ML20141L714
| ML20141L714 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/14/2020 |
| From: | NRC/OCIO |
| To: | |
| Shared Package | |
| ML20141L707 | List: |
| References | |
| FOIA, NRC-2019-000279 | |
| Download: ML20141L714 (255) | |
Text
09//0/2014 U.S. Nu<:leur Reg11J fl!!!_ff Com111/1*sio11 Operatio11s Center Event!!_eport _ _ _ _ ____ P_.a._
,e__l, This Event is not for public disclosure until 09/17/2014.
Agreement State (AGR) Event# 50438 Rep Org: TEXAS DEPARTMENT OF HEALTH Notification Date/ Time: 09/09/2014 18:10 (EDT)
Licensee: CHEVRON PHILLIPS CHEMICAL COMPANY LP Event Date / Time: 09/09/2014 (CDT)
Last Modification: 09/09/2014 Region: 4 Docket#:
1 City: PASADENA Agreement State: Yes County: License#: 00230 S,tate: TX NRC Notified by: ART TUCKER Notifications: RAY AZUA R4DO HQ Ops Officer: DONALD NORWOOD FSMEEVENTSRESOURCE EMAIL Emergency Class: NON EMERGENCY 10 CFR Section :
AGREEMENT STATE AGREEMENT STATE REPORT - STUCK SHUTTERS ON TWO PROCESS GAUGES The following information was received via E-mail:
"On September 9, 2014, the Agency (Texas Department of State Health Services] was notified by the licensee that while taking a tank out of service for repairs, it was unable to close the shutters on two Ohmart Vega model SH-F2 level gauges, each containing 500 milliCuries of Cesium-137. The shutters are stuck in the open position, which is the normal operating position for the gauges. The licensee has contacted a service provider who will be on site on September 10, 2014 to make repairs to the gauges. The gauges do not create an exposure hazard to any individual. Additional information will be provided as it is received in accordance with SA-300."
Texas Incident#: 1-9231
..,.09_V_JO__V_20.,.1_4._ _ _ _ _ _ U.S. Nuclear Reg11/11tory Commission Qp_eratitms Ce'!!_e~ Event !!_eport _ _ _ _ _ Page I Part 21 (PAR) Event# 50439 Rep Org: CAMERON MEASUREMENT SYSTEMS Notification Date I Time: 09/09/2014 18:37 (EDT)
Supplier: CAMERON MEASUREMENT SYSTEMS Event Date I Time: 09/09/2014 (PDT)
Last Modification: 09/09/2014 Region: 4 Docket #:
City: CITY OF INDUSTRY Agreement State: Yes County: License#:
State: CA NRC Notified by: ISAAC RAMSINI Notifications: TODD JACKSON R1DO HQ Ops Officer: DONALD NORWOOD SCOTT SHAEFFER R2DO Emergency Class: NON EMERGENCY KENNETH RIEMER R3DO 10 CFR Section : RAY AZUA R4DO 21 .21(d){3)(i) DEFECTS AND NONCOMPLIANCE PART 21 GROUP EMAIL PART 21 REPORT - DEFECTIVE BARTON DIFFERENTIAL PRESSURE SWITCHES The following is a synopsis of information received via facsimile:
Cameron Measurement Systems has issued a product advisory concerning nuclear qualified versions of Barton Model 288A, 289A, 580A and 581A differential pressure indicating switches and blind switches and spare switch assemblies shipped from the Cameron factory.
The defect being reported is an out of specification thread on the screws that depress the switch operating plunger which can cause a change in the switch setpoint. The maximum change in screw position observed during testing equates to a switch set point change of approximately 8.4 percent of the instrument's factory calibrated span. The screws of concern did not enter the Cameron stock before February of 2014 for the ones used in the Model 580A and 581A instruments and not before June of 2014 for the ones used in Model 288A and 289A instruments.
Cameron recommends that new switch actuator arm assemblies be replaced on any unit that is evaluated to be a concern by their customers.
Notification to NRC provided by ISAAC RAMSINI, Manager Quality and Safety, (562) 321-9158 .
Ni l Fer P11llll1 lll'l1l rlll11llu1 Summary Information - Power Reactor Status Re ort for 9 / 10/ 2014 R; g 1Unlt 9 / 10/ 2014 9 / 9 / 2014 Comments {previousd ay's co;;;;ents In lt11/lc}
r-- - -
1 Hope Creek 1 0% 0 % PLANNED MAINTENANCE OUTAGE 1 Oyster Creek 100% 9 D% l~-EDUCED POWER FOR SURVEILLANCE TESTING 1 Susquehanna 2 0% 0 % MAINTENANCE OUTAGE - TURBINE WORK 2 Brunswick 1 100% 96
% ;~CREASING POWER TO 100%
2 McGuire 1 99% lOOo/o COASTDOWN TO REFUELING OUTAGE 2 Saint Lucie 1 95% JOO% REDUCED POWER FOR PLANNED MAINTENANCE 3 Clinton 98% 98% 100% ELECTRICAL CAPABILITY EPU TESTING PENDING 13 Monticello 88%
BB% EPU TESTING IN PROGRESS 4 Grand Gulf 1 100% l Bo/o ;~CREASING POWER AFTER ROD PATTERN ADJUSTMENT 2 Plants In Refueling Outage Region 1 Region 2 Region 3 Region 4 FltzPatrlck - 8/24/2014 North Anna 2 - 9/ 6/ 2014 S Plants Coasting Down to Outage Region 1 [Region 2 Region 3 Region 4 Browns Ferry 1 - 93% Dresden 3 - 96% Cooper - 93%
McGuire 1 - 99% Duane Arnold - 92%
U.S. Nuclear Regulatory Commission Operations Center tJ)Jftlhi fsFse 9,;J!, Sc!!@N ri~z Belated lrifocrr,atlon
- Event Su,nmary ***
Date Range: 09/09/2014 - 091/0/2014 Non-Responsive Record Non-Responsive Record 8/fttiul 61st 8a.; &ta,;~ Re,Vftt# l o,fa: ,111tis,r Wed11esday, September JO, 1014 Par:e I of I
F8R 8PPJCf; IL f;'ff @.! 'L l' L CfJ4./T£.D DISTlll.BLlTLON This report may contain "law enforcement sensitive" information Please do 1101 relay tltis i11Jormatio11 to imlivirluals who rlo not have a "need lo know" Non-Responsive Record ur ~ 'es ' L'zz f?nt:,
Page I of2
i'¥Hli 8 1....1._,C.AL 1 i tf8E 8 * 'LJ' L}I':,
,, - 'Yt'EfJ l tJl.8't'lt1Btf'f':(j -1
.1 1\i Tltis report may contain "law enforcement sensUive" information Please do 110 1 relay tit is information to individuals who do 1101 have a "need to know" Non-Responsive Record Po, 8/ficiu/ b'se 8111)
Pagel n/2
From: Evans, Michele Sent: Wednesday, September 10, 2014 3:16 PM To: Dorman, Dan; Uhle, Jennifer
Subject:
FW: Info: results of meeting to determine process for reviewing seismic information in Diablo Canyon State of California Report Jennifer and Dan, I guess I haven't been in the loop on some of the direction that has been provided to the staff on how to proceed with the Diablo Canyon report. So when I read the discussion below I was surprised by the recommended path forward and the lack of involvement by NRR/DE folks. I spoke with Joe Sebrosky a few minutes ago and got a better appreciation for how things are progressing. I'd appreciate a dialogue among the three of us tomorrow regarding the DE piece. As for the inspection direction presented below, evidently Marc Dapas is driving that, so Joe does want to make sure that Jennifer/ET is on board very soon, if we agree with that direction. I know that Joe is working with Sherry to set up the meeting with the ET that is referenced below.
Talk to you guys tomorrow.
Michele From: Sebrosky, Joseph Sent: Wednesday, September 10, 2014 1:57 PM To: Pruett, Troy; Difrancesco, Nicholas; Hay, Michael; Walker, Wayne; Hipschman, Thomas; Whaley, Sheena; Markley, Michael; Oesterle, Eric; OKeefe, Nell; Roth(OGC), David; Cruz, Holly; Bowen, Jeremy; Buchanan, Theresa; Jackson, Diane; Kock, Andrea; Farnholtz, Thomas; Lund, Louise; Evans, Michele; Flanders, Scott; Munson, Clifford
Subject:
Info: results of meeting to determine process for reviewing seismic information in Diablo canyon State of california Report To all, The purpose of this email is to summarize the results of an internal meeting to develop a recommendation on what process should be used to review new seismic information in the Diablo Canyon State of California report.
Attendees: Troy Pruett, Mike Markley, Wayne Walker, Neil O'Keefe, David Roth, Diane Jackson, Sheena Whaley, and Joe Sebrosky Outcome:
- A recommendation was made that the review of the report will be performed in accordance with the NRC inspection process, headquarters wi ll support the inspection as necessary and a TIA will be developed
- Action items include:
o DORL to coordinate a meeting between Jennifer Uhle, Scott Flanders, Troy Pruett, Wayne Walker Michele Evans, Andrea Kock, Louise Lund and Mike Markley.
- The purpose of the meeting is to brief Jennifer on the recommendation and have her confirm the decision or develop an alternate proposal
- A secondary purpose is for Scott to provide Jennifer with resource impacts given the support and what Fukushima 2.1 seismic activities may slip as a result of the resource redirection o RIV will open inspection report tacs so that Headquarters staff who have started reviewing the report have a tac to which to charge their time.
o DORL will revise the project plan to capture this process o DORL will reach out to Holly Cruz to brief her on the TIA that will be forthcoming A scheduler to the individuals above will be com ing shortly from Sherry Schwartz.
Let me know if you have any questions.
- Thanks, Joe
Original Appointment-----
From: Sebrosky, Joseph Sent: Wednesday, September 10, 2014 10:20 AM To: Sebrosky, Joseph; Pruett, Troy; DiFrancesco, Nicholas; Hay, Michael; Walker, Wayne; Hipschman, Thomas; Whaley, Sheena; Markley, Michael; Oesterle, Eric; OKeefe, Neil; Roth(OGC), David; Cruz, Holly; Bowen, Jeremy; Buchanan, Theresa Cc: Jackson, Diane; Kock, Andrea; Farnholtz, Thomas
Subject:
internal meeting to discuss process for reviewing seismic Information In Dlablo Canyon State of california report When: Wednesday, September 10, 2014 12:30 PM-1:30 PM (UTC-05:00) Eastern Time (US & Canada).
Where: HQ-OWFN-14B08-14p Bridge: 888-677-0690 Passcode! (b)(6J I
Purpose:
To make a decision of what process will be used to evaluation new seismic information found in Diablo Canyon State of California report Outcome: Decision made Agenda:
I. Background
- a. State of California report includes new seismic information
- b. PG&E to provide a 9/10/14 letter providing an interim evaluation consistent with guidance in 10/12/12 letter that transmitted the staff's previous assessment on the shoreline fault
- c. The attached project plan provides background information and links if you need the information (please ignore the process described - the purpose of the meeting is to determine the process II. Process options
- a. Inspection
- b. Followon to October 12, 2012, letter and RIL
- i. Consider addendum to RI L and issue a cover letter updating conclusion in the 10/12/12 letter
- c. Combination of inspection and October 12, 2012, letter
- d. Other 2
From: Uhle, Jennifer Sent: Wednesday, August 20, 2014 11:37 AM To: Markley, Michael; Lantz, Ryan; Lund, Louise Cc: Dorman, Dan; Evans, Michele; Wertz, Trent Subje ct: RE: Drop-In w/ Pacific Gas & Electric Thx. We talked about the need for a comm plan of some type for the report and the DPO. Trent is going to talk to Renee Pederson to get some bullets on the DPO messages. Please work with him to establish a mini comm plan and update OPA. Thanks in advance, Jennifer From: Markley, Michael Sent: Wednesday, August 20, 2014 11:08 AM To: Dorman, Dan; Uhle, Jennifer; NRR-OWFN-13D20-1Sp; Lund, Louise; Hiland, Patrick; Davis, Jack; Oesterle, Eric; Slngal, Balwant; Case, Michael; Ake, Jon; Munson, Clifford Cc: NRR_ET_Activity Resource; Bamford, Peter; Nichols, Chelsea; Schwarz, Sherry; Cohen, Sharl; DE_calendar Resource; DORLCAL Resource; Flanders, Scott; Whaley, Sheena; Kock, Andrea; NRR_JLD Resource; Lubinski, John; Ross-Lee, MaryJane; Manoly, Kamal
Subject:
RE: Drop-In w/ Pacific Gas & Electric It is still a drop-in. I am told the bridge line was added to allow for PG&E contractors to participate, if needed.
Original Appolntment-----
From: HIiand, Patrick On Behalf Of Dorman, Dan Sent: Wednesday, August 20, 2014 9:52 AM To: Markley, Michael
Subject:
FW: Drop-In w/ Pacific Gas & Electric When: Friday, August 22, 2014 1:00 PM-2:00 PM {UTC~ Eastern Time (US & canada).
Where: 0-13D20 (Bridgellne: 888-452-5138; Passcode~
Mike, can you confirm this will be a teleconference vs. drop-in? I received a revised scheduler this a.m., and the room location has been crossed out and phone number highlighted?
Original Appointment-----
From: Dorman, Dan Sent: Tuesday, August 05, 2014 9:59 AM To: Dorman, Dan; Uhle, Jennifer; NRR-OWFN-13D20-15p; Lund, Louise; Hiland, Patrick; Davis, Jack; Markley, Michael; Oesterle, Eric; Slngal, Balwant; case, Michael; Ake, Jon; Munson, Clifford Cc: NRR_ET_Activlty Resource; Bamford, Peter; Nichols, Chelsea; Schwarz, Sherry; Cohen, Sharl; DE_calendar Resource; DORLCAL Resource; Flanders, Scott; Whaley, Sheena; Kock, Andrea; NRR_JLD Resource; Lubinski, John; Ross-Lee, MaryJane; Manoly, Kamal
Subject:
Drop-In w/ Pacific Gas & Electric When: Friday, August 22, 2014 1:00 PM-2:00 PM (UTC-05:00 Eastern Time (US & Canada).
Where: 0 -13D20 (Bridgeline: 888-452-5138; Passcode: (b)(G) 08/20/201 4 - Update -
Bridgeline Information 888-452-5138
PasscodeG Requested by Peter Bamford (2833)
Licensee for Diablo Canyon - meeting is on seismic Pacific Gas and Electric management plans to update NRR management regarding a seismic report that will be submitted to the State of California pursuant to CA Assembly Bill 1632. The licensee plans to update NRR management with a high level summary of the results of the study and discuss the licensee's plans going forward. The licensee has indicated that the study will likely conclude that the Shoreline fault could be longer (and thus more capable) than previously believed, but they believe the overall earthquake loads would remain bounded by the site's existing Hosgri fault analysis. A copy of the CA Assembly Bill 1632 report will also be submitted to the NRC.
2
From: Uhle, Jennifer Sent: Thursday, September 04, 2014 4:12 PM To: Flanders, Scott
Subject:
Fw: seismic update Sorry, wrong Scott!
From: Kock, Andrea Sent: Thursday, September 04, 2014 03:42 PM To: Uhle, Jennifer; Morris, Scott; Jackson, Diane Cc: Difrancesco, Nicholas; Franovich, Mike
Subject:
RE: seismic update Jennifer- Sounds good. We should also update you on our final screening decisions for the plants that were conditionally screened in.
I've copied Nick and Mike so they can work to get something on your calender.
Andrea Kock, Acting Deputy Director Division of Site Safety and Environmental Analysis Office of New Reactors United St ates Nuclear Regulatory Commission Ph. 301-415-2368 From: Uhle, Jennifer Sent: Thursday, September 04, 2014 2: 18 PM To: Morris, Scott; Jackson, Diane; Kock, Andrea
Subject:
seismic update Everyone is thrilled with all the great work the team had done and progress you guys have made. I also heard the Chairman briefing by Cliff on Diablo went well today. Thanks for that. Can I get an update on the seismic issues early next week. No need for slides. I have written down issues that you were working on and wanted to hear the resolution or path forward. The matters are:
ESEP template contents ESEP review (what that entails and level of effort)
IPEEE plants that screen out, are we asking licensees to do any ESEP Final answer on doing anything beyond 2 x SSE for ESEP Any plant specific issues that industry owes us information Anything else you think is worthy of an update. I am thinking a quick 30 min or so. Is that okay?
Thanks in advance, Jennifer
From: Uhle, Jennifer Sent: Thursday, September 04, 2014 4:15 PM To: Morris, Scott
Subject:
RE: seismic update No meant Scott Flanders!!
From: Morris, Scott Sent: Thursday, September 04, 2014 2:19 PM To: Uhle, Jennifer
Subject:
RE: seismic update Did you mean to include me on this? Maybe for Andrea's performance appraisal?
From: Uhle, Jennifer Sent: Thursday, September 04, 2014 2:18 PM To: Morris, Scott; Jackson, Diane; Kock, Andrea
Subject:
seismic update Everyone is thrilled with all the great work the team had done and progress you guys have made. I also heard the Chairman briefing by Cliff on Diablo went well today. Thanks for that. Can I get an update on the seismic issues early next week. No need for slides. I have written down issues that you were working on and wanted to hear the resolution or path forward. The matters are:
ESEP template contents ESEP review (what that entails and level of effort)
IPEEE plants that screen out, are we asking licensees to do any ESEP Final answer on doing anything beyond 2 x SSE for ESEP Any plant specific issues that industry owes us information Anything else you think is worthy of an update. I am thinking a quick 30 min or so. Is that okay?
Thanks in advance, Jennifer
From: Uhle, Jennifer Sent: Thursday, September 04, 2014 6:09 PM To: Kock, Andrea
Subject:
RE: seismic update Thanks very much Andrea. I appreciate it. Glad that you are over there permanently. Jennifer From: Kock, Andrea Sent: Thursday, September 04, 2014 4:34 PM To: Uhle, Jennifer Cc: Jackson, Diane; Franovich, Mike
Subject:
Re: seismic update That's a good one too! We will be ready to discuss.
Sent from NRC blackberry Andrea Kock I (b)(6) I From: Uhle, Jennifer Sent: Thursday, September 04, 2014 04:15 PM To: Kock, Andrea
Subject:
RE: seismic update Thanks. I forgot to add where are we on SFP. Thx J From: Kock, Andrea Sent: Thursday, September 04, 2014 3:42 PM To: Uhle, Jennifer; Moirris, Scott; Jackson, Diane Cc: Difrancesco, Nicholas; Franovich, Mike
Subject:
RE: seismic update Jennifer- Sounds good. We should also update you on our final screening decisions for the plants that were conditionally screened in.
I've copied Nick and Mike so they can work to get something on your calender.
Andrea Kock, Acting Deputy Director Division of Site Safety and Environmental Analysis Office of New Reactors United States Nuclear Regulatory Commission Ph. 301-415-2368 From: Uhle, Jennifer Sent: Thursday, September 04, 2014 2:18 PM To: Morris, Scott; Jackson, Diane; Kock, Andrea
Subject:
seismic update
Everyone is thrilled with all the great work the team had done and progress you guys have made. I also heard the Chairman briefing by Cliff on Diablo went well today. Thanks for that. Can I get an update on the seismic issues early next week. No need for slides. I have written down issues that you were working on and wanted to hear the resolution or path forward. The matters are:
ESEP template contents ESEP review (what that entails and level of effort)
IPEEE plants that screen out, are we asking licensees to do any ESEP Final answer on doing anything beyond 2 x SSE for ESEP Any plant specific issues that industry owes us information Anything else you think is worthy of an update. I am thinking a quick 30 min or so. Is that okay?
Thanks in advance, Jennifer 2
From: Uhle, Jennifer Sent: Monday, September 08, 2014 6:09 PM To: Davis, Jack
Subject:
RE: Uhle Seismic Briefing Prep You know best but I would like to ensure that we are not bringing in a whole group of new people that need to c,ome up to speed. There are some in NRR/DE that I would like to talk about with you if that is okay. J From: Flanders, Scott Sent: Monday, September 08, 2014 6:04 PM To: Davis, Jack; Uhle, Jennifer Cc: Kock, Andrea; Bowen, Jeremy; Jackson, Diane; Whaley, Sheena; DiFrancesco, Nicholas
Subject:
RE: Uhle Seismic Briefing Prep Similarly, if Pat and Joe attend, it would be useful to invite John Monninger and John Tappert as well.
Scott From: Davis, Jack Sent: Monday, September 08, 2014 5:37 PM To: Uhle, Jennifer Cc: Kock, Andrea; Bowen, Jeremy; Jackson, Diane; Whaley, Sheena; Flanders, Scott; DiFrancesco, Nicholas
Subject:
Uhle Seismic Briefing Prep Hi Jen, For the seismic briefing this Friday, I've asked Sheena to start the presentation off and go over the programmatic/licensing activities and the high-level plan for the ESEP reviews (including review team construct) followed by Diane going through the more technical details (e.g., catalog, etc.). In addition, I think that we should invite DE and DRA to the briefing since we will be talking about the review teams and the senior oversight teams. DE and DRA were particularly interested in the make-up of these teams and how the construct would support NRR technical staff in the review. Unless you have reservations, I'm going to invite Pat Hiland/MJ, and Joe Giitter to the meeting.
- Thanks, Jack From: Uhle, Jennifer Sent: Thursday, September 04, 2014 2:18 PM To: Morris, Scott; Jackson, Diane; Kock, Andrea
Subject:
seismic update Everyone is thrilled with all the great work the team had done and progress you guys have made. I also heard the Chairman briefing by Cliff on Diablo went well today. Thanks for that. Can I get an update on the seismic issues early next week. No need for slides. I have written down issues that you were working on and wanted to hear the resolution or path forward. The matters are:
ESEP template contents ESEP review (what that entails and level of effort)
IPEEE plants that screen out, are we asking licensees to do any ESEP Final answer on doing anything beyond 2 x SSE for ESEP
Any plant specific issues that industry owes us information Anything else you think is worthy of an update. I am thinking a quick 30 min or so. Is that okay?
Thanks in advance, Jennifer 2
From: Wertz, Trent Sent: Thursday, September 18, 2014 2:04 PM To: Dorman, Dan; Uhle, Jennifer; Evans, Michele
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
FYI.
From: Markley, Michael Sent: Thursday, September 18, 2014 2:02 PM To: Wertz., Trent Cc: Lund, Louise; Wilson, George; Sebrosky, Joseph; Oesterle, Eric
Subject:
FW: Did PG&E and the NRC work together to spin news on* Diablo Canyon quake safety?
Please share with Michele, Jennifer, and Dan.
From: Willis, Dori Sent: Thursday, September 18, 2014 1:28 PM To: Sebrosky, Joseph; Markley, Michael Cc: Kanatas, Catherine; Roth(OGC), David; Oesterle, Eric; Useldlng, Lara; Lund, Louise; Walker, Wayne
Subject:
RE: Did PG&E and the NRC work together to spin news on Dlablo Canyon quake safety?
Yes, I believe it should be sent to the IG as it is about NRC wrongdoing.
Thanks Dori From: Sebrosky, Joseph Sent: Thursday, September 18, 2014 12:22 PM To: Markley, Michael; Willis, Dori Cc: Kanatas, Catherine; Roth(OGC), David; Oesterle, Eric; Useldlng, Lara; Lund, Louise; Walker, Wayne
Subject:
RE: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
- Mike, I believe it asserts collusion on part of the NRC, so should it be in IG space?
Joe From: Markley, Michael Sent: Thursday, September 18, 2014 12:09 PM To: Willis, Dori Cc: Kanatas, Catherine; Roth(OGC), David; Oesterle, Eric; Sebrosky, Joseph; Uselding, Lara; Lund, Louise
Subject:
FW: Did PG&E and the NRC work together to spin news on Dlablo Canyon quake safety?
- Dori, Aside from the obvious handling of the FOIA, whenever it is received, this reads like an allegation? What is the OAC view on this?
Mike Markley, Acting Deputy Director DORL/NRR 301-415-5723 From: Uselding, Lara Sent: Thursday, September 18, 2014 10:28 AM To: Walker, Wayne; Hipschman, Thomas; Reynoso, John; Buchanan, Theresa; Sebrosky, Joseph; Sebrosky, Joseph; Markley, Michael
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
From: Dricks, Victor Sent: Thursday, September 18, 2014 9:16 AM To: Dapas, Marc; Kennedy, Kriss; Pruett, Troy; Uselding, Lara; Brenner, Eliot
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
FYI Victor Dricks Senior Public Affairs Officer U.S. Nuclear Regulatory Commission/ Region IV 1600 E. Lamar Blvd.
Arlington, Texas 76011 (817) 200-1128 (Office)
I (b)(6) I (Cell)
From: Bill Walker [1]
Sent: Thursday, September 18, 2014 9:13 AM To: Dricks, Victor
Subject:
Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
For lmmediat.e Release: September 18, 2014 Expert Contacts:
Ben Schreiber, (202) 352-4223, bschreiber@foe.org Dave Freeman, (310) 902-2147, greencowboysdf@gmail.com Communications Contacts:
EA Dyson. (202) 222-0730, edyson@foe.org (East Coast)
Bill Walker, (510) 759-9911 , bw.deadline@gmail.com (Yvest Coast)
Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
Friends of the Earth files Freedom of Information Act request WASHINGTON, D.C. - Last week the Nuclear Regulatory Commission denied a dissent by the former chief inspector at the Diablo Canyon nuclear plant, who said new seismic data show the plant may be vulnerable to earthquakes of greater magnitude than allowed by its license. On the same day, Pacific Gas & Electric Co. released a long-awaited seismic study that, like the NRC's ruling, also claimed that Diablo Canyon is safe.
2
Under federal law, the NRC has 20 days to respond to the Freedom of Information Act request.
Bill Walker dba Deadline Now Bcrkcky, CA (510) 759-9911 Twitter: (tl'deadlinerum Faccbook: DcadlincNow Skype: dcudlincnow http://www.deadlinenow.com 4
From: McMillan, Joseph Sent: Thursday, September 18, 2014 6:09 PM To: Uhle, Jennifer Cc: Raspa, Rossana
Subject:
RE: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
Thanks, I'll review and get back with you via bb.
- Regards, Joseph A. McMillan Assistant Inspector General for Investigations Office of the Inspector General Nuclear Regulatory Commission WP: (301) 415-5929 CP: (b)(6)
Fax: 301 415-50 1 From: Uhle, Jennifer Sent: Thursday, September 18, 2014 5:31 PM To: McMillan, Joseph Cc: Markley, Michael
Subject:
Fw: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
Joe, I am on travel to INPO and am on my bberry so can streamline this email. The refore you need to read through a number of forwarded ema ils to get to the issue. It is a member of the public claiming nRC staff wrong doing. Please talk to Mike Markley if you have any questions. Thanks, Jennifer From: Markley, Michael Sent: Thursday, September 18, 2014 10:35 AM To: Lund, Louise; Wilson, George; Uhle, Jennifer; Dorman, Dan; Dudek, Michael; Oesterle, Eric
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
FYI From: Uselding, Lara Sent: Thursday, September 18, 2014 10:28 AM To: Walker, Wayne; Hipschman, Thomas; Reynoso, John; Buchanan, Theresa; Sebrosky, Joseph; Sebrosky, Joseph; Markley, Michael
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
From: Dricks, Victor Sent: Thursday, September 18, 2014 9:16 AM To: Dapas, Marc; Kennedy, Kriss; Pruett, Troy; Uselding, Lara; Brenner, Eliot
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
FYI The rest of the email string may be found as document M/55 in interim response #5 in FOIA/PA-2014-0488 (ML15224A774).
From: Uhle, Jennifer Sent: Friday, September 12, 2014 8:59 AM To: Dorman, Dan; Davis, Jack Cc: Dapas, Marc; Kennedy, Kriss; Pruett, Troy; Evans, Michele; Flanders, Scott; Johnson, Michael
Subject:
RE: Diablo I also think we will need to have some publicly available document indicating the justification for adhering to the 50.54f schedule, if that is what the technical assessment supports. As Dan indicated, we are working out the details on what level of assessment needs to be done. Thanks, Jennifer From: Dorman, Dan Sent: Friday, September 12, 2014 8:52 AM To: Davis, Jack Cc: Dapas, Marc; Kennedy, Kriss; Pruett, Troy; Uhle, Jennifer; Evans, Michele; Flanders, Scott; Johnson, Michael
Subject:
Re: Diablo
- Jack, The following is where I believe we left it:
HQ will provide technical support as needed to Region IV's evaluation of the licensee's operability determination and justification of continued operation. After that is completed, HQ will document (internal memo?) basis for concluding w het her completing the 50.54f process is the appropriate path forward, or other as yet unidentified alternative. Need to work out the appropriate level of effort to reach that conclusion, but I think that you, Scott, Jennifer and I are all aligned that it is a modest level of effort based on advanced stage of the 50.54f process, robust seismic margins of the facility and relatively modest increase in assessed hazard.
- Thanks, Da n From : Davis, Jack Sent: Thursday, September 11, 2014 01: 14 PM To: Dorman, Dan
Subject:
Diablo
- Dan, I know that you were briefed on options for dealing with Diablo today. It would seem to me that ensuring in some quick way that we are ok to wait on the seismic hazard re-evaluation done under the 50.54(f) request would be the best approach and the least impact to the Fukushima work that I'm trying to complete for the Agency. If we need Scott's expertise to do something more extensive, then delays in the Fukushima seismic work will be inevitable.
Jack 1
From: Uhle, Jennifer Sent: Thursday, September 18, 2014 5:24 PM To: Lund, Louise
Subject:
Re: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
Yes. J From: Lund, Louise Sent: Thursday, September 18, 2014 02:25 PM To: Uhle, Jennifer
Subject:
Fw: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
Can you send to OIG?
Sent from an NRC Blackberry Louise Lund (b)(6)
From: Markley, Michael Sent: Thursday, September 18, 2014 02:01 PM To: Wertz., Trent Cc: Lund, Louise; Wilson, George; Sebrosky, Joseph; Oesterle, Eric
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
Please share with Michele, Jennifer, and Dan.
From: Willis, Dori Sent: Thursday, September 18, 2014 1:28 PM To: Sebrosky, Joseph; Markley, Michael Cc: Kanatas, catherine; Roth(OGC), David; Oesterle, Eric; Uselding, Lara; Lund, Louise; Walker, Wayne
Subject:
RE: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
Yes , I believe it should be sent to the IG as it is about NRC wrongdoing.
Thanks Dori From: Sebrosky, Joseph Sent: Thursday, September 18, 2014 12:22 PM To: Markley, Michael; Willis, Dori Cc: Kanatas, catherine; Roth(OGC), David; Oesterle, Eric; Uselding, Lara; Lund, Louise; Walker, Wayne
Subject:
RE: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?
- Mike, I believe it asserts collusion on part of the NRG, so should it be in IG space?
Joe
From: Markley, Michael Sent: Thursday, September 18, 2014 12:09 PM To: Willis, Dori Cc: Kanatas, Catherine; Roth(OGC), David; Oesterle, Eric; Sebrosky, Joseph; Uselding, Lara; Lund, Louise
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
Dori, Aside from the obvious handling of the FOIA, whenever it is received, this reads like an allegation? What is the OAC view on this?
Mike Markley, Acting Deputy Director DORL/NRR 301-415-5723 From: Uselding, Lara Sent: Thursday, September 18, 2014 10:28 AM To: Walker, Wayne; Hipschman, Thomas; Reynoso, John; Buchanan, Theresa; Sebrosky, Joseph; Sebrosky, Joseph; Markley, Michael
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
From: Drlcks, Victor Sent: Thursday, September 18, 2014 9:16 AM To: Dapas, Marc; Kennedy, Kriss; Pruett, Troy; Uselding, Lara; Brenner, Eliot
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
FYI Victor Dricks Senior Public Affairs Officer U.S. Nuclear Regulatory Commission/ Region IV 1600 E. Lamar Blvd.
Arlington, Texas 76011 (817) 200-1128 (Office)
! (bJ(6) j (Cell)
From: Bill Walker [2]
Sent: Thursday, September 18, 2014 9:13 AM To: Drlcks, Victor
Subject:
Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
for Immediate Release: September 18, 2014 Expert Contacts:
Ben Schreiber, (202) 352-4223, bschreiber@foe org Dave Freeman , (310) 902-2147, greencowboysdf@gma1I com Communications Contacts:
EA Dyson, (202) 222-0730, edyson@foe.org (East Coast)
Bili Walker, (510) 759-9911 , bw.deadhne@gmail.com (West Coast)
The rest of this email string may be found as document M/55 in interim response #5 2 in FOIA/PA-2014-0488 (ML15224A774).
From: Uhle, Jennifer Sent: Thursday, September 18, 2014 6:59 PM To: McMillan, Joseph
Subject:
Re: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
Thanks. Jennifer From: McMillan, Joseph Sent: Thursday, September 18, 2014 06:15 PM To: Uhle, Jennifer
Subject:
RE: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
Jennifer: I reviewed the e-mail string and directed my staff to input as an allegation.
- Regards, Joseph A. McMillan Assistant Inspector General for Investigations Office of the Inspector General Nuclear Regulatory Commission WP: (301) 415-5929 CP: (b)(6)
Fax: 301 415-5091 From: Uhle, Jennifer Sent: Thursday, September 18, 2014 5:31 PM To: McMillan, Joseph Cc: Markley, Michael
Subject:
Fw: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
Joe, I am on travel to INPO and am on my bberry so can streamline this email. Therefore you need to read through a number of forwarded emails to get to the Issue. It is a member of the public claiming nRC staff wrong doing. Please talk to Mike Markley if you have any questions. Thanks, Jennifer From: Markley, Michael Sent: Thursday, September 18, 2014 10:35 AM To: Lund, Louise; Wilson, George; Uhle, Jennifer; Dorman, Dan; Dudek, Michael; Oesterle, Eric
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
FYI From: Uselding, Lara Sent: Thursday, September 18, 2014 10:28 AM To: Walker, Wayne; Hipschman, Thomas; Reynoso, John; Buchanan, Theresa; Sebrosky, Joseph; Sebrosky, Joseph; Markley, Michael
Subject:
FW: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?
The rest of this email string may be found as document M/55 in interim response #5 in FOIA/PA-2014-0488 (ML15224774).
From: Uhle, Jennifer Sent: Wednesday, September 17, 2014 5:12 PM To: Lund, Louise; Evans, Michele; Dorman, Dan
Subject:
Re: RIV Status Call re: Diablo Canyon Last I talked with Marc we did not support having a public meeting since it was not our report and we would make our asssessment of the safet significance public. And do blog type thing. J From: Lund, Louise Sent: Wednesday, September 17, 2014 04:48 PM To: Evans, Michele; Uhle, Jennifer; Dorman, Dan
Subject:
FW: RIV Status Call re: Diablo canyon For your awareness From: Oesterle, Eric Sent: Wednesday, September 17, 2014 11:28 AM To: Sebrosky, Joseph; Markley, Michael Cc: Lund, Louise; Karas, Rebecca; Lupold, Timothy
Subject:
RIV Status can re: Diablo Canyon FYI ... heard today on the call that Marc Dapas had periodic meeting with Chairman yesterday via VTC and they discussed the possibility of an NRC public meeting out there in the next few months - timed appropriately with PG&E public outreach meeting on AB1632 seismic report and the next SSHAC meeting that PG&E is considering making public. Sounded like it would be led by RIV. Chairman was apparently supportive of the idea. Thought you all should know.
fvio'R. <9~e+"le, Acting Branch Chief NRR/DORL/LPL4-1 301-415-1014
From: Dudek, Michael Sent: Monday, August 25, 2014 1:20 PM To: Markley, Michael; Uhle, Jennifer; Lund, Louise Cc: Sebrosky, Joseph; Case, Michael; Davis, Jack; Uselding, Lara; Burnell, Scott
Subject:
RE: DPO story has run Thanks Michael. I am available to support your communication needs. As we discussed this morning, this may warrant a Commission walk-around. If so, please let me know and I will coordinate.
Mlchael I. Dudek I OEDO Executive Technical Assistant I U.S. NRC u : Michael,Dydek@nrc,aoy 111 : (301 ) 41 5-6500 I BB:j (t.,(tl I
Original Message-----
From: Markley, Michael Sent: Monday, August 25, 2014 12:12 PM To: Uhle, Jennifer; Lund, Louise; Dudek, Michael Cc: Sebrosky, Joseph; Case, Michael; Davis, Jack; 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 still 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
Original Message-----
From: Uselding, Lara Sent: Monday, August 25, 2014 11 :52 AM To: Oesterle, Eric; Singal, Balwant; Sebrosky, Joseph; Markley. Michael; Gibson, Lauren; Hipschman, Thomas; Reynoso, John Cc: Walker, Wayne; Buchanan, Theresa
Subject:
FW: DPO story has run
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 The rest of this email string may be found as document F/25 in interim response #3 in FOIA/PA-2014-0488 (ML15033A279).
From: Burnell, Scott Sent: Monday, August 25, 2014 3:03 PM To: Markley, Michael; Pedersen, Renee; McIntyre, David Cc: Case, Michael; Sebrosky, Joseph; Davis, Jack; Uselding, Lara; Uhle, Jennifer; Dorman, Dan; Lund, Louise; Dudek, Michael; Brenner, Eliot
Subject:
RE: Someone has posted DPO online Lara; I spoke to Renee and here's the response for today:
Until the NRC completes its internal review process for a Differing Professional Opinion, the agency is unable to comment on any potential DPO documentation. Once a given review is complete the agency will have a final decision on the DPO and associated documentation.
Scott
Original Message-----
From: Markley, Michael Sent: Monday, August 25, 2014 2:52 PM To: Pedersen, Renee Cc: Case, Michael; Sebrosky, Joseph; Davis, Jack; Uselding, Lara; Burnell, Scott; Uhle, Jennifer; Dorman, Dan; Lund, Louise; Dudek, Michael
Subject:
FW: Someone has posted DPO online
- Rene, Lara Uselding, OPA in RIV is looking for some assistance regarding this. The Diablo Canyon DPO appears have gone cyber and she wants to know what she can discuss. From my view, it is not much except that it is still in process and that we have not made a final determination. The DPO is non-public and we cannot release it or discuss our evaluation of its contents.
Mike
Original Message-----
From: Uselding, Lara Sent: Monday, August 25, 2014 2:15 PM To: Markley, Michael; Walker, Wayne; Buchanan, Theresa; Alexander, Ryan Cc: Sebrosky, Joseph; Case, Michael; Davis, Jack; Burnell, Scott
Subject:
Someone has posted DPO online Importance: High Can someone verify if what Mothers for Peace Jane Swanson has sent out to media and the public is the actual DPO? See her link to below:
From: Jane Swanson [mailto! (b)(6)
Sent: Monday, August 25, 201412:30 PM
To: Swanson Jane
Subject:
MORE on AP story Detailed information about NRC Inspector Dr. Peck's Differing Professional Opinion is at http://libcloud.s3.amazonaws.com/93/5a/8/4821 /Diablo_Canyon_Seismic_DPO.pdf It is at the heart of the AP story.
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, Jack; 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 still 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
Original Message-----
From: Uselding, Lara Sent: Monday, August 25, 2014 11 :52 AM To: Oesterle, Eric; Singal, Balwant; Sebrosky, Joseph; Markley, Michael; Gibson, Lauren; Hipschman, Thomas; Reynoso, John Cc: Walker, Wayne; Buchanan, Theresa
Subject:
FW: DPO story has run
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 The rest of this email string may be found as document U37 in interim response #5 By Michael R. Blood in FOIA/PA-2014-0488 (ML15224A774).
Associated Press, August 25, 2014 2
From: Markley, Michael Se nt: Wednesday, August 27, 2014 8:45 AM To: Hay, Michael; Lund, Louise; Evans, Michele; Uhle, Jennifer; Dorman, Dan; Walker, Wayne; Holahan, Patricia Cc: Oesterle, Eric; Sebrosky, Joseph; Pedersen, Renee; Uttal, Susan; Kanatas, Catherine Subje ct: FW: DPO story has run FYI From: case, Michael Sent: Wednesday, August 27, 2014 6:49 AM To: Markley, Michael; Sebrosky, Joseph; Hill, Brittain; Bernhard, Rudolph
Subject:
FW: DPO story has run FYI From: Peck, Michael Sent: Tuesday, August 26, 2014 6:46 PM To: case, Michael
Subject:
RE: DPO story has run Thanks - I've been out on training and hadn't heard. I wasn't the one who leaked the DPO.
msp From: case, Michael Sent: Tuesday, August 26, 2014 7:32 AM To: Peck, Michael
Subject:
FW: DPO story has run Good morning, Michael. FYI.
From: Dudek, Michael Sent: Monday, August 25, 2014 1:20 PM To: Markley, Michael; Uhle, Jennifer; Lund, Louise Cc: Sebrosky, Joseph; case, Michael; Davis, Jack; Uselding, Lara; Burnell, Scott
Subject:
RE: DPO story has run Thanks Michael. I am available to support your communication needs. As we discussed this morning, this may warrant a Commission walk-around. If so, please let me know and I will coordinate.
Michael I. Dudek I OEDO Executive Technical Assisr ot I II S NJ U : Mjchael,Dudek@nrc,gov 111: (301 ) 41 5-6500 I BB: ,b (6
Original Message-----
From: Markley, Michael Sent: Monday, August 25, 2014 12:12 PM To: Uhle, Jennifer; Lund, Louise; Dudek, Michael Cc: Sebrosky, Joseph; Case, Michael; Davis, Jack; Uselding, Lara; Burnell, Scott The rest of this email string may be found as document F/25 in interim response #3 in FOIA/PA-2014-0488 (ML15033A279).
From: Lund, Louise Sent: Friday, September 05, 2014 2:34 PM To: Evans, Michele; Uhle, Jennifer
Subject:
FW: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?
I'm sure you will appreciate Dave's recitation below of "a day in the life of an OPA staffer" From: McIntyre, David Sent: Friday, September 05, 2014 2:18 PM To: Markley, Michael; Oesterle, Eric Cc: Walker, Wayne; Wertz., Trent; Singal, Balwant; Lyon, Fred; Sebrosky, Joseph; Walker, Wayne; Burnell, Scott; Alexander, Ryan; Uselding, Lara; Burnell, Scott; Pedersen, Renee; Lund, Louise
Subject:
RE: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?
Mike, Joe, et al - the Comm Plan was NOT given to the Commission. This was one of those "hair on fire" things that went like this:
- 1. I was asked by the Chairman's COS to prepare talking points on the Foreign Ownership SECY in time for him to present to other COSs at 1030.
- 2. At 1015, Chairman's COS asks me to attend the 1030 "and bring the Diablo DPO Comm Plan"
- 3. I call Lara, who sends the urgent request to you guys.
- 4. I get several documents and print out a pile at 1028 and rush upstairs.
- 5. The other COS don't want to see the Comm Plans. I mentioned that it was in draft and would be updated after staff is briefed on the CA seismic study and sees EDO's letter on the OPO decision.
Everyone was satisfied, and I brought the stack of papers back downstairs with me.
So please pretend that all this never happened and do what you intended to do all along And thanks for your help! © From: Markley, Michael Sent: Friday, September 05, 2014 2:05 PM To: Oesterle, Eric Cc: Walker, Wayne; Wertz., Trent; Singal, Balwant; Lyon, Fred; Sebrosky, Joseph; Walker, Wayne; Burnell, Scott; Alexander, Ryan; Uselding, Lara; Burnell, Scott; Pedersen, Renee; Mcintyre, David; Lund, Louise
Subject:
FW: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?
Eric, Joe raises a worthy point. Since the RIV Communications Plan is now with the Commission, it makes no sense for us to finalize the communications plan we had in process. Our task on Monday will be to update the DPO portion of what is already out there with insights from the DPO case file. We will need to get that incorporated and routed quickly so that it is ready to use when the appeal is issued.
Likewise, once we have access to the AB1632 report, we will need to update that section as well.
Mike From: Sebrosky, Joseph Sent: Friday, September 05, 2014 1:10 PM
To: Markley, Michael; Oesterle, Eric Cc: Singal, Balwant
Subject:
RE: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?
Mike and Eric, If you look at the email chain below you will see that the attached pdf version of RIV's Diablo Canyon communication plan has been provided to the Chairman's staff (Phillip Niedzielski-Eichner) with the caution that the DPO portion and the State of California report section is to be updated.
I will call you at 1:30 in Mike's office to discuss this and other things.
- Thanks, Joe From: McIntyre, David Sent: Friday, September 05, 2014 10:41 AM To: Alexander, Ryan Cc: Uselding, Lara; Mcintyre, David; Sebrosky, Joseph; Walker, Wayne; Buchanan, Theresa
Subject:
RE: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?
Understood. Thanks!
Sent via My Workspace for iOS On Friday, September 5, 2014 at 10:34:55 AM, "Alexander, Ryan" <Ryan.Alexander@nrc.gov> wrote:
David:
Per your request of Lara, attached is the current "best version" of the DCPP Comm Plan.
HOWEVER, please note:
( 1) The section on AB-1632 California Report is only a limited strawman pending input from Joe Sebrosky (NRR) on Tuesday, 9/9 following the staff's initial review of the AB-1632 report (limited availability on 9/8).
(2) The Non-Concurrences/DPO section is only updated to the point knowing that the DPO is still in process without any additional information regarding what the DPO Panel's/NRR Director's conclusions were.
RIV (with NRR's input) plans to put the Comm Plan into concurrence on or about 9/9 so that this document can finally be formalized and available on the OEDO Comm Plan website.
Please contact Wayne Walker (RIV DRP BC for DCPP - Office: 817-200-1148) with any questions.
Thank you, Ryan D. Alexander Senior Project Engineer NRC Region IV, Div. of Reactor Projects, Branch A Cell : I Office: (817) 200-1195 (b)(6) l 2
~ Please consider the environment before printing this e-mail.
From: Uselding, Lara Sent: Friday, September 05, 2014 9:15 AM To: Sebrosky, Joseph; McIntyre, David; Walker, Wayne; Alexander, Ryan
Subject:
Joe: cAN YOU PLEASE SEND DAVE THE LATEST COMM PLAN?
Importance: High From: McIntyre, David Sent: Friday, September 05, 2014 9:11 AM To: Uselding, Lara
Subject:
Diablo DPO Lara - can you help with this?
From: Niedzielski-Eichner, Phillip Sent: Friday, September 05, 2014 10:10 AM To: McIntyre, David
Subject:
RE: REVISED FOCD Talking Points One additional question ... is there a Com Plan for Diablo Canyon?
From: Niedzielski-Eichner, Phillip Sent: Friday, September 05, 2014 10:09 AM To: McIntyre, David
Subject:
RE: REVISED FOCD Talking Points Dave...will we have talking points for the Diablo Canyon DPO? Are you planning to join us at 10:30 am? Thanks. Phil From: McIntyre, David Sent: Friday, September 05, 2014 10:04 AM To: Niedzielski-Eichner, Phillip Cc: Dorman, Dan; Howe, Allen; Layton, Michael; Mizuno, Beth; Dusaniwskyj, Michael; Simmons, Anneliese; Morris, Scott; Galloway, Melanie; Uhle, Jennifer; Burnell, Scott; Harrington, Holly; Brenner, Eliot; Vietti-Cook, Annette; Schwartzman, Jennifer
Subject:
REVISED FOCD Talking Points Importance: High Phil - Attached are revised talking points on the FOCD SECY paper, for your use in this morning's COS meeting. These incorporate edits and comments from NRR (Scott Morris) and OGC (Ed Williamson).
Dave 3
HES'f AVAltAIUE (;OPY From: !J,eld,no. Lara To: Gibson. Lauren; Set11 osky. Josepl 1
Subject:
Mello agafn from Lara In RIV Dat e: Thursday, August 21, 2014 4:46:41 PM Attachments: STAJE REPORT MESSAGING.docx I can't not seek your input © so let me know what you both want for Christmas?
So attached are draft talkers for a seismic report we expect to receive next week. Lauren, I highlighted one portion on ONE question to see if you all think that answer is sufficient.
Joe: You have long history with us at Diablo and so IF YOU HAVE TIME. let me know if you have any comments.
We've had some major turnover in PMs for Diablo and so the acting group will get this but just wanted some expert input. Needing this back tomorrow or Monday morning. If not possible, that's OK.
Lara Lura U~.:lding I ' ,,, I< I I ** ,,1,, '\i I I lt1*u1 1 I\ \1 1* , I\ \,1 817 200. 1519 laru.uscldi ng(@11rc.gov
DRAFT Talking Points: State Report 09/25/2014 3:54 PM
- As required by the NRC, as documented in the RJ L, 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 to the NRC's review ofthe January 201 I Shoreline Fault Report, PG&E made the following commitment to the NRC:
"Ifduring PG&E 's ongoing collec:1io11 ofseismic data, new fau/Js 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 ac1ions 1aken or planned to address the higher seismic hazard relative lo the design basis, as appropriate, prior to completion ofrhe evaluations reques1ed in the NRC staff's March 12, 20 / 2, 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 JO ofthe Code of Federal Regulations 50.54(/) Regarding Recommendations 2.1. 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident,"
March 12, 2012
- The NRC performed an independent deterministic analysis of new seismic information provided 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 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 PG E'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 I 632, has been presented to the NRC as a condition of the RJL 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 injtial 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 RlL docwnents 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 now it
appears the shoreline fault is more capable. Further analysis on site by PG&E and has determined 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 sti ll 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 20 15.
- In addition, a longer-term review is underway by the License renewal staff to determine whether an amendment to the 201 1 issued Draft EIS (ML# .... ) is needed.
0 and A:
What will 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 fau lt remains bounded by the Hosgri fault for which the plant was built and licensed to withstand. This new information docs not negate or invalidate the NRC's assessment laid out in the RIL and therefore the plant remains safe to operate.
The I000-page document has also been given to the Japan Lessons Learned Di rectorate 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(1) letter, through the SSHAC process and a final Seismic Hazard and Ground Motion Response Spectra (GMRS) will be submitted to the NRC by March 2015. The updated Seismic Hazards/GMRS wi ll be used as input to an updated Seismic Probabilistic Risk Assessment (SPRA), which will be submitted to the NRC by June 2017.
(Jfpushed on any unkowns " in the report : ((necessary, actions could include orders to halt operations ifthe new information suggests there is an immediate safety concern. The NRC will fulfill J/s mandate to protect public health and safety.)
(Ifasked what fhings the plam has done since Fukushima: ft 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 incorporated into the more comprehensive 50.54f analysis due to the NRC in March 20 15. 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 lo operate. The NRC has looked at this evaluation and agrees based on the info that the Hosgri bounds all seismic events.
Why dido 't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault in 2011 prior to issuing the RIL'?
California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of2006) directs the Califo rnia 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 lo evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 2D and 3D mapping. This is different methodology than what was used for the 20 11 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 I I 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 20 11 Shoreline Fault Report remains valid.
From: Buchanan Thef't'sa To: Alexander Ryan; walker. Wayne: Prnett Troy; Hay. M,ct,aeJ; Htoscnrnan Thomas: use1d,nq. Lara; ~ ;
w111ram~. Megan: Oes\erle Eur: S1ooa1 Ba1wdn1: 1:10,,:no An9,:1
Subject:
Diablo Canvon Topics of Interest Communlcatloll Plan review and concurrence Date: Thursday, September 11, 2014 2:20:08 PM Attachments: Updated Memo Reo Connirrence on Rey Pace~
D1ab10 commun,catoo Plan Rev o12*B 14).cfro
- Hello, You are all listed on the attached memo for concurrence on the also attached Diablo Canyon "overall" communication plan. Because this communication plan was extensively reviewed and commented upon back in March, I am asking that you do a review of only the significant changes, specifically associated with the AB 1632 report, DPO, and Sewell report sections. Each section can be reached from the table of contents on page 8. Since both the AB-1632 and DPO sections are excerpted from their own reviewed and approved communication plans. I am asking for you to review and comment within the next few days so that I can get this communication plan issued the beginning of next week. I realize that is short turnaround, but as I said. the majority of this document has already been reviewed, commented upon, and comments incorporated.
Thank you for your timely response to this short turnaround item.
Theresa Buchanan Senior Project Engineer RIV DRP Branch A 817-200-1503
UPDATED: 10/01/201411:02 AM Communications Plan -
Diablo Canyon 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 continuously evaluated for the need to update key messages, and a full review/update will be evaluated approximately once per calendar quarter.
NOTE: Although this communication plan is marked as OUO-SII, all sections marked as "Key Messages" and "Questions and Answers" are releasable to the public.
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 acceleration for a Safe Shutdown Earthquake (SSE) in its construction permit applications in 1967 and 1968. (Note: PG&E uses the terms Design Earthquake and Double Design Earthquake when referring to the OBE and SSE, respectively.)
After construction permits were issued, during the Atomic Energy Commission's and NRG'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 DGPP site. After assessing information provided by PG&E and the U.S. Geological Survey (USGS) during the operating license review, NRG issued operating licenses for the two units in 1984 and 1965. 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 0.75g, a value believed to bound the expected ground motion resulting from an earthquake occurring along the Hosgri fault. PG&E established its Long Term Seismic Program (LTSP) to guide additional seismic evaluations and updated the Final Safety Analysis Report to incorporate the results of its LTSP study. PG&E concluded that DCPP Units 1 and 2 could withstand ground motion up to 0.75 g.
In 2008, PG&E notified the NRG about the newly discovered Shoreline fault zone. PG&E completed characterization of the Shoreline and other local earthquake faults in January 2011 .
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efflCIAL t:191: ONLY 91:NSl'fl'f'I: nnl:ftHAL lf4fi6ftMAT16N On October 20, 2011. PG&E submitted a license amendment request for approval to revise the current licensing basis, as described in the Updated Final Safety Analysis Report and Technical Specifications, to provide requirements for the actions, evaluations, and reports necessary when PG&E identifies new seismic information relevant to the design and operation of DCPP.
The NRC completed its independent review of the new seismic information and documented the results in a Research Information Letter (RIL) issued on October 10, 2012, which was subsequently communicated to PG&E two days later. NRC concluded that maximum ground motion at the site from a seismic event along 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(f) request for information provides a process for assessing new seismic information at Diablo Canyon and rendered the portion of the October 20, 2011 , PG&E license amendment in this area unnecessary. In a letter dated October 25, 2012, PG&E provided the basis for withdrawing its October 20, 2011 , license amendment request. The staff accepted the withdrawal of the license amendment in a letter dated October 31 , 2012.
PG&E is currently performing a seismic hazard update through a SSHAC Level 3 process. The resulting site-specific probabilistic seismic hazard analysis will be used to respond to the NRC's March 2012 50.54(f) request for information letter.
Key Messages
- Although the original OBE and SSE values of 0.2g and 0.4g were specified as part of the design basis (calculation) in 1968, the 0.75g Hosgri event was incorporated in the licensing basis (along with the OBE and SSE) prior to issuance of the DCPP units' operating licenses in 1984 and 1985.
o Upon discovery of the Hosgri fault (1971 ), PG&E reanalyzed and significantly upgraded the structures, systems, and components to accommodate the postulated ground motion values (up to 0.75g) from the Hosgri fault.
o The NRC staff reviewed and 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 Hosgri event). Both the ACRS and ASLB concluded that the revised seismic design basis was appropriately conservative and there was reasonable assurance that both units could be operated at full power without undue risk to the health and safety of the public.
- The NRC performed an independent deterministic analysis of new seismic information provided by PG&E in 2011 relating to the Shoreline fault. NRC's conclusions are Page 2 6FfilCIJl.t t:19! H4LV 8EH81TIVf lf4'ff~NAL U41'0fltMATION
8FFl81AL tJSE 6NLY SEHS1'fl¥E IN'fERNilcl lf4F6RMATl6f4 documented in Research Information Letter (RIL) 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.
- 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.1 The results of PG&E's re-evaluation of seismic hazards for DCPP will include identification of any changes in seismic risks (due to new information identified during more recent seismic surveys) and a comparison to the current plant seismic design basis. This evaluation is to be submitted to NRC by March 2015. If the updated seismic hazards exceed the current SSE (the value that NRC directed PG&E to use for comparison) ,
PG&E has indicated they will complete an expedited seismic evaluation process by January 2016 and a full seismic risk analysis by June 2017. Plant modifications, if required, would likely be completed in the 2018 timeframe.
- The expectation that the seismic issues will take some years to resolve at DCPP is not a safety concern. The NRC has followed the progress of PG&E's seismic re-evaluation process since the beginning. The NRC will continue to evaluate seismic data to ensure our understanding of the seismic hazard is informed and that there is no new challenge to safety.
- The NRC continues to conclude Diablo Canyon is built to safely withstand the effects of a Hosgri earthquake and that the plant would protect the public and the environment. The reasons for this are laid out in the RIL.
- If new information suggests that the plant has the potential to not withstand new seismic hazards. the NRC would take acti.on. This could include a plant shutdown until the issues could be resolved.
- 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 (ref: AB-1632 report). The information did not indicate th~re is an immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions. The licensee's current actions 1
See NRG letter, dated March 12, 2012, issued to all power reactor licensees Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(() Regarding Recommendations 2. 1, 2.3.
and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident. "
(http://pbadupws.nrc.gov/docs/ML 1205/ML12053A340.pd0 Page 3 8FFl81AL ~8E eHLY SEP4Sl'flt/E lf4'fERt4>91L lt4f6RM>9cll6N
eFFlelAL ~SE 614L'f SEf4SlflVE 114fEftNAL lf4F6ftMAfl6f4 meet the Manual Chapter 0326 guidance for having reasonable assurance of operability, pending further evaluation.
- The NRC will continue to review the new information in the AB-1632 report and will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit its preliminary evaluation.
- Diablo Canyon will incorporate the AB-1632 report's information into its March 2015 seismic hazard re-analysis submittal to the NRC.
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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, 2011 Task Interface Agreement (TIA) 2011-010, "Concurrence on Diablo Canyon Seismic Qualification Current Licensing and Design Basis," August 1, 2011 TIA 2012-012, "Revised Response to Task Interface Agreement -Diablo Canyon Seismic Qualification Current Licensing and Design Basis, IA 2011-01 O (TIA 201 2-01 2) (TAC NOS.
ME9840 and ME9841)," November 19, 2012 RIL 2012-01 , "Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone," September 19, 2012 (ML121230035)
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Ol'l'lelAL t1SE 6NLY SEHS11'11t1E INl'Eft:NAL IP~F6RMitcTl8U Non-Concurrences & Differing Professional Opinions
Background
The former SRI at the Diablo Canyon Power Plant (OCPP) submitted non-concurrence papers (NCPs) in January 2011 and January 2012, followed by a Differing Professional Opinion (OPO) in July 2013 detailing a disagreement with the NRC about how new seismic information should be compared to the plant's current seismic license requirements. OPO 2013-02 restated the issues presented in NCP 2012-01 and added a concern that a license amendment was needed incorporate the Shoreline fault into Diablo Canyon's FSAR as described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults. In accordance with Management Directive 10.159, a DPO Ad Hoc Review Panel was established to review the OPO submittal, meet with OPO submitter, and issues a DPO report including conclusions and recommendations regarding disposition of the issues presented in the OPO. The panel completed its report in May 2014 and a decision on the DPO was rendered in letter dated May 29, 2014, to the DPO submitter. The OPO submitter appealed the decision to the EDO in accordance with the NRCs DPO process. The EDO completed his consideration of the DPO appeal on September 9, 2014, concluding that he was in agreement with the original decision.
The purpose of this communication plan is to provide key messages associated with the EOO's decision on the OPO appeal and public release of the DPO Case File.
Kev Messages:
- 1. NRC strives to establish and maintain an environment that encourages all NRC employees and contractors to raise concerns and differing views promptly without fear of reprisal through various mechanisms. The free and open exchange of views or ideas conducted in a non-threatening environment provides the ideal forum where concerns and alternative views can be considered and addressed in an efficient and timely manner that improves decision making and supports the agency's safety and security mission.
- 2. The NRC appreciates members of the staff bring issues like this to its attention
- 3. The NRC encourages the use of non-concurrences and the Differing Professional Opinion (DPO) process
- 4. The NRC reviews all non-concurrences and DPOs thoroughly and in accordance with agency guidance (MD 10.158, MD 10.159) and believes that this is a healthy and necessary part the regulatory process
- 5. The NRC believes that, in the end, all of our regulatory decisions are better because of this process
- 6. The NRC does not tolerate retaliation against employees who engage in our processes for raising differing views (i.e., Open Door Policy, NCP, and DPO Program).
- 8. Upon disposition of the DPO via a Director's decision, the OPO submitter has appeal rights to the EOO Page 6 Ol'l'ICIAL tJS! erRV 9!U91T11;l! IUTl!ftUP,L 114f'Ol!tMATIOl4
@FPl91'4L tJ!E 8NLY 9!f4SITl't'I! INTl!f\f4AL IHf'Of\liiA I IOI~
- 9. While the DPO is under review or appeal, NRC is prohibited from engaging in discussions with external stakeholders regarding the specifics of the of the DPO submittal
- 10. After the EDO's decision on the appeal, the DPO submitter can request that the DPO Case File be made public. Management performs a review consistent with agency policies to support discretionary release. Regarding the DPO for Diablo Canyon, the NRC has been and will continue to be as open and scrutable as possible while protecting the privacy rights of the individual
- 11. The NRC does not know the source of the public release of the Diablo Canyon DPO submittal prior to the EDO rendering a decision on the appeal
- 12. The NRC can, however, comment on a few aspects of the DPO appeal review o A Director's Decision has been made and the DPO appeal to the EDO has been finalized o The EDO and the DPO submitter have both agreed that the issues raised in the DPO do not present an immediate safety concern for Diablo Canyon o The NRC has sought permission from the DPO submitter to allow the DPO case file to be made publicly available and the DPO submitter has agreed o We would expect the public release of the DPO case file to be within a few days of the EDO's appeal decision
- 13. Regarding the operational status of Diablo Canyon Power Plant, Units 1 and 2 o The plant remains within its approved design and licensing basis o There are no current operability concerns resulting from the DPO o The recent earthquake in the Napa Valley did not reach Diablo Canyon - it was neither felt nor detected Background Documents
[NON-PUBLIC] Non-concurrence NCP 2011-103, dated November 7, 2011 Non-concurrence NCP 2012-01 , dated January 26, 2012 [publically available in ADAMS]
[NON-PUBLIC] Differing Professional Opinion 2013-02, dated July 18, 2013 Page 7 err1e1J1tt tJS! eHLY !EH!ITIVE lf4TffU.AL IUP"@PIMATltm
6FFlelAL tlSE ONLY - SENSl'fl'tE IN'fE"NAL INF6"MA'fl6N 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 Q&As Design/Initial Licensing Basis Questions (DE/DDE/Hosgri/Tsunami) ........... ............................. 21 Long Term Seismic Program (LTSP) Questions ....................................................................... 24 Shoreline Fault Questions .......................................... ...................... ...... ................ ........... ........ 26 State of California Seismic Report (AB-1632) ................... ........................................................ 30 Los Osos and San Luis Bay Faults ........................................................................................... 34 Research Information Letter (RIL) Questions ............................................................................ 35 "Sewell" Report/ Tsunami. ........................................................................................................ 36 Non-concurrence and DPO Questions ..................................................................................... .42 RIS 2005-20, 2013-005, and Operability Evaluation Questions ........................................ ......... 47 Enforcement Questions .. ...................................................................... .................................... 48 Current Licensing Questions ........................... ................................................................. ,........ 49 50.54(f) Questions .................... .......... .... .... .......... ...... .............................................................. 52 Tier 3 Expedited T ransfer of Spent Fuel to Dry Cask Storage ................................................... 57 DCPP Licensing Basis Verification Project (LBVP) ...................................................................60 Continued Storage Rule (formerly "Waste Confidence") .......................................... .................63 Public Cancer Risks .......................................................................................................... ........64 Emergency Preparedness Concerns ........................................................................................ 65 Page 8
Ofls iCl~L tJSE 614L'f SEHSITl't1E n*TEfU*At n*11e"MAT1er*
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.org/)
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-24 h) 1 State and local Government agencies, including:
California Governor's Office of Emergency Services, California Public Utilities Commission, California Independent Peer Review Panel (IPRP),
California Energy Commission, and California Coastal Commission.
Industry groups (e.g. , Nuclear Energy Institute)
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eFFlelAL tJ!E er4LY 9fU9"1Vf IUlERUAL 1Uf8RMATl8H 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 81 7-200-1291 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 Acting Sr. Project Theresa Buchanan R-IV/DRP/RPB-A 817-200-1503 EnQineer 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 8 17-200-1243 Jon Ake Senior Seismologist RES/DE/SGSEB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301 -415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Joseph Sebrosky Senior Project Manager NRR/JLD 301-415-1132 Scott Burnell Public Affairs Officer OPA 301-415-8204 Jenny Weil Congressional Affairs OCA 301-415-1 691 Angel Moreno Congressional Affairs OCA 301-415-1697 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Elaine Keegan License Renewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301-415-2321 Nick DiFrancesco Japan Lessons Learned JLD 301-415-1115 Page 10 eFFlelAL tJ9E 6HL1i' 9EU91T1Vf IUfl!IIUli',t INf'OftMATION
eprpr1e 1At t19E 6HL1( 9!f491TIVE ,u,ERUAL 1Uf8RMA?18U Communications Tools The communication team may and have used any of the following tools to communicate with our stakeholders:
Internal Briefings The communication team will conduct internal briefings as required to keep internal stakeholders informed of activities and messages.
Public Meetings In May 2009, a town hall public meeting was conducted in San Luis Obispo, California, to discuss the Shoreline Fault. In September 2010, a two-day public workshop was conducted in San Luis Obispo, California, to present topics of interest regarding seismic issues. In January 2011, a public meeting was conducted in San Luis Obispo, 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 DCPP'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 I Report I Document Title Lead Office Date (ADAMS/Reference number, as appropriate)
Submitted 50.72 notification with an operability 1 assessment to the NRC PG&E November 21 , 2008 (Event Number: 44675) 2 FAQ 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 (ML090720505)
PG&E December 17, 2008 Page 11
OFFICl1'L tJSE 014t, S!l4Sl'l'l'O'! 114'1'!fltHAL lf4FORMATION Activity / Report / Document Title Lead Office Date (ADAMS/Reference number, as aooropriate)
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 April 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 April 30, 2009 assessment and a preliminary review of the DORL tsunami hazard bv RES.
Complete an operability evaluation of potential 9 PG&E April 30, 2009 ground deformation Support a town-hall meeting, conducted by Region IV, in which the Shoreline Fault is NRR, 10 NRO, & May 28, 2009 expected 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 Analysis NRR/ Division of Operating Reactor Licensing 13 (DORL) to submit Research Assistance Request NRR April 29, 2010 for review of Secondary Rupture Meeting with RES, NRO, and NRR/DORL to 14 discuss User Need Request to determine future NRR March 29,2010 actions regarding the Shoreline Fault RES to provide confirmatory review of secondary 15 rupture analysis RES July 31 , 2010 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 Fault NRR August 11 , 2010 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 2010 21 Complete geologic studies PG&E December 2010 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 report.
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Ol'PICIAL tJ9l!! er*tv 9Ef491Tl'o'E IN'fE"NAL INfiOftM~lleU Activity / Report / Document Title Lead Office Date (ADAMS/Reference number. as aDPropriate)
NRR/
24 Meeting on LTSP Amendment December 9, 2010 DORL 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; th erefore, 27 interim reports will not be submitted to NRR/DE January 2011 stakeholders for review until all data are integrated into final report in December.
28 Complete final Shoreline report PG&E January 2011 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 LT SP Amendment January 26, 2011 DORL NRR/
32 Third Meeting on LT SP Amendment March 2011 DORL 33 LTSP Amendment submittal (LAR 11-05) PG&E October 20, 2011 The NRG held an annual assessment meeting 34 RIV June 2011 and discussed seismic at Diablo 35 The NRG issued the RI L 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)
W ritten response to questions posed by U.S.
NRR (w/
38 Senate Environmental & Public Works Late January 2014 OCA) subcommittee staff Regional 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 September 10, 2014 report to the state of California Page 13
8f Pl81AL t18E 8ttLV 8EU81llVI! IH!fERUAL IUF8RMAll8U List of Applicable Acronyms and Abbreviations 2-0/3-D Two-Dimensional/Three-Dimensional (relative to seismic mapping studies)
ACRS NRC's Advisory Committee on Reactor Safety AS LB 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 DDE Double Design Earthquake (DCPP specific term, equivalent to SSE)
DE Design Earthquake (DCPP specific term, equivalent to OBE)
DGEIS Draft Generic Environmental Impact Statement DPO Differing Professional Opinion GMC Ground Motion Characterization (relative to SSHAC process)
HE Hosgri Event (i.e., seismic event occurring on the Hosgri fault)
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 NTIF 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 Earthquake SSHAC Senior Seismic Hazard Analysis Committee TIA Task Interface Agreement TS Technical Specification U/FSAR Updated/Final Safety Analysis Report Page 14 6fflelP,L 1:::19E 8ULV 8EU81flVE IUTEfU4AL lf4Fe"M)l(Tl6f4
eFl'lelAL t:19E 6f4t¥ 9!f49ITl'II! lf4'1!RUAL IUPeRMATleU 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, 1 O 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 , "Damping Values for Seismic Design of Nuclear Power Plants," was issued. The RG allowed more damping to be used in seismic evaluations than had previously been used in the DE and ODE at Diablo Canyon. PG&E used the RG 1.61 values in the Hosgri evaluation and did not revise the DE or DOE.
1/10/77 Revision of Appendix A to 10 CFR 100 was issued 6/3/77 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 "we [NRC staff] require that the plant design be shown to be adequate for the Hosgri event and the applicant is proceeding with the work necessary to demonstrate this."
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el'l'l91AL ~81!! 8f4L'f 8EP481l"IVE INTERNAL INFORMATlot*
Timeline 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 Dlablo Canyon plant will be able to withstand any earthquake 1hat 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 6FFl81AL ~SE 6ULV 8EPJ81TP11E IHTEfWAL IHF8RMAll@U.
C'"' l'ICb\t: tj9E 8f4l'f t!U!Hsi,rtf INf ERf4AL INf'6RMAfl6N Timeline of Seismic Issues at DCPP (cont'd) 2006 A new phase of the CRADA is implemented and includes both a large set of new field studies and the application of new advanced seismological techniques to small magnitude recorded earthquakes.
11/14/08 PG&E notified the NRC of a potential *line of epicenters about one mile offshore from the plant. This was followed up on 11/21/08 with Event Notification 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 (RIL) 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 201 O PG&E submitted a progress report on the Shoreline Fault Action Plan.
Sept 2010 The NRC sponsored a seismic workshop in San Luis Obispo, CA, to help inform the public about seismic evaluations and design. Independent seismic experts were invited to make presentations.
Sept 2010 DCPP 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 DOE.
Oct 2010 DCPP SRI questions PG&E on the capability/operability of SSCs to withstand the Shoreline Fault acceleration using the DE/DOE evaluation method.
Dec 2010 PG&E concluded that no operability evaluation was needed to compare the Shoreline Fault ground acceleration to the DE/ODE evaluations. PG&E believed that the.y 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 ML110140400). This report included deterministic 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 2011-01 O posing questions needed to help resolve seismic operability evaluation issues involving Diablo Canyon's use of the Hosgri and LTSP methods as the only bounding design basis conditions for newly identified faults.
Page 17
CP:P:ICIAL tj!E er*tv SENSl'flYE IN'fERN>f<L 1m*e~MA"614 Timeline of Seismic Issues at OCPP (cont'd) 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 1o 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 DOE (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 in the UFSAR.
Sept -
Page 18 011111e1At t:19! Offt'I' .. ser.emvE 1u,e,mAt iunHtMATleN
eFFlelAL t:j9E 6f4LY w 9!f491llVE lfffERNAl lf4f.i8"MAll8N 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.
11/9112 NRG held a meeting to discuss the 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 NRG issued TIA 2011-010, "Revised Response to Task Interface Agreement -
Diablo Canyon Seismic Qualification Current Licensing and Design Basis, TIA 2011-010 (TIA 2012-012) (TAC NOS. ME9840 and 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 NRG 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 Motion 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 workshop.
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eFFlelAL tl3E 6f4LY 3EN91l'l't'E INl'EftNAL INF6ftMAfl6H Future Events:
Sept. 2014 PG&E expected to submit the AB-1632-mandated SEISMIC REPORT to State of California (IPRP to review) . A copy will be provided to NRC for review.
March 2015 PG&E due to submit ground motion response spectrum to the NRC in response to March 2012 50.54(f) request. Current information from the SSHAC process supports the expected conclusion that the new ground motion response spectrum will be bounded by the original HE ground motion response spectrum.
June 2017 PG&E due to submit the results of the new Seismic PRA to the NRC in response to 50.54(f) request.
Page 20 eFFlelAL tf81! @HL'f 8E1491TIVI 114Tl"UAL IUl'O"MATION
6ffl61>9ll tJ9E 6'4LV w 9EH91TPiE IHTERP4AL 1Pff8RMATl8t4 Design/Initial Licensing Basis Questions (DE/DDE/Hosgri/Tsunami}
- 1. When was the Hosgri fault identified?
1971 . During geological investigations in support of the DCPP operating lfcense applications, oil company geoscientists discovered a major zone of faulting a few miles off shore. When the DCPP Final Safety Analysis Report (FSAR) was initially submitted for NRC review in 1973, it briefly described the offshore fault zone, calling it the East Boundary Fault Zone. The zone became known as the Hosgri fault.
- 2. How was the Hosgri fault addressed in the licensing and design of DCPP?
Although the original OBE and SSE values of 0.2g and 0.4g were specified as part of the design basis (calculation) in 1968, the 0.75g Hosgri event was incorporated in the licensing basis (along with the OBE and SSE) prior to issuance of the DCPP units' operating licenses in 1984 and 1985.
Upon discovery of the Hosgri fault (1971), PG&E reanalyzed and significantly upgraded the structures, systems, and components to accommodate the postulated ground motion values (up to 0.75g) from the Hosgri fault.
The NRC staff reviewed and accepted PG&E's revised seismic analysis ln 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 a,nd 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 DE response spectrum is enveloped by the DOE response spectrum at all frequencies, and the DOE response spectrum is enveloped by the HE response spectrum at all frequencies. In addition to the magnitudes of the spectra being different, the shapes of the spectra are also different. This is due to differences in how the response spectra were developed as well as differences in the hypothetical earthquake that each design basis level Page 21 6fifil61AL tJ9E 6NLY .9EN91Tl"f'E INTEffNAL INf6ffMATl6f4
6FFlelAL ~SE 6NLY 9EN91'f1VE lfffERH>'<L lf4FeRMATl6N is based on. Generally speaking, the response spectra were constructed based on modified versions of similar real earthquakes, normalized 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 OCPP operating license defines the ODE 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 Diablo Canyon site, two design basis earthquakes (ground motion) were established. The operating basis earthquake (OBE) represents the ground motion reasonably expected during the lifetime of the plant. At DCPP, this is called the Design Earthquake (DE), and is 0.2g. The safe shutdown earthquake is defined as having twice the acceleration of the operating basis earthquake to ensure safety margin. At DCPP, this is called the Double Design Earthquake, and is 0.4g.
Pacific Gas and Electric (PG&E, the licensee) was required to show that all equipment necessary for continued operation without undue risk to the health and safety of the public would withstand the OBE/DE (i.e., remain functional) , and that all safety-related equipment needed to safely shut the plant down and maintain a safe shutdown condition would withstand the SSE/DOE.
The licensee obtained the construction 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 part of a collaborative research program between PG&E and the U.S. Geological Survey (USGS). The NRC worked with the USGS office to ensure that the seismic hazard was properly characterized. This effort determined that the Hosgri fault could produce up to 0.75g ground motion at the 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/DOE requires the licens,ee 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/DOE. At Diablo Canyon, this was demonstrated through a combination of calculations and tests. Because the ASME, Section Ill requirements for design of pressure boundary components and supports were not mandated by 10 CFR 50.55a until the mid-1980's, the acceptance criteria for DCPP rely on a combination of the ASME Code and ANSI Code for piping, applicable at the time of initial licensing, that provide an equivalent level of safety assurance as required by 10 CFR 50.55a.
Page 22 Ol"l"ICIAL 119! ONLY 9!1411Tl"il'I!! IUTl!"fJAL U41'C"MATICf4
61'1'1CIAL tf!I! er4LY !1!14!1TIVI! H4,l!ftf4AL 1Nfi6RMATl6f4 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 DDE/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 withstand any earthquake that can reasonably be expected to occur on the Hosgri fault".
- 6. Is it accurate to state that meeting the SSE/DOE also means that the licensee has to test and model some of the other reactor's structures, systems and compQnents (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 it accurate to state that NRC did not require the licensee to meet all of the requirements of the SSE/ODE when it came to its Hosgri earthquake analysis (and that this is basically what you sent in the documents)?
No. The functional requirements remained the same, and were met. As indicated in the answer to Question 5, although a limited number of components relied on alternative Code acceptance criteria to demonstrate functionality up to the HE, those components still meet the applicable Code.
- 8. What size tsunami is the plant designed/built to withstand?
The design basis tsunami is 35 feet. The DCPP site sits atop a coastal bluff, 85 feet above sea level, decreasing its vulnerability to a tsunami hazard. The only safety-related system that has components within the projected sea wave zone is the Auxiliary Saltwater (ASW)
System. The ASW pump motors are housed in watertight compartments within the intake structure. The intake structure is designed with an elevated air intake (48 feet) so that the ASW pumps can operate during the design combination of a tsunami and storm wave run up.
- 9. How is the plant designed for each design basis earthquake? How are those design criteria/methodologies/analytical methods different? Why are they different?
[Answer under development.]
Page 23 8fifileliltt tJSE 6NLY SEf~Sl'flVI! INTl!PU~At INl'O"MATION
erne1itcL tJSE 0NLV - SENSlfl't'E lf4'fEf(NAL INF0RMATl6N 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 analysis" included as an original plant license condition . The LTSP 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 Diablo 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 ODE. 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 Oiablo 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 LTSP by itself is not sufficient to meet this requirement.
Page 24 8FFlelAL t:ISE erRY - SENS1'f1't1E IN'fEf(NAL lf41-6f(MATl6N
8fFl81AL ~8! 8HLY 8Ef491flVE n4,Eff f4Al lf4fi6f\MA"er4 Following issuance of the TIA, the NRG documented a violation for the failure to perform an operability evaluation in NRC Report 05000275; 323/201105. The violation has low safety significance because NRC reviews concluded the Hosgri event bounds the Shoreline fault.
TIA 2012-012 was issued on November 19, 2012. This TIA superseded TIA 2011-010 and identified that the Shoreline scenario should be considered a lesser included case under the Hosgri evaluation and that the licensee should update the FSAR , as necessary.
The NRC's independent evaluation, documented in RIL 12-01 , concluded that there is very little evidence that the Shoreline fault has ever been active. While its size was used to create a worst reasonable case ground motion curve, the region shows only some symptoms of a fault. There Is no evidence that there is slippage, which would indicate this was an active fault in the past. Therefore, it is reasonable to bound the Shoreline fault by the LTSP/Hosgri method.
Page 25 Of filCIAL t:ISI! ONL'f S!!N!ITlttl! INTl!"NAL lf41'0"MATI014
8FFl8 1AL 1;18E 8HLV 8!U8ITIVIE IU'ffiRUAL IUF6RM#Fl6U 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. What are the characteristics of the Shoreline fault?
Studies conducted in 2009 and 201 O concluded that the Shoreline fault is a right-lateral strike slip fault. approximately 23 kilometers (14.3 miles) in length, with a slip rate between 0.2 and 0.3 millimeters per year. The closest segment of the fault is located about 600 meters southwest of the Power Block (the reactors) and 300 meters southwest of the Intake Structure.
The studies also updated information on other faults in the region. The 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/ODE method.
In November 2012, the NRC concluded that it was appropriate to treat the Shoreline fault as a special case, and that using the same methods and criteria as was used for the 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 NRG issued Research Information Letter (RIL) 09-01 , "Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon NPP from Newly Identified Shoreline Fault." This was an independent study of potential impacts of the Shoreline Fault.
The NRG concluded that adequate seismic margin existed and the plant was safe to operate.
The NRC concluded that it was appropriate to use the same methods and criteria as was used for the LTSP/Hosgri to evaluate the Shoreline fault. This was because the Shoreline Fault frequency and peak ground acceleration at the plant were below what LTSP/Hosgri would produce at the plant.
Page 26 Ol'l'ICIAL US! Of-LY - 9!N91Tl'o'.! INT!l!tNAt INJ!IC "M1'<TIOU
OflflClll!tl t:ISE eNLY SENSITl't'E lfffEfUfJlcL lfff8RMAfl6N
- 6. Was Diablo Canyon's sole use of the LTSP appropriate for evaluating the Shoreline Fault?
No. The design and licensing basis for Diablo Canyon included two different evaluation methods with two different acceptance criteria which could be considered bounding. The licensee could not use the method that had been used to evaluate and accept the Hosgri 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?
Diablo Canyon has completed an operational evaluation to show the plant is safe to operate.
The NRC reviewed and agreed the evaluation indicates the plant is safe to withstand earthquake hazards. Based on what the NRG 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 is not safe the NRG would take immediate action to resolve the issue.
- 9. Why is the NRC allowing Oiablo Canyon to operate when experts inside and outside the NRC believe the Shoreline Fault represents a threat to the plant and serious questions have been raised regarding whether the facility meets NRC's license requirements?
Page 27 6fifil61AL t:18E @'4LY 8EP481ll¥E IHfEftf4AL 114F6ftMATIOf4
Ol'l'ICIAL t:J!! er~LY ... !Ef481fl'IE nt,ERUAL lftF(U~MA'fl@N When the NRC set out to perform an independent assessment of the Shoreline Fault we put together a team of NRC seismic experts as well as a team of consultants from outside the agency to ensure that we had the right expertise to perform the analysis and that the resulting document would be technically defensible. Our independent deterministic analysis of the Shoreline Fault determined that the ground shaking at the plant site that could result from earthquakes on the Shoreline Fault is bounded by the larger ground motions that could result at the plant site from earthquakes on the Hosgri fault. Based on the NRC's independent analysis of the 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 NRG senior resident inspector has questioned how the Shoreline Fault fits within the seismic design ano 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 staff's results. The plant was evaluated and licensed for the Hosgri ground motions; therefore the facility does meet NRC's license requirements.
- 10. Is it accurate to state that generally speaking, when a licensee does not meet its license requirements, there are 3 typical options: 1) NRC can order the reactor to shut down until the license requirements are met, 2) NRC can approve a set of mitigation measures the licensee could take that would satisfy the license requirements; or 3)
NRC can approve a license amendment to alter the requirements of the license?
The options listed are valid 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 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.
Page 28 Ol'l'ICIAL t:J!I! ONLY SEHSl'flVE lf4TERNAL 1Nf'6RMATl6f4
el'l'lel~L t1SE 6t4LY - SENSITl't'E INTERNAL INF6RMATl6N 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 if 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 Orders) if a licensee is not meeting its regulatory requirements. These options are described in the enforcement guidance listed on NRC's Enforcement web page at http://www.nrc.gov/about-nrc/regulatory/enforcementhtml. 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, lhe NRC will take whatever action is necessary to ehsure 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 OCPP to address NRC's own conclusion that the reactor has likely not met its SSE/DOE 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. T he NRC has not identified a safety issue at Diablo Canyon in this case.
Shortly after PG&E notified the NRC of the potential for a new fault (later referred to as the Shoreline Fault), it provided the NRC with sets of initial scientific data and information related to the hypothesized fault. Based on this initial information, the NRC staff immediately performed a preliminary review of possible implications of the Shoreline fault to the DCPP to determine if an immediate safety concern existed. The NRC continued to review new data and information on the Shoreline fault 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 existing design basis for the plant is sufficient to withstand ground motions from the Shoreline fault.
Page 29 6fFletilcL l1SE 6HLY - 9ff481'1VIE lflftif(UAL 1Nf6ltMA'flON
erP'ICIAL t18f! @UL¥ 8EU81fl¥E IHfEfUJAL IHF8RMAfl8'4 State of California Seismic Report (AB-1632)
Note: This section is excerpted from the "Communications Plan - Diablo Caynon Power Plant T opics of Interest State of California Seismic Report" dated 9/10/14. Please refer to that communications plan for the most current information.
Background
California Assembly Bill 1632 {Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulne-rabllity 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; ahd 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 3D mapping to compile this report. This is a different and more extensive data set than what was used for the 2011 Shoreline Fault evaluation.
The purpose of this communication plan is to provide key messages associated with the public release of this report.
Key Messages
- NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event.
PG&E's evaluation of the new seismic information, as documented in the report, concludes that the ground motions resulting from the faults discussed in the report (i.e.*
Shoreline, Hosgri. San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.
- The NRC staff will review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.
- PG&E will incorporate the findings from 81111632 report into their upcoming March 2015 probabilistic seismic hazard analysis as part of the NRC's post-Fukushima activities.
The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.
Questions and Answers
- 1. What is the impact of this new information on seismic design and licensing of DCPP'?
H,as the licensee entered this new information into the corrective action program and Page 30 Of PICIAL ~81! 6f4LV 8ff4Sl'fl'tE IHTERNAL lf~li6RMATl6f4
OfflelAL tJSE ONLY 9EN91flVE IN,ERHt.L IUF8RMA"fleU performed an operability evaluation?
In accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001 ,
PG&E has entered the new preliminary seismic information into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.
In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:
"If during PG&E's ongoing collection of seismic data. new faults are discovered or information is uncovered that would suggest tt:ie Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information (Reference 2)." Reference 2 is NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)
Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," March 12, 2012.
NRC Resident Inspectors, and Region IV staff looked at the licensee's documentation in their corrective action process assessing new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions.
In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the faults discussed in the report (i. e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.
The NRC will review the new information provided in the report to the State of California including the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRG staff will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRG to revisit the conclusions in the RIL.
- 2. Has OCPP provided the seismic report to the NRC?
Yes, in accordance with the guidance in the October 12, 2012, letter transmitting RIL 2012-001 , PG&E has provided the information to the NRG. In addition, the report was also provided to address license renewal issues (see question 8).
- 3. What does the new report state?
The new report includes information obtained from 2-dimensional and 3-dimensional high energy and low-energy seismic surveys both onshore and offshore of the DCPP site. The report provides more details on the regional faults, including more precise readings and additional data points where previously there were gaps. While a lot of the information from the previous Shoreline Fault report of 2011 was confirmed, some of the new data suggests Page 31 OP'P'lelAL tJSE ONLY - SEHSl'fl'tf lf4'ffU4At IUl'Ol!O"ATION
o,,ie1At lill! 6NLY 9flf491fl\!E IUlERfh\L IUF9RMltll9U the following :
- Reduced slip rate on the Hosgri Fault Zone and the Shoreline Fault Zone
- Postulated connection of the Hosgri and the San Simeon faults which could result in a longer, larger, but more infrequent earthquake
- The unique geometry involved with intersecting the Hosgri Fault and the Shoreline Fault Zone results in an extension of a few kilometers, but with a lower frequency of occurrence
- Extension of the Shoreline Fault zone southern segment
- The new datc1 does not alter the assessment of the closest approach of the Shoreline fault to DCPP which is 600 meters from the power block and 300 meters from the intake structure. Because the Shoreline fault is considered to be somewhat longer, potential earthquakes could also occur farther from the plant.
- Updated analysis for the San Luis Bay, and Los Osos faults The report concludes that the ground motions for the Hosgri and LTSP evaluations continue to bound potential ground motions from the regional faults, including the Shoreline Fault, San Luis Bay, Los Osos, San Simeon and Hosgri. The DCPP continues to operate safely within the seismic margin they were designed to withstand.
- 4. How will the AB 1632 seismic report be coordinated with the 50.54(f) required submittal in March 2015?
PG&E plans to incorporate the findings from Bill 1632 report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.
(If pushed on any "unknowns~ in the report: If necessary, actions could include orders to halt operations if new information suggests there is an immediate safety concern. The NRC will fulfill its mandate to protect public health and safety).
(If asked what things the plant has done since Fukushima: It is important to note that DCPP is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).
- 5. Why is the report "final" for the state but "preliminary for the NRC?
For the State, the report is final. For the NRC, this information is expected to be incorporated into the more comprehensive 50.54f analysis due to the NRC in March 2015.
However, because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is safe to continue to operate. PG&E's evaluation of the new seismic information, as documented in the report , concludes that the ground motions resulting from the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.
Page 32 8ffl81AL ti8E 9ULV Sl!!NSITIW! INT!IUUct H~POIUfll<TIObl
eFFlel>'cl t:JSE eNLY SEHSl'flVE IN'fEIU4AL IP41-6RMA'fl6N
- 6. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault in 2011 prior to issuing the RIL?
California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station, to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault in the 2011 report.
The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analyses which is due for OCPP in March 2015.
- 7. What is the impact of this new information on seismic design and licensing of DCPP?
Based on the preliminary results of the studies that are under review, PG&E determined that the Shoreline Fault Zone may be capable of producing somewhat larger earthquakes than considered in the January 2011 Shoreline report. The NRC staff is independently assessing PG&E's determination. The process outlined In the 50.54(f) letter includes a detailed analysis of new seismic Information (including shoreline faults and other faults around the plant). PG&E is scheduled to provide this assessment in the March 2015 time frame. The staff will continue to review the information in the new CA 1632 report and the final results of the new data from the more rigorous analysis to be completed by March 2015. The NRC staff will take appropriate regulatory action up to and including issuing Orders to ensure safe operation of the plant.
- 8. Will the Report be considered in the License Renewal Process Yes. In addition to the report being developed to address California Assembly Bill 1632 ,
PG&E is providing the report to the State of California as part of the State of California coastal zone consistency certification associated with the license renewal for DCPP. The State of California coastal zone consistency certification is considered by the NRC during the license renewal environmental review process. In addition, the Staff will be reviewing the report to see how, if at all, it is relevant to the Staff's license renewal review. There is a contention related to the Shoreline fault and its consideration in the facility's severe accident mitigation alternatives analysis that is admitted in the license renewal proceeding (see ML14224A320; See CLl-11-11).
Page33 6 FFl61AL t:ISE 6NL'f SENSITIVE INTERP4AL IP4f'eftMATlel4
OfifilCIAL t:JSE ONLY S!NSITrf'! u~,EfU.At IUP@RMfcl'ICN 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 faults 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 34
eFFlelAL 69E eNE, SEHSI 11 vE IFH El<NAL INI 61<MA 116N Research Information Letter (RIL) Questions
- 1. What is a RIL?
RI Ls are documents issued by the Office of Nuclear Regulatory Research (RES) to the NRC Regulatory and Regional Offices that summarize, synthesize, and/or interpret significant research information, provide new or revised information, and discuss how that information may be used in regulatory activities. RIL's allow NRC Regulatory Offices or Regional Offices to readily understand what new information has been obtained, and the significance of that information for current and future licensing reviews or other regulatory activities.
- 2. What is the purpose of RIL 2009-001?
Research Information Letter (RIL) 2009-001 was issued on April 8, 2009. RIL 2009-001 was initiated for RES to complete an independent analysis of the Shoreline Fault.
In RIL 2009-001 , the NRC concluded that the seismic-loading levels predicted for a maximum magnitude earthquake on the Shoreline fault were below those levels for which the plant was previously analyzed in the LTSP.
- 3. What is the purpose of RIL 2012-01?
Research Information Letter 2012-01 was issued on September 19, 2012. RIL 2012-01 was initiated for RES to complete an independent analysis of seismic hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone.
The NRC's independent evaluation, documented in RIL 2012-01 , concluded that there is very little evidence that the Shoreline fault has ever been active. While its size was used to create a worst reasonable case ground motion curve, the region shows only some symptoms of a fault. There is no evidence that there is slippage, which would indicate this was an active fault in the past. Therefore, it is reasonable to bound the Shoreline fault by the LTSP/Hosgri method.
- 4. Now that the Rlls have been issued, is PG&E done with its studies?
No. PG&E has performed additional studies including three-dimensional (3-D) marine and two-dimensional (2-D) 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 DCPP: 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 walkdowns 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 35
OfifilelAL t1SE ONLY - SENSITIVE INTERNAL lf4fi0ftMA'flOf4 "Sewell" Report I Tsunami Concerns
Background
In March of 2004, as part of the review for the Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) license review, the Center for Nuclear Waste Regulatory Analysis (CNWRA, a division of Southwest Research Institute), transmitted to the NRC a Tsunami Hazard Study that applied to the Diablo Canyon site. Within the scope of the CNWRA review of the Diablo Canyon ISFSI application, a CNWRA contractor, Dr. Robert Sewell, developed a draft report (the "Sewell Report") on the potential for landslide tsunamis impacting the site. The report postulated wave elevations from potential landslide tsunami scenarios that could exceed the current licensing basis tsunami height for Diablo Canyon.
CNWRA did not endorse Dr. Sewall's work, but did transmit the report to the NRC to inform the NRC of developments in the landslide generated tsunami area of study. The Sewell Report was reviewed by the Seismic Issues Technical Advisory Group (SITAG) in the NRC's Office of Research. In November 2005, the SITAG review concluded that the tsunami scenarios contained in the Sewell Report were based on rudimentary modeling with little geologic and geotechnical data. SITAG further concluded that the study should not be used in any licensing actions.
In February 2006, the Office of Nuclear Reactor Regulation's (NRR's) Division of Engineering terminated further consideration of the Sewell Report, based on NRC participation in other cooperative government reviews of tsunami hazards under the President's Office of Science and Technology Policy (OTSP). NRR concluded that the OTSP effort would provide a more technically credible forum to broaden the NRC's understanding of tsunamis and inform efforts to reassess the tsunami design criteria in the Standard Review Plan.
The design basis tsunami for DCPP considers distantly-generated tsunamis and locally-generated tsunamis. The design basis tsunami is the greater of these tsunamis and is 34.6 feet. Additionally, DCPP sits atop a coastal bluff, 85 feet above sea level, decreasing its vulnerability to a tsunami hazard.
The intake structure auxiliary salt water pump room vents are extended with steel snorkels to prevent seawater ingestion due to splash-up during the design flood event and is thus ensured of operation during extreme tsunami drawdown and combined tsunami and storm wave conditions. The only safety-related system that has components within the projected sea wave zone is the auxiliary salt water system. The auxiliary salt water pump motors are housed in watertight compartments within the intake structure. These compartments are designed for a combination tsunami-storm wave activity to elevation +48 feet MLLW (+45.4 feet MSL). The massive concrete intake structure ensures that the pumps remain in place and operate during extreme wave events. The intake structure is arranged to provide redundant paths for seawater to the pumps, ensuring a dependable supply of seawater.
A 2011 staff overview of Diablo Canyon (http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML111290158 )
includes reference to a 2010 PG&E report on updated tsunami hazards (http://peer.berkeley.edu/tsunami/tasks/task-1-tsunami-hazard-analysis/ ). part of an academic review of California tsunami hazard.
Page 36 Ol'l'ICIAL tj8! CULV !!f4Slf1VE INTERNAL INfiOftMA'fleN
Ol'l'ICIAL t,9E ONLY - SENSITl'11E INTERNAL lf4FeRMtlcl'ler4 After identification of the Shoreline fault in 2008, PG&E determined that the tsunami hazard threat from Shoreline is relatively small since it is a strike-slip fault rather than a reverse fault and there is not expected to exceed the design basis. The NRC performed an evaluation of the tsunami hazard and an independent deterministic seismic hazard analysis of the fault based on information provided by the licensee to confirm DCPP's conclusions regarding safe operation.
After the earthquake and tsunami in Japan on March 11 . 2011 , the NRC issued ,n March 2012 a request for information (also known as a 50.54(f) letter) requesting each nuclear power plant to re-evaluate the flooding hazard at their site, including tsunami. This re-evaluation is due from DCPP in March 2015. DCPP was given 3 years to respond due to the technical complexities involved in their re-evaluation.
Key Messages
- The NRC did not publicly release the draft report for two reasons:
- 1. Although the staff considered the report during the licensing of DCPP Independent Spent Fuel Storage Installation (ISFSI), it did not form the basis for any licensing action
- 2. The draft report was considered preliminary and its conclusions based on limited data and methods
- The design basis tsunami for DCPP considers distantly-generated tsunamis and locally-generated tsunamis. The design basis tsunami is the greater of these tsunamis and 34.6 ft.
Additionally, DCPP sits atop a coastal bluff, 85 ft above sea level, decreasing its vulnerability to a tsunami hazard
- The NRG licensed DCPP independent spent fuel storage installation based on its conclusion that the probable maximum tsunami flooding at the proposed ISFSI was adequately addressed by PG&E, based on the licensee's assessment of more recent tsunami information in the area, as well as the much higher elevations of the ISFSI site and transporter route relative to the previously analyzed hazard for the power plant. T his conclusion was reached with full consideration of this report.
- T he NRC is continuing to re-evaluate the tsunami hazard. After the earthquake and tsunami in Japan on March 11, 2011 , the NRC issued in March 2012 a request for information (also known as a 50.54(f) letter) requesting each nuclear power plant to re-evaluate the flooding hazard at their site, including tsunami. This re-evaluation is due from DCPP in March 2015.
DCPP was given 3 years to respond due to the technical complexities involved in their re-evaluation.
- DCPP's ability to withstand large waves and the maximum wave height at the intake structure were determined through extensive and detailed scaled model wave testing. The only safety-related components within the project sea wave zone (auxiliary salt water system) are protected from tsunami effects.
Questions and Answers
- 1. Why did the NRC decide to not release the draft report to the public?
The NRC did not release the report for two reasons. First, although considered during the Page 37 6FFl81AL l;j!E @)Ht'( !EU!lflVE lf4l'EfU4AL IP4FeRMAfleN
eFFl81AL t:JSE eNLY SEf~SITl"f'E lf~lERNAL lf4F6RMJ8cll6f4 licensing of DCPP ISFSI, it did not form the basis for that licensing action. Second, the draft report was considered preliminary and its conclusions based on limited data and methods.
- 2. What has the NRC done to evaluate the report?
The NRC was assisted by experts from the Center for Nuclear Waste. Regulatory Analyses (CNWRA) in performing a comprehensive safety and technical review of PG&E's license application for an ISFSI. The CNWRA, in turn, contracted the services of Dr. Robert Sewell specifically to assess PG&E's application with respect to tsunami hazards.
The NRC and CNWRA concluded that the probable maximum tsunami flooding at the proposed ISFSI was adequately addressed by PG&E, based on PG&E's assessment of more recent tsunami information in the area, and the much higher elevations of the ISFSI site and transporter route relative to the previously analyzed hazard for the power plant.
The CNWRA assessed the information in Dr. Sewell's report upon receiving it in November 2003. The report was forwarded for NRC's consideration in March 2004, after CNWRA had completed its review of the DCPP ISFSI application. Both the principal investigator for the CNWRA, an expert geologist and seismologist, and the NRC determined that the findings in the report were too speculative to be considered in current licensing decisions, but that they might warrant further review by the NRC. In February 2005, the NRC staff initiated further review of the report, consistent with its efforts to assess the December 2004 tsunami in southeast Asia. In May 2005, the NRC directed that a special review of the report be performed by NRC seismic experts. That group reached its preliminary conclusions on Dr.
Sewell's report in November 2005, and completed its evaluation in January 2006.
- 3. Why did it take the NRC group of seismic experts from SITAG so long to review the report?
The NRC group made an initial assessment of the hazard and the credibility of the report and determined that a 6 to 12 month review time frame was appropriate in consideration of NRC's other high priority safety and regulatory issues currently under development. The preliminary assessment was completed in November 2005, with revisions in January 2006.
- 4. Was the concern about the tsunami hazard potential at DCPP related to the December 2004 earthquake and tsunami in Sumatra and the Indian Ocean?
No. The study of the potential tsunami hazard was performed during the licensing of the proposed ISFSI at the DCPP site, prior to the 2004 event in the Indian Ocean. In response to the tsunami in Sumatra and the Indian Ocean, PG&E initiated Its own study of the tsunami threat to DCPP. A 2011. staff overview of Diablo Canyon (http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?AccessionNumber=ML111290158 )
includes reference to a 2010 PG&E report on updated tsunami hazards (http://peer.berkeley.edu/tsunami/tasks/task-1-tsunami-hazard-analysis/ ), part of an academic review of California tsunami hazard.
Following the earthquake and tsunami in Japan on March 11 , 2011, the NRC issued a demand for information letter (also referred to as a 50.54(f) letter) in March 2012 requesting information from each nuclear power plant regarding the current flooding hazard at the site, using the most up-to-date methodologies. DCPP's response to this letter is due March 12, 2015. DCPP was given three years to complete this re-evaluation due to the technical Page 38 err1e1>11t t:JSE 6HL'f w SEHSlflllf IHfffU4AL U4F6ftMAfl6f4
Ol'filelAL t:J9E 6NLY SENSITPt! U4TEfU4AL INf6ftMAfl0'4 complexities involved at their site.
- 5. Are coastal nuclear facilities safe today from the tsunami threat?
Yes, the coastal nuclear facilities are safe from the threat of tsunamis. The NRC has licensed a number of nuclear facilities on the US Pacific, Atlantic, and Gulf coasts. These facilities include commercial nuclear reactors, 1SFSl's, and research and test reactors (RTR's). The NRC has determined that public health and safety continue to be maintained for these facilities.
The NRC design philosophy for natural phenomena hazards, such as tsunamis, is based on consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area with sufficient margin for limited accuracy, quantity, and period of time for which the historical data have been accumulated. Existing nuclear facilities were licensed consistent with this design philosophy.
In general, facilities located along the Pacific coastline are more likely to be impacted by tsunamis due to the more frequent occurrence of large earthquakes along the margins of the Pacific Ocean. Deep ocean trenches off the coasts of Alaska, the Kuril Islands, Japan, and South America are well known for their large earthquakes and as potential sources for Pacific-wide tsunamis. The most recent damaging tsunami along the Pacific coast was caused by the 1964 magnitude 9.2 Alaskan earthquake with a wave height of 21 ft recorded in Crescent City, far from DCPP. Tsunamis generated by local sources, such as submarine landslides, also have the potential to impact coastal sites. The design of nuclear facilities along the Pacific coast was based on historical tsunami information and considered both local and distant tsunami sources as well as local onshore and offshore topography. Hence the facilities have been designed for the largest recorded tsunami effect with additional safety margins.
Therefore the NRC staff believes that there continues to be adequate protection of public health and safety from the tsunami threat to nuclear facilities on the Pacific coastline.
The design basis tsunami for OCPP considers distantly-generated tsunamis and locally-generated tsunamis. The design basis tsunami is the greater of these tsunamis and 34.6 ft.
Additionally, DCPP sits atop a coastal bluff, 85 ft above sea level, decreasing its vulnerability to a tsunami hazard. DCPP's ability to withstand large waves and the maximum wave height at the intake structure were determined through extensive and detailed scaled model wave testing. The only safety-related components within the project sea wave zone (auxiliary salt water system) are protected from tsunami effects.
- 6. Has NRC assessed the potential impact of a tsunami, as predicted by Dr. Sewell, on the DCPP and public safety?
The NRC's assessment of potential tsunami hazard is ongoing and the DCPP response to the 50.54(f) letter is due March 2015. However, the NRG has concluded that the tsunami scenarios described by Dr. Sewell in the report are based on preliminary data and analysis and should not be used as a basis for any licensing action. NRC continues to evaluate the potential tsunami hazard for coastal nuclear facilities to ensure the most up to date scientific information is assessed and properly considered.
Page 39 6fflelAL t:J!E 6f4LY ' !Ef4!1Tl't'E lf4,EfU4AL lf4F6f'MAfl6f4
6 1'fllCIAL t:ISE 6NLY Sl!f4Slf l7t'E UH'ERNAL lf4F6RMAl'l6N
- 7. What is the NRC doing to address any generic implications for coastal sites other than DCPP?
Following the March 11 , 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami.
The NRC used criteria to prioritize each site's response due date , ranging from 2013 to 2015. Once the NRC receives the response, experts will evaluate the data to determine if additional action is required.
- 8. Has NRC discussed the results of their review of the report with Dr. Sewell and has he responded to NRC's comments?
The NRC has discussed the findings with the NRC's contractor CNWRA, who subcontracted the study to Dr. Sewell.
- 9. If the NRC was dissatisfied with the draft report it received from Dr. Sewell, why didn't it return the report to him and require he make the changes necessary to address the staffs concerns?
After the SITAG's findings that the report's conclusions were based on limited data and methods, the NRC determined that it would be more effective to spend its resources participating in several ongoing initiatives to reassess tsunami hazards sponsored by NOAA, USGS, and the White House Office of Science and Technology Policy, rather than further reviewing or revising Dr. Sewell's report.
Following the March 11, 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami.
The NRC used criteria to prioritize each site's response due date, ranging from 2013 to 2015. Once the NRC receives the response, experts will evaluate the data to determine if additional action is required.
- 10. What actions has the NRC taken to ensure it is correct in addressing the areas it used to discount Dr. Sewell's report?
A 2011 staff overview of Diablo Canyon (http://adamswebsearch2.nrc.gov/webSearch2/main.jsp?Access1onNumber=ML111290158 }
includes reference to a 2010 PG&E report on updated tsunami hazards (http://peer.berkeley.edu/tsunami/tasks/task-1-tsunami-hazard-analysis/ ), part of an academic review of California tsunami hazard.
Following the March 11 , 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami.
This re-evaluation must be completed using current methodologies and data. Therefore, the re-evaluation, when received in March 2015, will address these areas. The NRC will then review and evaluate this response and determine what, if any, actions are needed.
11 . How has the tsunami hazard been changed based on the identification of the Shoreline fault?
After identification of the Shoreline fault in 2008, PG&E determined that the tsunami hazard threat from Shoreline Is relatively small since it is a strike-slip fault rather than a reverse fault Page 40 8FFl81AL ~8f 8HLV 8f'4811fl'lf IH1fffU4AL H4F8ftMA1fl8H
err1e 1At tJSE 614LY 9Ef491'flVE lf4'ffffNAL lf4fi6ffMAfleN and there is not expected to exceed the design basis. The NRC performed an evaluation of the tsunami hazard and an independent deterministic seismic hazard analysis of the fault based on information provided by the licensee to confirm DCPP's conclusions regarding safe operation.
- 12. Why 'hasn't anything been done w ith this report post-Fukushima?
After the SITAG's findings that the report's conclusions were based on limited data and methods, the NRC determined that the report should not be used as a basis for any licensing action.
However,. following the March 11, 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami. This re-evaluation must be completed using current methodologies and data.
Therefore, the re-evaluation, when received in March 2015, will address these areas. The NRC will then review and evaluate this response and determine what, if any, actions are needed.
Page 4 1
el'l'lelAL tJ!! eHLY - !EN91'flVE IN'fEftNAL lf~F6ftMA'fl6N Non-concurrence and DPO Questions Refer to "Communications Plan - Diablo Canyon Power Plant Topics of Interest Differing Professional Opinion and Appeal" for most current information.
NOTE: General FAQs on the DPO Program are included on the DPO Web site (look under Employee Resources-Employee Concerns.
No. The former DCPP SRI was not reassigned. He applied for an instructor position in his area of expertise at the NRC's technical training center in Chattanooga, TN , at about the time he submitted his non-concurrence in accordance with the Non-Concurrence Process described in MD 10.158. He was competitively selected for this sought-after position, and reported to his new assignment in September 2012. Resident inspector assignments are limited to 7 years to ensure objectivity. It is common for resident inspectors to apply for their next job when a desirable position comes open.
- 2. When were the non-concurrences filed?
Two non-concurrences were filed by the DCPP SRI.
11/7/11 . The DCPP SRI submitted NCP 2011-103. on inspection report 05000275; 323/201104.
1/26/12. The DCPP SRI submitted NCP 2012-01 , on inspection report 05000275; 323/201105.
- 3. What were the non-concurrences?
Both non-concurrences involve the same subject; regulatory actions in response to the discovery of the Shoreline Fault.
NCP 2011-103 was filed by the DCPP SRI on the basis that no violation was issued (as he had submitted in the draft report) related to operability evaluation of the Shoreline fault in Report 2011-04. NCP 2011-103 was dispositioned finalizing the violation in IR 2011 -05 issued on 2/14/12. (The employee requested that the NCP be non-public.)
NCP 2012-01 was filed by the DCPP SRI because the SRI believed the violation In NRC IR 2011-05 should be for an inadequate operability evaluation of the Shoreline Fault rather than not doing an operability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault. NCP 2012-01was discussed with NRC stakeholders representing NRR/DE, NRR/OORL, RIV, and RES. NCP 2012-01 was dispositioned as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (interim) operability evaluation in June 2011 . Additionally, the offices involved in NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the 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.
Page 42 OPPlellcL 119! ONLY 9!N91Tl't'! INT!fU4AL U4JJOJtMATIOH
OffletAL tJSE 6NLY - SENSITl't'E lf4lEftNAL lf4f6ftMAll6N However, by 3Q/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event. (The employee supported public release of the NCP ADAMS ML121A173.)
- 4. When was the DPO filed?
July 18, 2013. The former DCPP SRI filed Differing Professional Opinion (DPO) 2013-02 associated with the regulatory response following the discovery of the Shoreline Fault.
NRC employees are encouraged to file a DPO if they believe an agency decision is in error.
The DPO process is in keeping with the agency's open and collaborative working environment.
- 5. What is the DPO?
DPO 2013-02 restated the issues presented in NCP 2012-01 and added a concern that a license amendment was needed incorporate the shoreline fault into Diablo Canyon's FSAR as described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults.
- 6. What is the status of the DPO?
A decision on the DPO was issued by the Office Director for NRR on May 29, 2014 consistent with the NRC's process included in MD 10.159. The DPO submitter appealed this decision to the EDO on June 23, 2014, and the appeal was thoroughly evaluated by the EDO and decision on the appeal was rendered on September 9, 2014.
As part of the agency's open and collaborative work environment, the NRC has established the DPO program as a means for employees to have their concerns reviewed by high level managers. The DPO Program is a formal process that allows all employees and contractors to have their differing views on established. mission-related issues considered by the highest level managers in their organizations, i.e., Office Directors and Regional Administrators. The process also provides managers with an independent, three-person review of the issue (one person chosen by the employee). After a decision is issued to an employee, he or she may appeal the decision to the Executive Director for Operations (or the Chairman for those offices reporting to the Commission).
- 7. Will the decision regarding the DPO be made public?
The NRC supports openness and will include a summary of the disposition of the DPO in the Commission's Weekly Information Report included on the NRC Web site (see Commission Documents under the Document Collections in the NRC Library). The DPO submitter has been contacted regarding the EDO's decision on the DPO appeal and has communicated support for the public release of the DPO Case File (with appropriate redactions). The DPO Case File should be publicly available within a few days of the EDO's DPO appeal decision.
Page43 8f'Fl81AL ~8E 8f4LV w S!l4Sl?l'O'I! lf4Tl!f'!HAL lf41'0~MA'l'ION
erir1e1At tl6E 8f4LY 8!f48ITIVE IH?EfUJAL lf4FeRMAllefJ No. As noted in Q&A #1 above, the SRI applied for and was selected to a highly sought instructor position at the NRC's Technical Training Center. The NRC does not tolerate retaliation for engaging in the NCP or the DPO Program and both MDs reiterate this policy and direct employees to resources in the event they believe that they have been retaliated against.
- 9. Would the OPO panel's conclusions or the DPO appeal decision change based on the new seismic information found in the State of California report?
PG&E, the licensee for Diablo Canyon, is providing a report to the State of California that includes the results of its most recent evaluation of the seismic hazards for the Diablo Canyon facility. The NRC understands that the report will be provided to the State of California on September 10, 2014, and that a copy will be provided to the NRC as well.
Prior to performing a detailed review of this report, the NRC is not able to ascertain whether the new seismic information contained in the report would change the DPO panel's conclusions or the DPO appeal decfsion. The NRC understands that PG&E plans to incorporate the findings from this report into their ongoing probabilistic seismic hazards analysis required by the NRC Post-Fukushima task force recommendations that are due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP. In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the ground motions resulting from the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.
NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event.
The NRC staff will review the new Information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.
- 10. Timeline of Events associated with the NCPs and DPO:
11/7/11 DCPP SRI submits Non-Concurrence NCP 2011-103. The SRI non-concurs on Inspection Report 05000275: 323/2011004 because the proposed violation involving the Shoreline Fault operability evaluation was not issued.
11/9/11 NCP 2011-103 is dispositioned by Region IV. The operability evaluation issue was documented as an Unresolved Item in Inspection Report 05000275; 323/2011002 and dispositioned as a violation in Inspection Report 05000275: 323/2011005.
4Q/2011 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.
Page 44 6fflelAL tJ!E er~LY 9Ef~91fl'IE lf~TEfU4AL lf~f6ftMATl6f~
OFFl81AL ij8E 8ULV 8Eff81"'1E lfffEf04AL INF6ftMAl'l614 1/26/12 DCPP SRI submits NCP 2012-01, non-concurring on inspection report 05000275; 323/201105. The SRI believed the violation in NRC Report 2011-05 should be for an inadequate operability evaluation of the Shoreline Fault rather than not doing an operability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault. (ADAMS Accession Number ML12151A173).
Feb 2012 DCPP SRI applies for instructor position vacancy at the Technical Training Center (TTC).
Feb 13, 2012 Response to NCP 2012-01 issued. NCP 2012-01 was discussed with NRC stakeholders representing NRR/DE, NRR/DORL, RIV, and RES. NCP 2012-01 was dispositioned as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (interim) operability evaluation in June 2011 . Additionally, the offices involved in NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the time of Report 2011-05 issuance it was expected that the requirements and methods would be addressed in a License Amendment Request that was under consideration. However, by 30/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event. (ADAMS Accession Number ML12151A173).
02/12-07/13 RIV management frequently encourages the DCPP SRI to submit a Differing Professional Opinion (DPO) during several discussions involving seismic issues.
May 2012 DCPP SRI is selected for instructor position at the Technical Training Center (TTC).
Sept 2012 The (now former) DCPP SRI reports to the TTC as a training instructor.
7/18/13 Former SRI submits a DPO regarding the agency's regulatory actions associated with the Shoreline Fault.
8/2/13 DPO 2013-002 was assigned to NRR for an independent review.
9/3/13 Director, NRR establishes a DPO 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 DPO Panel completes its review of DPO 2013-002 and submits its report to the Director, NRR.
Page 45 8PPl81AL 1:19E 6NLV !EN!lfl'O'E INfEftNAL INFOftMATION
615 Flel~L ~9!!! 6NLY 9!N91Tl't1E IN'f!RNil<L INF6RMAfl6f4 5/29/ 14 Director, NRR issues his decision on DPO 2013-002 by memo to the former DCPP SRI.
6/23/ 14 Employee submits DPO appeal.
6/27/14 Director. NRR provided Statement of Views on contested issues in appeal.
7/7/14 DPO appeal package provided to EDO for disposition and decision.
8/25/14 Associated Press article released discussing the DPO.
9/10/14 EDO renders final decision regarding DPO. DPO submitter agrees to public release of DPO.
Page 46 6FF1e1iect ~eE 6P4LY - eEr49i,1ve 114T!ftf4AL IHl'eftMATlel4
OfifilCIAL t:J!E eNLV - 9Ef491'flVE m,EfUIAL IUF@RMAfl6N RIS 2005-2<0, 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, and (5) request the voluntary participation of the nuclear industry in NRG-sponsored pilot programs or the voluntary submittal of information. A RIS does not communicate new or revised NRC requirements.
- 2. How does the RIS apply to failures to meet design requirements (e.g.; General Design Criteria (GDC))?
RIS 2013-005 restated the NRC's position regarding operability evaluations for 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 licensee have a nonconformance with requirements and still operate?
Yes. RIS 2005-20, Revision 1, "Revision to NRC Inspection Manual Part 9900 Technical Guidance, 'Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety,"' describes the actions licensees must take to evaluate nonconforming conditions.
For the Shoreline fault. the NRC issued a violation for Diablo Canyon's failure to perform an operability evaluation. The licensee completed the evaluation and the NRC concluded that the guidance in RIS 2005-20 had been met. In particular:
The use of the LTSP was appropriate to characterize and bound t he faults as part of the operability evaluation process. Additionally, 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 47 8FFlelAL tl8E 8NLY w 9Ef491'fl't1E INTl!!fU4AL INl'e"-MATION
Enforcement Questions
- 1. Did the NRC issue any violations involving the Shoreline Fault?
Yes. Inspection Report 2011 -05 documented a violation for the failure to perform an operability evaluation of the Shoreline fault.
- 2. What corrective actions did Diablo Canyon take in response to the violation?
Diablo Canyon completed an operability evaluation for the Shoreline fault which met the guidance in RIS 2005-020. Diablo 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 48 e,,1e1,;t ~,1 el4L'f 9EU9111¥1!! lftfl!RUAL IUPeRMATl~,rJ
ernelAL tJSE 6NLY 8Ef48ITIVE lftl'fiftN,'.L INF6RMATl6N 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 2, 11 "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 capability to perform their safety functions. Criterion 2 also stated that design bases for these structures, systems, and components shall reflect:
- Appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and 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,"
for establishing the three DCPP design basis earthquakes:
- Design earthquake (Operating Basis Earthquake) - That earthquake which could reasonably be expected to affect the plant site during the operating life of the plant; it is that earthquake which produces the vibratory ground motion for which those features of the nuclear power plant necessary for continued operation without undue risk to the health and safety of the public are designed to remain functional.
- Double design earthquake (Safe Shutdown Earthquake) - That earthquake based upon an evaluation of the maximum earthquake potential which produces the maximum vibratory ground motion for which certain structures, systems, and components are designed to remain functional.
Hosgri Event - a special postulated earthquake applicable only to DCPP.
[See Q&As for "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. NRR/DORL Page 49 8FFl81AL ~8E 6f4LV w SEf4Slfl'l'E IN:Y:EfU4AL INF6ftMA'fl6N
8PPlelAL ~8E 8Hllf 8!U81TIV! IHlffUJAL lfJF6RMATl6N subsequently confirmed that pre-application meetings in mid-2011 had not included discussion of the HE as the SSE.
- 3. Did the NRC accept PG&E's amendment request for the Shoreline Fault?
PG&E withdrew the amendment request on October 25, 2012.
During the NRC acceptance review the NRC noted that PG&E had not submitted all of the information needed to review the Hosgri method against the Standard Review Plan (SRP) requirements.
- 4. Why was the LAR withdrawn?
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 clarify the licensing basis by revising safe shutdown earthquake. PG&E requested that the NRC designate the Hosgri event as the safe shutdown earthquake at Diablo Canyon.
During the NRC review of the LAR, the NRC required that the Hosgri fault be assessed against the acceptance criteria for the DOE. Since PG&E had not performed or submitted such an evaluation, the LAR was not accepted and Diablo Canyon withdrew the LAR.
On March 12, 2012, the NRC issued a 50.54(f) letter to all power reactor licensees requiring a seismic hazard re-evaluation . The NRC specifi.cally required PG&E to compare the results of this re-evaluation to the DOE. The NRC expects that the seismic re-evaluation at Diablo Canyon will yield results very similar to the LTSP results, because the methods and data are similar.
- 5. Did the NRC allow PG&E to bypass Diablo 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 California 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 DOE are separate methods for evaluating seismic information. As a result of the 50.54(f) letter review the NRC expects that Diablo Canyon will select a single method consistent with the already NRC reviewed 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 50 e,,,e1At tj8@ eutv 8EH81,r1E IHlffU4AL INF6RMJfcTler*
- 7. When will Diablo 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 51 Ol'l'ICIAL tJ!I! ONLY -- !EN!l'fl'IE lf4'EfU4At IUPeRMATI014
OfflCIAt: tf8E 8fU:Y 81!U8ITIVI! IHTERHAL 1Hf8RMATl8f4 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?
Diablo Canyon is being required to reevaluate the seismic hazards at their site. This reevaluation uses both modern methods and updated information. Additionally, Diablo Canyon is required to provide an assessment of the plant's ability to cope with the reevaluated hazard. The NRC will use this information to determine if additional regulatory action is appropriate.
- 3. When is Diablo required to provide a response?
No later than March 2015.
- 4. What actions will be required following the NRC's review of Diablo's response?
For facilities in the Western United States, within approximately 30 days of receipt of the last submittal, the NRC will determine the acceptability of the licensee's 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 Diablo Canyon already have a Seismic PRA? If so, why is their completion date April 2018?
The March 12, 2012 orders (http://pbadupws.nrc.gov/docs/ML 1205/ML12053A340.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 52 8fFl81AL tf8E 8HLY 8EU81TIVE IUTERHAL U~f61i!MAfl6N
Ofifi1e,,_t tl3E 6NLY - 9EN31Tl'IE lf4lERftAL INFe~MA'fl6N
- 6. Why is it expected to take several years to complete the review?
The expectation that the seismic issues will take some years to resolve at DCPP is not a safety concern. The NRC has followed the seismic re-evaluation process since the beginning at DCPP. The NRC will continue to evaluate seismic data to ensure our understanding of the seismic hazard Is informed and that there is no new challenge to safety.
By following the rigorous NRG-approved process, which will take several years. It is expected that PG&E will produce a single seismic hazard analysis for NRC review using the latest available methods. If approved by the NRC, these results can then be used to clarify the Diablo Canyon seismic licensing basis.
10 CFR 100.23, paragraphs (c) and (d) require that the geological, seismological, and engineering characteristics of a site and its environs be investigated in sufficient scope and detail to permit an adequate evaluation of the Safe Shutdown Earthquake (SSE) Ground Motion for the site. In addition, 10 CFR 100.23, paragraph (d)(1), "Determination of the Safe Shutdown Earthquake Ground Motion, requires that uncertainty inherent in estimates of the SSE be addressed through an appropriate analysis such as a probabilistic seismic hazard analysis (PSHA).
In response to these requirements, in 1997, the NRC published NUREG/CR-6372, "Recommendations for Probabilistic Seismic Hazard Analysis: Guidance on Uncertainty and the Use of Experts." Written by the Senior Seismic Hazard Analysis Committee (SSHAC),
the NUREG provides guidance regarding the manner in which the uncertainties in PSHA should be addressed using expert judgment.
The SSHAC Level 3 process uses a panel of independent experts to study all available seismic data, identify the need for new data, and use the latest seismic analysis tools to develop a Seismic Source Characterization (SSC) and Ground Motion Characterization (GMC) in creating a risk-informed seismic hazard estimate (i.e. the PSHA). The NRC was intimately involved in the development of this formal methodology. This is a new method that did not exist at the time of licensing for the current generation of nuclear power plants, but is now required for applicants seeking a new reactor license.
- 8. Why is the NRC giving the Western U.S. plants more time (than the Central and Eastern U.S.) to complete their seismic reevaluation when the seismic 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 perform a seismic hazard reevaluation) takes 3 - 4 years.
The SS'HAC study produces the seismic hazard models that are needed to perform the seismic reevaluation. When Fukushima occurred, the Central and Eastern US plants (CEUS) were in the middle of conducting a SSHAC Level 3 study sponsored by the NRC, DOE, and EPRI, so when the 50.54(f) letters went out the CEUS already had the models they needed to perform the seismic reevaluation, which is why we gave them a shorter period of time to respond to the 50.54(f) letter.
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Ol'P'ICIAL t:l!E er.LY scr*!l'Fl\'E n*=rERNAL INFORMAifleP*
The Western U.S. does not have a regional model like the CEUS - so the NRC required all Western U.S. plants to complet,e a SSHAC Level 3 study in order to develop site-specific seismic hazard models. The Western U.S. plants were given three* years to complete the SSHAC study and their seismic reevaluations. This is a significant amount of work to complete in three years and is realistically the fastest timeline that the Western U.S. plants would be able to adhere to while still following the rigorous requirements of a SSHAC Level 3 study.
- 9. Why does the NRC believe 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 regulatory approach and the current plant capabilities, the sequence of events which occurred at the Fukushima accident are unlikely to occur in the United States. While the NRC concluded that the NTTF recommendations would enhance safety, the staff determined that none of the NTTF report findings identified an imminent hazard to the public health and safety. As such, continued safe operation of nuclear power plants is warranted while the safety improvements required by the orders are implemented.
- 10. Why did the NRC approve industry's request for a six month extension in submitting the Central and Eastern U.S. seismic reevaluations?
The seismic hazard reevaluations for the Central and Eastern U.S. (CEUS) were originally due 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 will be fed into the SSHAC study and hazard re-evaluation as part of PG&E's response to the 50.54(1) letter.
Page 54
- 12. In an October 12, 2012, letter to Diablo Canyon, the NRC states that "The NRC recognizes that using the DOE as the basis of comparison will most likely result in the Shoreline fault and the Hosgri earthquake being reported as having greater ground motion than the SSE."
Is it accurate to state that this means that the licensee has not shown that it meets the requirements in its license that the reactor and its safety systems be capable of withstanding the ground shaking associated with the DOE/SSE earthquake using the methods specified in the SSE/DOE?
No. The quoted statement is referring to a comparison the NRC requested licensees make in 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 DOE 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 NRG-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 DOE, 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 DOE, 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 independently 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.
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eFFlelJlct t:ISE eNt'f 8Em8"l'IE IUfERU.flL IUF6RMzC:Tl6H
- 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 you better characterize the ground motions (shaking at the site).
Specific new studies being conducted by PG&E for seismic source characterization (most have already occurred):
- Onshore 20/30 Seismic Reflection Surveys
- Onshore Geologic Mapping
- Onshore Light Detection and Ranging (UDAR) Mapping (topographic mapping)
- Offshore Multi Beam Echo Sounds (MSES) Mapping (of the sea floor)
- Offshore 20/30 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 30 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 30 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 resources. 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.
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Non-Responsive Record Page 57 6Ffl9h\L ~8E 8ULV 81!!rt81TI'(! U.T!fU4AL lf4f'e"MJ1tfl6f4
6FFlelAL tJSE 6NLY w 9ff491fl'JE IWfEUU4>1,l lf4f!6RMATl6H Non-Responsive Record Page 58 eFFlel~L tJSE 6NLY - SENSITlttE lfffEfU4AL lf4f8f'MAllON
eFFlelAL t:ISE 6NLY - SENSITIVE IN'fEftNAL IHl'O"MATIOr*
Non-Responsive Record Page 59 8PPl81AL tl9! er4t'I' SEf4Sl'fl'O'E U4'fE"f4AL INl'O"-MATIOl4
Ol'l'lelAL t:J!E er4LV - 9Et491TIVE INTERHAL IHF8RM~'fl8U DCPP Licensing Basis Verification Proiect (LBVP)
[From Licensee Status Briefing 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 objective 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 deficiencies in these systems.
- 8. Provide an updated tool to aid in operability determinations.
Who Is Involved with the LBVP?
PG&E Oversight with work done by Chicago Bridge and Iron (CB&I - formerly Shaw, Stone & Webster). partnered with Westinghouse (DCPP NSSS Supplier). CB&I has the lead. Westinghouse is responsible for various FSAR sections including Accident Analysis Chapter 15, RCS, RHR, Reactor, and others.
- Phase I (February - October 2010)
Phase I of the LBVP reviewed and evaluated design and analysis changes to the Component Cooling Water (CCW) and Auxiliary Feedwater (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 60
~"!")lf'~f'lllllf'!C~IA~L~~~8~E!!o"1@i!tNf4t,,t*""t~ 811tE1iitf~48~1~T~l'v1111!1ii!fflf~4TN!lf"ttfilt'l4A~L""'"lfi!tj4,li48"1~~M~Ap11T1Hl6111tifN4- -
findings, lessons learned, and recommendations, all of which was addressed in the Phase I summary Report.
Licensing 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 with licensing basis requirements . LBR reviewed internally by PG&E and by an Independent Review Board.
System Reviews Following the LBR, validate the licensing basis requirements and FSAR implementation into plant documents (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 NRC.
Current schedule DCPP committed to the NRC to complete the LBVP by 12/31/2015. Completion clarified in document DCL-12-003 as follows: Completion of LBVP Phase II includes completion of applicable licensing basis reviews, system reviews, component design basis report reviews, electronic database upgrades, implementation of new current licensing basis search tools, and correction of licensing basis deficiencies that do not require prior NRC approval. In addition, completion of LBVP Phase II includes submittal of License Page 61 6ffl81AL ~!f 6HLY !Ef4!1"VE m,EPU4>'ct lf4F6ftMAfl6f4
6fifil1fct ~81! 8ULV 8EH81fl't'E lf4fEfU4AL lf~fi6ftMA'fl6N Amendment Requests (LARs) and initiating design changes. The completion of the design changes and the receipt of approved LARs will extend beyond the completion date of December 31 , 2015.
NRC Conclusions (as of Sept 2013)
- 1. The licensee is performing a good review of their Licensing Basis.
- 2. They are identifying and correcting errors.
- 3. They continue to evaluate and improve the LBVP process
- 4. The process is not perfect. The NRC Is still identifying problems with Licensing Basis Documents and how the licensee implements their licensing basis.
- 5. The Summer 2013 Component Design Basis Inspection (Inspection Report 2013-007) noted a significant improvement in Licensing Basis Documents at the site.
Page 62 e,.fl1e1At t:19! er*tY w 9l!H91TIV! mT!fut:e:t mreftMATION
erne1~t ~8E 8ULV 8EH81Yl't'E lf4,EftNAL INF6ftMATl6f4 Non-Responsive Record Page 63 OFFICIAL tJSE OHLY w SEf4!"1VE lf4fEfU4AL lf4l'0"MAT1SH
OP'filelAL t:ISE ONLY - seNSl'flVE IN'fEffNAL IHF8ffMMl8H Public Cancer Risks Refer to "Communications Plan: Analysis of Cancer Risks in Populations Living Near Nuclear Facilities - Phase 2 Pilot Studies" (ML13274A664), maintained by RES, for the most current information.
The following 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 Regulatory Commission (NRC) asked the National Academy of Sciences (NAS) to conduct this study now?
- 03. Which seven sites will be included in the pilot study?
- 04. Which additional nuclear facilities could be 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?
- 014. 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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Ol'l'lelAL t:191: er.tv - 91:H!ITl't'I: INTl:RPJAL U4f6RMA118H Emergency Preparedness Concerns
- NOTE - The following is predecisional, non-public information, with the exception of the Unresolved Item that was included in the 4Q/2013 Resident Inspector Report which initially described this potential issue.
Background
In November 2005, Diablo Canyon Power Plant revised its emergency plan without prior NRC approval. This change removed a table used 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 prior to implementation. This issue is currently being evaluated using our significance determination process and through traditional enforcement.
Key Messages - Predecisional/nonpubllc
- The licensee made a change to an emergency plan procedure that inadvertently removed the ocean from a table that provided guidance on making protective action recommendations.
- The individuals responsible for making protective action recommendations are highly trained and qualified individuals (they are senior reactor operators) so they have to go through a rigorous training and evaluation process to obtain a license and must undergo continuing training and periodic evaluation to maintain the license.
- The licensee recommends protective actions to the state and local officials, who make the actual call about what protective actions to take.
- The county had procedures in place that included evaluating the ocean for evacuation.
- Therefore, at no time was the public going to be allowed to stay in an area that had the potential for radioactivity if an event had occurred.
- This is a preliminary determination, is still undergoing evaluation through our processes, and is subject to change upon further review.
Questions and Answers
""UNDER DEVELOPMENT**
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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E LAMAR BLVD ARLINGTON, TX 76011 -451 1 September 11 , 2014 MEMORANDUM TO: Wayne Walker. Chief Division of Reactor Projects. Branch A FROM: Multiple Addressees, as listed below
SUBJECT:
COMMUNICATIONS PLAN - DIABLO CANYON POWER PLANT TOPICS OF INTEREST The purpose of this memo is to transmit and request comments/concurrence on the enclosed Communications Plan for Diablo Canyon Power Plant (DCPP). The enclosed document is based on several iterations of informal communication plans, Q&A documents, and responses to congressional questions developed primarily by Region IV, NRR, OPA, and OCA over the last several years.
This communication plan describes the methods and resources that NRC staff will use to communicate with internal and external stakeholders regarding the DCPP seismic history and ongoing seismic evaluations being conducted in response to the Japan Lessons Learned Near-Term Task Force recommendations. Additionally, as applicable to current issues of interest to DCPP stakeholders, this communications plan integrates key messages related to spent fuel/dry cask storage and waste confidence issues (primarily by referencing other active communication plans).
This revision also incorporates Q&As for the most recent issues of concern including the licensee's AB-1632 Report to the State of California and the "Sewell Report."
Once finalized, the Communications Plan will be posted on the OEDO Communications website for use by the communications team and more broadly across the agency as necessary.
Most of those on concurrence have each provided significant input to iterations of this document (or documents from which this Plan was developed). As such, we are requesting your review/comments/concurrence in the next few days (due by COB, Monday, September 15). Please forward your comments/concurrence on the document to Theresa Buchanan (Theresa.Buchanan@nrc.gov and/or ph: (817) 200-1 503) of my staff.
The concurrence block noted on the next page will be used to document your concurrence on the enclosed Communications Plan.
Enclosure:
As stated
Multiple Addressees The individuals whose concurrence is requested for this Communications Plan are:
T. Pruett, Acting Division Director, RIV/DRP M. Hay, Acting Deputy Division Director, RIV/DRP W. Walker, Chief, RIV/DRP/RPB-A T. Hipschman, Sr. Resident Inspector, RIV/DRP/RPB-A L. Uselding, RIV/OPA W. Maier, RIV/RSLO M. Williams, RIV/DRS/EB1 E. Oesterle, Acting Chief, NRR/DORULPL-IV-1 B. Singal, Senior Project Manager, NRR/DORL/LPL-IV-1 A. Moreno, OCA RIV/DRP/A RIV/DRP/A RIV/DRP/A RIV/DRP/A RIV/OPA RAlexander TBuchanan THipschman WWalker LUselding 09/ /2014 09/ /2014 I /2014 I /2014 I /201 4 RIV/RSLO RIV/DRS/EB1 NRR/DORL/LPL-IV- NRR/DORL/LPL-IV- NRR/JLD 1 1 WMaier MWilliams BSingal EOesterle JSebrosky I /2014 I /2014 I /2014 I /2014 I /2014 OCA RIV/DRP RIV/DRP AMoreno MHay TPruett I /2014 I /2014 I /2014 OFFICIAL RECORD COPY
eFFlelAL tlSE 8HL¥ 8EHS1T1't'E U4'Eftf4AL lf4F8ftM,tcfl8f4 UPDATED: 09/03/2014 3:33 PM Communications Plan -
Diablo Canyon 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 continuously evaluated for the need to update key messages, and a full review/update will be evaluated approximately once per calendar quarter.
NOTE: Although this communication plan is marked as OUO-SII, all sections marked as "Key Messages" and "Questions and Answers'" are releasable to the public.
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 acceleration for a Safe Shutdown Earthquake (SSE) in its construction permit applications in 1967 and 1968. (Note: PG&E uses the terms Design Earthquake and Double Design Earthquake when referring to the OBE and SSE, respectively.)
After construction permits were issued, during the Atomic Energy Commission's and NRC's review of information submitted to support operating licenses, new information became available as a result of offshore seismic surveys. These surveys identified the Hosgri fault, approximately 3.5 miles offshore of the 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 DCPP. PG&E was also required to evaluate the plant's response to ground motion of 0.75g, a value believed to bound the expected ground motion resulting from an earthquake occurring along the Hosgri fault. PG&E established its Long Term Seismic Program (LTSP) to guide additional seismic evaluations and updated the Final Safety Analysis Report to incorporate the results of its LTSP study. PG&E concluded that OCPP Units 1 and 2 could withstand ground motion up to 0.75 g.
In 2008, PG&E notified the NRC about the newly discovered Shoreline fault zone. PG&E completed characterization of the Shoreline and other local earthquake faults in January 2011 .
Page 1 eFFl61AL tJ8E er4L'( w 8fl491fl\lE U4fEfU4AL U4Fe"MATlet4
6fflelAL t:JSE 6NLY SEf~Sl'fl't'I!! U4,!ftl4lllt 114FeRMATlel4 On October 20, 2011 , PG&E submitted a license amendment request for approval to revise the current licensing basis, as described in the Updated Final Safety Analysis Report and Technical Specifications, to provide requirements for the actions, evaluations, and reports necessary when PG&E identifies new seismic information relevant to the design and operation of DCPP.
The NRC completed Its independent review of the new seismic information and documented the results in a Research Information Letter (RIL) issued on October 10, 2012, which was subsequently communicated to PG&E two days later. NRC concluded that maximum ground motion at the site from a seismic event along 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(f) request for information provides a process for assessing new seismic information at Diablo Canyon and rendered the portion of the October 20, 2011 , PG&E license amendment in this area unnecessary. In a letter dated October 25, 2012, PG&E provided the basis for withdrawing its October 20, 2011 , license amendment request. The staff accepted the withdrawal of the license amendment in a letter dated October 31 , 2012.
PG&E is currently performing a seismic hazard update through a SSHAC Level 3 process. The resulting site-specific probabilistic seismic hazard analysis will be used to respond to the NRC's March 2012 50.54(f) request for information letter.
Key Messages
- Although the original OBE and SSE values of 0.2g and 0.4g were specified as part of the design basis (calculation) in 1968, the 0.75g Hosgri event was incorporated in the licensing basis (along with the OBE and SSE) prior to issuance of the DCPP units' operating licenses in 1984 and 1985.
o Upon discovery of the Hosgri fault (1971 ), PG&E reanalyzed and significantly upgraded the structures, systems, and components to accommodate the postulated ground motion values (up to 0.75g) from the Hosgri fault.
o The NRC staff reviewed and 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 Hosgri event). Both the ACRS and ASLB concluded that the revised seismic design basis was appropriately conservative and there was reasonable assurance that both units could be operated at full power without undue risk to the health and safety of the public.
- The NRC performed an independent deterministic analysis of new seismic information provided by PG&E in 2011 relating to the Shoreline fault. NRC's conclusions are Page 2 6ffl@JIAL t:JSE er4LY SENSITl'IE INTERNAL U4f6RM~Tlel4
Of F ICIAE USE 614L, !l!H!iflYE IP4fERNAL INF6RMAfl6H documented in Research Information Letter (RIL) 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.
- 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 1
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 (AB 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 1
See NRC letter, dated March 12, 2012, Issued to all power reactor licensees Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(() Regarding Recommendations 2. 1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident.
(http.Jlpbadupws.nrc.gov/docs/ML 1205/ML12053A340pdQ Page 3 6fflelAL tJSE 614L'f - SEP4Slfl\lE m,EfU4AL IP4f6RMATl8H
methodologies using 2D and 3D mapping. This is different methodology that what was used for the 2011 Shoreline Fault.
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, 2011 Task Interface Agreement (TIA) 2011-010, "Concurrence on Diablo Canyon Seismic Qualification Current Licensing and Design Basis," August 1, 2011 TIA 2012-012, "Revised Response to Task Interface Agreement-Diablo Canyon Seismic Qualification Current Licensing and Design Basis, IA 2011-010 (TIA 2012-012) (TAC NOS.
ME9840 and ME9841)." November 19, 2012 RIL 2012-01 , "Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone," September 19. 2012 (ML121230035)
Page 4
9Ffl81AL tl8E eutv 8EU8"1YE llf,EfU4AL lf4F6ftMA'fl6f4 Non-Public Information Regarding Non-Concurrences & Differing Professional Opinions
Background
The former SRI submitted non-concurrence papers (NCPs) in January 2011 and January 2012, followed by a Differing Professional Opinion (DPO) in July 2013 detailing a disagreement with the NRC about how 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 issued (as he had submitted in the draft report) related to operability evaluation of the Shoreline fault in Inspection Report 2011-04. NCP 2011-103 resulted in finalizing the violation in Inspection Report 2011-05 issued on 2/14/12.
- NCP 2012-01 was filed by the (now former) DCPP 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. The disposition of NCP 2012-01 contained 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 DCPP 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 currently re-evaluating the seismic hazards at all nuclear power plants in the US as part of its response to the accident at the Fukushima Dai-ichi nuclear power plant. DCPP is required to provide its response to the re-evaluation in March 2015.
- In order to clarify the regulatory process in this area, the NRC is committed to revise its formal regulatory guidance for evaluating new information on natural hazards, including new seismic information, as part of its response to the Fukushima accident.
- 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 (submitter). When the process is complete (i.e., when the EDO issues a decision on the DPO appeal), a summary of the disposition will be included in the Commission's Weekly Information Report, included on the NRC Web site (see Commission Documents under the Document Collections in the NRC Library). If the submitter supports public rel,ease, the DPO Case File (with appropriate redactions) will be included.
- The former DCPP SRI applied for and was selected for a highly sought after position within the agency. He was not reassigned.
Page 5 6FFlelietL tfSE 6NLV 8EU81llVE lffTERUAL lftF9RMf,fl@H
6fifilCIAL tl9E eiiu.v Sl!H81T11/I! U4f l!"f4~L INP'OftMATION
- The NRC encourages and welcomes differing opinions and offers several paths for staff for officially document their differing views.
Background Documents
[NON-PUBLI C] Non-concurrence NCP 2011-103 1 dated November 7, 2011 Non-concurrence NCP 2012-01 , dated January 26, 2012 [publically available in ADAMS]
{NON-PUBLIC] Differing Professional Opinion 2013-02, dated July 18, 2013 Page6
eP:Pl81AL ~8f 8HLV 9ff491'flVE lf4'fERN>91L INF6RM>91'fl6N ATTACHMENTS Audience/Stakeholders .................. ............................................................................................ 8 Communication Team .................... ....................................... ..................................................... 9 Communications Tools .............................................................................................................. 10 List of Applicable Acronyms and Abbreviations ........ ................................................................. 13 Timeline of Seismic Issues at DCPP ...................... .. .................................................................14 Specific Q&As Design/Initial Licensing Basis Questions (DE/DDE/Hosgriffsunami).........................................20 Long Term Seismic Program (LTSP) Questions .......... ..... ................................................. ........23 Shoreline Fault Questions ...................................................................... ............ ................. ...... 25 State of California Seismic Report (AB-1632) ...........................................................................29 Los Osos and San Luis Bay Faults ................................. ..........................................................30 Research Information Letter (RIL) Questions .................. .......................................................... 31 "Sewell" Report/ Tsunami Concerns .........................................................................................32 Non-concurrence and DPO Questions ......................................................................................38 RIS 2005-20, 2013-005, and Operability Evaluation Questions ........ ......................................... 42 Enforcement Questions ........................ .....................................................................................43 Current Licensing Questions ............ ........................................................................................ .44 50.54(f) Questions ....................... ............................ ................................................................. 47 Tier 3 Expedited Transfer of Spent Fuel to Dry Cask Storage .................... ....... ........................ 52 DCPP Licensing Basis Verification Project (LBVP) ...................................................................55 Continued Storage Rule (formerly Waste Confidence")........................ .................................... 58 Public Cancer Risks ...... .............. .......................................................... ....... .. ........ ....... ............ 59 Emergency Preparedness Concerns ............................... ............. .............................................60 Page 7 6FFl81>'<L t:19E 8NLY - SENSITIVE lf4fERf4AL lf4F8RM:1:'J'l@f*
6ffleliatt tJSE e,~tY SEHSITl'/E UffERP~AL INf6RMAl'l6N 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 org/)
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-24 1h)
State and local Government agencies, including:
California Governor's Office of Emergency Services, California Public Utilities Commission, California Independent Peer Review Panel (IPRP),
California Energy Commission, and California Coastal Commission.
Industry groups (e.g., Nuclear Energy Institute)
Page 8 6fflelAL t:ISE e,~tY 8EH81TIVE IHfffU4Al lfJfit,RMAflOU
eFF1e1At tteE eNtY w eer49ITIVE U4TERH>>trL INFORM>'.TION 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 Acting Sr. Project Theresa Buchanan R-IV/DRP/RPB-A 817-200-1503 En<:1ineer 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 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORL/LPLIV 301-415-3016 Joseph Sebrosky Senior Project Manager NRR/JLD 301-415-1132 Scott Burnell Public Affairs Officer OPA 301-415-8204 Jenny Weil Congressional Affairs OCA 301-415-1691 Amy Powell Associate Director OCA 301-415-1673 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200- 1267 Elaine Keegan License Renewal NRR/DLR 301-415-8517 Cathy Kanatas Attorney OGC 301 -415-2321 Nick DiFrancesco Japan Lessons Learned JLD 301 -41 5- 11 15 Page 9 eFFlelitcL tf9E er4LY w 9Ef491Tl"t'E lf4TEftP4AL lf4f'6ftMA1'16N
OfflelAL ~9t! eNLY 9EU911fl\FE IUll!RUAL lfJF8RMATl6fJ Communications Tools The communication team may and have used any of the following tools to communicate with our stakeholders:
Internal Briefings The communication team will conduct internal briefings as required to keep internal stakeholders informed of activit1es and messages.
Public Meetings In May 2009, a town hall public meeting was conducted in San Luis Obispo, California, to discuss the Shoreline Fault. In September 2010, a two-day public workshop was conducted in San Luis Obispo, California, to present topics of interest regarding seismic issues. In January 2011 , a public meeting was conducted in San Luis Obispo, 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 DCPP'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 appropriate)
Submitted 50.72 notification with an operability 1 assessment to the NRC PG&E November 21 , 2008 (Event Number: 44675) 2 FAQ 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 10 eFFlelAL tf8E @fJLY 8Ef.81flVE nnEPUUL IUF8RMATl8U
Ol'flCIAL tJSE ONLY !!N!lfl1o'E IN'fEftf4111L lf4FOftMlllfl6f4 Activity / Report I Document Title Lead Office Date
{ADAMS/Reference number, as aooropriate)
The NRC concluded the Action Plan and schedule are reasonably complete and NRR January 5, 2009 5
comprehensive in scope for this study.
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 April 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 April 30, 2009 assessment and a preliminary review of the DORL tsunami hazard by RES.
Complete an operability evaluation of potential 9 PG&E April 30, 2009 Qround deformation Support a town-hall meeting, conducted by NRR, Region IV, in which the Shoreline Fault is 10 NRO, & May 28, 2009 expected 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, 201 O Analysis NRR/ Division of Operating Reactor Licensing 13 (DORL) to submit Research Assistance Request NRR April 29, 2010 for review of Secondary Rupture Meeting with RES, NRO, and NRR/DORL to 14 discuss User Need Request to determine future NRR March 29,2010 actions reqardinQ the Shoreline Fault RES to provide confirmatory review of secondary 15 RES July 31 , 201 O rupture analvsis 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, 201 O Fault 18 Seismic Workshop in San Luis Obispo Region IV September 8 and 9, 2010 19 Complete seismicity studies PG&E December 201 O 20 Complete geophysical studies PG&E December 2010 21 Complete geologic studies PG&E December 2010 Complete Shoreline Fault source characterization 22 PG&E December 2010 for inteqration into final report.
Complete ground motion studies to be integrated 23 PG&E December 201 O into final report.
Page 11 eFFlelAL tJ8E 6P4LV SENSITIVE IN'fEPU4AL 114FOffNIAfl6N
err1e1,tct ~81!! eHtv 91!H!ITl'tl! lffTl!fUfAL IHF6RMAfl8H Act ivity / Report / Document Title Lead Office Date (ADAMS/Reference number, as aooropriate)
NRR/
24 Meeting on LTSP Amendment December 9, 2010 DORL Research Assistance Request for pre-application NRR/
25 discussions on LTSP Amendment March 2011 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 data are inteQrated into final report in December.
28 Complete final Shoreline report PG&E January 2011 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 NRG held an annual assessment meeting 34 RIV June 2011 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 questfons posed by U.S.
NRR (w/
38 Senate Environmental & Public Works Late January 2014 OCA) subcommittee staff Regional 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 September 10, 2014 report to the state of California Page 12 eFFl81AL tJ9f 6'4LV 8!U81Tl'lf IUTl!RUAL IUPeRMAflef4
OfifilCIAL tJSE OHLY SEf4Sl'flVE U4fEfU4AL IHF8ftMAll8H List of Applicable Acronyms and Abbreviations 2-0/3-0 Two-Dimensional/Three-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 DOE Double Design Earthquake (DCPP specific term, equivalent to SSE)
DE Design Earthquake (DCPP specific term , equivalent to OBE)
DGEIS Draft Generic Environmental Impact Statement DPO Differing Professional Opinion GMC Ground Motion Characterization (relative to SSHAC process)
HE Hosgri Event (i.e., seismic event occurring on the Hosgri fault)
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 NTIF 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 Earthquake SSHAC Senior Seismic Hazard Analysis Committee TIA Task Interface Agreement TS Technical Specification U/FSAR Updated/Final Safety Analysis Report Page 13 8FFl81AL t:18! 8HLV 8Ef481lP;tE IHTEfUJAL lfJF8ftMAll8f4
eFFlelAL tJSE eNLY SENSllTt1E IN'fEftNAL INF6ftMA'fl6H 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 , "Damping Values for Seismic Design of Nuclear Power Plants," was issued. The RG allowed more damping to be used in seismic evaluations than had previously been used in the DE and ODE at Diablo Canyon. PG&E used the RG 1.61 values in the Hosgri evaluation and did not revise the DE or DOE.
1/10/77 Revision of Appendix A to 10 CFR 100 was issued 6/3/77 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 "we [NRC staff] require that the plant design be shown to be adequate for the Hosgri event and the applicant is proceeding with the work necessary to demonstrate this."
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Ol'l'ICIAL tl!l: ONLY 31:N!ITIYI!! U4T!ftl4>\L IIQP ORNIAflON Timeline 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 15 arrr1e1At tf8f erttY 31!H31fll'f IN'fl:IUtAL IHfiOftMA'flON
et-r1e11ct t:JSE eNtY WWW ser4s1,1ve U4'fEfmAt 1u,eRMAT1 eu Timeline of Seismic Issues at DCPP (cont'd) 2006 A new phase of the CRADA is implemented and includes both a large set of new field studies and the application of new advanced seismological techniques to small magnitude recorded earthquakes.
11/14/08 PG&E notified the NRC of a potential line of epicenters about one mile offshore from the plant. This was followed up on 11/21/08 with Event Notification 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 (RIL) 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 2010 The NRC sponsored a seismic workshop in San Luis Obispo, CA, to help inform the public about seismic evaluations and design. Independent seismic experts were invited to make presentations.
Sept2010 DCPP SRI becomes aware that the PG&E preliminary results show peak ground acceleration for the Shoreline Fault is in excess of the values used in the ODE.
Oct 2010 DCPP SRI questions PG&E on the capability/operability of SSCs to withstand the Shoreline Fault acceleration using the DE/DOE evaluation method.
Dec 2010 PG&E concluded that no operability evaluation was needed to compare the Shoreline Fault ground acceleration to the DE/ODE 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 ML110140400). This report included deterministic 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 2011-010 posing questions needed to help resolve seismic operability evaluation issues involving Diablo Canyon's use of the Hosgri and LTSP methods as the only bounding design basis conditions for newly identified faults.
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eFFlelAL t:19[ ONLY - SEt.SlfPIE INTERNAL IHF8RMAfl9U Timeline of Seismic Issues at DCPP (cont'd) 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 DOE.
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 DOE (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 in the UFSAR.
Sept -
Page 17 eFFlelAL tJSE OP4LY SENSITIVE U4TEfU4At INF6RMATlel4
erflelAL tlSE 6NLY w 9ENS1'fl't1E IN'fERNAL INF6RMATl6N 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 the 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, "Revised Response to Task Interface Agreement -
Diablo Canyon Seismic Qualification Current Licensing and Design Basis, TIA 2011-010 (TIA 2012-012) (TAC NOS. ME9840 and 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 Motion Characterization Project website. NRG 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 workshop.
Page 18 OfifilelAL t:ISE eHLY 8Ef481T1Vf lf4Tl!fU4AL lf4P'ORMATIOH w
eFFlelAL ij9f 8HL'f w 3EN91Tl't1E INTERHAL INl'eftMATIOIQ Future Events:
Sept. 2014 PG&E expected to submit the AB-1632-mandated SEISMIC REPORT to State of California (IPRP to review). A copy will be provided to NRC for review.
March 2015 PG&E due to submit ground motion response spectrum to the NRC in response to March 2012 50.54(f) request. Current information from the SSHAC process supports the expected conclusion that the new ground motion response spectrum will be bounded by the original HE ground motion response spectrum.
June 2017 PG&E due to submit the results of the new Seismic PRA to the NRC in response to 50.54(f) request.
Page 19
--Ol'l'ICIAL l':JS! ONLY 9EN91'fl't1E lf4'EPU4AL m,e"MATION
Design/Initial licensing Basis Questions (DE/DDE/Hosgri/Tsunami)
- 1. When was the Hosgri fault identified?
1971. During geological investigations in support of the DCPP operating license applications, oil company geoscientists discovered a major zone of faulting a few miles off shore. When the DCPP Final Safety Analysis Report (FSAR) was initially submitted for NRC review in 1973, it briefly described the offshore fault zone, calling it the East Boundary Fault Zone. The zone became known as the Hosgri fault.
- 2. How was the Hosgri fault addressed in the licensing and design of DCPP?
Although the original OBE and SSE values of 0.2g and 0.4g were specified as part of the design basis (calculation) in 1968, the 0.75g Hosgri event was incorporated in the licensing basis (along with the OBE and SSE) prior to issuance of the DCPP units' operating licenses in 1984 and 1985.
Upon discovery of the Hosgri fault (1971), PG&E reanalyzed and significantly upgraded the structures, systems, and components to accommodate the postulated ground motion values (up 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 desm gn 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 ODE: 0.4g HE: 0.75g The DE response spectrum is enveloped by the ODE response spectrum at all frequencies, and the DOE response spectrum is enveloped by the HE response spectrum at all frequencies. In addition to the magnitudes of the spectra being different, the shapes of the spectra are also different. This is due to differences in how the response spectra were developed as well as differences in the hypothetical earthquake that each design basis level Page 20 9P'P'l@UAL tlS! 6f4LV 9!f4SITIV! lf4T!fU4AL IHP'9ftMATl9'4
is based on. Generally speaking, the response spectra were constructed based on modified versions of similar real earthquakes, normalized 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 OCPP operating license defines the ODE 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 Diablo Canyon site, two design basis earthquakes (ground motion) were established. The operating basis earthquake (OBE) represents the ground motion reasonably expected during the lifetime of the plant. At DCPP, this is called the Design Earthquake (DE), and is 0.2g. The safe shutdown earthquake is defined as having twice the acceleration of the operating basis earthquake to ensure safety margin. At DCPP, this is called the Double Design Earthquake, and is 0.4g.
Pacific Gas and Electric (PG&E, the licensee) was required to show that all equipment necessary for continued operation without undue risk to the health and safety of the public would withstand the OBE/DE (i.e., remain functional), and that all safety-related equipment needed to safely shut the plant down and maintain a safe shutdown condition would withstand the SSE/ODE.
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 part of a collaborative research program between PG&E and the U.S. Geological Survey (USGS). The NRC worked with the USGS office to ensure that the seismic hazard was properly characterized. This effort determined that the Hosgri fault could produce up to 0.75g ground motion at the 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 ODE 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.SSa?
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/DOE. At Diablo Canyon, this was demonstrated through a combination of calculations and tests. Because the ASME, Section Ill requirements for design of pressure boundary components and supports were not mandated by 10 CFR 50.55a until the mid-1980's, the acceptance criteria for DCPP rely on a combination of the ASME Code and ANSI Code for piping, applicable at the time of initial licensing, that provide an equivalent level of safety assurance as required by 10 CFR 50.SSa.
Page 21
6ffil61ilcL t:JSE ONL'/ SENSITIVE INTERNAL INFO"MATl6H 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 rernain 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 withstand any earthquake that can reasonably be expected to occur on the Hosgri fault".
- 6. Is it accurate to state that meeting the SSE/DOE also means that the licensee has to test and model some of the other reactor's structures, systems and components (SSCs) to ensure they can withstand the sort of shaking that could be caused by the 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 DOE/SSE.
As discussed in the answer to Question 5, this same rigor was also required for Diablo Canyon up to the HE (0.75g) design basis for the same equipment.
- 7. Is it accurate to state that NRC did not require the licensee to meet all of the requirements of the SSE/DOE when it came to its Hosgri earthquake analysis (and that this is basically what you sent in the documents)?
No. The functional requirements remained the same, and were met. As indicated in the answer to Question 5, although a limited number of components relied on alternative Code acceptance criteria to demonstrate functionality up to the HE, those components still meet the applicable Code.
- 8. What size tsunami is the plant designed/built to withstand?
The design basis tsunami is 35 feet. The DCPP site sits atop a coastal bluff, 85 feet above sea level, decreasing its vulnerability to a tsunami hazard. The only safety-related system that has components within the projected sea wave zone is the Auxiliary Saltwater (ASW)
System. The ASW pump motors are housed in watertight compartments within the intake structure. The intake structure is designed With an elevated air intake (48 feet) so that the ASW pumps can operate during the design combination of a tsunami and storm wave run up.
- 9. How is the plant designed for each design basis earthquake? How are those design criteria/methodologies/analytical methods different? Why are they different?
[Answer under development.]
Page 22 6Ff'l61AL t:19t! er~LY SENSITIVE INTl!!RNAL lf4P'6ftM)l(Tll!tfJ
6fflelAL tJSE 6f4LY SEf~Slfl't'E lf4fERf~AL INf6RMAll6f4 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 L TSP is a "seismic margin analysis" included as an original plant license condition. The LT SP 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 Diablo 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 assessmenUseismic 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 L TSP 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 LTSP by itself is not sufficient to meet this requirement.
Page 23 6FFlel~L ~8f 8ULY 8ff481lll/l! IUTl!RU:< 11*,elllMATIOt,
erFlelAL tJ9f 6f4L'I' 9Ef491lWE lf4fEIU4AL lf4F6"MAfl614 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 NR~ 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 24 ePFlelAL t:19E eNLY 9EN91:Y:IVE INfERNAL lf4fl6RMATION
e rrrr1e1>tct tJ91!! 6'4LY 9!1~91fl't'E IH'ffftNAL lf~fi6ftMA'fl6N 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. *-UPDATE AS NECESSARY BASED ON THE AB-1632 REPORT**
- 3. What are the characteristics of the Shoreline fault?
Studies conducted in 2009 and 201 Oconcluded that the Shoreline fault is a right-lateral strike slip fault, approximately 23 kilometers (14.3 miles) in length, with a slip rate between 0,2 and 0.3 millimeters per year. The closest segment of the fault is located about 600 meters southwest of the Power Block (the reactors) and 300 meters southwest of the Intake Structure.
The studies also updated information on other faults in the region. The 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 (RI L) 09-01 , "Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon NPP from Newly Identified Shoreline Fault." This was an independent study of potential impacts of the Shoreline Fault.
The NRC concluded that adequate seismic margin existed and the plant was safe to operate.
The NRC concluded that it was appropriate to use the same methods and criteria as was used for the LTSP/Hosgri to evaluate the Shoreline fault. This was because the Shoreline Fault frequency and peak ground acceleration at the plant were below what LTSP/Hosgri would produce at the plant.
Page 25
Ol'l'lelAL t:J91! eNLY 91!N91TIVE INTERNAL 1Nfi6RMATl6t4
- 6. Was Diablo Canyon's sole use of the LTSP appropriate for evaluating the Shoreline Fault?
No. The design and licensing basis for Diablo Canyon included two different evaluation methods with two different acceptance criteria which could be considered bounding. The licensee could not use the method that had been used to evaluate and accept the Hosgri 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 NRG 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 NRG 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?
Diablo Canyon has completed an operational evaluation to show the plant is safe to operate.
The NRC reviewed and agreed the evaluation indicates the plant is safe to withstand earthquake hazards. Based on what the NRG 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 is not safe the NRG would take immediate action to resolve the issue.
- 9. Why is the NRC allowing Diablo Canyon to operate when experts inside and outside the NRC believe the Shoreline Fault represents a threat to the plant and serious questions have been raised regarding whether the facility meets NRC's license requirements?
Page 26 efiflelAL tJ!E 6HLY - SENSITIVE lfUERf4AL INfi6fitMATl6N
6FFlel>'cl tteE 6ULV 8!f491'fl¥E Uffl:IU4AL INf6ftMAfl6N When the NRC set out to perform an independent assessment of the Shoreline Fault we put together a team of NRC seismic experts as well as a team of consultants from outside the agency to ensure that we had the right expertise to perform the analysis and that the resulting document would be technically defensible. Our independent deterministic analysis of the Shoreline Fault determined that the ground shaking at the plant site that could result from earthquakes on the Shoreline Fault is bounded by the larger ground motions that could result at the plant site from earthquakes on the Hosgri fault. Based on the NRC's independent analysis of the 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 facility does meet NRC's license requirements .
- 10. Is It accurate to state that generally speaking, when a licensee does not meet its license requirements, there are 3 typical options: 1) NRC can order the reactor to shut down until the license requirements are met, 2) NRC can approve a set of mitigation measures the lice nsee 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 valid 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 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.
Page 27 eFFlel>'ct t:JSE 6f4LY - SEHSITIVE INTEftN>'cL U4F6RM>'cTl6N
ef f1e1At tJSE eNtY WWW 9Ef481"E m,e,rnAt mFeftMAlleH 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 if 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 Orders) if a licensee is not meeting its regulatory requirements. These options are described in the enforcement guidance listed on NRC's Enforcement web page at http://www.nrc.gov/about-nrc/regulatory/enforcemenLhtml. 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/DOE 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 Dlablo Canyon in this case.
Shortly after PG&E notified the NRC of the potential for a new fault (later referred to as the Shoreline Fault), it provided the NRC with sets of initial scientific data and information related to the hypothesized fault. Based on this initial information, the NRC staff immediately performed a preliminary review of possible implications of the Shoreline fault to the DCPP to determine if an immediate safety concern existed. The NRC continued to review new data and information on the Shoreline fault 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 Anal'ysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone"). The licensee's report provided NRC with new geological, geophysical, and seismological data on the Shoreline fault, obtained using up-to-date methods and technologies. The NRC's independent assessment determined that the Shoreline fault could create ground motion lower than the ground motion for which the plant had previously been evaluated (i.e., the 0.75g, HE). As such, the NRC's October 12, 2012, letter concluded that the existing design basis for the plant is sufficient to withstand ground motions from the Shoreline fault.
Page 28 eFFlelAL t:ISE 6HLY SEf4Slfl'lf lf4Tfftf4AL lf4F6ftMAll6f4
6f'f'le1AL tJ9E ONL\' - 9EN91l'l¥E lf~l'EffNAL INfi6ffMAl'l6N State of California Seismic Report (AB-1632)
Background
California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report. This is different methodology than what was used for the 2011 Shoreline Fault.
Planned Communication Activities
- UNDER DEVELOPMENT ***
Questions and Answers
- UNDER DEVELOPMENT **"
Page 29 eprpr1e1At 1:1se eHLY - 9Er~Sll'l¥E n~l'EffHAL U~flOftMATleH
8FFl81AL tf8E 8HLY 9EH91TI\IE IWfE~HAL lf4F6RMAll6P4 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 201 1 Shoreline Report for comparison, though no new data on these faults 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 30 OFPlelAL tlS! er~LY - SEH91ll't'E IHlERHAL INFO"MATleN
err1e1At t1ee et4t¥ w SEH91"E lf4l'EIU4At lf4FeRMA'fleN Research Information Letter (RIL) Questions
- 1. What is a RIL?
Rlls are documents issued by the Office of Nuclear Regulatory Research (RES) to the NRC Regulatory and Regional Offices that summarize, synthesize, and/or interpret significant research information, provide new or revised information, and discuss how that information may be used in regulatory activities. RIL's allow NRC Regulatory Offices or Regional Offices to readily understand what new information has been obtained, and the significance of that information for current and future licensing reviews or other regulatory activities.
- 2. What is the purpose of RIL 2009-001?
Research Information Letter (RIL) 2009-001 was issued on April 8, 2009. RIL 2009-001 was initiated for RES to complete an independent analysis of the Shoreline Fault In RIL 2009-001 , the NRC concluded that the seismic-loading levels predicted for a maximum magnitude earthquake on the Shoreline fault were below those levels for which the plant was previously analyzed in the LTSP.
- 3. What is the purpose of RIL 2012-01?
Research Information Letter 2012-01 was issued on September 19, 2012. RIL 2012-01 was initiated for RES to complete an independent analysis of seismic hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone.
The NRC's independent evaluation, documented in RIL 2012-01 , concluded that there is very little evidence that the Shoreline fault has ever been active. While its size was used to create a worst reasonable case ground motion curve, the region shows only some symptoms of a fault. There is no evidence that there is slippage, which would indicate this was an active fault in the past. Therefore, it is reasonable to bound the Shoreline fault by the LTSP/Hosgri method.
- 4. Now that the Rlls have been issued, is PG&E done with its studies?
No. PG&E has performed additional studies including three-dimensional (3-0 ) marine and two-dimensional (2-D) 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 DCPP: 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 walkdowns per the March 2012 50.54(1) request from the NRG. The results from PG&E's actions will be due in March 2015.
Page 31 6ffl61AL t:ISE ONL'f 9EP491,i11E IP4fEfU4AL IUP@UIMATltU.
effllCIAL t:ISE eNtY SENSl"l:/E lf4fERUAL IHP:8RM~Tl@U "Sewell" Report / Tsunami Concerns
Background
In March of 2004, as part of the review for the Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) license review, the Center for Nuclear Waste Regulatory Analysis (CNWRA, a division of Southwest Research Institute), transmitted to the NRC a Tsunami Hazard Study that applied to the Diablo Canyon site. Within the scope of the CNWRA review of the Diablo Canyon ISFSI application, a CNWRA contractor, Dr. Robert Sewell, developed a draft report (the "Sewell Report) on the potential for landslide tsunamis impacting the site. The report postulated wave elevations from potential landslide tsunami scenarios that could exceed the current licensing basis tsunami height for Diablo Canyon.
CNWRA did not endorse Dr. Sewell's work, but did transmit the report to the NRG to inform the NRG of developments in the landslide generated tsunami area of study. The Sewell Report was reviewed by the Seismic Issues Technical Advisory Group (SITAG) in the NRC's Office of Research. In November 2005, the SITAG review concluded that the tsunami scenarios contained in the Sewell Report were based on rudimentary modeling with little geologic and geotechnical data. SITAG further concluded that the study should not be used in any licensing actions.
In February 2006, the Office of Nuclear Reactor Regulation's (NRR's) Division of Engineering terminated further consideration of the Sewell Report, based on NRC participation in other cooperative government reviews of tsunami hazards under the President's Office of Science and Technology Policy (OTSP). NRR concluded that the OTSP effort would provide a more technically credible forum to broaden the NRC's understanding of tsunamis and inform efforts to reassess the tsunami design criteria in the Standard Review Plan.
The design basis tsunami for DCPP considers distantly-generated tsunamis and locally-generated tsunamis. The design basis tsunami is the greater of these tsunamis and is 34.6 feet. Additionally, DCPP sits atop a coastal bluff, 85 feet above sea level, decreasing its vulnerability to a tsunami hazard.
The intake structure auxiliary salt water pump room vents are extended with steel snorkels to prevent seawater ingestion due to splash-up during the design flood event and is thus ensured of operation during extreme tsunami drawdown and combined tsunami and storm wave conditions. The only safety-related system that has components within the projected sea wave zone is the auxiliary salt water system. The auxiliary salt water pump motors are housed in watertight compartments within the intake structure, These compartments are designed for a combination tsunami-storm wave activity to elevation +48 feet MLLW (+45.4 feet MSL). The massive concrete intake structure ensures that the pumps remain in place and operate during extreme wave events. The intake structure is arranged to provide redundant paths for seawater to the pumps, ensuring a dependable supply of seawater.
A 2011 staff overview of Diablo Canyon (http.//adamswebsearch2.nrc.gov/webSearch2/main 1sp?Access1onNumber=ML111290158 )
includes reference to a 201 O PG&E report on updated tsunami hazards (http://peer.berkeley.edu/tsunami/tasks/task- 1-tsunam1-hazard-analysis/ ), part of an academic review of California tsunami hazard.
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After identification of the Shoreline fault in 2008, PG&E determined that the tsunami hazard threat from Shoreline is relatively small since it is a strike-slip fault rather than a reverse fault and there is not expected to exceed the design basis. The NRC performed an evaluation of the tsunami hazard and an independent deterministic seismic hazard analysis of the fault based on information provided by the licensee to confirm DCPP's conclusions regarding safe operation.
After the earthquake and tsunami in Japan on March 11 , 2011 , the NRC issued in March 2012 a request for information (also known as a 50.54(f) letter) requesting each nuclear power plant to re-evaluate the flooding hazard at their site, including tsunami. This re-evaluation is due from DCPP in March 2015. DCPP was given 3 years to respond due to t he technical complexities involved in their re-evaluation.
Key Messages
- The NRC did not publicly release the draft report for two reasons:
- 1. Although the staff considered the report during the licensing of DCPP Independent Spent Fuel Storage Installation (ISFSI), it did not form the basis for any licensing action
- 2. The draft report was considered preliminary and its conclusions based on limited data and methods
- The design basis tsunami for DCPP considers distantly-generated tsunamis and locally-generated tsunamis. The design basis tsunami is the greater of these tsunamis and 34.6 ft.
Additionally, DCPP sits atop a coastal bluff, 85 ft above sea level, decreasing its vulnerability to a tsunami hazard
- The NRC licensed DCPP independent spent fuel storage installation based on its conclusion that the probable maximum tsunami flooding at the proposed ISFSI was adequately addressed by PG&E, based on the licensee's assessment of more recent tsunami information in the area, as well as the much higher elevations of the ISFSI site and transporter route relative to the previously analyzed hazard for the power plant. This conclusion was reached with full consideration of this report.
- The NRC is continuing to re-evaluate the tsunami hazard. After the earthquake and tsunam i in Japan on March 11 , 2011 , the NRC issued in March 2012 a request for information (also known as a 50.54(f) letter) requesting each nuclear power plant to re-evaluate the flooding hazard at their site, including tsunami. This re-evaluation is due from DCPP in March 2015.
DCPP was given 3 years to respond due to the technical complexities involved in their re-evaluation.
- DCPP's ability to withstand large waves and the maximum wave height at the intake structure were determined through extensive and detailed scaled model wave testing. The only safety-related components within the project sea wave zone (auxiliary salt water system) are protected from tsunami effects.
Questions and Answers
- 1. Why did the NRC decide to not release the draft report to the public?
The NRC did not release the report for two reasons. First, although considered during the Page 33 Ol'l'lelAL t:J9! 014L'i 9!1491TIV! 114T!ftHAL 1141'0ftMATIOl4
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licensing of DCPP ISFSI, it did not form the basis for that licensing action. Second, the draft report was considered preliminary and its conclusions based on limited data and methods.
- 2. What has the NRC done to evaluate the report?
The NRC was assisted by experts from the Center for Nuclear Waste Regulatory Analyses (CNWRA) in performing a comprehensive safety and technical review of PG&E's license application for an ISFSI. The CNWRA, in turn, contracted the services of Dr. Robert Sewell specifically to assess PG&E's application with respect to tsunami hazards.
The NRC and CNWRA concluded that the probable maximum tsunami flooding at the proposed ISFSI was adequately addressed by PG&E, based on PG&E's assessment of more recent tsunami information in the area, and the much higher elevations of the ISFSI site and transporter route relative to the previously analyzed hazard for the power plant.
The CNWRA assessed the information in Dr. Sewell's report upon receiving it in November 2003. The report was forwarded for NRC's consideration in March 2004, after CNWRA had completed its review of the DCPP ISFSI application. Both the principal investigator for the CNWRA, an expert geologist and seismologist, and the NRC determined that the findings in the report were too speculative to be considered in current licensing decisions, but that they might warrant further review by the NRC. In February 2005, the NRC staff initiated further review of the report, consistent with its efforts to assess the December 2004 tsunami in southeast Asia. In May 2005, the NRC directed that a special review of the report be performed by NRC seismic experts. That group reached its preliminary conclusions on Dr.
Sewell's report in November 2005, and completed its evaluation in January 2006.
- 3. Why did it take the NRC group of seismic experts from SITAG so long to review the report?
The NRC group made an initial assessment of the hazard and the credibility of the report and determined that a 6 to 12 month review time frame was appropriate in consideration of NRC's other high priority safety and regulatory issues currently under development. The preliminary assessment was completed in November 2005, with revisions in January 2006.
- 4. Was the concern about the tsunami hazard potential at OCPP related to the December 2004 earthquake and tsunami in Sumatra and the Indian Ocean?
No. The study of the potential tsunami hazard was performed during the licensing of the proposed ISFSI at the DCPP site, prior to the 2004 event in the Indian Ocean. In response to the tsunami in Sumatra and the Indian Ocean, PG&E initiated its own study of the tsunami threat to DCPP. A 2011 staff overview of Diablo Canyon (http://adamswebsearch2.nrc.gov/webSearch2/matr1 jsp?AccessionNumber=ML111290158 )
includes reference to a 201 O PG&E i"eport on updated tsunami hazards (http//peer.berkeley edu/tsunami/tasks/task- 1-tsunam1-hazard-analys1s/ ), part of an academic review of California tsunami hazard.
Following the earthquake and tsunami in Japan on March 11 , 2011 , the NRC issued a demand for information letter (also referred to as a 50.54(f) letter) in March 2012 requesting information from each nuclear power plant regarding the current flooding hazard at the site, using the most up-to-date methodologies. DCPP's response to this letter is due March 12, 2015. DCPP was given three years to complete this re-evaluation due to the technical Page 34 6FFlelAL tJSE 6NLY !l:f4!1TIV! INT!l'tNAL IN,.OftMATION
Ol'l'ICIAL t:ISE 6NLY SENSl:Y:l't'E INTERNAL INF6RMA'fl0N complexities involved at their site.
- 5. Are coastal nuclear facilities safe today from the tsunami threat?
Yes, the coastal nuclear facilities are safe from the threat of tsunamis. The NRC has licensed a number of nuclear facilities on the US Pacific, Atlantic, and Gulf coasts. These facilities include commercial nuclear reactors, ISFSl's, and research and test reactors (RTR's). The NRC has determined that public health and safety continue to be maintained for these facilities.
The NRC design philosophy for natural phenomena hazards, such as tsunamis, is based on consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area with sufficient margin for limited accuracy, quanti1ty, and period of time for which the historical data have been accumulated. Existing nuclear facilities were licensed consistent with this design philosophy.
In general, facilities located along the Pacific coastline are more likely to be impacted by tsunamis due to the more frequent occurrence of large earthquakes along the margins of the Pacific Ocean. Deep ocean trenches off the coasts of Alaska, the Kuril Islands, Japan, and South America are well known for their large earthquakes and as potential sources for Pacific-wide tsunamis. The most recent damaging tsunami along the Pacific coast was caused by the 1964 magnitude 9.2 Alaskan earthquake with a wave height of 21 ft recorded in Crescent City, far from OCPP. Tsunamis generated by local sources, such as submarine landslides, also have the potential to impact coastal sites. The design of nuclear facilities along the Pacific coast was based on historical tsunami information and considered both local and distant tsunami sources as well as local onshore and offshore topography. Hence the facilities have been designed for the largest recorded tsunami effect with additional safety margins.
Therefore the NRC staff believes that there continues to be adequate protection of public health and safety from the tsunami threat to nuclear facilities on the Pacific coastline.
The design basis tsunami for DCPP considers distantly-generated tsunamis and locally-generated tsunamis. The design basis tsunami is the greater of these tsunamis and 34.6 ft.
Additionally, DCPP sits atop a coastal bluff, 85 ft above sea level, decreasing its vulnerability to a tsunami hazard. DCPP's ability to withstand large waves and the maximum wave height at the intake structure were determined through extensive and detailed scaled model wave testing. The only safety-related components within the project sea wave zone (auxiliary salt water system} are protected from tsunami effects.
- 6. Has NRC assessed the potential impact of a tsunami, as predicted by Dr. Sewell, on the DCPP and public safety?
The NRC's assessment of potential tsunami hazard is ongoing and the DCPP response to the 50.54(f) letter is due March 2015. However, the NRC has concluded that the tsunami scenarios described by Dr. Sewell in the report are based on preliminary data and analysis and should not be used as a basis for any licensing action. NRC continues to evaluate the potential tsunami hazard for coastal nuclear facilities to ensure the most up to date scientific information is assessed and properly considered.
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- 7. What is the NRC doing to address any generic implications for coastal sites other than DCPP?
Following the March 11, 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami.
The NRC used criteria to prioritize each site's response due date, ranging from 2013 to 2015. Once the NRC receives the response, experts will evaluate the data to determine if additional action is required.
- 8. Has NRC discussed the results of their review of the report with Dr. Sewell and has he responded to NRC's comments?
The NRC has discussed the findings with the NRC's contractor CNWRA, who subcontracted the study to Dr. Sewell.
- 9. If the NRC was dissatisfied with the draft report it received from Dr. Sewell, why didn't it return the report to him and require he make the changes necessary to address the staff's concerns?
After the SITAG's findings that the report's conclusions were based on limited data and methods, the NRC determined that it would be more effective to spend its resources participating in several ongoing initiatives to reassess tsunami hazards sponsored by NOAA, USGS, and the White House Office of Science and Technology Policy, rather than further reviewing or revising Dr. Sewell's report.
Following the March 11, 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami.
The NRC used criteria to prioritize each site's response due date, ranging from 2013 to 2015. Once the NRC receives the response, experts will evaluate the data to determine if additional action is required.
1O. What actions has the NRC taken to ensure it is correct in addressing the areas it used to discount Dr. Sewell's report?
A 2011 staff overview of Diablo Canyon (http://adamswebsearch2.nrc.gov/WebSearch2/main jsp?Access1onNumber=ML111290158 )
includes reference to a 2010 PG&E report on updated tsunami hazards (http://peer berkeley edu/tsunami/tasks/task-1-tsqnam1-hazard-analys1s/ ), part of an academic review of California tsunami hazard.
Following the March 11, 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami.
This re-evaluation must be completed using current methodologies and data. Therefore, the re-evaluation , when received in March 2015, will address these areas. The NRC will then review and evaluate this response and determine what, if any, actions are needed.
11 . How has the tsunami hazard been changed based on the identification of the Shoreline fault?
After identification of the Shoreline fault in 2008, PG&E determined that the tsunami hazard threat from Shoreline is relatively small since it is a strike-slip fault rather than a reverse fault Page 36 CfifilCIP,l 1:191: eNLY 31:N31'flVI: 114'fl:ftNAL INfieftMA'flCIN
6fifilelAL tJSE eNLY SENSl'flVE IN'fERf4AL lf4FORMA'flON and there is not expected to exceed the design basis. The NRC performed an evaluation of the tsunami hazard and an independent deterministic seismic hazard analysis of the fault based on information provided by the licensee to confirm DCPP's conclusions regarding safe operation.
- 12. Why hasn't anything been done with this report post-Fukushima?
After the SITAG's findings that the report's conclusions were based on limited data and methods, the NRC determined that the report should not be used as a basis for any licensing action.
However, following the March 11 , 2011 earthquake and tsunami in Japan, the NRC issued a 50.54(f) letter requiring each nuclear plant to re-evaluate their flooding hazards, including tsunami. This re-evaluation must be completed using current methodologies and data.
Therefore, the re-evaluation, when received in March 2015, will address these areas. The NRC will then review and evaluate this response and determine what, if any, actions are needed.
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8FFl81AL t:f!E 8HLV 91!f49"1VE IWFEfU4AL lf4F6ftMATl6N Non-concurrence and DPO Questions NOTE: General FAQs on the DPO Program are included on the DPO Web site (look under Employee Resources-Employee Concerns.
- 1. Was the former OCPP SRI reassigned because he filed two non-concurrences?
No, the former DCPP SRI was not reassigned. He applied for an instructor position in his area of expertise at the NRC's technical training center in Chattanooga, TN, at about the time he submitted his non-concurrence in accordance with the Non-Concurrence Process described in MD 10.158. He was competitively selected for this sought-after position, and reported to his new assignment in September 2012. Resident inspector assignments are limited to 7 years to ensure objectivity. It is common for resident inspectors to apply for their next job when a desirable position comes open.
- 2. When were the non-concurre nces filed?
Two non-concurrences were filed by the DCPP SRI.
11/7/11 . The DCPP SRI submitted NCP 2011-103, on inspection report 05000275; 323/201104.
1/26/12. The DCPP SRI submitted NCP 2012-01. on inspection report 05000275; 323/201105.
- 3. What were the non-concurrences?
Both non-concurrences involve the same subject; regulatory actions in response to the discovery of the Shoreline Fault.
NCP 2011-103 was filed by the DCPP SRI on the basis that no violation was issued (as he had submitted in the draft report) related to operability evaluation of the Shoreline fault in Report 2011-04. NCP 2011-103 was dispositioned finalizing the violation in IR 2011-05 issued on 2/14/12. (The employee requested that the NCP be non-public.)
NCP 2012-01 was filed by the DCPP SRI because the SRI believed the violation In NRC IR 201 1-05 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 2012-0 1 was dispositioned as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (interim) operability evaluation in June 2011 .
Additionally, the offices involved in NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the 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 3Q/2012, Page 38 8FFl81AL tl9E et4l¥ S!NSITIV! INTl!f'NAL U~l'OftMA1'10N
eFFlelAL l1SE eNLV SENSITIVE INTERNAL INF6RMATI014 enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event. (The employee supported public release of the NCP ADAMS ML121A1 73.)
- 4. When was the DPO filed?
July 18, 2013. The former DCPP SRI filed Differing Professional Opinion (DPO) 2013-02 associated with the regulatory response following the discovery of the Shoreline Fault.
NRC employees are encouraged to file a DPO if they believe an agency decision is in error.
The DPO process is in keeping with the agency's open and collaborative working environment.
- 5. What is the DPO?
DPO 2013-02 restated the issues presented in NCP 2012-01 and added a concern that a license amendment was needed incorporate the shoreline fault into Diablo Canyon's FSAR as described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults.
- 6. What is the status of the DPO?
The DPO is being reviewed consistent with the NRC's process included in MD 10.159. In particular. a decision was issued by the Office Director for NRR on May 29, 2014. The employee appealed the decision to the EDO on June 23, 2014, and the issue is currently being evaluated through the appeal process.
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. Will the decision regarding the DPO be made public?
The NRC supports openness and will include a summary of the disposition of the DPO in the Commission's Weekly Information Report included on the NRC Web site (see Commission Documents under the Document Collections in the NRC Library). If the submitter supports public release, the DPO Case File (with appropriate redactions) will be included.
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No. As noted in Q&A #1 above. the former SRI applied for and was selected to a highly sought instructor position at the NRC's Technical Training Center. The NRC does not tolerate retaliation for engaging in the NCP or the OPO Program and both MDs reiterate this policy and direct employees to resources in the event they believe that they have been retaliated against.
- 9. Tlmeline of Events associated with the NCPs and DPO:
11/7/11 DCPP SRI submits Non-Concurrence NCP 2011-103. The SRI non-concurs on Inspection Report 05000275; 323/2011004 because the proposed violation involving the Shoreline Fault operability evaluation was not issued.
11 /9/11 NCP 2011-103 is dispositioned by Region IV. The operability evaluation issue was documented as an Unresolved Item in Inspection Report 05000275; 323/2011002 and dispositioned as a violation in Inspection Report 05000275; 323/2011005.
40/2011 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 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. (ADAMS Accession Number ML12151A173).
Feb 2012 DCPP SRI applies for instructor position vacancy at the Technical Training Center (TIC).
Feb 13, 2012 Response to NCP 2012-01 issued. NCP 2012-01 was discussed with NRC stakeholders representing NRR/OE, NRR/DORL, RIV, and RES . NCP 2012-01 was dispositioned as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (interim) operability evaluation in June 2011 . Additionally, the offices involved in NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the 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 3Q/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event. (ADAMS Accession Number ML12151A173).
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8FFl81AL t:18( 8ULV 9Ef491Tlt+'E INTERNAL INFeRM~TION 02/12-07/13 RIV management frequently encourages the DCPP SRI to submit a Differing Professional Opinion (DPO) during several discussions involving seismic issues.
May 2012 DCPP SRI is selected for instructor position at the Technical Training Center (TIC).
Sept 2012 The (now former) DCPP SRI reports to the TIC as a training instructor.
7/18/13 Former SRI submits a DPO regarding the agency's regulatory actions associated with the Shoreline Fault.
8/2/13 DPO 2013-002 was assigned to NRR for an independent review.
9/3/13 Director, NRR establishes a DPO 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 DPO Panel completes its review of DPO 2013-002 and submits its report to the Director, NRR.
5/29/14 Director, NRR issues his decision on DPO 2013-002 by memo to the former DCPP SRI.
6/23/14 Employee submits DPO appeal.
6/27/14 Director, NRR provided Statement of Views on contested issues in appeal.
7/7/14 DPO appeal package provided to EDO for disposition and decision.
8/25/14 Associated Press article released discussing the DPO.
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OFFl61tcl t:ISE ONLY 9fH81TIVf 1"4TEfU4AL INF0ftMAI16f4 RIS 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, and (5) request the voluntary participation of the nuclear industry in NRC-sponsored pilot programs or the voluntary submittal of information. A RIS does not communicate new or revised NRC requirements.
- 2. How does the RIS apply to failures to meet design requirements (e.g.; General Design Criteria (GDC))?
RIS 2013-005 restated the NRC's position regarding operability evaluations for 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 licensee have a nonconformance with requirements and still operate?
Yes. RIS 2005-20, Revision 1. "Revision to NRC Inspection Manual Part 9900 Technical Guidance, 'Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety,"' describes the actions licensees must take to evaluate nonconforming conditions.
For the Shoreline fault, the NRC issued a violation for Diablo Canyon's failure to perform an operability evaluation. The licensee completed the evaluation and the NRC concluded that the guidance in RIS 2005-20 had been met. In particular:
The use of the LTSP was appropriate to characterize and bound the faults as part of the operability evaluation process. Additionally, 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.
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el'l'ICIAL tl!E 6fRY !EN!ITl'f'E INTERNAL INF6RMAifl6N Enforcement Questions
- 1. Did the NRC issue any violations involving the Shoreline Fault?
Yes. Inspection Report 2011-05 documented a violation for the failure to perform an operability evaluation of the Shoreline fault.
- 2. What corrective actions did Diablo Canyon take in response to the violation?
Diablo Canyon completed an operability evaluation for the Shoreline fault which met the guidance in RIS 2005-020. Diablo 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.
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6FFlelAL t1SE 6NLY w 8Ef481'fl'IE U4'fEfU4iltL U4F6RMilt'f16f4 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 2, "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 capability to perform their safety functions. Criterion 2 also stated that design bases for these structures, systems, and components shall reflect:
- Appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and 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,"
for establishing the three DCPP design basis earthquakes:
- Design earthquake (Operating Basis Earthquake) - That earthquake which could reasonably be expected to affect the plant site during the operating life of the plant; it is that earthquake which produces the vibratory ground motion for which those features of the nuclear power plant necessary for continued operation without undue risk to the health and safety of the public are designed to remain functional.
- Double design earthquake (Safe Shutdown Earthquake) - That earthquake based upon an evaluation of the maximum earthquake potential which produces the maximum vibratory ground motion for which certain structures, systems, and components are designed to remain functional.
Hosgri Event - a special postulated earthquake applicable only to DCPP.
[See Q&As for "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. NRR/DORL Page 44 6FFlelAL t1SE 6'4LY - 8Ef491'fl¥1! IU'f!RUAL IUJIO"M:ATleJl4
OP'..lelAL tl!E 6f4L't' !!H!ITl'f1! lf4T!ftNAL U4fl6ftMATl8H subsequently confirmed that pre-application meetings in mid-2011 had not included discussion of the HE as the SSE.
- 3. Did the NRC accept PG&E's amendment request for the Shoreline Fault?
PG&E withdrew the amendment request on October 25, 2012.
During the NRC acceptance review the NRC noted that PG&E had not submitted all of the information needed to review the Hosgri method against the Standard Review Plan (SRP) requirements.
- 4. Why was the LAR withdrawn?
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 clarify the licensing basis by revising safe shutdown earthquake. PG&E requested that the NRC designate the Hosgri event as the safe shutdown earthquake at Diablo Canyon.
During the NRG review of the LAR, the NRC required that the Hosgri fault be assessed against the acceptance criteria for the DOE. Since PG&E had not performed or submitted such an evaluation, the LAR was not accepted and Diablo Canyon withdrew the LAR.
On March 12. 2012, the NRC issued a 50.54(f) letter to all power reactor licensees requiring a seismic hazard re-evaluation . The NRC specifically required PG&E to compare the results of this re-evaluation to the DOE. The NRG 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 Diablo Canyon seismic licensing requirements?
No. All seismic hazard information collected to date has been evaluated by the NRC. The NRG 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 California Energy Commission that the NRC expects Diablo will exceed Its DOE once it completes this ongoing seismic review.
What does it mean when the NRC says they will exceed their DOE? What changes will the plant be required to make? If none, why not?
The Hosgri and ODE are separate methods for evaluating seismic information. As a result of the 50.54(f) letter review the NRG expects that Diablo Canyon will select a single method consistent with the already NRG 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.
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- 7. 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. Oiablo Canyon's initial response is due by March 2015. Diablo Canyon's risk assessment, if assigned a high priority, will be due no later than April 2018.
- 8. When does the FSAR need to be updated with new seismic information?
Per the requirements of 10CFR 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 46 6f"FlelAL tJ91!! 6HLV - 91!N91Tl't'I!! INTl!f\NAL 1Nrel'!MATl6f4
6ffle1Al t:1Se 6NLY w !l!f491TIVI! lf4T!!ftf4AL INP'eftMATl@ff 50.54(0 Questions
- 1. When was the 50.54(f) letter issued?
March 2012.
- 2. What is the purpose of the seismic 50.54(f) letter?
Diablo Canyon is being required to reevaluate the seismic hazards at their site. This reevaluation uses both modern methods and updated information. Additionally, Diablo Canyon is required to provide an assessment of the plant's ability to cope with the reevaluated hazard. The NRC will use this information to determine if additional regulatory action is appropriate.
- 3. When is Diablo required to provide a response?
No later than March 2015.
- 4. What actions will be required following the NRC's review of Diablo's response?
For facilities in the Western United States, within approximately 30 days of receipt of the last submittal, the NRC will determine the acceptability of the licensee's 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 Diablo Canyon already have a Seismic PRA? If so, why is their completion date April 2018?
The March 12, 2012 orders (http.//pbadupws nrc.gov/docs/ML 1205/ML12053A340 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.
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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 NRC has followed the seismlc re-evaluation process since the beginning at DCPP. The NRC will continue to evaluate seismic data to ensure our understanding of the seismic hazard is informed and that there is no new challenge to safety.
By following the rigorous NRG-approved process, which will take several years. It is expected that PG&E will produce a single seismic hazard analysis for NRC review using the latest available methods. If approved by the NRC, these results can then be used to clarify the Diablo Canyon seismic licensing basis.
10 CFR 100.23, paragraphs (c) and (d) require that the geological, seismological, and engineering characteristics of a site and its environs be investigated in sufficient scope and detail to permit an adequate evaluation of the Safe Shutdown Earthquake (SSE) Ground Motion for the site. In addition, 10 CFR 100.23, paragraph (d)(1 ), "Determination of the Safe Shutdown Earthquake Ground Motion." requires that uncertainty inherent in estimates of the SSE be addressed through an appropriate analysis such as a probabilistic seismic hazard analysis (PSHA).
In response to these requirements, in 1997, the NRC published NUREG/CR-6372, "Recommendations for Probabilistic Seismic Hazard Analysis: Guidance on Uncertainty and the Use of Experts." Written by the Senior Seismic Hezard Analysis Committee (SSHAC),
the NUREG provides guidance regarding the manner in which the uncertainties in PSHA should be addressed using expert judgment.
The SSHAC Level 3 process uses a panel of independent experts to study all available seismic data, identify the need for new data, and use the latest seismic analysis tools to develop a Seismic Source Characterization (SSC) and Ground Motion Characterization (GMC) in creating a risk-informed seismic hazard estimate (i.e. the PSHA). The NRC was intimately involved in the development of this formal methodology. This is a new method that did not exist at the time of licensing for the current generation of nuclear power plants, but is now required for applicants seeking a new reactor license.
- 8. Why is the NRC giving the Western U.S. plants more time (than the Central and Eastern U.S.) to complete their seismic reevaluation when the seismic 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 perform a seismic hazard reevaluation) takes 3 - 4 years.
The SSHAC study produces the seismic hazard models that are needed to perform the seismic reevaluation. When Fukushima occurred, the Central and Eastern US plants (CEUS) were in the middle of conducting a SSHAC Level 3 study sponsored by the NRC, DOE, and EPRI, so when the 50.54(f) letters went out the CEUS already had the models they needed to perform the seismic reevaluation, which is why we gave them a shorter period of time to respond to the 50.54(f) letter.
Page 48 OFFl0lit.L l::1SE ONLY w SEP4S"l'IE UJ1'Eftf4AL IUF@RMh'fl8FJ
6fifilelilcl tJSE 6HLV 9EN91'fl't'E IH'fERNAL 1Nfi6RM>'c'fl6N The Western U.S. does not have a regional model like the CEUS - so the NRC required all Western U.S. plants to complete a SSHAC level 3 study in order to develop site-specific seismic hazard models. The Western U.S. plants were given three years to complete the SSHAC study and their seismic reevaluations. This is a significant amount of work to complete in three years and is realistically the fastest timeline that the Western U.S. plants would be able to adhere to while still following the rigorous requirements of a SSHAC level 3 study.
- 9. Why does the NRC believe 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 (NTTF} report concluded that with the current regulatory approach and the current plant capabilities, the sequence of events which occurred at the Fukushima accident are unlikely to occur in the United States. While the NRC concluded that the NTTF recommendations would enhance safety, the staff determined that none of the NTTF report findings identified an imminent hazard to the public health and safety. As such, continued safe operation of nuclear power plants is warranted while the safety improvements required by the orders are implemented.
- 10. Why did the NRC approve industry's request for a six month extension in submitting the Central and Eastern U.S. seismic reevaluations?
The seismic hazard reevaluations for the Central and Eastern U.S. (CEUS) were originally due 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 will be fed into the SSHAC study and hazard re-evaluation as part of PG&E's response to the 50.54(f) letter.
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- 12. In an October 12, 2012, letter to Diablo Canyon, the NRC states that "The NRC recognizes that using the ODE 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 DOE/SSE earthquake using the methods specified in the SSE/DOE?
No. The quoted statement is referring to a comparison the NRC requested licensees make in 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 DDE for Diablo Canyon) and as-built design margins. The NRC specifically requested that licensees compare the results of their seismic re-evaluation to the DDE/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 NRG-specified process may result in higher ground motion when compared to the DDE/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 DDE, 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 DDE. 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 Hosgrl fault and the Shoreline fault in the re-evaluation will likely result in a seismic hazard that exceeds the DDE, 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 independently assess the new information and determine if it changes the staff's current position that ground motion associated with the Shoreline fault is at or below the HE.
Page 50 8ffl81AL l:f8E 8ftt¥ 9EH91fl'tf lf4'ERf4AL lf4F6RMA'f16N
ePPlelAL ~81! eutv 8EH81flVE IN'fERNAL 1Nf6RMATl6N
- 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 you better characterize the ground motions (shaking at the site).
Specific new studies being conducted by PG&E for seismic source characterization (most have already occurred):
- Onshore 20/30 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 20/30 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 30 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 30 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 resources. 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 51 o,,ie1,ct tlSI ONLY S!!NSITl't! INT!I.U~AL INPOflMATION
6fflCIAL tJSE 6HLY SENSITIVE lf4TER:NAL IHF6RMATl6N Non-Responsive Record Page 52 6FFICIAL tJSE 6NLY SENSITIVE. lf4TERHAL INF6ftMATl6N
Ol'flCIAL t:191: 6NL't' SEN91'Fl'IE IN'FERt4AL INFORMA'FION Non-Responsive Record Page 53 6F,tCIAL t19E 6NLY - SEf4Sl'fl't'E IP4'fEft.H"L IHF8~M,lc'flC"4
eFFlelAL ~9E 8P4l¥ 9!ff81TIV! IHT!RUAL 1141'0RMATION Non-Responsive Record Page 54 8FFl81AL ij8E @ULY 3EN31TIVl; INTl:RN*t 1Nf 6ftMAI16N
8FFl81AL ~8[ 8UL¥ 8fft91TIVE m,eRUAL IUF9RMATl9U DCPP Licensing Basis Verification Proiect (LBVP)
[From Licensee Status Briefing 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 objective 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.
Obiectives
- 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 deficiencies in these systems.
- 8. Provide an updated tool to aid in operability determinations.
Who Is Involved with the LBVP?
PG&E Oversight with work done by Chicago Bridge and Iron (CB&I - formerly Shaw, Stone & Webster), partnered with Westinghouse (DCPP NSSS Supplier). CB&I has the lead. Westinghouse is responsible for various FSAR sections including Accident Analysis Chapter 15, RCS, RHR, Reactor, and others.
- Phase I (February - October 2010)
Phase I of the LBVP reviewed and evaluated design and analysis changes to the Component Cooling Water (CCW) and Auxiliary Feedwater (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 55 eFFICIAL tlSE eNLY SEN!ITlttE IWfE"NAL INFeftM,UleN
eFFlelAL tJSE eHLY w SEl4SITl't'E IWfEftf4;1ct IUF6ftM:lt'fl@U findings, lessons learned, and recommendations, all of which was addressed in the Phase I summary Report.
Licensing 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 with licensing basis requirements. LBR reviewed internally by PG&E and by an Independent Review Board.
System Reviews Following the LBR, validate the licensing basis requirements and FSAR implementation into plant documents (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 NRC.
Current schedule DCPP committed to the NRC to complete the LBVP by 12/31/2015. Completion clarified in document DCL-12-003 as follows: Completion of LBVP Phase II includes completion of applicable licensing basis reviews, system reviews, component design basis report reviews, electronic database upgrades, implementation of new current licensing basis search tools, and correction of licensing basis deficiencies that do not require prior NRC approval. In addition, completion of LBVP Phase II includes submittal of License Page 56 Of'FlelAL ~SE er~LV SEf4Slfl't'E lt4TffU4AL U4F@RMAf18fJ
Amendment Requests (LARs) and initiating design changes. The completion of the design changes and the receipt of approved LARs will extend beyond the completion date of December 31 . 2015.
NRC Conclusions (as of Sept. 2013}
- 1. The licensee is performing a good review of their Licensing Basis.
- 2. They are identifying and correcting errors.
- 3. They continue to evaluate and improve the LBVP process
- 4. The process is not perfect. The NRC is still identifying problems with Licensing Basis Documents and how the licensee implements their licensing basis.
- 5. The Summer 2013 Component Design Basis Inspection (Inspection Report 2013-007) noted a significant improvement in Licensing Basis Documents at the site.
Page 57 err1e1At tl!I! erRY w !l!H!ll'l\11! INl'!ftf~AL INFOftMATION
6FFl61Jlct tJSE 6HLY SEHSlfl't'E IHfffU4JlcL IP4F6ftMitcfl6H Non-Responsive Record Page 58 6FFlelAL t:19e eNLY 9f!f481TIVE lffTl:fU4AL IW"6ftMA?l6f4
OfflCIAL tJ3t: CNbV lfrt81l'l¥1!! IUl'EfU4AL U4F6~MA'fl6H Public Cancer Risks Refer to "Communications Plan: Analysis of Cancer Risks in Populations Living Near Nuclear Facilities - Phase 2 Pilot Studies* (ML13274A664), maintained by RES, for the most current information.
The following 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 Regulatory Commission (NRC) asked the National Academy of Sciences (NAS) to conduct this study now?
- 03. Which seven sites will be included in the pilot study?
- 04. Which additional nuclear facilities could be 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?
- 014. 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?
Page 59 err1e1AL t:ISE 6HL'f 9Ef491TIVE! IUTl!fUJAL IHl'OfUlilATIOU
91'1'1elAL t:191!! 6HLY 9l!!HS1Tl't11!! lf4Tl!!ftf4AL IHl'9ftMATl9f4 Emergency Preparedness Concerns
..... NOTE - The following is predecisional, non-public information, with the exception of the Unresolved Item that was included in the 4Q/2013 Resident Inspector Report which initially described this potential issue.
Background
In November 2005, Diablo Canyon Power Plant revised its emergency plan without prior NRC approval. This change removed a table used 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 may have reduced the effectiveness of the plan and required NRC approval prior to implementation. This issue is currently being evaluated using our significance determination process and through traditional enforcement.
Kev 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.
- 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
- 1. Has there been a situation between November 2005 and when this issue was discovered in late 2013 where PG&E failed to make a required Protective Action Recommendation over the ocean areas?
- UNDER DEVELOPMENT ***
- 2. Why did it take so long for this issue to be identified : (a) by PG&E? (b) by the State?
(c) by the NRC?
Page 60 OfflCIP.b tj8E @UL¥ 9EH81'flVE lf4fEfU4,tcL lf4fl0RMATION
ePPlelAL tJ8E 6NLY - 9Et491ll'il! INTERNAL IP~f6RMATl6N 0
" UNDER DEVELOPMENT "**"'
- 3. What actlon(s) has the licensee taken to fix this problem?
"** UNDER DEVELOPMENT *it*
- 4. What actions(s) will the NRC take against PG&E for this violation?
- UNDER DEVELOPMENT ***
- 5. The process for emergency plan changes sounds broken. If public health and safety is your overriding mission, why doesn't the NRC review and approve all emergency plan changes?
it** UNDER DEVELOPMENT ***
Page 61 8ffle1AL ~8E 8ULV Sl!NSITl't'I! INTl!ftNtcL INfiCftMATICN
From: Markley, Michael Sent: Monday, September 08, 2014 3:08 PM To: Wertz, Trent Cc: Oesterle, Eric; Lund, Louise; Singal, Balwant; Walker, Wayne; Pruett, Troy; Dapas. Marc; Evans, Michele; Uhle, Jennifer; Dorman, Dan; OKeefe, Neil
Subject:
RE: DPO Release Review
- Trent, We reviewed all of the items in DPO Case File (DP0-2013-002) and have no objection to releasing the DPO Case File to the public in its entirety. If the DPO submitter requests that the DPO case File be released to the public and does not request his name or other personally identifiable information to be withheld, we find no other apparent information that would qualify for withholding. We recommend that the NRR Director notify OE that our releasabillty review is complete and can DPO Case File be released In the its entirety.
According to the guidance for the releasability review of DPO Case Files, OE will seek input from the DPO submitter on whether the individual would like the DPO Case File non-public or public. OE will also seek release authorization from OGC and 01 .
Michael T. Markley, Acting Deputy Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-5723 From: Wertz, Trent Sent: Monday, September 08, 2014 1:10 PM To: Markley, Michael; Oesterle, Eric
Subject:
DPO Release Review Importance: High Mike/Eric, Dan Dorman told me that the EDO is looking to Issue his decision on the DPO appeal this afternoon. Are we in a position to let OE know that the file can be released in its entirety?
- Thanks, Trent L. Wertz Technical Assistant Office of Nuclear Reactor Regulation 301-415-1568 trent. wertz@nrc.gov
From: Markley, Michael Sent: Tuesday, September 09, 2014 3:40 PM To: Pedersen, Renee; Dorman, Dan Cc: Wern, Trent; Uhle, Jennifer; Evans, Michele; Case, Michael; Holahan, Patricia; Solorio, Dave; Sewell, Margaret; Lund, Louise; Oesterle, Eric; Singal, Balwant; Walker, Wayne; Dapas, Marc; Pruett, Troy
Subject:
RE: ACTION: Need Approval for Public Release of DPO Case File
- Dan, We have reviewed the updated DPO Case File with the NRR Director's Statement of Views and EDO's Appeal Decision. We continue to believe the DPO Case File can be released in its entirety without redaction. With your approval, the DORL staff will work with OE to make the DPO Case File publicly available and forward an EDO Daily Note when the documents are available publicly.
Michael T. Markley, Acting Deputy Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-5723 From: Pedersen, Renee Sent: Tuesday, September 09, 2014 2:53 PM To: Dorman, Dan Cc: Wertz., Trent; Uhle, Jennifer; Evans, Michele; case, Michael; Markley, Michael; Holahan, Patricia; Solorio, Dave; Sewell, Margaret
Subject:
ACTION: Need Approval for Public Release of DPO case File Importance: High
- Dan, The EDO has issued his decision and the employee has asked that the DPO Case File be made available to the public.
We have previously communicated with your staff and they indicated that they did not see the need for any redactions in the DPO Case File.
In accordance with the guidance in MD 10.159, you are responsible for ensuring that information is appropriately released to the public.
Therefore, please confirm that you support public release of the complete DPO Case File.
If you have any questions, please let us know.
We are hoping to get this declared as a public OAR ASAP so it will be available to the public by tomorrow.
Renee
From: Markley, Michael Sent: Wednesday, September 10, 2014 8:46 AM To: Pedersen, Renee Cc: Oesterle, Eric; Solorio, Dave; Sewell, Margaret; Wertz, Trent
Subject:
RE: ACTION: Need Approval for Public Release of DPO Case File
- Renee, Very good. The licensee is making its new seismic report available at 11 :00 a.m. PDT (2:00 p.m. EDT). We would like the DPO to be available before that time.
Mike From: Pedersen, Renee Sent: Wednesday, September 10, 2014 8:29 AM To: Markley, Michael Cc: Oesterle, Eric; Solorio, Dave; Sewell, Margaret; Wertz., Trent
Subject:
RE: ACTION: Need Approval for Public Release of DPO case File
- Mike, I'm sorry if there is a misunderstanding about the process. I thought I explained this before that NRR does the review of existing records and provides approval for discretionary release, but OE has responsibility for creating and releasing the stand-alone DPO Case File record. (Trent is familiar with our process.)
We have been working closely with OEDO and have taken action to have the DPO Case File available for immediate public release. We did this last night and it should be available later today. I hope this addresses your concern.
Renee From: Markley, Michael Sent: Wednesday, September 10, 2014 8:08 AM To: Pedersen, Renee Cc: Oesterle, Eric
Subject:
RE: ACTION: Need Approval for Public Release of DPO Case File Importance: High
- Renee, Please call me. The MD states that the DPO PM makes the DPO Case File Publicly available. Your e-mail seems to state that NRR is responsible for making the Case File available publicly. We could do that except that the DPO Case File I saw in ADAMS this morning still does not have the NRR Director's Statement of Views or EDO's Appeal Decision loaded into the case file. This needs to be made publicly available this morning in advance of the release of the new DCPP seism ic report.
Please call me at 415-5723 as soon as practicable this morning. I have several meetings, if you miss me, please call Eric Oesterle at 415-1014.
Mike Markley The rest of this email string may be found as document U7. in interim response #5 in FOIA/PA-2014-0488 (ML15224774).
From: Buchanan, Theresa Sent: Monday, August 25, 2014 10:23 AM To: Oesterle, Eric Cc: Hipschman, Thomas; Reynoso, John; Walker, Wayne; Uselding, Lara
Subject:
FW: Can you get back to Eric on his Q2? FW: COMMUNICATIONS STRATEGY ON STATE REPORT Importance: High Eric.
My understanding is that PG&E has already entered this new information into their corrective action program and have determined that the previous operability assessment performed when the shoreline fault was initially discovered is still bounding, HOWEVER, they will be updating the original operability assessment to include the new data. They will not specifically give the NRC the operability assessment, but the residents can review it as part of their normal activities. Tom/John, feel free to correct me if I misunderstood.
Theresa Buchanan Senior Project Engineer RIV DRP Branch A 817 -200-1503 From: Oesterle, Eric Sent: Monday, August 25, 2014 8:49 AM To: Uselding, Lara
Subject:
RE: COMMUNICATIONS STRATEGY ON STATE REPORT Hi Lara, I had a chance to look over the attached and find it pretty good. I would rephrase one of our key statements as follows "Simply put. it produces more energy but over a wider area which is why the NRC agrees that it is still bounded by the Hosgri fault."
Also, sort of consistent with Mike's comments about t1meline. it was not clear to me exactly when PG&E will provided seismic report to NRC Does PG&E also plan to provide Operability Assessment to NRC at same time they provide report to NRC?
Eric From: Uselding, Lara Sent: Thursday, August 21, 2014 4:53 PM To: Oesterle, Eric Cc: Walker, Wayne; Hipschman, Thomas; Singal, Balwant; Burnell, Scott; Brenner, Eliot; Markley, Michael
Subject:
COMMUNICATIONS STRATEGY ON STATE REPORT Importance: High Eric: The Region has put together the attached messaging and Q&A for the report we expect to receive next week. We want to share that with you and get your insights prior to us briefing Marc Dapas Monday morning.
Could you take a look and let me know your thoughts?
Remember, this is what I will use to respond to questions next week from the public and reporters. OPA's plan is to NOT issue a press release, or a blog but to take questions as they come in. We already have a communications plan on Diablo so the attached will be incorporated into the existing comm plan. No other action is needed on that front.
We can have a call to discuss strategy with the involved parties from RIV and HQ at your convenience.
Lara Usclding I .,.1\11,kar lh-~uluh*r) l ,11111111\,HIII ,, l(L l 1uhl1(* .\ lbu, Rcc11111 I\ . \il,11:_.?h" l .:,.a, 817.200. 15 19 lara.uselding@nrc.gov 2
From: Williams, Megan Sent: Wednesday. October 01, 2014 9:57 AM To: Baca, Bernadette
Subject:
Electronic documents requested for FOIA 2014-0488 Attachments: Draft mini-Comm Plan on DCPP DPO_final.docx Importance: High From: Oesterle, Eric Sent: Wednesday, September 10, 2014 11:32 AM To: Sebrosky, Joseph; Markley, Michael; Munson, Clifford; Stovall, Scott; Kock, Andrea; Williams, Megan; Li, Yong Cc: Well, Jenny; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, 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; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittick, Brian; Harris, Brian; Roth(OGC), David; Kanatas, Catherine; OKeefe, Neil
Subject:
Comm Plan for DPO & Appeal Importance: High
- Everyone, Attached for your use and for Region to fold into their "living DCPP Comm Plan" is the DPO & Appeal Comm Plan. It has been extensively coordinated with the Comm Plan for the PG&E Seismic Report (AB 1632) that is being issued today. The EDO has provided his decision on the DPO Appeal and the DPO Case File has been made public. As a result of these actions, we are issuing this DPO Comm Plan for timely use. If you have any questions please contact me. Thanks.
fri,c;'R. O~e-v~
Acting Branch Chief NRR/D0RL/LPL4-1 301-415-1014 From: Sebrosky, Joseph Sent: Wednesday, September 10, 2014 10:44 AM To: Markley, Michael; Munson, Clifford; Stovall, Scott; Kock, Andrea; Williams, Megan; Li, Yong; Oesterle, Eric Cc: Weil, Jenny; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, 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; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson,
From: Kock, Andrea Sent: Wednesday, September 10, 2014 7:32 AM To: Flanders, Scott
Subject:
Fw: info: status of public release of Diablo Canyon State of California report Attachments: nrr dd 9-9 diablo brief.docx Note: The attachment is part of document C/27 in interim response #2 in FOIA/PA-2014-0488 (ML14322A751).
Fyi- the diablo canyon seismic report will be released today. Cliff has had substantial input to the communication plan PG andE will not be able to provide information to support a CDF conclusion so cliff Is looking at doing a deterministic analysis and comparing to the hosgri.
Sent from NRC blackberry Andrea Kock (b)(6)
From: Sebrosky, Joseph Sent: Tuesday, September 09, 2014 12:18 PM To: Markley, Michael; Munson, Clifford; Stovall, Scott; Kock, Andrea; Williams, Megan; Li, Yong; Oesterle, Eric Cc: Weil, Jenny; Manoly, Kamal; Lund, Louise; Dudek, Michael; case, Michael; Burnell, Scott; Hay, Michael; Franovlch, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazik, Michael; Slngal, Balwant; Farnholtz, Thomas; Kanatas, Catherine; Hipschman, Thomas; Reynoso, John; Ake, Jon; Folk, Kevin; DIFrancesco, Nicholas; Balazfk, Michael; Reynoso, John; Hill, Brittain; Walker, Wayne; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittick, Brian; Harris, Brian; Roth(OGC), David; Kanatas, catherine; OKeefe, Neil; Uhle, Jennifer; Lund, Louise
Subject:
Info: status of public release of Diablo canyon State of California report To all.
Based on my discussions with Philippe Soenen of PG&E, PG&E is targeting the public release of the State of California report for 11 :00 am Pacific time (2:00 pm eastern) on 9/10/1 4. PG&E intends to do the following:
- Issue an announcement
- Issue a press release
- Make the document publicly available on their website
- Provide a hard copy to the County
- Walk a copy of the repon to us to be provided to the document control desk 1n accordance with 1o CFR 50.4 requirements On a different note, Mike Markley, Eric Oesterle, and I briefed Jennifer Uhle on the status of Diablo seismic issues using the attached briefing sheet.
No action required on your part. Thought you should know.
Let me know if you have any questions.
- Thanks, Joe Sebrosky 301-415-1 132 1
Subject:
Drop-In w/ Pacific Gas & Electric r::::-1 Location: 0 -13D20 'Bridgeline: 888-452-5138; Passcode~
Start: Fri 08/22/2014 1:00 PM End: Fri 08/22/2014 2:00 PM Show Time As: Tentative Recurrence: (none)
Meeting Status: Not yet responded Organizer: Dorman, Dan Required Attendees: Uhle, Jennifer; NRR-OWFN-13020-15p; Lund, Louise; Hiland, Patrick; Davis, Jack; Markley, Michael; Oesterle, Eric; Singal, Balwant; Case, Michael; Ake, Jon; Munson, Clifford Optional Attendees: NRR_ET_Activity Resource; Bamford, Peter; Nichols, Chelsea; Schwarz, Sherry; Cohen, Shari; DE_Calendar Resource; DORLCAL Resource; Flanders, Scott; Whaley, Sheena; Kock, Andrea; NRR_JLD Resource; Lubinski, John; Ross-Lee, MaryJane; Manoly, Kamal 08/20/2014 - Update -
Bridgefine Information 888-452-SpB--,
Passcode~
Requested by Peter Bamford (2833)
Licensee for Diablo Canyon - meeting is or, seismic Pacific Gas and Electric management plans to update NRR management regarding a seismic report that will be submitted to the State of California pursuant to CA Assembly Bill 1632. The licensee plans to update NRR management with a high level summary of the results of the study and discuss the licensee's plans going forward. The licensee has indicated that the study will likely conclude that the Shoreline fault could be longer (and thus more capable) than previously believed, but they believe the overall earthquake loads would remain bounded by the site's existing Hosgri fault analysis. A copy of the CA Assembly Bill 1632 report will also be submitted to the NRC.
From: Hill, Brittain Sent: Wednesday, August 27, 2014 857 AM To: Kock, Andrea Cc: Flanders, Scott; Jackson, Diane
Subject:
FYI: Review of updated Diablo communication plan & seismic report Just to keep you 1n the loop, I'm currently helping NRR/RIV a bit with their communication plan for Diablo and the new CA Coastal Commission report, which is due to be released on 9/8 or 9/9.
Joe Sebrosky asked if Jon Ake and I could take a quick look at the report via the Diablo electronic reading room (next week?), to see if there are any showstoppers in the new analysis of Shoreline Fault ground motions. I have time to do this, and have let Joe know I can lend a hand and help align their communication plan with key results of the 1000-page report.
Am also working with Eric Oesterle on potential communications for the DPO on Diablo, as there's a sense that EDO may make determination around end of month. Results likely are relevant to the Coastal Commission report and associated NRC actions/communications.
Thanks-Britt
Original Message-----
From: Oesterle, Eric Sent: Wednesday, August 27, 2014 8:10 AM To: Sebrosky, Joseph; Markley, Michael; 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:
RE: action: Review of updated communication plan and proposal to ask PG&E to provide draft copy of report in an electronic reading room Joe, et al Just confirming the discussion this AM with Mike Markley that we agree that setting up an electronic reading room with limited access rights for NRC staff to look at a draft copy of PG&E's report to CA is a good idea.
Also, as we discussed this am, please find attached to updated comm plan a proposed question acknowledging the existence of the DPO without getting into details of its contents. I believe it is consistent with recent OPA talking point and we should get OGC eyes on it as well. Thanks.
Eric
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, Neil; Folk, Kevin; Wrona, David; Difrancesco, Nicholas; Balazik, Michael; Hipschman, Thomas; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara ;
Lyon, Fred The rest of this email string may be found as document L/55 in interim response #5 in FOIA/PA-2014-0488 (ML15224A774).
From: Weil, Jenny Sent: Thursday, August 28, 2014 5:38 PM To: Hipschman, Thomas Cc: Moreno, Angel
Subject:
RE: info: updates to Diablo Canyon shoreline fault seismic communication plan -update to 1st item Thanks Tom Could you add Angel Moreno to your list? He is the new congressional affairs officer who will be taking over Region IV plants (I'll be his backup).
Hope it's another sunny, beautiful day in California.
-Jenny From: Hipschman, Thomas Sent: Thursday, August 28, 2014 4:32 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; Balazik, 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 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 8th. The specific details whether this would require an in-person review or electronic reading room access 1s 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; Manely, 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.
Status l
- 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 9/10. 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 At + 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:
"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 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 NRG staff's March 12, 2012, request for information."
- 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 devel,oped 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 39
From: Uselding. 1ara To: Walker Wayne ; Sebrosky Joseol]; Markley. Michael; Buchanan Theresa; Alexander Rvan Cc: Pruett Troy: Hay Michael
Subject:
See this link to more Info on state report Date: Wednesday, September 10, 2014 2:12:31 PM Today PGE issued a seismic study report to the state per Assembly Bill 1632. The PG&E report , press release, and additional information can be found hem..
From: Nc-~wtcr 3r*W To: lbl<Naao Jbs"S)I)
Subject:
RE: SPE Turnover (Week of 9/ 2)
Daile: Sunday, September 07, 20lq 3:3 1:00 PM Theresa:
I do hope your week away was restful and your mind is clear A handful of things but you should have been on every key e-mail shifted around this week
- 1. We were responsible for getting the 2 Luminant Letters into ADAMS since HQ was not the addressee. No big deal just a lesson learned.
- 2. The CP CAL Closure Letter (short version) has gone into concurrence. However, Wayne & I are still worried that despite Troy's direction, when the "short version" gets to Dapas he may balk at it and want a more traditional CAL closure letter that lays out the whole story. As such, I updated the LONG VERSION of the letter that is saved in S:\DRP\PBA\_CPNPP\SFP CAL 4 004<file://fl\nrc.gov\nrc\R4\shared\DRP\PBA\_CPNPP\SFP%20CAL%204-12-004> as a backup in case that happens.
- 3. Sebrosky wants us to hold on the OVERALL DC Comm Plan until no earlier than 9/9 after the review team gets a quick review of the AB-1632 report, and Joe is able to tweak his mini-comm plan for that section. The most current AB -1632 work plan and mini-comm plan received from Joe was saved in the S:\DRP\PBA\_DIABLO CANYON\Comm Plan\Other Office lnputs<file:///\\nrc.gov\nrc\R4\shared\DRP\PBA\_DIABL0%20CANYON\Comm%20Plan\Other%200ffice%201nputs>
folder, both dated 9/4/14@ 11 :43 AM. Speaking of subfolders, see below .. .
- 4. With all of the inputs we are/may be getting and several iterations loo, I cleaned up the Comm Plan folder and would suggest that we keep it as such so that Wayne knows exactly which Is the current copy:
Main folder - keep only the CURRENT working MS Word version, the current "distributed/PDF version* (see #7 below), and the ADAMS Submission Form and Concurrence Routing Memo Subfolder - PBA Drafts - if you make a significant change to the working version, save that in the main folder with a new date & move the old version into this folder Subfolder - Other Office Inputs - After integrating the input to the main wori<ing copy, this ,s where I tiled all of Joe S.'s inputs, the Sewell mini-input, & the draft EP mini etc 4, Also, ii sounds like the DPO appeal decision may be released next week too, so Joe has engaged NRR to determine who should update the DPO portion of the comm plan. If NRR/EDO does it. I was thinking we could change our OVERALL plan lo just reference that plan instead (like we do others) since I'm sure NRR/EDO will get OE's buy-in on that Comm Plan and we don't want to be stepping on toes.
Non-Responsive Record
- 6. I also created additional questions for the EP Concerns section - I understand that DRS briefed Dapas on Wednesday & they are moving forward with one SUit/associated White. However, the EP issue will not be final until at least the end of September, so Wayne wants us to have a placeholder for the EP issue ONLY in the version that we send out for concurrence next week. The current version of the Overall Plan is saved with today's date (9/5/14) . Look at my e-mail to you and Gilbert from around 11 :25 AM on 9/5 for more Info.
- 7. You will note there is a PDF version of the Comm Plan in the folder "Diablo Communication Plan
- NO AB 1632, DPO Update, or EP Issue (9 14).pdf' That is the version that we sent out to David McIntyre (OPA) and Cindy Pederson (RIii RA) this week per speclal requests/direction by Dapas. As noted that version only has limited AB1632 and EP issue info, & no updated DPO info. If we get any additional "special requests* for the Comm Plan prior to the completing the concurrence process. this version may be the best choice to share. rather than our "Working version".
I think that's all of it... Sorry not sending this until I got to Chattanooga today!
Talk to you soon.
Ryan
--- -Original Message---*-
From: Buchanan, Theresa Sent: Friday, Au.g ust 29, 2014 2 :52 PM To: Alexander, Ryan Subject RE: SPE update Ryan.
There are a bunch of e-mails related lo DC and the DPO/seismic/Friends of the Earth 2.206 petition, too many to send to you. I'm sure Wayne will send you anything you need.
Joe Sebrosky's been pulled out of the JLD to work on the DC seismic study "mini comm plan" (which will be incorporated into our "master" comm plan when finished). He's also working on a review plan.
I'm going to send Joe an e-mail to put you in the cc chain for the DC e-mails.
For the CP SFP CAL, the other item that's needed is the ML number for the CP letter telling us they've met the requirements of the CAL. The letter is on my desk if you want to read it. That ML number will need to go into the enclosure of the report (similar to the list of Docs reviewed in inspection reports) . I keep checking ADAMS but it hasn't been input yet or something.
I think that's it, I will NOT be checking e-mail while on vacation, so if there's something I'm missing, talk to
- Wayne, Theresa
- ---Original Message---
From: Alexander, Ryan Sent: Thursday, August 28, 2014 7 :14 PM To: Buchanan, Theresa
Subject:
RE: SPE update
Theresa:
Thank you for the turnover. I have been watching the media since the DPO was leaked - lovely, just freaking lovely!'
And it should be interesting what NRR comes up on the AB1632 report.
Challenge board for findings? Is this a new DRP process or are you referring to the internal branch debrief??
And no problem on the abbreviated CAL closure letter. I will work to get Troy's eyes on it.
Ryan D. Alexander US NRC, Region IV 0 : 817-200-1195 cj___ (b_)<6_) _ ...
From: Buchanan, Theresa Sent: Thursday, August 28, 2014 14:37 To: Alexander, Ryan
Subject:
SPE update Ryan, I'm still going to try to send you a turnover tomorrow, but just in case:
The big thing going on right now is Diablo. NRR has the lead for the comm plan pieces associated with the AB 1632 report. Once they get those, please keep our master comm plan updated. I'll try to remember to send ari e-mail to Joe Sebrosky tomorrow to make sure that he keeps you in the loop next week on this.
Also for next week, Troy preferred the short version of the CP SFP CAL closure letter (titled the same but with the word 'alternate'). He's been out of town, but if he's in next week, try to get comments and get that ready for issuance.
The end of the quarter is rapidly approaching and a challenge board needs to be scheduled for any repon
violations. I'll try to talk to Wayne today and see if we can't get something set up before I leave (hopefully for next week).
Just to keep this in mind once you're back for good: Because of the NOED, Tom needs to remember to put a URI into the Inspection report (required by the NOED manual chapter). The in-process checklist is on my desk if you need it for anything, but I don't think you will.
Actually, that's pretty much the turnover. I'll let you know if there are any changes or updates tomorrow.
Otherwise, have a good Labor Day.
Theresa Buchanan Senior Project Engineer RIV DRP Branch A 817-200-1503
From: Wk!Jn~
To: MarklrY Michael; scbeoskv, Jowoh; Lund, I ou1se; Walker, Wayne Cc: Alexander Ryan
Subject:
RE: FYI : DCPP OPO Appealed to EDO Date: Friday, July 11, 2014 7:53:49 AM Hey thanks for this update. So now we wait another 30 days for EDO response and then a SUNSI review of final before releasing to public, correct?
From: Markley, Michael Sent: Friday, July 11, 2014 6:54 AM To: Sebrosky, Joseph; Lund, Louise; Walker, Wayne Cc: Uselding, Lara
Subject:
FYI: DCPP DPO Appealed to EDO Louise, Joe, I ran into Mike Case this morning. I asked if Michael Peck had appealed the DPO Panel's findings to the EDO. He said. "Yes, Michael Peck did appeal to the EDO." Mike Case said they would need to prepare another briefing, etc.
Just an update.
Mike
From: Weit, Jl!nny To: Markley. M1chact; Darns Eugene; Powell. Amy; Moreno. Angel; wa1ker. wavnt'; Umsct,man. Tt10mas; ~
John; SN1tosky lQSCJlb: 0,:,st\'rle t;rrr,
Subject:
RE: Diablo report Date: Friday, August 29, 2014 1:18:07 PM Correct. I told her we do not have a copy of the report. She is going to contact PG&E directly.
Original Message*****
From: Markley, Michael Sent: Friday, August 29, 2014 1:17 PM To: Weil, Jenny; Dacus, Eugene; Powell, Amy; Moreno1 Angel; Walker, Wayne; Hipschman, Thomas; Reynoso, John; Sebrosky, Joseph; Oesterle, Eric
Subject:
RE: Diablo report By the "report," I presume you mean the PG&E seismic report. We are told that the licensee Will not give us an advance copy and that the NRC will receive it at or about the same time as the State of California on 9/9 or 9/10.
Mike
Original Message-----
From: Weil, Jenny Sent: Friday, August 29, 2014 12:15 PM To: Dacus, Eugene; Powell, Amy; Moreno, Angel; Walker, Wayne; Hipschman, Thomas; Reynoso, John; Sebrosky, Joseph; Markley, Michael; Oesterle, Eric
Subject:
Re: Diablo report Just an FY1 -- the staffer to Sens. Markey and Boxer has already gotten wind that the report is coming.
Original Message-----
From: Freedhoff, Michal (EPW)
Sent: Friday, August 29, 2014 12:07 PM To: Weil, Jenny Cc: Freedhoff, Michal (EPW)
Subject:
Dlablo Jenny I hear the state-mandated report on Shoreline is about to be released. Does NRC have a copy, and if so can you please send it my way?
Thanks Michal
Fn>m: Orf, Tracy To: MarkleY, Michael: Oestc:rle E!!c; Singal Br1lwant
Subject:
FW: Oiablo Canyon DPO Date: Monday, August 25, 2014 11:47:29 AM FYI From: Wertz., Trent Sent: Monday, August 25, 2014 11:16 AM To: Orf, Tracy
Subject:
FW: Diablo Canyon DPO See below regarding the Communication Plan for the Diablo Canyon DPO. OPA may have some good input.
From: Pedersen, Renee Sent: Monday, August 25, 2014 11:12 AM To: Wertz., Trent Cc: Sewell, Margaret; Solorio, Dave
Subject:
RE: Dlablo Canyon DPO Trent.
OE has generic DPO FAQs on our internal Web site. We"d recommend that your communication plan include a link to them because they can be a helpful source of information for OPA.
OPA was very helpful 1n generating challenging questions for our NCP Assessment. I"d recommend that you let them get familiar with the case and help identify cha llenging questions. such as "Why did this case take so long?"
Renee From: Wertz., Trent Sent: Monday, August 25, 2014 10:56 AM To: Pedersen, Renee Cc: Sewell, Margaret; Solorio, Dave
Subject:
RE: Diablo Canyon DPO
- Renee, We are working on the Comm plan. Do you have any FAQs you would want to include on the OPO process?
- Thanks, Trent From: Pedersen, Renee Sent: Tuesday, August 19, 2014 10:30 AM To: Wertz., Trent Cc: Sewell, Margaret; Solorio, Dave
Subject:
RE: Diablo Canyon DPO
- Trent, The EDO has not issued a Decision yet. We'll reach out to the EDO's office and see if we can confirm an expected issue date. Because of the interest in this case, as we've mentioned before, NRR should consider having a communication plan ready when the DPO goes public in the WIR By process, after the decision is issued, we'll ask the submitter if he wants the case file public, which he's likely to say yes. OE will assemble the DPO Case File and ask NRR to review for release. When we have the releasable case file we'll include the ADAMS number in the WIR.
Renee From: Sewell, Margaret Sent: Tuesday, August 19, 2014 10:23 AM To: Pedersen, Renee
Subject:
FW: Dlablo Canyon DPO Marge Sewell Safety Culture Specialist Office of Enforcement/Concerns Resolution Branch 301-415-8045 ma rgaret. sewell@nrc.gov From: Wertz., Trent Sent: Tuesday, August 19, 2014 9:13 AM To: Sewell, Margaret
Subject:
RE: Diablo Canyon DPO Yea, I forwarded the email I sent you then he called me back with the update. OPA was asking about it.
From: Sewell, Margaret Sent: Tuesday, August 19, 2014 9:11 AM To: Wertz., Trent
Subject:
RE : Dlablo Canyon DPO Ok ... thanks for sharing I was out yesterday. so I guess I missed that.
From: Wertz., Trent Sent: Tuesday, August 19, 2014 9:06 AM To: Sewell, Margaret
Subject:
RE: Diablo Canyon DPO Dave told me yesterday that we're expecting something 1n mid September.
From: Sewell, Margaret Sent: Tuesday, August 19, 2014 9:02 AM
To: Wertz., Trent
Subject:
RE: Diablo Canyon DPO Hi Trent, No, I haven't heard anything yet. I'll check with Renee to see if she's heard any news.
Marge From: Wertz., Trent Sent: Monday, August 18, 2014 1:04 PM To: Sewell, Margaret
Subject:
FW: Diablo Canyon DPO Didn't know if Renee is here. Any word from OEDO?
From: Wertz., Trent Sent: Monday, August 18, 2014 12:09 PM To: Pedersen, Renee
Subject:
Dlablo Canyon DPO
- Thanks, Trent L. Wertz Technica l Assistant Office of Nuclear Reactor Regulation 301-415-1568 trent,wer tz@nrc.eov
From: Summy. Jeff To: ocsteclc. I cic
Subject:
RE: conference number for 8/22 drop *In Date: Thursday, August 21, 2014 3:23:02 PM Attachments: 1m,1aeoo1.onq
- Eric, Thanks. Yes we are expecting one individual. Norm Abrahams on our Sr Seismologist in case you have technical questions we can't answer although we would prefer this not get too tecnical. Just update and info Jeff Summy Sent from my Verizon Wireless 4G LTE smartphone
--****** Original message -*******
From: "Oesterle, Eric" Date:08/20/2014 12:24 PM (GMT-05:00)
To: "Summy, Jeff"
Subject:
conference number for 8/22 drop-in
- Jeff, Hello. Just wanted to provide you with the conference call-in number and passcode for your Drop-In meeting with NRC on 8/22. I understand that you may have some folks back in CA wanting to call in to this to provide support, if needed.
888 -452-5138 (passcode8 )
Eric R. Oesterle Acting Branch Chief NRR/D0RL/LPL4-1 301-415- 1014
[ cld: lmageOO 1.png@O 1CFBC71.A6E47480)
PG&E Is committed to protecting our customers' privacy.
To learn more, please visit http://www,pge,com/about/company/pnvacy/custorner/
From: Keegan. E1a,ne To: oestcrte Enc
Subject:
RE: Request Date: Monday, August 11, 201'1 12:39:10 PM Hi Eric.
Thanks for the information . Do you have a few minutes this afternoon when I could come down and chat?
Elaine From: Oesterle, Eric Sent: Monday, August 11, 2014 8:13 AM To: Keegan, Elaine; Markley, Michael
Subject:
RE: Request Hi Elaine, The drop in is scheduled on 8/22 from 1PM - 2PM. I will forward the scheduler to you . We have not heard any specifics about it other than PG&E wants to inform NRR of its plans regarding the seismic report that they need to provide to the state of CA We have not seen a ticket on this yet but I will also forward you an email from the former Diablo PM on the subject. Please let me know if you have any questions.
Eric From: Keegan, Elaine Sent: Friday, August 08, 2014 2:02 PM To: Oesterle, Eric; Markley, Michael
Subject:
Request Gentlemen, When you hear the specifics about the drop-in between PG&E and Dan Dorman on August 22, could you please let me know. John Lubinski has asked about the meeting and wants to make sure DLR is in the loop. Thanks.
Elaine ELAINE M KEEGAN SR. PROJECT M ANAGER DI VISION OF LICENSE RENEWAL, NRR U.S. N ucLE11R REGUL 11 roRv COMMISSION 301-415-8517
From: Walker, Wayne Sent: Monday, August 25, 2014 3:15 PM To: Pruett, Troy; Hay, Michael; Farnholtz, Thomas; Williams. Megan; Hipschman. Thomas Cc: Buchanan, Theresa
Subject:
DRAFT RA BRIEFING SHEET ON DC SEISMIC REPORT, SEWELL REPORT, AND DPO ATIACHED Attachments: DC Seismic Brief 8-25-14.docx 1
POP 08/25/14 RPBA Diablo Canyon Seismic Brief for RA PURPOSE Brief the regional administrator on current seismic topics of interest related to Diablo Canyon.
OBJECTIVES
- 1. Staff provides information on the three topics - The ABN1632 seismic study, the "Sewell" report, and the upcoming DPO decision.
- 2. Regional Administrator receives and understands the information provided.
PROCESS ABN 1632 Seismic Study
- Licensee projects release of the report on August 28, 2014
- Licensee had a drop-in with headquarters' staff on August 22, 2014 (outcomes?)
- Licensee plans a public event in October (do we plan to attend/observe/hold our own meeting?)
- Communication plan currently being updated to include related talking points (pgs 49-53) o Report being reviewed o No immediate safety concern o Although more capable, updated analysis shows Shoreline still bounded by Hosgri "Sewell" Report "A Preliminary Numerical Study of the Hazard from Local Landslide Tsunami Scenarios at the Diablo Canyon Site in Central California"
- Seismic Issues Technical Advisory Group (SITAG) review determined that the use of low resolution data with considerable uncertainty made this report unsuitable for regulatory applications
- February 2006 memo (ML060460441) contains documentation of the Commission direction to withhold release of this draft report UNLESS a thorough staff review and comment resolution is performed
- Current FOIA in process for this report. Originally classified as exempt under Exemption 5 (predecisional)
- Requesting individual is not considered a state official. RPBA branch chief will contact this individual.
- Updating Communication plan to include this information Upcoming Differing Professional Opinion Decision
- Currently in appeal to EDO's office, who is scheduled to issue the decision mid-September. After the decision is issued, the DPO submitter will decide whether or not to make the decision public
- Current communications plan contains a section providing information on the DPO. This plan will be updated once the EDO decision is issued (pgs. 37-40)
- Associated Press story released 8/25 on DPO.
From: Bamford, Peter Sent: Monday, August 04, 2014 2:26 PM To: Walker, Wayne; Maier, Bill; Farnholtz, Thomas; Hipschman. Thomas; Williams, Megan; Reynoso, John; Uselding, Lara Cc: Oesterle, Eric Subje ct: RE:
SUMMARY
OF ASSEMBLY BILL 1632 SEISMIC CALL All: here is a quick summary of the initial call we held on 7/29/14.
Region IV provided an update on the licensee's status regarding the analysis being developed to respond to CA Assembly Bill 1632. The lfcensee is planning on addressing all relevant Dlablo Earthquakes (DE, ODE, Hosgri, LTSP} in their planned operability assessment. The licensee has indicated that they will submit the report to the NRC when it is submitted to the state of CA NRR updated the group on outreach received from the licensee for a possible HQ drop-Jn sometime 1n August 2014.
Action items:
NRR to work directly with the licensee to coordinate a drop-in at HQ All parties to think about the mechanism for HQ support of RIV's review of the licensee's operability assessment. (TIA, licensee submittal review, RIL update, other)
RIV to draft an update to the communications plan and route it for comment to the group All parties will need to consider all ongoing Diablo seismic activities in the communication plan NRR will schedule a second update teleconference with this group for the week of August 41~
Peter Bamford NRR/DORL/LPL4-1 Diablo Canyon and ANO Project Manager 301-415-2833 from: Walker, Wayne Sent: Tuesday, July 29, 2014 3:01 PM To: Bamford, Peter
Subject:
SUMMARY
OF ASSEMBLY BILL 1632 SEISMIC CALL
- Pete, Will you be writing a summary of the actions from the call we had? On the phone for RIV was Bill Maier, Lara Uselding, myself, Tom Farnholtz, Tom Hipschman, John Reynoso, and Megan Williams. Thanks for setting up meeting. I appreciate it.
Wayne
From: Bamford, Peter To: Markley. Michael Cc: Oesterle Enc
Subject:
Diablo canyon Update for 0845 call - 7/28/14 Date: Monday, July 28, 2014 7:50:00 AM Attachments: lmageoo t pnq Mike, here is a short summary for the 0845..
PG&E Is nearing completion of a seismic report that they will be submitting to the State of California pursuant to California Assembly Bill 1632. The report is currently going through Internal PG&E reviews and is expected to be completed around the end of August 2014. PG&E plans to provide the analysis to the NRC . The report will Include a new risk-informed. probab11istlc assessment of the various faults and the potential to impact Diablo Canyon. The report is likely to generate significant public interest, and the licensee is considering submitting a 50.72 report, similar to when they reported the Shoreline fault in 2008. PG&E has informed NRC resident inspection staff that the report may indicate that the Shoreline fault is somewhat longer than was previously analyzed and thus could have more capability.
The licensee currently believes the outcome will remain bounded by the site's existing Hosgri analysis, and that Hosgri remains representative of the worst case seismic event. PG&E has indicated a willingness to provide NRR management with a drop-in summary of the report's findings prior to issuance.
Peter Bamford NRR/DORL/LPL4- 1 Diablo Canyon and ANO Project Manager 301-415-2833
From: Bamford, Peter To: Cho Esther
Subject:
Dlablo canyon Drop*ln Meeetlng 8/22/14 Desalptlon Date: Tuesday, August OS, 2014 9:49:00 AM Attachments: 1maaeoo3.ona Esther, here is a short meeting description*
Pacific Gas and Electric management plans to update NRR management regarding a seismic report that will be submitted to the State of Cahforn1a pursuant to CA Assembly Bill 1632. The licensee plans to update NRR management with a high level summary of the results of the study and discuss the licensee's plans going forward. The licensee has indicated that the study will likely conclude that the Shoreline fault could be longer (and thus more capable) than previously believed, but they believe the overall earthquake loads would remain bounded by the site's existing Hosgri fault analysis. A copy of the CA Assembly Bill 1632 report will also be submitted to the NRC Peter Bamford NRR/D0RL/LPL4* 1 Diablo Canyon and ANO Project Manager 301-4 15-2833
From: use1tJ1no, Lara To: Wilhams. Megan: Sebroskv Joseph: Mmson. Qttford: Oesre,te, En~; Mar~tey, *-1rc11ae1 Cc: Walker. wayne; H1psch111an. TOQIJldl>
Subject:
PLEASE READ review or blog prior to sending to Ehot Date: Wednesday, September 10, 2014 1:07:37 PM Importance: High Hello: Please disregard this email below. I've called Megan and will work directly with her on this. There is too much saturation on input and l"m controlling one copy now.
Lara From: Williams, Megan Sent: Wednesday, September 10, 2014 12:05 PM To: Sebrosky, Joseph; Munson, Clifford; Oesterle, Erle; Markley, Michael Cc: Useldlng, Lara; Walker, Wayne; Hlpschman, Thomas
Subject:
RE: Scott/Joe ; review of blog prior to sending to Eliot I have some suggestions to the blog .... Again. I would campaign to include all the additional data from the report, not just the increased earthquake capab1hty ...
rt.
megan From: Sebrosky, Joseph Sent: Wednesday, September 10, 2014 10:59 AM To: Williams, Megan; Munson, Clifford; Oesterle, Eric; Markley, Michael Cc: Uselding, Lara; Walker, Wayne; Hipschman, Thomas
Subject:
FW: Scott/Joe ; r,eview of blog prior to sending to Eliot Megan, Cliff, Eric, and Mike, Attached is the latest version of the blog that includes Scott"s comments that removes some language that had me concerned I still have one issue
- The blog indicated that the staff will "independently verify the calculations." I don't believe this is correct. Can we say the staff will "independently assess the information in the report " I do not believe we are going to do a complete independent verification of all the calculations which. in my opinion the sentence implies.
Lara .
Is someone from OGC looking at the language given the FOE petition?
Joe From: Burnell, Scott Sent: Wednesday, September 10, 2014 11:47 AM To: Useldlng, Lara; Sebrosky, Joseph
Subject:
RE: Scott/Joe ; review of blog prior to sending to Eliot The complete email string may be found as document M/35 in interim response #5 in FOIA/PA-2014-0488 (ML19119A067).
From: Sebrosky, Joseph Sent: Tuesday, September 16, 2014 9:17 AM To: Stovall, Scott; Munson, Clifford; Williams, Megan; Li, Yong; Hipschman, Thomas; Walker, Wayne; Oesterle, Eric; Singal, Balwant; Markley, Michael; Jackson, Diane; DiFrancesco, Nicholas; Whaley, Sheena; Uselding. Lara; Ake, Jon; Burnell, Scott; OKeefe, Neil; Farnholtz, Thomas; Kanatas, Catherine; Roth(OGC), David; Manoly, Kamal; Reynoso, John; Hill, Brittain; Dudek, Michael; John Stamatakos Ustam@swri.org); Stirewalt, Gerry; Buchanan, Theresa; Weaver, Thomas; Karas, Rebecca; Graizer, Vladimir; Hiland, Patrick; Ross-Lee, MaryJane; Lupold, Timothy; Wilson, George Cc: Weil, Jenny; Moreno, Angel
Subject:
info: possibility of Diablo SSHAC meeting To all ,
The purpose of this email is to inform you of the possibility that PG&E may schedule another public senior seismic hazard analysis committee (SSHAC) meeting 1n the late October time frame to discuss the information that is in the State of California report and how it will be addressed in the 50.54(f) response that is due to the NRC in March of 2015. The information in this email is based on discussions between the Diablo Canyon senior resident inspector and PG&E and is preliminary in nature. No final decisions have been made and no action is required on your part.
Background
As you know California Assembly Bill (CAB) 1632 directed the California Energy Commission (CEC) to assess the potential vulnerability of California's largest baseload power plants to a major disruption due to major seismic event and other issues. PG&E's September 10. 2014, State of California seismic report is in response to CAB 1632. The California Public Utilities Commission has convened its own Independent Peer Review Panel (IPRP) to review and comment on PG&E's study plans and the findings associated with CAB 1632.
PG&E has indicated that the IPRP schedule is to review the State of California report within 30 days. PG&E 1s considering having a SSHAC at the end of October which would provide enough time for the IPRP to review the report and participate in the SSHAC meeting. PG&E believes that the SSHAC, if it were to be held. would have to be scheduled by the end of October in order for PG&E to meet the schedule to provide its 50.54(f) response by March 2015.
Please let me know if you have any questions. RIV or I will update you as more information becomes available regarding the SSHAC meeting at the end of October
- Thanks, Joe Sebrosky 3
From: Oesterle, Erle To: Buchanan. Theresa: Useldlna, Lard : Dncks, Y,<<or Cc: s1naa1. Balwant: Walker Wayne Bee: Markley Michael
Subject:
draft Briefing Package for 8/22 PG&E Drop-In w/ NRR Date: Friday, August 15. 201"1 12:51:00 PM Attachments: Draft PG&E DCPP Semor Manam:menr Drop la oack.-,m: for 22 Aug 2014,docx 1maaeoo1 .ono Attached is the draft briefing package for the subject drop-in by PG&E with NRR Front Office to discuss their seismic report to the State of California. I'd like to coordinate this with you all prior to sending it up to the NRR Front Office and I apologize in advance for the short notice. As you may or may not know, our Diablo Canyon PM, Peter Bamford, moved up to JLD, and the new PM (Balwant Singal}, including me, are new to Diablo but we're coming up to speed fast. I put the attached together with a little help from Peter, the Mid-Cycle report, and OCA, but have not finished adding info on recent news articles.
Please have a look over the attached to make sure that I generally am correct on what I'm saying and that I haven't missed anything that would be glaring. Ideally, If you could give some feedback by Tuesday that's the best I can ask for. Thanks!
Still standing by on the potential NOED for Unit 2.
f r-(,CI 'R. O~le, Acting Branch Chief NRR/DORL/LPL4-1 301-415-1014
6FFlelAL t:JSE 6NLY - 9EHSITl¥E lf~'TERHAL INF6RMATl0N August 15, 2014 MEMORANDUM TO: Dan Dorman Acting Director Office of Nuclear Reactor Regulation FROM: Eric R. Oesterle, Acting Chief/
Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
BRIEFING PACKAGE FOR DROP-IN VISIT ON AUGUST 22, 2014, BY EXECUTIVES OF PACIFIC GAS AND ELECTRIC COMPANY WITH DIRECTOR, OFFICE OF NUCLEAR REACTOR REGULATION (TAC NOS. MF1180 AND MF1181)
Enclosed is the briefing package in support of the drop-in visit on August 22, 2014, by Messrs. Edward D. Halpin, Senior Vice President and Chief Nuclear Officer, Barry S. Allen, Site Vice President, Jeff Summy, Senior Director, Engineering and Technical Services, and Thomas R. Baldwin, Manager, Regulatory Services, Pacific Gas and Electric Company (PG&E). The PG&E representatives will meet with Mr. Dan Dorman, Acting Director, Office of Nuclear Reactor Regulation (NRR); Ms. Jennifer Uhle, Deputy Director for Reactor Safety Programs, NRR; and Ms. Michele Evans, Acting Deputy Director for Engineering and Corporate Support, NRR, regarding the Diablo Canyon Power Plant, Units 1 and 2.
OFFl61>f<L t:JSE ONLY - 9ENS1fl¥E INfERNAL INfORMAflON
6fflelAL tJSE eNtY - SEf4SITIYE INTERNAL INf6ftMAfl6N D. Huyck If you need any additional information, please contact Balwant Singal at 301-416-3016 or by e-mail at balwant.singal@nrc.gov.
Docket Nos. 50-275 and 50-323
Enclosure:
Briefing Package cc w/encl:
D. Dorman, NRR J . Uhle, NRR M. Evans, NRR L. Lund, NRR M. Markley, NRR R. Lantz, NRR J. Lubinski, NRR W. Walker, Region IV E. Williamson, OGC Ol'l'ICIAL t:19~ er~LY - 9~N91Tl'f~ INT~ftNAL INl'OftMATIOr~
- via email OFFICE NRR/D0RULPL4/PM NRR/D0RL/LPL4/LA RIV/DRP/RPB-B/BC NRR/DORULPL4/BC(A)
NAME JBurkhardt DATE 6fFlelAL tJ!E 6f4LY - 9Ef491"fl'f'E lf4"fEfU4AL lf4F6ftMA"fl6N
-vu.S.NRC 't"NITED STATES h' lTCl.EAR. REGULATORY COMMISSION Protecting P~opu'! nud the E1n:ironn1e11t PACIFIC GAS AND ELECTRIC COMPANY DROP-IN VISIT AUGUST 22, 2014 MLXXXXXXXX 6fflelAL t:ISE 6NLY - SENSl'fl'f'E IN'fEftNAL 1Nf'6"MATl6N
Of'f'ICIAL t:J9E ONLY - 9EH91TIYE INTERNAL INf'ORMATION CONTENTS TAB AGENDA ............................................................................................................. 1A FACILITY DATA Facility Data ................................................................................................ 3 FACILITY PERFORMANCE Reactor Oversight Process Information Or Facility Oversight Info ........................................................................ 5 Current Issues ............................................................................................ 6 FACILITY MANAGEMENT DATA Facility Organization ................................................................................. 7 Biographical Data of Principal Managers ................................................ 8 Of'f'ICIAL t:J9E OHL¥ - 9Ef491TIYE lf4TERNAL lf41'0ftMATION
6FFlelAL t:JSE 6NLY - 9Ef~S1Tl't'E IWfERNl<L IHF6RMl<Tl6N TAB 1A Drop-In Visit Agenda August22, 2014 ITINERARY TIME PERSON VISITED CONTACT EXTENSION PERSON 1:00 p.m. - 2:00 p.m. Dan Dorman, Acting Director, Office of Sherry Schwarz 301-415-1270 Nuclear Reactor Regulation Jennifer Uhle, Deputy Director for Reactor Safety Programs, NRR Ms. Michele Evans, Acting Deputy Director for Engineering and Corporate Support, NRR VISITORS REPRESENTING PACIFIC GAS AND ELECTRIC COMPANY (PG&E)
- Edward D. Halpin, Senior Vice President and Chief Nuclear Officer, PG&E
- Meetings with NRR Director and Deputy Directors:
- Seismic Studies performed to support State of California requirements
- PG&E plans for report submittal to CA
- PG&E plans to provide information copy of report to NRC
- PG&E plans for assessing any new seismic information TAB 3 Facility Data Oiablo Canyon Power Plant
Of'f'ICIAL t:JSE ONLY - 9Ef491'fl'f'E lf~TEftNAL INf'6ftMATl6f4 6
Utility: Pacific Gas and Electric Company Location: Avila Beach, CA County: San Luis Obispo County, California Unit 1 Unit 2 Operating License DPR-80 DPR-82 Docket Nos. 50-275 50-323 Construction Permit Date April 23, 1968 December 9, 1970 Full Power License Date November 2 , 1984 August 26, 1985 Commercial Operation Date May 7, 1985 March 13, 1986 OL Expiration Date November 2, 2024 August 26, 2025 Plant Characteristics Reactor Type PWR Containment Type Dry ambient Power Level 3411 MWt/ 1120 MWe NSSS Vendor Westinghouse Constructor Utility Turbine Supplier Westinghouse/Alstom Condenser Cooling Method Once through cooling from the Pacific Ocean Ultimate Heat Sink Pacific Ocean Dry Cask Storage Approved in 2007 NRC Staff Region IV Branch Chief: Wayne Walker Resident Inspectors: Tom Hipschman, SRI John Reynoso, RI NRR Branch Chief: Eric Oesterle (Acting)
Project Manager: Balwant Singal 6PPlelAL t:JSE etRY - 9Ef4SITIV! INT!~14AL IN,.O~IWIATION
eflfilCIAL l:l!E eNt'f - 9EN91'fl¥E IN'fERNAL lf4fi6RMA'fl6N TAB5 Reactor Oversight Process CROP) Information Diablo Canyon Power Plant, Units 1 and 2 On March 4, 2014, the U.S. Nuclear Regulatory Commission (NRC) staff issued the Annual Assessment Letter for Diablo Canyon Power Plant (DCPP), Units 1 and 2 (Agencywide Documents Access and Management System (ADAMS Accession No. ML14063A572). Plant performance is within the Licensee Response Column (Column 1) of the NRC's Reactor Oversight Process (ROP) Action Matrix, because all inspection findings had very low (i.e.,
Green) safety significance and all performance indicators indicated that performance was within the nominal, expected range (i.e., Green). The NRC also completed its Mid-Cycle Plant Performance Summary for Diablo Canyon Units 1 and 2 which resulted in no change to the above results .
As a result of the Safety Culture and Common Language Initiative, the terminology and coding of cross-cutting aspects were revised effective January 1, 2014. The NRC determined that new cross-cutting aspects will be coded in accordance with the latest revision to the NRC Inspection Manual Chapter (IMC) 0310, dated December 19, 2013. While there were no cross-cutting themes identified during the assessment period, three (3) findings were associated with the previously defined Human Performance Cross-Cutting Aspect (CCA) designator H.4(a). Those three findings were identified in the 3rd and 4th quarter 2013 reports. With the new CCA designations effective January 1, 2014, those findings formerly associated with H.4(a), work practices (human error prevention), could be reassessed as H.11 (challenge the unknown) or H.12 (avoid complacency). However, since no findings were identified with H.11 or H.12 CCAs in the 1st and 2nd quarter 2014 reports, the Branch was not required to re-evaluate the H.4(a) findings to determine the appropriate new bin for those findings to assess for a potential cross-cutting theme in either H.11 or H.12.
No traditional enforcement violations were issued during the assessment period. However, DRS is currently processing an URI, with the potential to be greater than green, for the failure to maintain an emergency plan where a range of protective action recommendations (PARs) are developed. Specifically for a period of approximately 8 years the licensee did not have Implementing procedures in place to provide PARs to members of the public on the Pacific Ocean within the 10 mile EPZ. There is a potential Severity Level Ill violation associated with this potential greater than green finding.
The colored performance indicators and inspection findings for this station can be viewed at the following URLs:
DCPP Unit 1: http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/DIAB1/diab1 chart.html OCPP Unit 2: http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/DIAB2/diab2 chart.html 6fifil61AL l:ISE ONLY - 9ENSl'fl't1E IN'fERf4AL 1Nfi6RMATl6f4
6FFl61Al tJSE 6NLY - SENSITIVE lf~l'EftNAL INF6ftMATl6N TABS Current Issues Diablo Canyon Power Plant, Units 1 and 2 A. EXPECTED DISCUSSION TOPIC Diablo Canyon Seismic Issues Pacific Gas and Electric Company (PG&E), licensee for the Diablo Canyon Power Plant, has been performing seismic studies that are intended to address several interrelated issues. These include seismic hazard re-analysis to address Fukushima Near Term Task Force Recommendations, License Renewal, operability assessment for the Shoreline Fault and associated Differing Professional Opinion, and a requirement by the State of California to provide a report to the California Coastal Commission. The report to the State of California is not required by NRC regulations but the licensee is planning to provide an information copy to the NRC. The licensee will also provide a briefing to the NRC on this report and its plans for assessing any new information found through the seismic re-evaluations. It is expected that much of the information contained in the report will also be used by the licensee to address the Fukushima Near Term Task Force Recommendations due in early 2015. PG&E has conducted six workshops related to the seismic studies process to date, with five of six open to the public.
All of the planned workshops are now complete. The NRC staff attended these meetings as observers and will continue to monitor the process. To date, no new issues have been identified that have challenged the NRC staff's assessment of DCPP's reasonable assurance of safety. The following provides additional background on each issue.
Background
Diablo Canyon Power Plant (DCPP) is located in a seismically active area along the interface of the Pacific and North American Plates. Multiple faults, both onshore and offshore, are located within 50 miles of the plant. Pacific Gas and Electric Company (PG&E, the licensee) maintains a Long-Term Seismic Program to reevaluate the seismic design bases against insights and knowledge gained with each seismic event. The plant was designed for ground motion from a Design Earthquake, equivalent to an "Operating Basis Earthquake, in which the plant can be expected to continue to operate. This value is ground motion acceleration at the containment base of 0.2 g. T he Double Design Earthquake, equivalent to a "Safe Shutdown Earthquake," is the design basis for most safety-related structures, and has ground motion acceleration of 0.4 g.
The plant is also evaluated for the maximum ground acceleration, which can result from an earthquake originating in the Hosgri fault (0.75 g). This evaluation ensures the plant can be safely shut down if the expected maximum ground motion were to occur. An automatic reactor trip is initiated for a nominal ground acceleration of 0.35 g. An earthquake monitoring system provides an alarm in the control room at a minimum of 0.01 g of ground acceleration.
Shoreline Fault On November 14, 2008, the licensee informed the U.S. Nuclear Regulatory Commission (NRC}
of a previously unknown fault located approximately 300 meters offshore. PG&E named the 6FFlelAL tJSE 6NLY - SENSITIVE lfffEftfOtL lf~F6ftMAfl6N
hypothesized fault the "Shoreline Fault." The licensee evaluated the seismic and tsunami effects and determined the site remained safe. On April 8, 2009, the NRC issued Research Information Letter (RIL)09-001 , "Preliminary Deterministic Analysis of Seismic Hazard at Diablo Canyon Nuclear Power Plant from Newly Identified 'Shoreline Fault,'" which provided an initial independent technical evaluation supporting the licensee's initial determination that the plant's current licensing basis remained valid and supported continued operability (Agencywide Documents Access and Management System (ADAMS) Accession No. ML090930459). In September 2010, the NRC hosted, with independent seismic experts, workshops for the public to gain knowledge of the seismic hazards and its applications for the safety and operation of commercial nuclear plants, including specific discussions on the DCPP. The licensee documented its final analysis, "Report on the Analysis of the Shoreline Fault Zone, Central Coastal California," on January 7, 2011 (ADAMS Accession No. ML110140431).
Research Information Letter 12-01 , "Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone," documented the NRC staff's independent and confirmatory evaluation of the licensee's Shoreline Fault Report as publicly released on October 12, 2012 (ADAMS Accession No. ML121230035). The letter concluded that the maximum ground acceleration at the site due to a postulated earthquake originating along the Shoreline Fault was within the ground motion previously determined to be safe for the plant.
The staff conducted a local public meeting to discuss the shoreline fault report on November 28, 2012. The cover letter for Research Information Letter 12-01 (ADAMS Accession No. ML120730106) places the NRC's review of the Shoreline Fault into context with the NRC Near-Term Task Force action to have all nuclear power reactor licensees conduct seismic reevaluations in response to the March 12, 2012, 10 CFR 50.54(f) letter and provide a basis to resolve the Shoreline fault in the current licensing basis and/or provide interim evaluations with described actions should the seismic reevaluations deem the Shoreline Fault more capable.
Differing Professional Opinion Involving Seismic Issues at Diablo Canyon On July 13, 2013, the former Senior Resident Inspector at Diablo Canyon submitted Differing Professional Opinion (DPO) 2013-02 associated with the regulatory response following the discovery of the Shoreline Fault. DPO 2013-02 restated previously disposition issues presented in Non Concurrence Paper (NCP) 2012-01 and added concerns that the license amendment was needed to incorporate the Shoreline fault into Diablo Canyon's FSAR as described in RIL 12-01 and alleged that the NRC did not review or take action on the Los Osbos and San Luis Bay Faults. NCP 2012-01 was associated with alleged non-performance by the licensee of an operability assessment upon discovery of the Shoreline fault.
On September 3, 2013, the NRC established a DPO Ad Hoc Review Panel to review the DPO.
meet with the DPO submitter, and issue a DPO report, including conclusions and recommendations regarding the disposition of the issues presented in the DPO. The DPO panel concluded that there was not a significant or immediate concern with the current understanding of seismic safety of the Diablo Canyon Nuclear Power Plant and that the new seismic information is bounded within the existing analysis for the plant. A letter was issued by the NRC on May 29, 2014, providing the above conclusion to the DPO submitter and specifically noted that the licensee and the NRC followed its processes for technical specification operability of the plant equipment and 10 CFR 50.59 evaluations with a reasonable technical and safety rationale.
The DPO panel acknowledged the complex and unique licensing history associated with eFFlelAL tJSE 6f4LY - SEf4SlllVE lf4'fERf4AL INF6RMA'fl6f4
seismic issues for the Diablo Canyon plant and also that confusion existed in how to evaluate new information on natural hazards due to the lack of formal regulatory guidance. Finally, the NRC identified that the work currently underway on the Fukushima Near Term Task Recommendation 2.1 (re-evaluation of seismic and flooding hazards) and 2.2 (require licensees to confirm seismic and flooding hazards every 1O years) will address the concern on evaluation of new information on natural hazards.
Near-Term Task Force Actions On March 12, 2012, the NRC staff issued a request for information pursuant to 10 CFR 50.54(f),
Recommendation 2.1 : Seismic, in which the staff detailed a two-phased approach related to reevaluating seismic hazards at all power reactor licensees in response to recommendations of the Near-Term Task Force review of the accident at Fukushima Dai-ichi nuclear facility (ADAMS Accession No. ML12056A046). The first phase is to perform a reevaluation of the seismic hazards at the DCPP site using updated seismic information and present-day regulatory guidance and methodologies. The results will then be compared to the current seismic design basis. In the case of DCPP, the NRC staff directed PG&E to compare the results of the new seismic hazard study to the Double Design Earthquake (the equivalent of the Safe Shutdown Earthquake), rather than the larger Hosgri Earthquake. For the higher seismicity sites of OCPP and San Onofre, the first phase includes an assessment of new seismic information and development of a review level ground motion response spectrum using a Senior Seismic Hazard Analysis Committee (SSHAC) Level 3 process.
The second phase is based on the results of the first phase and consists of the NRC staff determining whether additional regulatory actions are necessary (e.g., update the design basis and structures, systems, and components important to safety) to provide additional protection against the updated hazards. The first phase of the process is expected to be completed by March 12, 2015, in accordance with the milestone provided in the March 12, 2012, request for information.
On June 7, 2012, PG&E provided its 90-day response to the seismic aspects of Recommendation 2.1 of the March 12, 2012, request for information issued pursuant to 10 CFR 50.54(f) (ADAMS Accession No. ML12160A295). To respond to the request for additional information, PG&E is completing ongoing seismic studies and is analyzing the data that is collected using a SSHAC Level 3 process as per NUREG-2117, Revision 1, "Practical Implementation Guidelines for SSHAC Level 3 and 4 Hazard Studies" (ADAMS Accession No. ML12118A445).
License Renewal PG&E submitted an application to renew the operating licenses for DCPP, Units 1 and 2, on November 23, 2009 (ADAMS Accession No. ML101120407). On April 10, 2011 , PG&E submitted correspondence to the NRC requesting deferral of issuance of its renewed operating license pending completion of additional seismic studies (ADAMS Accession No. ML11109A063). Therefore, the NRC staff has minimized work on the license renewal application and will wait for a request from PG&E to perform further review. The staff issued the Safety Evaluation Report in June 2011 and will supplement it. as necessary, at a time closer to the license renewal decision. The draft environmental impact statement has not been issued.
OFFICIAL tlSE Of~LY - SENSl'flYE IN'fEftNAL INFOftMATION
e,al'ICIAL U!I!! 6f4LY - 91!f491Tl't11!! INTl!!ftNAL lf41'0ftMATleN Following completion of its seismic studies, it is expected that PG&E may ask the NRG to proceed with its review of it's license renewal application.
Concurrent Seismic Studies to meet State of California Requirements In accordance with specific requirements for the State of California, PG&E must obtain a Coastal Consistency Certification from the California Coastal Commission. PG&E agreed to perform state-of-the-art seismic mapping techniques to explore the fault zones around OCPP.
In order to commence these seismic studies, PG&E sought, and the California Public Utility Commission approved, a rate request to pay for the testing. The study included forming a State Independent Peer Review Panel to review the results of the information that will be collected.
The Independent Peer Review Panel includes earthquake scientists from the California Public Utility Commission, California Energy Commission, California Seismic Safety Commission, California Coastal Commission, and California Geologic Survey. The low-energy two-dimensional (20) and three-dimensional (30) seismic mapping have been completed along with high-energy 30 seismic on-shore mapping. PG&E needed to obtain 12 permits from State and Federal agencies to be able to conduct the high-energy offshore studies. There was significant public opposition to this high-energy 30 testing , and the permitting process and the seismic studies were covered extensively in the news.
In November 2012, the California Coastal Commission rejected the permit request for the high-energy 30 offshore mapping due to potential environmental impacts and the limited expectation from new information that this testing would reveal. PG&E considered and determined that the high-energy 30 testing was not necessary to conclude that its obligation had been met and is pursue final certification with submittal of the report to the State of California.
Seismic Hazard Reanalysis With the seismic study efforts related to the Near-Term Task Force actions and license renewal running concurrently and utilizing similar resources and methods, the NRC staff expects PG&E to update its seismic probabilistic risk assessment with the results of the SSHAC Level 3 process in the 2017 time frame. PG&E is coordinating with other western United States nuclear plant licensees (San Onofre and Palo Verde Nuclear Generating Stations) concerning the performance of the required SSHAC Level 3 activities and has completed two DCPP workshops, one jolnt workshop, and observed one San Onofre workshop. The NRC staff continues to monitor the SSHAC Level 3 process at various stages.
"Sewell Report" In March of 2004, as part of the review for the Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) license review, the Center for Nuclear Waste Regulatory Analysis (CNWRA, a division of Southwest Research Institute), transmitted to the NRC a Tsunami Hazard Study that applied to the Olablo Canyon site. Within the scope of the CNWRA review of the Oiablo Canyon ISFSI application, a CNWRA contractor, Dr. Robert Sewell, developed a draft report (the "Sewell Report") on the potential for landslide tsunamis impacting the site. The report postulated wave elevations from potential landslide tsunami scenarios that could exceed the current licensing basis tsunami height for the Diablo Canyon power plant. CNWRA did not 6fi'l'lelAL U!! ONLY - SENSl'fl'o'E IN'fEfitNAL INf6fitMA'fl6N
6fiflCIAL l:JSE 6NLY
- 8Ef4SITIVE. IN'fEftNAL INfi6ftMATl6H endorse Dr. Sewell's work, but did transmit the report to the NRC so that the 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.
Overall Performance This topic is reviewed in Tab 5, "Reactor Oversight Process (ROP) Information," and in section B below titled, "Current Plant Status I Recent Plant Events."
OTHER RECENT DISCUSSION TOPICS Not applicable.
B. OTHER TOPICS OF INTEREST Current Plant Status I Recent Plant Events DCPP, Units 1 and 2, are currently in Mode 1 at or near 100 percent power (as of the date of this package). From 2013 to the present, both units have experienced down-power occurrences due to ocean debris fouling of the condenser and cooling system. Additionally, the following reactor shutdowns occurred:
- October 14, 2013, Unit 1 power was reduced to 50 percent due to an unplanned loss of a main feedwater pump.
- October 28, 2013, Unit 1 power was reduced to 50 percent for planned circulating water tunnel cleaning.
- May 30, 2014, Unit 1 power was reduced to approximately 18 percent power to perform cold washing of 500 kV insulators.
- January 9, 2014, Unit 2 power was reduced to 50 percent for planned maintenance to clean main circulating water condensers and tunnels.
- March 1. 2014 Unit 2 power was reduced to 25 percent in anticipation of severe weather and high ocean swell conditions.
- June 1, 2014 Unit 2 power was reduced to approximately 18 percent power to perform cold washing of 500 kV insulators.
6fifilCIAL 1:J8E 6NLY - 9ENS1Tl't'E lfH'ERNAL INfi6RMAl'l6N
Ol'l'ICIAL t:J!E ONLY - 9Ef491fl"f'E INfEftf4AL INfiO"MAfl0f4 Organizational Issues In 2012, PG&E selected Mr. Ed Halpin as the new Chief Nuclear Officer and Mr. Barry Allen as the new Site Vice President.
Escalated Enforcement, Non-green Findings, and Non-Green performance Indicators There was one escalated enforcement case associated with incomplete and inaccurate reporting in 2005 in response to GL 2003-01 for control room in-leakage as discussed above (Severity Level Ill, no civil penalty). There have been no greater than Green findings or performance indicators within the last assessment cycle (2014). There is potential for a greater than green, for the failure to maintain an emergency plan where a range of protective action recommendations (PARs) are developed. Specifically for a period of approximately 8 years the licensee did not have implementing procedures in place to, provide PARs to members of the public on the Pacific Oce*an within the 10 mile EPZ. There is a potential Severity Level Ill violation associated with this potential greater than green finding.
Open Investigations There are no open investigations at DCPP.
Open Allegations There are no open allegations at DCPP.
Freedom of Information Act (FOIA) Requests A FOIA request on behalf of the San Luis Obispo Mothers for Peace was received on August 5.
2014, regarding documents associated with the "Sewell Report" (discussed above) that addressed tsunami hazards associated with local landslides. Specifically, the request focused on the consideration of the "Sewell Report" by the NRC in licensing proceedings or other safety determinations or assessments for Diablo Canyon, including records from the NRC's Seismic Issues Technical Advisory Group (SITAG) relative to evaluation of the "Sewell Report".
Congressional Interest Congressional interest in Diablo Canyon has focused largely on seismic issues over the past couple of years. Rep. Lois Capps and her staff have inquired about seismic design basis issues and an associated DPO and non-concurrence from a former Diablo resident inspector. At a Sept.1 O, 2013 hearing before the House Energy and Commerce Subcommittee on Environment and the Economy, Rep. Capps expressed concerned about a study that concluded an earthquake much larger than current NRC estimates was possible along the Hosgri and Shoreline faults. She also raised concerns about Diablo Canyon becoming a de facto permanent storage site for the reactor's spent fuel. She reiterated her concerns about the safe shutdown earthquake standard for the plant at a Dec.12, 2013 House Energy and Commerce joint subcommittee hearing and asked for copies of the non-concurrence and DPO.
Ol'l'ICIAL t:ISE ONLY
- SEf4Sl'fl'f'E INfeftNAL lf41'0"MAflON
e....,elAL l19E ONLY - 9El491'fl'f'E lf4'fERNAL lf4f6RMATl6f4 Sen. Barbara Boxer's staff also requested a copy of the DPO. Both Sen. Boxer and Rep. Capps' offices were provided information on the DPO review and appeals processes and explained that the DPO submitter may elect to make the records public at the end of the process.
Senator Boxer's staff separately inquired about the reason why PG&E withdrew the Diablo Canyon seismic license amendment request filed in October 2011 after the issuance of the Research Information Letter. The Senator's staffer had questions about the plant's operating license and the Double Design Earthquake (ODE) and Safe Shutdown Earthquake (SSE) requirements.
More recently, there has been interest from Sen. Boxer and Sen. Dianne Feinstein's staff in a 2003 draft report (i.e., "Sewell Report" discussed above) prepared by a contractor to the Center for Nuclear Waste Regulatory Analyses (CNWA) on potential tsunami hazards in the vicinity of Diablo's ISFSI. Sen. Boxer was provided an unredacted copy of the report that was marked "not for public release."
The California congressional delegation had been following the California Coastal Commission's actions relating to a permit for the 30 high-energy offshore seismic surveys, and congressional staff has been interested in the Senior Seismic Hazard Analysis Committee (SSHAC) workshops and related activities.
Harassment and Intimidation Issues None.
2.206 Petitions None specific to DCPP at this time.
Selected News Articles DCPP receives frequent media attention. Recently, most media attention has been in the following areas: license renewal, impact of the recent waste confidence decision, and offshore seismic surveys/studies. Example articles are provided below:
The San Luis Obispo Tribune reports (4/24/2013) an editorial article by Mr. Ed Halpin, Senior Vice President and Chief Nuclear Officer, PG&E regarding the government's role in accepting spent nuclear fuel.
Significant Reportable Events None.
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eFFlelAL l:ISE eHLY - SEHSlfl't'E INfEfU4AL U4Pe"MAfl6N TAIB 8 Biographical Data of Principal Managers Edward (Ed) 0. Halpin Senior Vice President and Chief Nuclear Officer Oiablo Canyon Power Plant Pacific Gas and Electric Company Ed Halpin is the Senior Vice President and Chief Nuclear Officer at Diablo Canyon Power Plant (DCPP) for Pacific Gas and Electric Company. He is responsible for the safe, reliable, and efficient operations of DCPP, the license renewal of our units, the decommissioning of Humboldt Bay Power Plant. and will serve as the lead contact with the Nuclear Regulatory Commission and the Institute of Nuclear Power Operations.
Halpin comes to DCPP from South Texas Project (STP) Nuclear Operating Company where he served as President, Chief Executive Officer, and Chief Nuclear Officer responsible for the overall strategic direction of STP and the operation of the STP's Units 1 & 2. In his more than 24 years with the company, Halpin advanced through positions of increasing responsibility and leadership, including site vice president, vice president of oversight, vice president and assistant to the CEO, plant general manager, operations manager, maintenance manager, systems engineering manager and design manager. He also played a key role in developing and sustaining the company's, strong collaborative culture, which was critical to STP's transition to excellence.
Halpin served as an officer in the U.S. Navy's Nuclear Power Submarine Service. He graduated with honors from the U.S. Naval Academy earning a Bachelor of Science in Ocean Engineer1 ing and holds a master's degree in Strategic Communication and Leadership from Seton Hall University and another master's degree in Human Development from Fielding Graduate University. Additionally, Halpin has a Senior Reactor Operator Certification and is a graduate of the Institute of Nuclear Power Operations' Senior Nuclear Plant Management course and the Senior Nuclear Executives Seminar.
In June 2011 , Halpin was selected as one of 12 industry leaders from across the nation to serve on the Fukushima Steering Committee. The Committee is comprised of industry executives and representatives from the Nuclear Energy Institute; the Institute of Nuclear Power Operations; and the Electric Power Research Institute.
Ol'l'ICIAL t:19!! 6f4LY - SEHSITl't'E IHTERHAL 1Nf6"MAfl6f4
e1-1-1e1At t'JSE ONLY - S!!!l4SITl1t!!! INT!!!lltNAL 1141'011tMATION Barry S. Allen Site Vice President Diablo Canyon Power Plant Pacific Gas and Electric Company Barry Allen is the site vice president of Diablo Canyon Power Plant for Pacific Gas and Electric Company. He oversees the daily operations of the facility and provide leadership over the plant's maintenance and security functions, as well as lead the periodic refueling of both reactor units.
Allen brings to Diablo Canyon more than 30 years of nuclear power industry experience, obtained while working in increasing levels of responsibility at Entergy and FirstEnergy Nuclear Operating Company (FENOC). He joined FENOC in 2003 as plant manager at the Davis-Besse Nuclear Power Station in Oak Harbor, Ohio. Allen was later named site operations director at Perry Nuclear Generating Station in North Perry, Ohio, in 2006 and became site vice president in 2007. In 2008, he assumed the position of site vice president at Davis-Besse. Prior to joining FENOC, Allen served in a number of engineering and maintenance assignments, including director of engineering, at Entergy's Waterford 3 Steam Electric Station in Louisiana.
He holds a Bachelor of Architecture Structures degree and a Master of Science in Civil Engineering degree from Texas Tech University.
eFFlelAL t'JSE 6NLY - SENSl'fl't'E INTERNAL ll~f'6RMA'fl6N
Ofifi'ICIAL tJS! ONLY - !!N!l'fl't'E IN'fEfU~AL lf~fi'OftMATION Jeff Summy Senior Director, Engineering & Technical Services Oiablo Canyon Power Plant Pacific Gas & Electric Company Jeff is responsible for all engineering and technical services including regulatory relations, license renewal, and seismic projects. Jeff's experience includes more than 30 years in the nuclear industry with time at several nuclear facilities including, San Onofre, Palo Verde, and Sequoyah in various leadership roles from systems engineer to his current role at Diablo Canyon.
Jeff has a Bachelor of Science from Park College in Missouri, a Senior Reactor Operator Certification from Sequoyah, and he started his career in the Navy Nuclear Power Program.
OfifilelAL tJSE ONLY - SENSITl't'E INTERNAL 1Nfi'ORMA'fl6N
6fflel>9tt tJSE eNLY - SEHSlfl'lfE IHfEIU4>9tL lf4f6ftM>9tflON Thomas R. Baldwin Manager, NRC Regulatory Services Diablo Canyon Power Plant Pacific Gas and Electric Company Tom Baldwin is the Manager of Regulatory Services at Diablo Canyon Power Plant (DCPP) and Humboldt Bay Power Plant (HBPP) for Pacific Gas and Electric Company. He is responsible for the implementation of regulatory processes and requirements at DCPP and HBPP, management of communications between PG&E and the NRC, oversight of all licensing activities for DCPP and HBPP, and facilitation of NRC staff in performance of their oversight roles at DCPP and HBPP.
Baldwin came to DCPP from PG&E's corporate offices where he served as the lead mechanical design engineer of the primary systems. In his more than 28 years with the company, Baldwin advanced through positions of increasing responsibility and leadership, including Regulatory Services Manager, Procedure Services Manager, Instrumentation and Electrical Engineering Manager, and Senior Reactor Operator.
Baldwin graduated from the University of Colorado at Boulder, earning a Bachelor of Science in Mechanical Engineering. He is a California-registered Professional Engineer in Mechanical Engineering.
OfflelAL t:19! eNtY - S1!f4Sl'flto'I! lf4Tl!"NAL INl'OP'-MATION
From: Oesterle, Erle To: Markley Mjchae1: Lu11d Louise Cc: Walker. Wayne
Subject:
RE: Drop-In w/ Pacific Gas & Electric Date: Wednesday, August 20, 2014 12:15:00 PM There is a draft comm plan from March 13, 2014, that is very good that I believe Region IV developed and which we could use as a starting point to develop mini-Comm plan .
Eric From: Markley, Michael Sent: Wednesday, August 20, 2014 11:48 AM To: Lund, Louise Cc: Oesterle, IEric; Walker, Wayne
Subject:
RE: Drop-In w/ Pacific Gas & Electric Yes, .. .er,.. Eric does ... in collaboration with RIV. We do have some prior information that can be dusted off the shelf.
From: Lund, Louise Sent: Wednesday, August 20, 2014 11:41 AM To: Markley, Michael
Subject:
RE: Drop-In w/ Pacific Gas & Electric You'll have the lead on this, right?
From: Markley, Michael Sent: Wednesday, August 20, 2014 11:39 AM To: Uhle, Jennifer; Lantz, Ryan; Lund, Louise Cc: Dorman, Dan; Evans, Michele; Wertz., Trent; Oesterle, Eric; Walker, Wayne; Singal, Balwant
Subject:
RE: Drop-In w/ Pacific Gas & Electric Will do.
From: Uhle, Jennifer Sent: Wednesday, August 20, 2014 11:37 AM To: Markley, Michael; Lantz, Ryan; Lund, Louise Cc: Dorman, Dan; Evans, Michele; Wertz., Trent
Subject:
RE : Drop-In w/ Pacific Gas & Electric Thx. We talked about the need for a comm plan of some type for the report and the DPO. Trent is going to talk to Renee Pederson to get some bullets on the DPO messages. Please work with him to establish a mini comm plan and update OPA.
Thanks in advance, Jennifer From: Markley, Michael Sent: Wednesday, August 20, 2014 11:08 AM
To: Dorman, Dan; Uhle, Jennifer; NRR-OWFN-13D20-15p; Lund, Louise; Hiland, Patrick; Davis, Jack; Oesterle, Eric; Singal, Balwant; Case, Michael; Ake, Jon; Munson, Clifford Cc: NRR_ET_Activity Resource; Bamford, Peter; Nichols, Chelsea; Schwarz, Sherry; Cohen, Shari; DE_Calendar Resource; DORLCAL Resource; Flanders, Scott; Whaley, Sheena; Kock, Andrea; NRR_JLD Resource; Lubinski, John; Ross-Lee, MaryJane; Manoly, Kamal
Subject:
RE: Drop-In w/ Pacific Gas & Electric It is still a drop-in. I am told the bridge line was added to allow for PG&E contractors to participate, if needed.
---Original Appointment-----
From: Hiland, Patrick On Behalf Of Dorman, Dan Sent: Wednesday, August 20, 2014 9:52 AM To: Markley, Michael
Subject:
FW: Drop-In w/ Pacific Gas & Electric When: Friday, AU$.JUSt 22, 2014 1:00 PM -2:00 PM (UTC~ astern Time (US & Canada).
Where: 0-13D20 \(Bridgeline: 888-452-5138; Passcode~
Mike, can you confirm this wi ll be a teleconference vs. drop-in? I received a revised scheduler this a.m., and the room location has been crossed out and phone number highlighted?
Original Appointment- ---
From: Dorman, Dan Sent: Tuesday, August OS, 2014 9:59 AM To: Dorman, Dan; Uhle, Jennifer; NRR-0WFN-13D20-15p; Lund, Louise; HIiand, Patrick; Davis, Jack; Markley, Michael; Oesterle, Eric; Singal, Balwant; Case, Michael; Ake, Jon; Munson, Clifford Cc: NRR_ET_Activity Resource; Bamford, Peter; Nichols, Chelsea; Schwarz, Sherry; Cohen, Shari; DE_Calendar Resource; DORLCAL Resource; Flanders, Scott; Whaley, Sheena; Kock, Andrea; NRR_JLD Resource; Lubinski, John; Ross-Lee, MaryJane; Manoly, Kamal
Subject:
Drop-In w/ Pacific Gas & Electric When: Friday, August 22, 2014 1:00 PM-2:00 PM (UTCi°S:00) ! astern Time (US & Canada).
Where: 0 -13D20 (Bridgeline: 888-452-5138; Passcode .,,,6 08/20/2014 - Update-Brjdge!jne Information 888-452-5138 Passcodei 10)(6>
Requested by Peter Bamford (2833)
Licensee for Diablo Canyon - meeting is on seismic Pacific Gas and Electric management plans to update NRR management regarding a seismic report that will be submitted to the State of Californ ia pursuant to CA Assembly Bill 1632. The licensee plans to update NRR management with a high level summary of the results of the study and discuss the licensee's plans going forward.
The licensee has indicated that the study will likely conclude that the Shoreline fault could be longer (and thus more capable) than previously believed, but they believe the overall earthquake loads would remain bounded by the site's existing Hosgri fault analysis. A copy of the CA Assembly Bill 1632 report will also be submitted to the
NRC.
From: oesterle, Eric To: Sebrosky. Joseph; Mdrkjey. M1cnac1: Kanatas Cathenne* Hmsc;nman. Thomas- Reynoso John: Manolv Kamal:
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Subject:
RE: action: Review of updated communication plan and proposal to ask PG&E to provide draft copy of report In an electronic reading room Date: Wednesday. August 27, 2014 8:10:00 AM Attachments: oc Cahr si:tsm1c rot comm otan srb ma ern.doq.
Joe, et al Just confirming the discussion this AM with Mike Markley that we agree that setting up an electronic reading room with limited access rights for NRC staff to look at a draft copy of PG&E's report to CA is a good idea. Also, as we discussed this am, please find attached to updated comm plan a proposed question acknowledging the existence of the DPO without getting into details of its contents. I believe it is consistent with recent OPA talking point and we should get OGC eyes on It as well. Thanks.
Eric
- 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, Neil; Folk, Kevin; Wrona, David; DiFrancesco, Nicholas; Balazlk, Michael; Hipschman, Thomas; Reynoso, John; Slngal, Salwant; 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 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 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 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 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 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 Regulation joseph.sebrosky@nrc.gov 301 -415-1132
From: Oesterle, Erfc To: Hill Brittain
Subject:
RE: Info and action: status of dlablo canyon state of californla report regarding seismic Issues Date: Tuesday, September 09, 2014 9:10:00 AM Attachments: 1manroo1 ong Understand, but we are not pre-judging. I am working on a separate question re: whether the new seismic info in PG&E report changes DPO report conclusions or appeal ... we simply don't know yet because we still have to do detailed review of report.
Eric From: Hilt, Brittain Sent: Tuesday, September 09, 2014 8:27 AM To: Oesterle, Eric
Subject:
Re: info and action: status of diablo canyon state of californla report regarding seismic Issues Eric - fm the last point on operability, I would restate first bullet slightly to focus on DPO Issues rather than broad statement on licensing basis1 omly because of the ongoing review of the Coastal Comm report and potential difficulties in evaluating new info. Dent want to give impression stating that D1ablo "remains" within current basis Indicates we've prejudged new info.
Thanks-Britt Sent from Brittain Hill's PDA (b)(6)
From : Oesterle, Eric Sent: Tuesday, September 09, 2014 08:05 AM Eastern Standard Time To: Sebrosky, Joseph; Markley, Michael; Munson, Clifford; Stovall, Scott; Kock, Andrea; Williams, Megan; LI, Yong Cc: Weil, Jenny; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovich, Mike; Whaley, Sheena; Bowman, Gregory; Bowen, Jeremy; Moreno, Angel; Balazlk, 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; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wlttick, Brian; Harris, Brian; Roth(OGC), David; Kanatas, Catherine; OKeefe, Neil
Subject:
RE: info and action: status of diablo canyon state of california report regarding seismic issues To all, The purpose of this email is to update you all on the status of the Diablo Canyon Power Plant (DCPP) DPO Appeal decision that has been working in parallel with our efforts on the PG&E Seismic Report to State of CA.
We were informed yesterday afternoon that the EDO's Decision on the DCPP DPO Appeal would be imminent. As a result, a team of NRR personnel reviewed the DPO Case File for public releasibility and determined that there was no information that needed to be withheld . An email was sent out to several individuals informing them that the review for public releasibility had been completed . Process wise. however, even though we have made that determination. the DPO Submitter must be asked whether or not they would like to have the DPO case released to the public.
The rest of this email may be found as document U33 in interim response #5 in FOIA/PA-2014-0488 (ML15224A774).
From: Oesterle, Erle To: p,,ctek. MlchaeJ
Subject:
RE: Info: status of actions associated with with Dlablo Canyon shoreline fault Date: Wednesday, September 03, 2014 1:46:00 PM Mike.
It should be OK to give to Commission as it does not address any issues associated with License Renewal (for which there is a contention) and the DPO.
Eric From: Dudek, Michael Sent: Wednesday, September 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. Dudek I OEDO Executive Technical Assls...t"'"
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'----'-'.:....:..--.l 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; Difrancesco, Nicholas; Balazik, Michael; Reynoso, John; Singal, Balwant; Hill, Brittain; Walker, Wayne; Uselding, Lara; Buchanan, Theresa; Keegan, Elaine; Jackson, Diane; Wittlck, Brian; Stovall, Scott Cc: Weil, Jenny; Li, Yong; Manoly, Kamal; Lund, Louise; Dudek, Michael; Case, Michael; Burnell, Scott; Hay, Michael; Franovlch, 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 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: Hlpschman, Thomas; Markley, Michael; Oesterle, Eric; 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; Wlttlck, 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 1nformat1on regarding a Chairman briefing Pro1ect Piao tor Reviewing New Seismic Information Attached 1s 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 rnformat1on 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 1s necessary, therefore, a public meeting 1s 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 ind1v1duals 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 California 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 part1c1pants in the briefing are: - Neil O'Keefe (RIV), Cathy Kanatas (OGC),
Cliff Munson (NRO), Kamal Manely (NRR/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
From: Oesterle, Eric To: Markley, M1chae1
Subject:
RE: 8:45 Items Date: Monday, September 08, 201'1 8:26:00 AM
- Mike, You are already aware of these item but I will provide:
- PG&E is expected to issue a Seismic Report to CA this week (9/10) that will Include new seismic information associated with Diablo Canyon. PG&E Is providing access to draft report for NRC staff via electronic reading room and to CA State personnel via physical reading room . NRC staff expected to provide preliminary assessment of report content sometime tomorrow
- EDO is expected to provide disposition of DPO appeal this week and NRC staff is preparing mini-Comm plan to support.
Eric From: Markley, Michael Sent: Monday, September 08, 2014 8:12 AM To: NRR_DORL_BCs Distribution Cc: Erlanger, Craig; Wengert, Thomas
Subject:
8:45 Items Craig and BCs Please forward any items for the 8:45 a.m. meeting today. For RI and RIV branches, we will not have the 8:30 a.m. meeting.
Mike
From: Oesterle, Eric To: Markley, Michael
Subject:
DPO commPlan Date: Wednesday, September 10, 2014 7: 15:00 AM Attachments: Draft roim-cornm Piao on ocee ppo doQS
,maaeoo,lono Importance: High
- Mike, Here is the updated DPO Comm Plan. I had to make some tweaks here and there to catch up with EDO decision on DPO appeal.
The last question addresses any connection between the new seismic report to CA and the DPO panel conclusions.
I also highlighted the 2 questions that are questionable that the Region wants to keep in this thing .
Please look over and let me know what to do with it. Thanks!
f vlcl 'R. O~e,,rlet Acting Branch Chief NRR/D0RL/LPL4-1 301-415-1014
.=- ),,.I
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DRAFT - efiflelAL t:JSE 6NLY 9Ef-9ITIYE IN'ffftNAL INfi6ftMA'fl6N - NeT fi6f( filt:JBLle ftELEASE Communications Plan -
Diablo Canyon Power Plant Topics of Interest Differing Professional Opinion and Appeal
Background
The former SRI at the Diablo Canyon Power Plant (DCPP) submitted non-concurrence papers (NCPs) in January 2011 and January 2012, followed by a Differing Professional Opinion (OPO) in July 2013 detailing a disagreement with the NRC about how new seismic information should be compared to the plant's current seismic license requirements. DPO 2013-02 restated the issues presented in NCP 2012-01 and added a concern that a license amendment was needed incorporate the Shoreline fault into Diablo Canyon's FSAR as described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults. In accordance with Management Directive 10.159, a DPO Ad Hoc Review Panel was established to, review the DPO submittal, meet with DPO submitter, and issues a DPO report including conclusions and recommendations regarding disposition of the issues presented in the DPO. The panel completed its report in May 2014 and a decision on the DPO was rendered in letter dated May 29, 2014, to the DPO submitter. The DPO submitter appealed the decision to the EDO in accordance with the NRCs DPO process. The EDO completed his consideration of the DPO appeal on September 9, 2014, concluding that he was in agreement with the original decision.
The purpose of this communication plan is to provide key messages associated with the EDO's decision on the DPO appeal and public release of the DPO Case File.
Key Messages:
- 1. The NRC appreciates members of the staff bring issues like this to its attention
- 2. The NRG encourages the use of non-concurrences and the Differing Professional Opinion (DPO) process
- 3. The NRG reviews all non-concurrences and DPOs thoroughly and believes that this is a healthy and necessary part the regulatory process
- 4. The NRC believes that, in the end, all of our regulatory decisions are better because of this process
- 5. The NRG has an obligation to protect the individual(s) submitting non-concurrences and DPOs and takes that obligation seriously
- 6. The DPO process is a non-public process and it is a strictly controlled and formalized process
- 8. Upon disposition of the DPO via a Director's decision, the DPO submitter has appeal rights to the EDO
DRAFT - el'l'ICIAL t:IS! eNLY
!EN!ITIV! INT!ftNAL INl'eftMATION - N6'f 1-6fit Plt:18LIC ftELEA!!
- 9. While the DPO is under review or appeal, NRG is prohibited from engaging in discussions with external stakeholders regarding the specifics of the of the DPO submittal
- 10. After the EDO's decision on the appeal, the DPO submitter has the right to make the DPO case file public to the extent that personal privacy information and SUNSI information is not contained in the DPO
- 11. Regarding the DPO for Diablo Canyon, the NRC has been and will continue to be as open and scrutable as possible while protecting the privacy rights of the individual
- 12. The NRC does not know the source of the public release of the Diablo Canyon DPO submittal prior to the EDO rendering a decision on the appeal
- 13. The NRG can, however, comment on a few aspects of the DPO appeal review o A Director's Decision has been made and the DPO appeal to the EDO has been finalized o The EDO and the DPO submitter have both agreed that the issues raised in the DPO do not present an immediate safety concern for Diablo Canyon o The NRG has sought permission from the DPO submitter to allow the DPO case file to be made publicly available and the DPO submitter has agreed o We would expect the public release of the DPO case file to be within a few weeks of the EDO's appeal decision
- 14. Regarding the operational status of Diablo Canyon Power Plant, Units 1 and 2 o The plant remains within its approved design and licensing basis o There are no current operability concerns resulting from the DPO o The recent earthquake in the Napa Valley did not reach Diablo Canyon - it was neither felt nor detected Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.
Team Member Position Organization Telephone Troy Pruett Division Director (Acting) RIV/DRP 817-200-1291 Wayne Walker 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
DRAFT - e1-1-1e1At tJ9E 6NLY 9!:N!ITl'l'!! U~l'!!ftNAL lf~fi6ftMATl6N - Nel' fie~ patJeue ftELEA!E Jon Ake Senior Seismologist RES/DE/SGSEB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Renee Pedersen DPOPM OE/CRB 301-415-2742 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno 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 PubIic Affairs Officer RIV 81 7-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Non-concurrence and DPO Questions (NOTE - this information is generally NON-PUBLIC, but is provided as background only]
NOTE: General FAQs on the DPO Program are included on the DPO Web site (look under Employee Resources-Employee Concerns.
No. Michael Peck was not reassigned. He applied for an instructor position in his area of expertise at the NRC's technical training center in Chattanooga, TN, at about the time he submitted his non-concurrence in accordance with the Non-Concurrence Process described in MD 10.158. He was competitively selected for this sought-after position, and reported to his new assignment in September 2012. Resident inspector assignments are limited to 7 years to ensure objectivity. It is common for resident inspectors to apply for their next job when a desirable position comes open.
- 2. When were the non-concurrences filed?
Two non-concurrences were filed by the DCPP SRI.
11/7/11. The DCPP SRI submitted NCP 2011-103, on inspection report 05000275; 323/201104.
1/26/12. The DCPP SRI submitted NCP 2012-01 , on inspection report 05000275; 323/201105.
- 3. What were the non-concurrences?
DRAFT - 6fflelAL t:JSE 6NLY 91!N91TIVI! INTl!ftNAL 1Nf6"MATl6N - NeT fie" fll::U:ttle ftELEASE Both non-concurrences involve the same subject; regulatory actions in response to the discovery of the Shoreline Fault.
NCP 2011-103 was filed by the DCPP SRI on the basis that no violation was issued (as he had submitted in the draft report) related to operability evaluation of the Shoreline fault in Report 2011-04. NCP 2011-103 was dispositioned finalizing the violation in IR 2011-05 issued on 2/14/12. (The employee requested that the NCP be non-public.)
NCP 2012-01 was filed by the DCPP SRI because the SRI believed the violation in NRC IR 2011-05 should be for an inadequate operability evaluation of the Shoreline Fault rather than not doing an operability evaluation until June 2012. The SRI beJieved the facility should be shutdown or the license amended to reflect the Shoreline fault. INCP 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 operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (interim) operability evaluation in June 2011 . Additionally, the offices involved in NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the time of 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 3Q/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event. (The employee supported public release of the NCP ADAMS ML 121A173.)
- 4. When was the DPO filed?
July 18, 2013. The former DCPP SRI filed Differing Professional Opinion (OPO) 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?
DRAFT - Ol'l'ICIAL l:"JS! ONL't' SENSl'fl'o'E IN'fE"NAL INF6"MA'fl6N - N6'f Fe" fi'tf 8tle "ELEASE A decision on the DPO was issued by the Office Director for NRR on May 29, 2014 consistent with the NRC's process included in MD 10.159. The employee appealed the decision to the EDO on June 23, 2014, and the appeal was thoroughly evaluated by the EDO and decision on the appeal was rendered on September 9, 2014.
As part of the agency's open and collaborative work environment, the NRC has established the DPO program as a means for employees to have their concerns reviewed by high level managers. The DPO Program is a formal process that allows all employees and contractors to have their differing views on established, mission-related issues considered by the highest level managers in their organizations, i.e., Office Directors and Regional Administrators. The process also provides managers with an independent, three-person review of the issue (one person chosen by the employee). After a decision is issued to an employee, he or she may appeal the decision to the Executive Director for Operations (or the Chairman for those offices reporting to the Commission).
- 7. Will the decision regarding the DPO be made public?
The NRC supports openness and will include a summary of the disposition of the DPO in the Commission's Weekly Information Report included on the NRC Web site (see Commission Documents under the Document Collections in the NRC Library). The DPO submitter has been contacted regarding the EDO's decision on the DPO appeal and has communicated support for the public release of the DPO Case File (with appropriate redactions).
No. As noted in Q&A #1 above, the SRI applied for and was selected to a highly sought instructor position at the NRC's Technical Training Center. The NRC does not tolerate retaliation for engaging in the NCP or the DPO Program and both MDs reiterate this policy and direct employees to resources in the event they believe that they have been retaliated against.
- 9. Would the DPO panel's conclusions or the DPO appeal decision change based on the new seismic information found in the State of California report?
PG&E, the licensee for Diablo Canyon, is providing a report to the State of California that includes the results of its most recent evaluation of the seismic hazards for the Diablo Canyon facility. The NRC understands that the report will be provided to the State of California on September 10, 2014, and that a copy will be provided to the NRC as well. Prior to performing a detailed review of this report, the NRC is not able to ascertain whether the new seismic information contained in the report would change the DPO panel's conclusions or the DPO appeal decision. The NRC understands that PG&E plans to incorporate the findings from this report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP. In addition , the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that
DRAFT - efiflelAL ti!! eNtY Sl!NSITl11'1! n*Tl!ftNAL INf'OftMATION - Ne=r f6R PtJ8tle ReteAse the faults discussed in the report (i.e.. Shoreline. Hosgri. San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.
NRC Resident Inspectors and Region IV staff looked at the licensee's documentation in their corrective action process assessing the new preliminary information concerning DCPP seismic and licensing bases. The licensee's information did not indicate there is an immediate threat to public health and safety nor did it call into question the ability of SSCs to perform their specified safety functions or necessary and related support functions.
The NRC staff will continue to review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.
From: Oesterle, Eric To: Buchanan Jhe,csa: Useldmo. Lara: Bumeu. Scott; Walker. Wayne: H1psd)man, Thomas: HIH. Bntta1n:
Sebroskv Joseph: Pedersen. Renee: Pruett Troy: w111,ams Megan Cc: Markley M1cbaet
Subject:
RE; dra~ DPO comm Plan Date: Wednesday, September 10, 201'111:17:00 AM Attachments: 1mageo04.png Draft m1oi comm Plan on ocer PPQ rp aooc 1maaeoo1.ong Importance: High I received comments from OE on the draft DPO Comm Plan and have incorporated those as well as some comments from AB-1632 Seismic Report comm plan. Please let me know ASAP if you have any comments as the DPO Case File is quickly moving to public availability. Thanks.
f y{,o R Oe¢e.rl.e, Acting Branch Chief NRR/D0RL/LPl 4- l 301-415-1014 From: Oesterle, Eric Sent: Wednesday, September 10, 2014 9:55 AM To: Buchanan, Theresa; Uselding, Lara; Burnell, Scott; Walker, Wayne; Hipschman, Thomas; Hill, Brittain; Sebrosky, Joseph; Pedersen, Renee; Pruett, Troy; Williams, Megan Cc: Markley, Michael
Subject:
draft DPO comm Plan Importance: High
- Everyone, Good morning. Attached please find a draft of the DPO Comm plan that was discussed at the 8:30 call this AM. This is provided to you for comment. Please note that it reflects real-time action on the DPO Appeal and incorporates comments from the discussion this morning on the AB-1632 Seismic Report. Much of the Q&A comes from the "living-DCPP Comm Plan" that is being maintained by RIV (the highlighted questions are troublesome to NRR/OORL but we understand that RIV prefers to maintain these). I have included a question at the end about whether new information in the AB-1632 report could impact the DPO conclusions. Also note that the Comm Plan does not contain a timeline as we are already real-time . Please let me know if you have any questions or comments.
£y{,c;'R, O~l.e, Acting Branch Chief
NRR/D0RL/LPL4- 1 301-415-1014
DRAFT - OfifilCIAL l::191: ONLY S!f4SITIV! INTl!ftNAL INfiO"MATION - f40T fiOft filt:18LIC ft!Ll:ASI:
Communications Plan -
Diablo Canyon Power Plant Topics of Interest Differing Professional Opinion and Appeal
Background
The former SRI at the Diablo Canyon Power Plant (DCPP) submitted non-concurrence papers (NCPs) in January 2011 and January 2012, followed by a Differing Professional Opinion (DPO) in July 2013 detailing a disagreement with the NRC about how new seismic information should be compared to the plant's current seismic license requirements. DPO 2013-02 restated the issues presented in NGP 2012-01 and added a concern that a license amendment was needed incorporate the Shoreline fault into Diablo Canyon's FSAR as described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults. In accordance with Management Directive 10.159, a DPO Ad Hoc Review Panel was established to review the DPO submittal, meet with DPO submitter, and issues a DPO report including conclusions and recommendations regarding disposition of the issues presented in the DPO. The panel completed its report in May 2014 and a decision on the DPO was rendered in letter dated May 29, 2014, to the DPO submitter. The DPO submitter appealed the decision to the EDO in accordance with the NRCs DPO process. The EDO completed his consideration of the DPO appeal on September 9, 2014, concluding that he was in agreement with the original decision.
The purpose of this communication plan is to provide key messages associated with the EDO's decision on the DPO appeal and public release of the DPO Case File.
Key Messages:
- 1. NRC strives to establish and maintain an environment that encourages all NRG employees and contractors to raise concerns and differing views promptly without fear of reprisal through various mechanisms. The free and open exchange of views or ideas conducted in a non-threatening environment provides the ideal forum where concerns and alternative views can be considered and addressed in an efficient and timely manner that improves decision making and supports the agency's safety and security mission.
- 2. The NRC appreciates members of the staff bring issues like this to its attention
- 3. The NRC encourages the use of non-concurrences and the Differing Professional Opinion (DPO) process
- 4. The NRG reviews all non-concurrences and DPOs thoroughly and in accordance with agency guidance (MD 10.158. MD 10.159) and believes that this is a healthy and necessary part the regulatory process
- 5. The NRC believes that, in the end, all of our regulatory decisions are better because of this process
DRAFT - 6fFlel>'cL t:19! 6NL'i1 S!:NSITl°O'! INT!"NAL INl'O"MATION - NOT 1'0" .. tJeue "!l!A!!
- 6. The NRC does not tolerate retaliation against employees who engage in our processes for raising differing views (i.e., Open Door Policy, NCP, and DPO Program).
- 8. Upon disposition of the OPO via a Director's decision, the DPO submitter has appeal rights to the EDO
- 9. While the DPO is under review or appeal, NRC is prohibited from engaging in discussions with external stakeholders regarding the specifics of the of the DPO submittal
- 10. After the EDO's decision on the appeal, the DPO submitter can request that the DPO Case File be made public. Management performs a review consistent with agency policies to support discretionary release. Regarding the DPO for Diablo Canyon, the NRC has been and will continue to be as open and scrutable as possible while protecting the privacy rights of the individual 11 . The NRC does not know the source of the public release of the Diablo Canyon DPO submittal prior to the EDO rendering a decision on the appeal
- 12. The NRC can. however, comment on a few aspects of the DPO appeal review o A Director's Decision has been made and the DPO appeal to the EDO has been finalized o The EDO and the DPO submitter have both agreed that the issues raised in the DPO do not present an immediate safety concern for Diablo Canyon o The NRC has sought permission from the DPO submitter to allow the DPO case file to be made publicly available and the DPO submitter has agreed o We would expect the public release of the DPO case file to be within a few days of the EDO's appeal decision
- 13. Regarding the operational status of Diablo Canyon Power Plant, Units 1 and 2 o The plant remains within its approved design and licensing basis o There are no current operability concerns resulting from the DPO o The recent earthquake in the Napa Valley did not reach Diablo Canyon - it was neither felt nor detected Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.
Team Member Position Organization Telephone Troy Pruett Division Director (Acting) RIV/DRP 817-200-1291 Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195
DRAFT - Offl61AL tlSE ONLY 9EN91'fl'l'E IN'fERNAL INFORMA'flON - NO'f FOR f'tlBL16 RELEASE 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 OCPP Thomas Farnholtz Branch Chief RIV/ORS/EB1 817-200-1243 Jon Ake Senior Seismologist RES/DE/SGS EB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORL/LPLIV 301-415-3016 Renee Pedersen DPOPM OE/CRB 301-415-2742 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno 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 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Non-concurrence and DPO Questions
[NOTE - this information is generally NON-PUBLIC, but is provided as background only)
NOTE: General FAQs on the DPO Program are included on the DPO Web site (look under Employee Resources-Employee Concerns.
- 1. Was the former OCPP SRI reassigned because he filed two non-concurrences?
No. Michael Peck was not reassigned. He applied for an instructor position in his area of expertise at the NRC's technical training center in Chattanooga, TN, at about the time he submitted his non-concurrence in accordance with the Non-Concurrence Process described in MD 10.158. Hie was competitively selected for this sought-after position, and reported to his new assignment in September 2012. Resident inspector assignments are limited to 7 years to ensure objectivity. It is common for resident inspectors to apply for their next job when a desirable position comes open.
- 2. When were the non-concurrences filed?
Two non-concurrences were filed by the DCPP SRI.
11/7/11 . The DCPP SRI submitted NCP 2011-103, on inspection report 05000275; 323/201104.
DRAFT - 61'1'1CIAL 1:191! er4tY SENSITIVE IN'fEfitNAL INl'6fitNIATl6N - Ne'f fi6fit flt:Jl!ltle fitELEASE 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 dispositionedl finalizing the violation in IR 2011-05 issued on 2/14/12. (The employee requested that the NCP be non-public.)
NCP 2012-01 was filed by the DCPP SRI because the SRI believed the violation in NRC IR 2011-05 should be for an inadequate operability evaluation of the Shoreline Fault rather than not doing an operability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault. NCP 2012-01was 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 operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (interim) operability evaluation in June 2011 . Additionally, the offices involved in NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the time of 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 3Q/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event. (The employee supported public release of the NCP ADAMS ML 121A173.)
- 4. When was the DPO filed?
July 18, 2013. The former OCPP SRI filed Differing Professional Opinion (DPO) 2013-02 associated with the regulatory response following the discovery of the Shoreline Fault.
NRC employees are encouraged to file a DPO if they believe an agency decision is in error. The 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
DRAFT - 6f'f'lelAL tt9f! 6NLY Sf!NSlfl¥f! IN'ff!ftNAL INf'6ftMA'fl6N - lrf6'f f'6ft flttBtle ftf!Lf!A9E described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults.
- 6. What is the status of the DPO?
A decision on the DPO was issued by the Office Director for NRR on May 29, 2014 consistent with the NRC's process included in MD 10.159. The DPO submitter appealed this decision to the EDO on June 23, 2014, and the appeal was thoroughly evaluated by the EDO and decision on the appeal was rendered on September 9, 2014.
As part of the agency's open and collaborative work environment, the NRC has established the DPO program as a means for employees to have their concerns reviewed by high level managers. The DPO Program is a formal process that allows all employees and contractors to have their differing views on established, mission-related issues considered by the highest level managers in their organizations, i.e., Office Directors and Regional Administrators. The process also provides managers with an independent, three-person review of the issue (one person chosen by the employee). After a decision is issued to an employee, he or she may appeal the decision to the Executive Director for Operations (or the Chairman for those offices reporting to the Commission).
- 7. Will the decision regarding the DPO be made public?
The NRC supports openness and will include a summary of the disposition of the DPO in the Commission's Weekly Information Report included on the NRC Web site (see Commission Documents under the Document Collections in the NRC Library). The DPO submitter has been contacted regarding the EDO's decision on the DPO appeal and has communicated support for the public release of the DPO Case File (with appropriate redactions). The DPO Case File should be publicly available within a few days of the EDO's DPO appeal decision.
No. As noted in Q&A #1 above, the SRI applied for and was selected to a highly sought instructor position at the NRC's Technical Training Center. The NRC does not tolerate retaliation for engaging in the NCP or the DPO Program and both MDs reiterate this policy and direct employees to resources in the event they believe that they have been retaliated against.
- 9. Would the DPO panel's conclusions or the DPO appeal decision change based on the new seismic information found in the State of California report?
PG&E, the licensee for Diablo Canyon, is providing a report to the State of California that includes the results of its most recent evaluation of the seismic hazards for the Diablo Canyon facility. The NRC understands that the report will be provided to the State of California on September 10, 2014, and that a copy will be provided to the NRC as well. Prior to performing a detailed review of this report, the NRC is not able to ascertain whether the new seismic
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information contained in the report would change the DPO panel's conclusions or the DPO appeal decision. The NRC understands that PG&E plans to incorporate the findings from this report into their ongoing analysis required by the NRC Post-Fukushima task force recommendations that are due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP. In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the ground motions resulting from the faults discussed in the report (i.e.,
Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.
NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event.
The NRC staff will review the new information provided in the report in accordance with the NRC's inspection process. The NRC will take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.
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UPDATED: 09/25/2014 2:12 PM08/.2&1:!014 2:47 PM Communications Plan -
Diablo Canyon Power Plant Topics of Interest State of California Seismic Report (ABN-1632)
Background
California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. Tt,e licensee has used the most state of the art methodologies using 2D and 30 mapping to compile this report. This is different methodology than what was used for the 2011 Shoreline Fault.
The purpose of this communication plan is to provide key messages associated with the public release of this report.
Key Messages
- The Bill 1632 report's information supports the NRC's and PG&E's existing conclusions that Diablo Canyon's seismic basis already accounts for quakes larger than what the Shoreline fault can generate.
- Diablo Canyon will incorporate the Bill 1632 report's information into its March 201 5 seismic hazard re-analysis submittal to the NRC.
Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.
Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1148
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Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195 Sr. Resident Inspector -
Thomas Hlpschman R-IV/DRP/RPB-A 805-595-2354 DCPP Resident Inspector -
John Reynoso R-IV/DRP/RPB-A 805-595-2354 DCPP Jon Ake Senior Seismologist RES/DE/SGS EB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Jenny Weil Congressional Affairs OCA 301-415-1691 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Dave Wrona License Renewal NRR/DLR OGC Nick DiFrancesco JLD Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Diablo Canyon, should be used to accomplish these actions.
Timeframe Action Responsible 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-IVIRPB-A (within T+1 PG&E's actions as currently understood and business day) implements the Communications Plan Entirety of Communications Team notifies R-IV; NRR/DORL; applicable Senior Managers in their respective NRR/DLR; NRR/JLD reporting chain OPA; OCA; OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. NO blog OR press release planned.
Within T+2 Other actions?? ???
business days 2
DRAF I - Ol'PICIAL ijSI! e1R, 1
~!U81Tl;t! lltT!Pllt*L 1141'e,.M.-?tel4 HeT l'ePl i'lj!Lle Pll!Ll!A31!
Tlmeframe Action Responsible Pa (les)
As requested Com lete a Commfssloners Assistants Brief R-IV; NRR
- 1. Questions and Answers Wtiat Is the Impact of this new Information on seismic design and licensing of DCPP?
Has the licensee entered this new Information Into the corrective action program and performed an operability evaluation?
As required by the NRC, as document in RIL2012-001 , PG&E has entered the new preliminary seismic Information Into their corrective action program. The results of the study are used to assess the impact on the current design and licensing basis of DCPP.
In response to the NRC's review of the January 2011 Shoreline Fault Report, PG&E made the following commitment to the NRC:
"If during PG&E's ongoing collection of seismic data, new faults are discovered or Information 1s uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation thal describes actions taken or planned to address the higher seismic hazard relative to the design basis.
as appropriate, prior to completion of the evaluations requested in the NRC staff's March 12, 2012, request for Information (Reference 2)." Reference 2 is NRC letter to All Power Reactor licensees and Holders of Construction Permits In Active or Deferred Status, "Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(1)
Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident,' March 12, 2012.
Region IV, Including the resident inspectors, have taken an Initial review of PG&E's assessment of this new information to verify that it does not affect the plant's ability to operate safely and to be able to remain safely shutdown following an earthquake. NRC's preliminary review is that the Olablo Canyon Units are safe to continue to operate based on:
- Based on assertions made by PG&E that the Shoreline Fa ult response spectra are still bounded by those for the Hosgrl and LTSP earthquakes for which the plant was previously analyzed
- The preliminary assessment by PG&E that the Shoreline Fault is capable of generating a magnitude 6.7 earthquake. As documented In the RIL the NRC statf has analyzed a scenario involving a Shoreline Fault of magnitude 6.7 and concluded that the response spectra developed by such an earthquake is bounded by the Hosgrl and LTSP spectra The NRC will review the new information provided In the report to the State of California including the Shoreline Fault characteristics. and the updated characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate If the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC staff to revisit the conclusions in the RIL.
- 2. Has OCPP provided the seismic report to the NRC?
3
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The new information, required by the state of CA AB 1632, has been provided to the NRC and shows that some previously separated segments of the Shoreline fault system are connected. These connections indicate that if the Shoreline Fault slips in the future, the earthquake from that slip might be slightly higher than previously considered posslble for the Shoreline Fault. But 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 wlll the AB 1632 seismic report be coordinated with the 50.54(f) required submittal In March 2015?
The NRC has reviewed the plant's corrective action program documentation for this new information. All indications are that the Shoreline fault remains bounded by the Hosgri fault for which the plant was licensed to withstand. The staff will continue to review the new information associated with the Shoreline Fault causes the NRC staff lo revisit the conclusions in the RIL.
tThe 1000-page document has also been given to the Japan Lessons Learned Directorate to be considered in the 50.54(f) review. :Co,:isistent with the UFSAR, the new p_reliminary Comment [SU31]: Thi. pnrat!ng Implies tile information regarding regional source characterization (i.e. fault capability) and potential site JlDis performing Ille 981smlc ,.111181ysls. How
~ 'The JLD wilt conelder the AS 1632 report ground motion will be evaluated in accordance with the process defined by the NRC in their w!lefl
- reviews Dieblo Canyon's Gl,IR S Fukushima 50.54(f) letter. through the SSHAC process and a final seismic hazard and tubmillal In Mardi 2016.'
Ground Motion Response Spectra (GMRS) that will be submitted to the NRC by March 2015. The updated SeisA'lis MacaFEl&IGMRS will-would be used as §filinput to a n y ~
Seismic Probabilistic Risk Assessment (SPRA) Diablo Canyon might have lo, wt:list:l will be submitteE# 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. II is important to note that OCPP is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event)
- 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 will is expected to be incorporated considered into the more comprehensive 50.541 analysis due to the NRC in March 2015. However, because the licensee must notify the NRC of any new seismic info, they have shared this report.and an initial operability evaluation showing why the plant is safe to operate. The NRC has looked at this evaluation and its preliminary assessment is that based on the information presented by PG&E the Shoreline Fault does not exceed previously considered seismic hazards
- 5. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault In 2011 prior to Issuing the RIL?
4
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California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission lo 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 ,,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 ma1or issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used In offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault In the 2011 report.
The NRC has requested licensees to submit a selsmfc hazard reevaluation using up-to-date methodologies and analysis which rs due for DCPP in March 2015. (Lauren, JLLD: anything to add here?)
- 6. What is the impact of this new information on seismic design and licensing of DCPP?
Based on the preliminary results of the studies that are under review, PG&E determined that the Shoreline Fault Zone may be capable of producing slightly larger earthquakes than considered in the January 2011 report. However, the ground motions from these larger earthquakes are still bounded by the Hosgri and LTSP ground motions. Since the seismic design of DCPP considered a range of ground motions from both a double design earthquake and a Hosgri earthquake, and the new ground motions do not exceed the Hosgrl earthquake, the new information is not expected to adversely impact the seismic design of DCPP. As a result, the assessment associated with the January 2011 Shoreline Fault Report remains valid.
5
From: Markley Mlc.hacl To: Day1s Jact,
- E@OPYic,h M1ks' Cc: Bpv1ma11 Gregory ; Bowen Jeremt: LutXI Lou*se: Oesterle. Enc: D1Francesco. Nicholas: Seorosky. Joseph:
Sinoat Ba1want
Subject:
FW: Dlablo Canyon DPO Date: Tue5day. August 26, 2014 7:59:55 AM Jack and Mike.
We are in urgent need of some prompt assistance from your staff on this. In particular. we would like to request JLD assistance from Joe Sebrosky who worked on the Diablo Canyon Research Information Letter (RIL) to assist in preparing communication plans and the likely preparation of testimony. Joe was the DORL PM of record during our review and evaluation of the Shoreline fault and has the best corporate history.
As you may know, the DPO on Diablo Canyon went cyber yesterday even though the NRG has not finished its review. The NRC Director's decision was finalized but the DPO submitter has appealed it to the EDO.
We are also preparing for the likely release of a new seismic study by PG&E in response to Assembly Bill 1632. That report is expected to be released between 8/28 and 9/8.
Mike Markley, Acting Deputy Director DORUNRR 301-415-5723 TUESDAY, AUGUST 26, 2014 7:00 AM EDT NRC NEWS NRC Official Questions Diablo Canyon Plant's Quake-Worthiness. News of the former NRC resident inspector's comments regarding Diablo Canyon plant's vulnerability to earthquake damage was covered heavily among regional outlets; less so by wire sources and first-tier media outlets. The Al:. (8/26, Blood, 1.05M) reports that the former senior resident inspector Michael Peck is "urging regulators to shut down the plant until "they can determine whether the facility"s twin reactors can withstand powerful shaking from any one of several nearby earthquake faults ." Peck submitted a 42-page. confidential report asserting that the NRC is "not applying the safety rules it set out for the plant's operation." Peck's document does not say the plant is unsafe, but argues that "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."
The Ae. (8/26) also ran an abbreviated version of the story.
The Los Angeles Times (8/25, 3.42M) adds that Peck argues that it is "unsafe to continue running [Diablo Canyon plant] without evaluating whether it can withstand quakes from nearby faultsn that are now believed to be "capable of producing more ground shaking than was known when the rplant was built and licensed." NRC regulators have determined that Diablo Canyon's "current design would be able to stand up to any earthquakes the
[Shoreline] fault might produce." Peck took issue "with the methodology used to analyze earthquake risks.ff NRC spokeswoman Lara Uselding "said the agency stands by its conclusion that the plant would safely withstand an earthquake."
The Homeland Security News Wire (8/26) reports. according to Peck's filing. Diablo Canyon"s owner Pacific Gas and Electric Co. "released research in 2011 that determined that any of the three nearby faults - the Shoreline, Los Osos. and San Luis Bay - is capable of producing significantly more shaking during an earthquake than was accounted
for in the design of the plant's most vulnerable equipment."
Reuters (8/26, Krishnan) reports that the group Friends of the Earth, said, "The NRC knows that Diablo Canyon's two reactors are the most vulnerable to earthquakes in the United States, but the agency has failed to heed Dr. Peck's repeated warnings." The group added, "Dr. Peck's dissent argues that Diablo Canyon is operating outside the conditions of its license and should be shut down until PG&E can prove that the reactors can withstand potential earthquakes on these faults."
The Hill (8/26, Cama, 237K) adds that Damon Mo.glen of the Friends of the Earth, called Peck "the canary in the coal mine, warning us of a possible catastrophe at Diablo Canyon before it's too late."
Yahoo' (8/26, Mosendz, 10.35M) adds on its website that Peck's report asserts that the NRC is "not applying the safety rules it set out for the plant's operation." Peck says "proper research has not been done into impact of the earthquake faults." The report was "obtained by both the Associated Press and Friends of the Earth, an environmental group."
Damon Moglen of Friends of the Earth, said, "We agree with him that Diablo Canyon is vulnerable to earthquakes and must be shut down immediately. Rather than the NRC keeping this a secret, there must be a thorough investigation with public hearings to determine whether these reactors can operate safely."
KSBY-IY San Luis Obispo, CA (8/25, 2K) covered the story on its website, while KFSN-IY Fresno, CA (8/25, 5:02 p.m. PDT, 81 K) , KGO-TV
- San Francisco (8/25, 6:25 p.m. PDT, 87K), KCOY-IY Santa Barbara, CA (8/25, 6:07 p.m. PDT, 12K), and KEYT-TV~ Santa Barbara, CA (8/25, 6:05 p.m. PDT. 16K) broadcast this story.
Boxer To Hold Hearings On Dlablo Canyon Safety. On its website, Southern California Public Radto (8/25, 85K) reported that the Senate Environment and Public Works Committee, will hold "hearings on earthquake risks at California's last operating nuclear power plant. " The Senate panel announced the hearings Monday after the AP "disclosed" Beck's claims about Diablo Canyon's vulnerability to "nearby earthquake faults." The Senate Committee is chaired by Sen. Barbara Boxer who said "she's alarmed that the recommendation by Michael Peck ... was made a year ago and the agency hasn't acted."
From: Orf, Tracy Sent: Tuesday, August 26, 2014 7:20 AM To: Evans, Michele; Lund, Louise; Lantz, Ryan; Markley, Michael
Subject:
Olablo Canyon DPO Heads upl Looks like Sen. Boxer wants to hold a hearing specifically on Diablo Canyon.
It's all over the news.
--Trace Tracy J. Orf Technical Assistant Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Phone: (301) 415-2788
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UPDATED: 09/25/2014 3:49 PM08!27/2014 i i44 AMOS/27/2014 i ;11i AM08/2i/201 4 8;17 EM08/2il2014 2:47 PM Communications Plan -
Diablo Canyon Power Plant Topics of Interest State of California Seismic Report (ABN-1632)
Background
California Assembly Bill 1632 (Blakeslee. Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest baseload power plants, Diablo Canyon Power Plant and San Onofre Nuclear Generating Station to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other maJor issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state of the art methodologies using 20 and 30 mapping to compile this report This is ~different and more extensive data set metl=taElalag~ than what was used for the 2011 Shoreline Fault evaluation. ..-iComment Ul]: JPA-Modlfied to be cons!Slenl J wldata ,ources The purpose of this communication plan is to provide key messages associated with the public release of this report.
Key Messages
- Based on a preliminary evaluation, NRC staff concludes the t+he 81111632 report's information is consistent with sJ;l998$ the NRC's and PG&E's existing conclusions that Oiablo Canyon's se1sm1c design basis already accounts tor ground motions §uake6 larger than WRaj-those&- postulated for a longer Shoreline tault-Gafl geAeFata Therefore, - Comment U2J: JPA*A3 written we can't support 1h11 bullet. Timlng problem among othef the NRC does not currently have a safety concern with the structures. systems and issues. You can't say tills before we have even components necessary to reach and maintain safe shutdown. being able to perform their leld eyu on the report! Note *uwe*ted wording. Must wait to say this until technical intended function should the site experience an earthquake from the Shoreline fault. staff haa at the very leat1 done a rapid. cursOJY read of the report.
- The NRC will continue to review the new information in the report and will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC to revisit its preliminary evaluation.
- Oiablo Canyon WIii incorporate the Bill 1632 report's information into its March 2015 se1sm1c hazard re-analysis submittal to the NRC.
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Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.
Team Member Position Organization Telephone Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195 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 Jon Ake Senior Seismologist RES/DE/SGS EB 301-251-7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Scott Burnell Public Affairs Officer OPA 301-415-8204 Jenny Weil Congressional Affairs OCA 301-415-1691 Victor Dricks Public Affairs Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Dave WronaElaine License Renewal NRR/DLR 301-415-~51 Z I Keeaan I Cathy: Kanatas Attorney: OGC 301-415-2321 I Nick DiFrancesco Ja12an Lessons Learned JLD 301-415-1115 Planned Communication Activities The contents on this communication plan, supplemented by information provided by PG&E/Diablo Canyon, should be used to accomplish these ~ction~.* _ _ _ _ _ ... * ~
- Comment [jl]: JPA-Where In thl1 Umellne does someone ectualy look at the repM?
Tlmeframe Action Responsible Party(les) Looks like within 1 day we go Into br1eflng mode.
T- 7 day:s PG&E 12rovides a draft of the re12ort in the PG&E I electronic readino room for initial staff assessment T- 1 PG&E notifies NRC of seismic report submittal to PG&E the state of California 2
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Tlmeframe Action Responsible 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 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/OORL; applicable Senior Managers in their respective NRR/OLR; NRR/JLD reporting chain OPA; OCA; OGC OPA available to use Communications Plan to R-IV; OPA answer media inquiries. NO blog OR press release planned.
WithinT+Z2 Glt:leF asUeAs;J;JJLQ !.Qmi:11~!~~ i:1r~liminsi!Y ~
business days assessment of final re12ort to determine if anll s!QQiliQQs!I s!~iQQ~ ~hQl,!IQ ~ tsik~n !;!riQr 12 lh~
submittal of the seismic reevaluation in March
~
As requested Complete a Commissioners Assistants Brief R-IV; NRR
- 1. Questions and Answers What Is the impact of this new information on seismic design and licensing of DCPP?
Has the licensee entered this new Information into the corrective action program and performed an operability evaluation?
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 seismic data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, PG&E will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information (Reference 2)." Reference 2 is NRC letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status,
' Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f)
Regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," March 12, 2012.
Region IV, including the resident inspectors, have µndertakert an initial review of PG&E's _ - - -[ Comment [J4]: JPA-?ok?
assessment of this new information to verify that it does not affecfthe plant's ability to operate safely and to be able to remain safely shutdown following an earthquake. NRC's 3
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preliminary review is that the Diablo Canyon Units are safe to continue to operate based on:
- 88aseel eA assertions made by PG&E that the Shoreline Fault response spectra are still bounded by those for the Hosgri and LTSP earthquakes for which the plant was previously ~nalyze~ - Comment US]: We should anticipate a external question hele-11 Ille NRC relying only on the PG&E assenment?
- The preliminary assessment by PG&E of the data acquired for the CA AB1632 report indicates that the Shoreline Fault may be is-capable of generating a magnitude 6.7 earthquake. As documented in the RIL the NRC staff has analyzed a scenario involving a Shoreline Fault of magnitude 6.7 and concluded that the response spectra developed by such an earthquake is bounded by the Hosgri and LTSP spectra The NRC will review the new information provided in the report to the State of California including the Shoreline Fault characteristics, and the updated characteristics associated with the soil properties near the site. The NRC staff will take additional regulatory action as appropriate if the NRC staff concludes that the new information associated with the Shoreline Fault causes the NRC ~to revisit the conclusions in the RIL.
- 2. Has DCPP provided the seismic report to the NRC?
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 afe-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. EM-aecause 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 will the AB 1632 seismic report be coordinated with the 50.54(f) required submittal In March 2015?
The NRC has reviewed the plant's corrective action program documentation for this new information. All indications are that the ground motions from the Shoreline fault remains bounded by those from the Hosgrl 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 essessl if it causes the NRC ~to revisit the conclusions in the RIL. ____ _ - Comment [j6]: JPA-seems as ~ some words missing here.
!The 1000-page document has also been given to the .tiB.QJJapan Lessons Learned Directoratel to be considered in the 50.54(f) review. Consistent with the UFSAR, the new Comment [SRll37]: This phrasing lm~les the preliminary information regarding regional seismic source characterization (i.e. fault JLO is performing the seismic re-analysis. How about "The JLD will consider the AB 1632 report capability) and potential site ground motion will be evaluated in accordance with the process when " reviews Diablo Canyon's GMRS defined by the NRC in their Fukushima 50.54(f) letter.~This requires an NRG-endorsed submtttal In March 2015."
formal structured recess to evaluate alternative inter relations when develo in the
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_-a-Spectra (GMRS) that will be submitted to the NRC by Mairch 2015. The updated seismic
_.--iComment [J8J: Recommend deleting the acronym.
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hazards Se1smiGHazaras/GMRS YAII wo11la will be used as an input to a n y ~ Seismic Probabilistic Risk Assessment (SPRA) 01ablo Canyon might have t0;- wh1GR will ee submi~
to the NRC b~~1~.n_e_2_0_17t - Com"*1t [J9): GMRS is not used in PAA-seismic haz.ard curves are.
(If pushed on any *unknowns* in the report: If necessary, actions could include orders to Com"*lt [JllOJ: Can the JlO Clleck the June 2017 dale. The 3112112 50.54(1) letter halt operations if new information suggests there 1s an immediate safety concern. The NRC gives up IO 3 years Jo complele lhe Mitmlc will fulfill its mandate to protect public health and safety). PRA after the GMRS b submitted In March of 2015. II appears lhat PG&E woutd have until March 2018 instead Of June 2017.
(If asked what things lRifl& the plant has done since Fukushima: It is important to note that OCPP is an industry leader in implementing FLEX which was a post-Fukushima industry initiative to have extra equipment available remotely in the event of a beyond design basis event).
- 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 will-is expected to be incorporated GOAsiaerea into the more comprehensive 50.54f analysis due to the NRC in March 2015. However. because the licensee must notify the NRC of any new seismic info, they have shared this report and an initial operability evaluation showing why the plant is safe to operate. The NRC has looked at this evaluation and its preliminary assessment is that based on the information presented by PG&E -the Shoreline Fault does not exceed previously considered seismic hazards.
- 5. Why didn't the NRC discover the length of the faults when it did its seismic review of the Shoreline fault in 2011 prior to issuing the RIL?
California Assembly Bill 1632 (Blakeslee, Chapter 722, Statutes of 2006) directs the California Energy Commission to assess the potential vulnerability of California's largest base:load power plants, Oiablo Canyon Power Plant and San Onofre Nuclear Generating Station, to a major disruption due to a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio. The licensee has used the most state-of-the-art 20 and 30 geophysical mapping techniques, which are commonly used in offshore petroleum resource exploration. These techniques provide higher-resolution data than what was available to characterize the Shoreline Fault int~
- ___ - i Com"*1tUUJ: Keypoinl 2011 report.
The NRC has requested licensees of operating nuclear power reactors to submit a seismic hazard reevaluation using up-to-date methodologies and analysis which is due for OCPP in March 2015. (Lauren, JLLO: anything to add here?)
I 6. What la the impact of -this new infonnation on seismic design and licensing of DCPP?
Based on the preliminary results of the studies that are under review, -PG&E determined that the Shoreline Fault Zone may be capable of producing somewhat~ larger , Comment Ul2]: J P ~ 10 be dear the earthquakes than considered in the January 2011 PG&E repori However, the ground magnitude inaease is relative to the PG&E magnitude, the All used 8.7.
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motions from these larger earthquakes are still bounded by the Hosgri and LTSP ground motions. Since the seismic design of DCPP considered a range of ground motions from both a :double design ~arthquakE( and a Hosgrl earthquake, and the new ground motions do not exceed the Hosgri earthquake, the new information is not expected to adversely
.-*IComment U13J: PA-Do we need to deflne this?
Impact the seismic design of DCPP. As a result, the assessment associated with the January 2011 Shoreline Fault Report remains valid.
- 7. WIii the Report be coneldered In the License Renewal Procen Yes, In addition to the report being developed to address California Assembly BjU 1632.
PG&E is providing the report to the state of California as part of the state of California coastal zone consistency certification associated with the license renewal for DCPP. The state of California coastal zone consistency certification is considered by the NRC during the license renewal environmental review process. In addition the Atomic Safety and Licensing Board <ASLB} has expressed interest in the report because it is associated wjth a contention that Is under consideration by the ASLB in the license renewal process <see ML14224A320}.
- a. The AP wire service recently roportod that there Is a Differing Profosstonat Opinion (OPOl associated with NRC's evaluation of the Shoreline Fault. Why has the existence of this DPO only now boon mado public?
The oeo process is a strictly controlled and formalized process witbi1 the agency that allows differing professional opinions to be thoroughly considered by the agency white at the same time protecting the privacy of the DPO submitter. A DPO was submitted and is still undergoing internal NRC review in accordance with this process. Until the NRC completes its internal review process for this DPO. the agency is unable to comment on any potential DPO resolution or documentation. once the review is completed the agency will have a final decision on the DPO and associated documentation.
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