tress are developed by several small model development teams of experts and the models are then combined by a technical facilitator integrator (TFI) who is expected to encourage and challenge the experts, and if needed, to orchestrate complex integration among the experts. Because of the differences in approach, in a SSHAC Level 3 study, the PPRP has a stronger role and provides both technical and process oversight. In a Level 4 study, the PPRP only reviews the process. Level 3 and 4 studies each have their benefits and drawbacks. However, in the case of studies to address the 50.54(f) letter, the benefits of a Level 3 study are significant.

19. Is there a way of integrating and coordinating among the SSHAC PSHA and the State's Independent Peer Review Panel (IPRP)?

As described in NUREG/CR-6372 and NUREG 2117, the SSHAC process is a structured formal expert interaction process designed to develop a model that captures the center, body and range of technically defensible interpretations. In order to achieve this, specific and highly defined activities and roles are required. Wrthin the SSHAC process, the only peer review panel that has formal .standing is the project's Participatory Peer Review Panel (PPRP). All other reviewers, including the State's IPRP and the NRC review team are observers.. It is anticipated that both the IPRP and the NRC's review team will observe the processes and provide input during the workshops at the times set aside for observer input. An example of the participation of an important outside group as observers is the USGS participation in the the Central and Eastern US Seismic Source Characterization for Nuclear Facilities Project. The USGS as an agency provided a review, which was considered by the project Technical Integration team, the PPRP, and the NRC during its sponsor review. However, only the PPRP's review and acceptance was required for project completion. In considering the acceptability of the SSHAC Level 3 studies that will be submitted in response to the 50.54(f) process, the level of PPRP review and the adherence to the SSHAC process will be fundamental review elements for the NRC. NRC staff and consultants will observe the SSHAC workshops and will provide feedback immediately at the workshops if issues or concerns arise; the IPRP is encouraged to also provide such feedback.

20. Does the PG&E SSHAC Level 3 project get any input from or participatiion by the USGS?

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Yes, the USGS is involved in the PSHA SSHAC process In several Important ways. First, at the first PG&E SSHAC PSHA workshop several USGS geologists, geophysicists, and seismologists were present and made presentations as resource experts. The role of resource experts is to provide in-depth unbiased information on data, models or methods, as discussed in section 3.6.1 of NUREG 2117. Second, several USGS geologists, geophysicists, and seismologists will likely participate in the second SSHAC workshop as proponent experts. The role of proponent experts is to promote the adoption of a particular model or interpretation and to defend a particular model or interpretation against challenge at the SSHAC workshop focused on discussion of proponent models (workshop#2) described in section 3.6.2 of NUREG 2117. Lastly, the SSHAC process makes extensive use of USGS data and models.

21. PG&E's January 2011 Shoreline report provided an updated probabilistic seismic hazards analysis that Included a discussion of other faults (e.g., San Luis Bay and Los Osos faults). Does the RIL address these faults in addition to the shoreline fault?

The RIL does not provide an evaluation of PG&E's updated PSHA, but does provide a limited review of the information provided relative to other faults. Based on the information provided, none of the faults in the region is capable of challenging the DCPPs licensing basis. All of the regional faults of interest will be evaluated and characterized in the SSHAC Level 3 project currently ongoing. The purpose of the RIL was to document the NRC's staffs independent deterministic evaluation of the Shoreline fault. However, in the Chapter 6 of the RIL, NRC summarizes some of the basic components of a PSHA and with an emphasis on geological and tectonic factors that are important to fault slip rates. Fault slip rate is not considered in a deterministic analysis, but is critical to understanding which faults contribute most to a seismic hazard in probabilistic assessments. The discussion found in Chapter 6 and appendix A of the RIL also discusses the process used to develop a PSHA from the Senior Seism ic Hazard Analysis Committee (SSHAC) process. The use of PSHA is also consistent with the March 12, 2012 request for additional information provided to all operating power plants pursuant to 10 CFR 50.54(f). Chapter 6 of the RIL notes that although the staff did not evaluate the PSHA, which will be updated based on information being collected to respond to the March 12, 2012 letter, that the staffs deterministic study does provide several insights; namely that the Shoreline fault is not a major contributor to the seismic hazard at DCPP and that the Hosgri fault remains a dominant seismic source. Additional Questions Associated with Three Dimensional High Energy Seismic Surveys

22. Is it an NRC requirement that the 30 high energy offshore seismic surveys be performed?

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No, it is not identified as a specific data need in the March 12, 2012 request for information issued pursuant to 10 CFR 50.54(1). However, if the surveys are performed they could be used as part of the dataset used to develop the response to the March 12, 2012 request for information. The 30 high energy offshore surveys are being performed in response to a California State law.1 The 30 seismic studies would be part of a much larger set of information that has been accumulated through and extensive program of onshore and offshore geologic, geophysical and seismic studies. These studies were initiated prior to the Fukushima Oa-ichi accident that is the basis for the NRC's March 12, 2012, request for information. The NRC's March 12, 2012 letter requests seismic reevaluations at the four western U.S plants to be conducted using a SSHAC level 3 or level 4 process to develop a new probabilistic seismic hazard assessment (PSHA) model. The SSHAC process is discussed in NUREG 2117, "Practical Implementation Guidelines for SSHAC Level 3 and 4 Hazard Studies,* and is summarized in Appendix A of the RIL. In accordance with the SSHAC process, the Technical Integration (Tl) Team will perform a thorough assessment of the existing data sets and consider resource expert input to determine the degree to which the 30 high energy offshore survey information is beneficial to development of the PSHA model used to respond to the March 12, 2012 request for information. The Tl Team assessment will be reviewed by the SSHAC Peer Review team . If the SSHAC Tl Team determines the information is sufficiently complete w ithout the new 30 high energy data to respond to the March 12, 2012 request for information, the DCPP may still be obligated to perform the surveys as part of the commitments made to comply with the California State law. Because there is a significant amount of current data available for the seismic hazard assessment at OCPP, the principal impact of the 30 seismic surveys would be to further refine the source characterization and to, thereby, reduce uncertainty in the model.

23. Given the staff's assessment of the Shoreline fault documented in the RIL that the ground motions from the fault are at or below those for which the plant was 1

The discussion of the California law can be found in Chapter 1 of the California State Lands Commission Final Environmental Impact Report on the Central Coastal California Seismic Imaging Project which is available at http:/twww.s1c.ca.goy/Oiyision Pages/DEPM/OEPM Programs and Reports/CCCSIP/CCCSIP html. The discussion that follows is paraphrased from this report. California Assembly Bill (AB)1632, directs the California Energy Commission (CEC) to assess the vulnerabthty of California's operating nuclear power plants to a major disruption due to a major seismic event or plant aging, the potential impacts of such a disruption, potential m pacts from the accumulation of nuclear waste at the State of California's existing nuclear plants, and other key pohcy and planning Issues regarding the future role of California's existing nuclear plants. The CEC conducted a comprehensive asse"Ssment of Diablo Canyon Power Plant and San Onofre Nuclear Generating Station as directed by AB 1632, and adopted this assessment In November 2008 (2008 Integrated Energy Policy Report (IEPR). The IEPR found that an extended shutdown at either plant would have major economic, environmental, and reliability Implications for Califomla. The CEC's 2008 IEPR recommended that the utilities update their nuclear plants' seismic assessments, and use "three-dimensional geophysical seismic reflection mapping and other adVanced techniques* to supplement ongoing seismic research programs. The CEC subsequently recommended and the California Public Utilities Commission (CPUC) directed the utilities to complete these advanced seismic studies and submit them as part of the CPUC's review of United States Nuclear Regulatory Commission (NRC) license renewal applications for these plants. In August 2010, the CPUC issued Decision 10-08-003, which established, among other things, an Independent Peer Review Panel (IPRP) to conduct a peer review of the proposed seismic study plans and, if the Project is implemented, to review study findings. The IPRP includes staff from the CPUC, CEC, California Seismic Safety Commission, California Coastal Commission (CCC), and County of San Luis Obispo with contract support from the Calrfomia Geological Suivey. 13

evaluated, why is the seismic reevaluation described in the March 12, 2012, request for information necessary? The RIL's scope of review was limited to a deterministic seismic hazard assessment (OSHA) of only one newly discovered fault (i.e., the Shoreline fault) to determine if a safety concern exists at the DCPP based on the new information. By contrast, the seismic reevaluation described in the March 12, 2012, request for information is based on a modern probabilistic seismic hazard assessment (PSHA) model that is developed through a systematic SSHAC Level 3 or Level 4 process and includes all known faults in the area using a process similar to what is done for siting of new reactors.

24. What alternative types of seismic studies (other than 30 high energy) would NRC consider adequate to support a senior seismic hazard analysis committee (SSHAC) level 3 or 4 analysis?

A significant amount of geologic, geophysical and seismic data and information has already been collected, or is planned, as a result of the current site investigation program. The 30 high energy studies are just one part of a much larger program to obtain data and information to characterize seismic hazard. The data sets. taken as a whole, are used to characterize the sources and ground motions at the site. The impact of any one type of data collection is typically a reduction in uncertainty in the final model. The benefit of the 30 high energy seismic surveys to the development of the PSHA model used to respond to the March 12, 2012, request for information Issued pursuant to 10 CFR 50.54(f) will be determined by the SSHAC Technical Integration and Peer Review teams in accordance with the SSHAC level 3 process outlined in NUREG 2117, -Practical Implementation Guidelines for SSHAC Level 3 and 4 Hazard Studies." Relative to collection of 30 high energy offshore survey information, the SSHAC Technical Integration and Peer Review teams could consider that the 30 high energy offshore survey information is not warranted because enough information Is available from the following sources:

• 20 and 30 low energy offshore survey information,
• 30 high~nergy on shore survey information,
• Bathymetric information,
• Paleoshorehne assessments,
• Seismic event database reevaluation,
• Gravity survey data,
• Magnetic survey data,
• Regional slip rate analyses,
• other sources of new information (e.g., new information available from the U.S. Geological Survey)

If the teams decide that enough information has already been collected such that the 30 high energy seismic surveys are not warranted, the DCPP may stilll be obligated to perform the 30 high energy offshore survey as part of the commitments made to comply with a California State law. 14}}