DCL-22-018, Independent Spent Fuel Storage Installation Responses to NRC Requests for Additional Information on License Amendment Request 21-04, Proposed Changes to the Emergency Plan for Post-Shutdown and Permanently.

Independent Spent Fuel Storage Installation Responses to NRC Requests for Additional Information on License Amendment Request 21-04, Proposed Changes to the Emergency Plan for Post-Shutdown and Permanently.

ML22083A116
Person / Time
Site:	Diablo Canyon
Issue date:	03/23/2022
From:	Zawalick M Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
DCL-22-018, DIL-22-007, EPID: L-2021-LLA-0190
Download: ML22083A116 (18)

Text

m PacHic Gas and Electric Company*

Maureen R. Zawalick Vice President Decommissioning and Diablo Canyon Power Plant Mail code 104/6/608 P.O. Box 56 Technical Services Avila Beach, CA 93424 805.545.4242 Internal: 691.4242 PG&E Letter DCL-22-018 PG&E Letter DIL-22-007 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Docket No. 72-26, Materials License No. SNM-2511 Diablo Canyon Independent Spent Fuel Storage Installation Responses to NRC Requests for Additional Information on License Amendment Request 21-04, Proposed Changes to the Diablo Canyon Power Plant Emergency Plan for Post-Shutdown and Permanently Defueled Condition

Reference:

1. PG&E Letter DCL-21-062, DIL-21-007, License Amendment Request 21-04, Proposed Changes to the Diablo Canyon Power Plant Emergency Plan for Post-Shutdown and Permanently Defueled Condition, dated October 8, 2021 (ML21284A003)

2. Email from NRC Project Manager, Samson Lee, Request for additional information - Diablo Canyon proposed changes to emergency plan for post-shutdown and permanently defueled condition (EPID: L-2021-LLA-0190), dated March 2, 2022 (ML22061A219)

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted License Amendment Request 21-04, to propose revisions to the Diablo Canyon Power Plant Emergency Plan to reflect the post-shutdown and permanently defueled condition.

In Reference 2, the Nuclear Regulatory Commission provided requests for additional information (RAIs) regarding Reference 1. The Enclosure to this letter provides PG&E responses to the RAIs.

PG&E makes no new or revised regulatory commitments (as defined in NEI 99-04) in this letter.

If you have any questions or require additional information, please contact Mr. Philippe Soenen at (805) 459-3701.

A membe r of the S TAR S Al li an ce C a ll aw ay

• D i ablo Can yon

• Pa lo Ver de

• Wo lf C reek

Document Control Desk PG&E Letter DCL-22-018 Page 2 PG&E Letter DIL-22-007 I state under penalty of perjury that the foregoing is true and correct.

Executed on March 23, 2022 .

Sincerely, 1

Maureen R. Zawalick Vice President, Decommissioning and Technical Services Enclosure cc: Diablo Distribution cc/enc: Nicholas A. Hernandez, NRC Acting Senior Resident Inspector Wade Horton, Administrative Officer, County of San Luis Obispo Office of Emergency Services Samson S. Lee, NRR Senior Project Manager Scott A. Morris, NRC Region IV Administrator Gonzalo L. Perez, Branch Chief, California Dept of Public Health Michael Warren, Manager, Radiological Preparedness Unit, California Governor's Office of Emergency Services A mem be r of the S TARS Al li an ce C a ll aw ay

• D ia blo C an yon

• Pal o Ver de

• Wo lf C reek

Enclosure PG&E Letter DCL-22-018 PG&E Letter DIL-22-007 Responses to NRC 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 11.B, Evaluation Criterion 8.1.a states that the site-specific ERO is developed.

Enclosure PG&E Letter DCL-22-018 PG&E Letter DIL-22-007

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.

Enclosure PG&E Letter DCL-22-018 PG&E Letter DIL-22-007 PG&E Response to RAI-1:

To ensure the continued effective and timely implementation of the major task of Technical Support/Accident Analysis, the proposed Diablo Canyon Power Plant (DCPP)

Emergency Plan (E-Plan) is revised to designate the Technical Support Center (TSC)

Engineering Advisor as a minimum staff 60-minute responder (i.e., within 60 minutes of the declaration of an Alert or higher emergency classification level [ECL]).

Qualifications for the TSC Engineering Advisor position selection criteria will align with the current position requirements. As discussed in Enclosure 1, Section 5.2.5a of the license amendment request, the Attachment 4 Task Analysis concluded that all of the TSC Engineers responsibilities and tasks can be eliminated. As such, no new tasks are being added to the TSC Engineering Advisor position and the Engineering function will continue to be maintained by the TSC Engineering Advisor without competing priorities. Revised DCPP E-Plan, Sections 5.19 and 5.22, markup and clean pages are provided in the Attachments of this Enclosure to reflect this change.

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).

Enclosure PG&E Letter DCL-22-018 PG&E Letter DIL-22-007 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.

PG&E Response to RAI-2:

To ensure the continued effective and timely implementation of the major task of Repair and Corrective Actions, the proposed DCPP E-Plan is revised to maintain the Operations Support Center (OSC) Director as a minimum staff 60-minute responder (i.e., within 60 minutes of the declaration of an Alert or higher ECL). In addition, one qualified Mechanical Maintenance technician and one qualified Electrical Maintenance technician will be minimum staff 60-minute OSC responders. Revised DCPP E-Plan, Sections 5.7.3, 5.19, 5.20, and 5.23, markup and clean pages are provided in the Attachments of this Enclosure to reflect these changes.

Enclosure Attachment 1 PG&E Letter DCL-22-018 PG&E Letter DIL-22-007 Revised Diablo Canyon Power Plant Emergency Plan, Sections 5.7.3, 5.19, 5.20, 5.22, and 5.23, Markup

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 17 of 48 Organizational Control of Emergencies 5.7.6 Operations Coordinator The Operations Coordinator is responsible for the following activities:

1) Coordinating operation's response outside the Control Room.

2) Ensuring the Control Room is updated on status of OSC team assignments.

5.7.75.7.2 Onsite Field Monitoring Teams (FMTs)RP Technicians The onsite Field Monitoring Team isRP Technicians are responsible for the following activities:

1) Performing radiation surveys around the plant site and obtaining appropriate samples for analysis.

2) Maintaining initial communications with the Site RP CoordinatorRadiological Manager and subsequently with the FMT Coordinator for reporting of monitoring results and maintaining cognizance of the emergency situation.

I -_

5.7.85.7.3 Maintenance Technicians, RP, Chemistry and Operations Personnel The following personnel provide support in planning and performing tasks in their disciplines.

1) Mechanical Maintenance personnel

2) Electrical Maintenance personnel

3) Technical Maintenance personnel

4) Radiation Protection personnel

5) Chemistry personnel

6) Operations personnel 5.8 EMERGENCY OPERATIONS FACILITY (EOF)

The principal functions of the EOF are to provide for strategic planning and control. The principal functions of the EOF staff are:

1) Control and Coordination The EOF utility staff, under the direction of the Emergency Director (ED), manages and coordinates all PG&E technical direction and control of the integrated emergency response effort.

When activated, the EOF determines status of notifications, provides Protective Action Recommendations (PARs) and Public Information releases under the ED's authority.

2) Liaison/Interface Rev 5.01TBD

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 41 of 48 Organizational Control of Emergencies Shift 60 90 Functional Area Major Tasks Emergency Positions Staffing Minutes Minutes Shift Supervisor (qualified as CFH) 1 --- ---

1. Plant Operations and Assessment of CFH 1 --- ---

Control Room Staff Operational Aspects NCO 3 --- ---

Operations Advisor (CR/TSC) --- 1 ---

Shift Supervisor 1* --- ---

Site Emergency Coordinator (TSC) --- --- 1

2. Emergency Direction and Control Command and Control Emergency Director (EOF) --- --- 1 EOF Director (EOF) -- -- 1 Licensee, Local/State, Federal CFH/NCO 1* --- ---

ENS Communicator (TSC) --- --- 1

3. Notification and Communication Communications Coordinator (EOF) --- --- 1 Engineering Liaison (EOF) --- --- 1 Government Relations Coord. (EOF) --- --- 1 Advisor to the County (EOF) --- --- 1 CFH/RP Technician 1* --- ---

Dose Assessment Radiological Manager (EOF) --- --- 1 Dose Assessor (EOF) --- --- 1 FMT Coordinator (EOF) --- --- 1

4. Radiological Assessment Offsite Surveys FMT Leader (RP Technician) (EOF) --- --- 2 FMT Driver (EOF) --- --- 2 Onsite (out-of-plant) Surveys RP Technician (OSC) --- 1* ---

In-plant Surveys RP Technician (OSC) 2 1 ---

Chemistry Radiological Advisor (TSC) --- --- 1 CFH 1* --- ---

Engineering Advisor (TSC) --- 1 ---

Technical Support Operations Advisor (CR/TSC) --- 1* ---

5. Plant System Engineering, Repair, and Radiological Advisor (TSC) --- --- 1*

Corrective Actions OSC Director (OSC) --- 1 ---

Repair and Corrective Actions Mechanical Technician (OSC) --- 1 ---

Electrical Technician (OSC) --- 1 ---

6. In-Plant Protective Actions Radiation Protection RP Technicians (OSC) 2* 1 ---

Local Local

7. Firefighting --- Fire Department 5 Support Support Local Local

8. First Aid and Rescue Operations --- Industrial Fire Officers 2*

Support Support

9. Site Access Control and Personnel Per Security Local Local Security and Accountability Security Personnel Accountability Plan Support Support TOTAL: 12 7 16

• May be performed by someone filling another position having functional qualifications.

Rev 5.01TBD

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 43 of 48 Organizational Control of Emergencies Emergency Response Facility Minimum Staff Site Emergency Coordinator Radiological Advisor Engineering Advisor TSC Operations Advisor ENS Communicator Security Advisor OSC Director RP Technicians OSC Mechanical Technician Electrical Technician Emergency Director EOF Director Radiological Manager Dose Assessor FMT Coordinator EOF Offsite FMT Engineering Liaison Communications Coordinator Advisor to the County Government Relations Coordinator None JIC Rev 5.01TBD

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 45 of 48 Organizational Control of Emergencies 5.22 FIGURE 5-2, TSC ORGANIZATION Emergency Director (EOF)

Site Emergency Coordinator Connect to Radiological Advisor 1

e,, eete1 I ....... ,,,,,, osc Make I ~SE I ,, (See OSC Chart) boxes gray

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Radiological

"~ I Ops Advisor I

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I Security Advisor I Advisor I I I #itffiS811

- Advisor A d¥i!te1

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C 8:B1111uaie11for - gray l~,1uliele=ieal Control double box -eR-B :at:. P1U~!DI Room and gray Ueeh11111ienl E11g;11ee1 l..r;e11e:.,/ ENS Communicator Eleehienl

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Shaded boxes indicate minimum staffing for facility activation Double boxes indicate 60-minute response positions lleade1 Other TSC positions are 90-minute responders 1;111!:HIHlP Rev 5.01TBD

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 46 of 48 Organizational Control of Emergencies 5.23 FIGURE 5-3, OSC ORGANIZATION Site Emergency Coordinator (TSC)

I OSC Director Make double box I

I rt'eam Coot din a tot I I I 1-le e:h: :llniul E-lecttieal Site RP Chembtry Oper :11tinns tun din:11'61 Oun din:llttn Coo11diee.to11 Coordiee.toF I

,r----------- --------- ,r- -- ----- -- ---- ------ ,r---------- ---------- ~---------- ----------1

Mechanical  : Electrical  : l &C 1-laint. e&RP  : ose i I I Personnel I

: Personnel :I Personnel (2) -f'ffn~ t+rl- -

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Make box r--- Note: gray Make double and gray Shaded boxes indicate minimum staffing for facility activation boxes; Double Outlined box es indicate 60-minute response positions C&RP replace Single Outlined boxes indicate 90-minute response positions 'Fechniciam t3~

"Personnel" with "Technician" Rev 5.01TBD

Enclosure Attachment 2 PG&E Letter DCL-22-018 PG&E Letter DIL-22-007 Revised Diablo Canyon Power Plant Emergency Plan, Sections 5.7.3, 5.19, 5.20, 5.22, and 5.23, Clean

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 12 of 13 Organizational Control of Emergencies

6) Planning and coordinating resources to conduct assessment, maintenance, repair or installation of special equipment.

7) Providing technical advice to evaluation personnel in the TSC.

8) Coordinating plant access and ensuring personnel entering a potentially hazardous plant area are informed of:

a) Plant status.

b) Potential hazards.

c) Safety and radiation protection provisions.

d) Appropriate protective equipment required.

9) Maintaining the capability of communicating with personnel engaged in operations, maintenance or chemistry and radiation protection emergency response activities.

10) Assisting the Control Room and TSC/OSC in communicating with response teams.

5.7.2 RP Technicians RP Technicians are responsible for the following activities:

1) Performing radiation surveys around the plant site and obtaining appropriate samples for analysis.

2) Maintaining initial communications with the Radiological Manager and subsequently with the FMT Coordinator for reporting of monitoring results and maintaining cognizance of the emergency situation.

5.7.3 Maintenance Technicians The following personnel provide support in planning and performing tasks in their disciplines.

1) Mechanical Maintenance personnel

2) Electrical Maintenance personnel 5.8 EMERGENCY OPERATIONS FACILITY The principal functions of the EOF are to provide for strategic planning and control. The principal functions of the EOF staff are:

1) Control and Coordination The EOF utility staff, under the direction of the Emergency Director (ED), manages and coordinates all PG&E technical direction and control of the integrated emergency response effort.

Rev TBD

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 30 of 31 Organizational Control of Emergencies 5.19 TABLE 5-1, DCPP ON-SHIFT AND AUGMENTED ERO Shift 60 90 Functional Area Major Tasks Emergency Positions Staffing Minutes Minutes Shift Supervisor (qualified as CFH) 1 --- ---

1. Plant Operations and Assessment of CFH 1 --- ---

Control Room Staff Operational Aspects NCO 3 --- ---

Operations Advisor (CR/TSC) --- 1 ---

Shift Supervisor 1* --- ---

Site Emergency Coordinator (TSC) --- --- 1

2. Emergency Direction and Control Command and Control Emergency Director (EOF) --- --- 1 EOF Director (EOF) -- -- 1 Licensee, Local/State, Federal CFH/NCO 1* --- ---

ENS Communicator (TSC) --- --- 1 Communications Coordinator (EOF) --- --- 1

3. Notification and Communication Engineering Liaison (EOF) --- --- 1 Government Relations Coord. (EOF) --- --- 1 Advisor to the County (EOF) --- --- 1 CFH/RP Technician 1* --- ---

Dose Assessment Radiological Manager (EOF) --- --- 1 Dose Assessor (EOF) --- --- 1 FMT Coordinator (EOF) --- --- 1

4. Radiological Assessment Offsite Surveys FMT Leader (RP Technician) (EOF) --- --- 2 FMT Driver (EOF) --- --- 2 Onsite (out-of-plant) Surveys RP Technician (OSC) --- 1* ---

In-plant Surveys RP Technician (OSC) 2 1 ---

Chemistry Radiological Advisor (TSC) --- --- 1 CFH 1* --- ---

Engineering Advisor (TSC) --- 1 ---

Technical Support Operations Advisor (CR/TSC) --- 1* ---

5. Plant System Engineering, Repair, and Radiological Advisor (TSC) --- --- 1*

Corrective Actions OSC Director (OSC) --- 1 ---

Repair and Corrective Actions Mechanical Technician (OSC) --- 1 ---

Electrical Technician (OSC) --- 1 ---

6. In-Plant Protective Actions Radiation Protection RP Technicians (OSC) 2* 1 ---

Local Local

7. Firefighting --- Fire Department 5 Support Support Local Local

8. First Aid and Rescue Operations --- Industrial Fire Officers 2*

Support Support

9. Site Access Control and Personnel Per Security Local Local Security and Accountability Security Personnel Accountability Plan Support Support TOTAL: 12 7 16

• May be performed by someone filling another position having functional qualifications.

Rev TBD

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 31 of 32 Organizational Control of Emergencies 5.20 TABLE 5-2, AUGMENTED ERO MINIMUM STAFFING FOR FACILITY ACTIVIATION Emergency Response Facility Minimum Staff Site Emergency Coordinator Radiological Advisor Engineering Advisor TSC Operations Advisor ENS Communicator Security Advisor OSC Director RP Technicians OSC Mechanical Technician Electrical Technician Emergency Director EOF Director Radiological Manager Dose Assessor FMT Coordinator EOF Offsite FMT Engineering Liaison Communications Coordinator Advisor to the County Government Relations Coordinator None JIC Rev TBD

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 33 of 34 Organizational Control of Emergencies 5.22 FIGURE 5-2, TSC ORGANIZATION Emergency Director (EOF)

Site Emergency Coordinator Radiological Advisor Ops Advisor Engineering Advisor ENS Communicator Security Advisor OSC Control Room (see OSC chart)

Note:

Shaded boxes indicate minimum staffing for facility activation Double boxes indicate 60-minute response positions Other TSC positions are 90-minute responders Rev TBD

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 34 of 35 Organizational Control of Emergencies 5.23 FIGURE 5-3, OSC ORGANIZATION Site Emergency Coordinator (TSC)

OSC Director Electrical Technician RP Technicians (2) Mechanical Technician Note:

Shaded boxes indicate minimum staffing for facility activation Double boxes indicate 60-minute response positions Other OSC positions are 90-minute responders Rev TBD