ML22061A219

NRR E-mail Capture - Request for Additional Information - Diablo Canyon Proposed Changes to Emergency Plan for post-shutdown and Permanently Defueled Condition

ML22061A219
Person / Time
Site:	Diablo Canyon
Issue date:	03/02/2022
From:	Samson Lee NRC/NRR/DORL/LPL4
To:	Richardson M Pacific Gas & Electric Co
References
L-2021-LLA-0190
Download: ML22061A219 (4)

Text

From: Lee, Samson Sent: Wednesday, March 2, 2022 3:31 PM To: Richardson, Michael Cc: Soenen, Philippe

Subject:

Request for additional information - Diablo Canyon proposed changes to emergency plan for post-shutdown and permanently defueled condition (EPID: L-2021-LLA-0190)

Background

By letter dated October 8, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21284A003), Pacific Gas and Electric Company (PG&E, the licensee) submitted a license amendment request (LAR) for proposed changes to the Diablo Canyon Power Plant (DCPP) Emergency Plan (E-Plan) for U.S. Nuclear Regulatory Commission (NRC) review and prior approval, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(q). The proposed changes would revise the staffing for certain emergency response organization (ERO) positions, based on receipt by the NRC of certification under 10 CFR 50.82(a)(2) that the DCPP reactors had permanently ceased operations and permanently removed fuel from the reactor vessels. The NRC staff has reviewed the license amendment request (LAR) and determined that additional information is required to complete the review. The NRC staffs requests for additional information (RAIs) are listed below.

The staff may have additional RAIs. The NRC staff held a draft RAI clarification call with the PG&E staff on March 2, 2022. The PG&E staff requested, and NRC agreed, to an RAI response by April 1, 2022.

The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. Please note that if you do not respond to this request by the agreed upon date or provide an acceptable alternate date, we may deny your application for amendment under the provisions of 10 CFR, Section 2.108. If circumstances result in the need to revise the agreed upon response date, please contact me at (301) 415-3168 or via e-mail Samson.Lee@nrc.gov.

Regulatory Requirements and Guidance:

• 10 CFR 50.47(b)(1) requires that each principal response organization has staff to respond and to augment its initial response on a continuous basis.

• 10 CFR 50.47(b)(2) requires that the on-shift facility licensee has adequate staffing to provide initial facility accident response in key functional areas is maintained at all times and timely augmentation of response capabilities is available.

• Associated guidance in NUREG-0654,Section II.B, Evaluation Criterion B.1.a states that the site-specific ERO is developed.

RAI 1

Issue: , Evaluation of the Proposed Changes, Section 5.2.5.a, Major Tasks: Technical Support/Accident Analysis, of the LAR states, in part:

The PG&E analysis of the proposed post-shutdown On-Shift and Augmented ERO Staffing Assessment concluded that in a permanently defueled condition, the TSC

[Technical Support Center] Engineering Advisor will be qualified to provide engineering support in response to a Fuel Handling Accident (FHA) in the fuel handling building or an event resulting in damage to the Spent Fuel Pool (SFP) integrity or loss of SFP cooling or inventory. As a result of this analysis, PG&E proposed that the TSC Engineering Advisor would assume the functions of engineering support and therefore, has proposed to eliminate both the currently approved Mechanical and Electrical Engineering 60-minute response positions and replacing those emergency positions with a proposed 90-minute response position of a TSC Engineering Advisor. [emphasis added]

The current ERO staffing for the DCPP was approved by the NRC in a letter dated August 21, 2019 (ADAMS Accession No. ML19196A309) and is based on the guidance provided in a letter to the Nuclear Energy Institute dated June 12, 2018 (ADAMS Accession No. ML18022A352),

that provided alternative guidance (referred to as the Revised Table B-1) to nuclear power plant licensees for Evaluation Criterion II.B in NUREG-0654, for minimum ERO on-shift and augmentation staffing.

However, the guidance in Revised Table B-1 identifies engineering support augmenting the on-shift staff within 60 minutes of the declaration of an Alert or higher emergency classification level (ECL). This is consistent with the current DCPP E-Plan staffing, as well as the current precedence of other decommissioning sites implementing these types of proposed changes to the ERO staffing.

As proposed, the minimum engineering staffing will not allow the facilities to perform the intended functions within 60 minutes (e.g., Plant System Engineering is provided by the TSC Engineering Advisor with a 90-minute response).

Request:

Describe how the augmented engineering staffing will continue to be aligned with the current DCPP E-Plan to ensure the continued effective and timely implementation of the major task of Technical Support/Accident Analysis within 60 minutes of the declaration of an Alert or higher ECL.

RAI 2

Issue: , Section 5.2.5.b, Major Tasks: Repair and Corrective Actions, of the LAR, states, in part:

The PG&E analysis of the proposed post-shutdown On-Shift and Augmented ERO Staffing Assessment concluded that in a permanently defueled condition, the OSC

[Operations Support Center] Director would assume the function of repair and corrective actions (e.g., Mechanical and Electrical Maintenance) as a 90-minute responder. As a result of the OSC Director assuming these functions, the OSC Mechanical and Electrical Maintenance Coordinators would be eliminated as 60-minute responders from the currently approved DCPP E-Plan. [emphasis added]

However, the guidance in Revised Table B-1 identifies Mechanical Maintenance and Electrical Maintenance personnel augmenting the on-shift staff within 60 minutes of the declaration of an Alert or higher ECL. This is consistent with the current DCPP E-Plan staffing as well as consistent with the current precedence of other decommissioning sites implementing these types of proposed changes to the ERO staffing.

As proposed, the minimum maintenance staffing will not allow the facilities to perform the intended functions within 60 minutes (e.g., maintenance support is provided by the OSC Director with a 90-minute response with Mechanical Maintenance and Electrical/Instrumentation and Controls (I&C) Maintenance positions called-in as needed to support repair and corrective actions).

Request:

Describe how the augmented maintenance staffing will continue to be aligned with the current DCPP E-Plan to ensure the continued effective and timely implementation of the major task of Repair and Corrective Actions within 60 minutes of the declaration of an Alert or higher ECL.

Docket Nos.: 50-275, 50-323, 72-26

Hearing Identifier: NRR_DRMA Email Number: 1542 Mail Envelope Properties (SA1PR09MB865331793E0919E2F9F3AD729A039)

Subject:

Request for additional information - Diablo Canyon proposed changes to emergency plan for post-shutdown and permanently defueled condition (EPID: L-2021-LLA-0190)

Sent Date: 3/2/2022 3:31:26 PM Received Date: 3/2/2022 3:31:00 PM From: Lee, Samson Created By: Samson.Lee@nrc.gov Recipients:

"Soenen, Philippe" <PNS3@pge.com>

Tracking Status: None "Richardson, Michael" <MJRm@pge.com>

Tracking Status: None Post Office: SA1PR09MB8653.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 6525 3/2/2022 3:31:00 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: