ML22187A025

Issuance of Amendment Nos. 242 and 243 Revision to Emergency Plan for Post-Shutdown and Permanently Defueled Condition

ML22187A025
Person / Time
Site:	Diablo Canyon
Issue date:	11/16/2022
From:	Samson Lee Plant Licensing Branch IV
To:	Gerfen P, Welsch J Pacific Gas & Electric Co
Lee S, 301-415-3158
References
EPID L-2021-LLA-0190
Download: ML22187A025 (34)

Text

November 16, 2022 Ms. Paula Gerfen Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424

SUBJECT:

DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 242 AND 243 RE: REVISION TO EMERGENCY PLAN FOR POST-SHUTDOWN AND PERMANENTLY DEFUELED CONDITION (EPID L-2021-LLA-0190)

Dear Ms. Gerfen:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 242 to Facility Operating License No. DPR-80 and Amendment No. 243 to Facility Operating License No. DPR-82 for the Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon), respectively. The amendments consist of changes to the Diablo Canyon Emergency Plan (E-Plan) in response to your application dated October 8, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21284A003), as supplemented by letter dated March 23, 2022 (ML22083A116).

The amendments revise the Diablo Canyon E-Plan for the post-shutdown and permanently defueled condition. The amendments will be effective after the following conditions have been met: (1) docketing of the certifications required by the Title 10 of Code of Federal Regulations Sections 50.82(a)(1)(i) and (ii) for Diablo Canyon; and (2) implementation of the Permanently Defueled Technical Specifications. The amendments must be implemented by Pacific Gas and Electric Company (the licensee) within 180 days of the effective date of the amendments. The effective date of the amendments is uncertain at this time because, by letter dated October 31, 2022, the licensee indicated that it is seeking to renew the Diablo Canyon licenses (ML22304A691).

P. Gerfen A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Samson S. Lee, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosures:

1. Amendment No. 242 to DPR-80

2. Amendment No. 243 to DPR-82

3. Safety Evaluation cc: Listserv

PACIFIC GAS AND ELECTRIC COMPANY DOCKET NO. 50-275 DIABLO CANYON NUCLEAR POWER PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 242 License No. DPR-80

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Pacific Gas and Electric Company (the licensee), dated October 8, 2021, as supplemented by letter dated March 23, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, by Amendment No. 242, Facility Operating License No. DPR-80 is hereby amended to authorize revision to the Diablo Canyon Power Plant Emergency Plan as set forth in the Pacific Gas and Electric Companys application dated October 8, 2021, as supplemented by letter dated March 23, 2022, and evaluated in the NRC staff safety evaluation for this amendment.

3. This license amendment is effective after the following conditions have been met:

Docketing of the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) for Diablo Canyon Nuclear Power Plant, Units 1 and 2; and The Diablo Canyon Nuclear Power Plant, Units 1 and 2, Permanently Defueled Technical Specifications are implemented.

The amendment shall be implemented within 180 days of the effective date of the amendment.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Michael Michael F F King Date: 2022.11.16 19:38:30 King -05'00' Andrea D. Veil, Director Office of Nuclear Reactor Regulation Date of Issuance: November 16, 2022

PACIFIC GAS AND ELECTRIC COMPANY DOCKET NO. 50-323 DIABLO CANYON NUCLEAR POWER PLANT, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 243 License No. DPR-82

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Pacific Gas and Electric Company (the licensee), dated October 8, 2021, as supplemented by letter dated March 23, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, by Amendment No. 243, Facility Operating License No. DPR-82 is hereby amended to authorize revision to the Diablo Canyon Power Plant Emergency Plan as set forth in the Pacific Gas and Electric Companys application dated October 8, 2021, as supplemented by letter dated March 23, 2022, and evaluated in the NRC staff safety evaluation for this amendment.

3. This license amendment is effective after the following conditions have been met:

Docketing of the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) for Diablo Canyon Power Plant, Units 1 and 2; and The Diablo Canyon Power Plant, Units 1 and 2, Permanently Defueled Technical Specifications are implemented.

The amendment shall be implemented within 180 days of the effective date of the amendment.

FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Michael F Michael F King Date: 2022.11.16 King 19:38:55 -05'00' Andrea D. Veil, Director Office of Nuclear Reactor Regulation Date of Issuance: November 16, 2022

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 242 TO FACILITY OPERATING LICENSE NO. DPR-80 AND AMENDMENT NO. 243 TO FACILITY OPERATING LICENSE NO. DPR-82 PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323

1.0 INTRODUCTION

By letter dated November 27, 2018 (Reference 1), in accordance with sections 50.4(b)(8) and 50.82(a)(1)(i) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, Pacific Gas and Electric Company (PG&E, the licensee) certified to the U.S. Nuclear Regulatory Commission (NRC, or Commission) that it had decided to permanently cease power operations at Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon or DCPP), upon expiration of the operating licenses (i.e., November 2, 2024, and August 26, 2025, for Units 1 and 2, respectively).

Upon the NRCs docketing of the PG&E certification that all fuel has been permanently removed from the reactor vessels and placed into the spent fuel pool (SFP), pursuant to 10 CFR 50.82(a)(2), the applicable licenses for the Diablo Canyon facility will no longer authorize operation of the reactors, or emplacement or retention of fuel into the reactor vessels.

The irradiated fuel will be stored in the SFP and in dry cask storage at the Independent Spent Fuel Storage Installation (ISFSI), located at the Diablo Canyon site and licensed under a site-specific license SNM-2511, until it is shipped offsite.

By application dated October 8, 2021 (Reference 2), as supplemented by letter dated March 23, 2022 (Reference 3), PG&E requested prior approval from the NRC for its proposed changes to the Diablo Canyon Emergency Plan (E-Plan), as required under 10 CFR 50.54(q)(4), to support the planned permanent cessation of operations and permanent defueling of Diablo Canyons reactors. Specifically, the proposed changes would revise the Diablo Canyon E-Plan emergency response organization (ERO) staffing to support the planned permanent cessation of operations and permanent defueling of the Diablo Canyon reactors. The proposed changes would revise the Diablo Canyon ERO on-shift and augmented staffing commensurate with the reduced spectrum of credible accidents for a permanently shutdown and defueled nuclear power reactor facility.

The supplemental letter dated March 23, 2022, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change Enclosure 3

the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on December 28, 2021 (86 FR 73819).

2.0 REGULATORY EVALUATION

An operating nuclear power reactor licensees E-Plan is developed for a level of effectiveness commensurate with the potential consequences to public health and safety for a wide spectrum of accident scenarios. With the permanent cessation of operations and the permanent removal of the fuel from the reactor vessels at Diablo Canyon, most of the accident scenarios postulated for an operating nuclear power reactor are no longer applicable. The irradiated fuel will be stored in the SFP and in the onsite ISFSI until the fuel can be moved offsite for long-term storage or disposal. The reactor coolant system (RCS) and reactor support systems are no longer in operation and will have no function related to the storage of the irradiated fuel.

Therefore, postulated accidents involving a failure or malfunction of the reactors, RCS, or reactor support systems are no longer applicable.

Chapter 15, Accident Analyses, of the Diablo Canyon Final Safety Analysis Report, as updated (UFSAR) (Reference 4), describes safety analyses for postulated design-basis accidents (DBAs) against which Diablo Canyon is designed and evaluated. The postulated DBA that will remain applicable to Diablo Canyon in its permanently shutdown and defueled condition is the fuel handling accident (FHA) in the fuel handling building where the SFPs are located.

The regulatory requirements and guidance on which the NRC staff based its review of the license amendment request are addressed below.

2.1 Regulatory Requirements Section 50.47(b)(1) of 10 CFR states, in part, that [e]ach principal response organization has staff to respond and to augment its initial response on a continuous basis.

Section 50.47(b)(2) of 10 CFR states, in part, that adequate staffing to provide initial facility accident response in key functional areas [be] maintained at all times, and that timely augmentation of response capabilities is available Section IV.A, Organization, of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50, states, in part, that [t]he organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization...

2.2 Guidance Regulatory Guide 1.101, Revision 2, Emergency Planning and Preparedness for Nuclear Power Reactors, dated October 1981 (Reference 5), endorses Revision 1 to NUREG-0654/FEMA-REP-1 [Federal Emergency Management Agency - Radiological Emergency Preparedness], Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980 (Reference 6) (hereinafter referred to as NUREG-0654), which provides guidance and acceptance criteria outlining an acceptable means for complying with the planning standards set forth in 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. These criteria provide a basis for NRC licensees, and State and local governments to develop radiological E-Plans.

In NUREG-0654, section II, Planning Standards and Evaluation Criterion, Evaluation Criteria II.B.1 and II.B.5 address planning standard 10 CFR 50.47(b)(2). Evaluation Criterion II.B.1 specifies the onsite emergency organization of plant staff personnel for all shifts, and its relation to the responsibilities and duties of the normal shift complement. In addition, Evaluation Criterion II.B.5, states, in part:

Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency. This capability shall be as indicated in Table B-1.

The NRCs Office of Nuclear Security and Incident Response (NSIR)/Division of Preparedness and Response (DPR) Interim Staff Guidance (ISG) document, NSIR/DPR-ISG-01, Emergency Planning for Nuclear Power Plants, dated November 2011 (Reference 7), provides updated guidance information to address emergency planning requirements for nuclear power plants.

Specifically, NSIR/DPR-ISG-01 was developed to address the assignment of tasks or responsibilities to on-shift ERO personnel that would potentially overburden them and prevent the timely performance of their E-Plan functions. The guidance of NSIR/DPR-ISG-01 also endorsed the Nuclear Energy Institute (NEI) document, NEI 10-05, Revision 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, dated June 2011 (Reference 8), which establishes a standard methodology for licensees to conduct analyses of the ability of on-shift staff to perform all required functions and tasks necessary to respond to a declared emergency for an operating power reactor. This methodology is one acceptable method to meet the requirement of Section IV.A.9 of Appendix E to 10 CFR Part 50 for all accident scenarios that are applicable in a permanently defueled condition.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the licensees regulatory and technical analyses in support of its proposed E-Plan changes, described in the licensees application, as supplemented. The NRC staff evaluated the application using the guidance in Table B-1, Minimum Staffing Requirements for Nuclear Power Plant Emergencies, of NUREG-0654.

The NRC staffs technical evaluation for each major functional area described in enclosure 1, Evaluation of the Proposed Changes, of the licensees application is detailed in this safety evaluation (SE). The NRC staff also reviewed the licensees ability to promptly implement the SFP mitigation strategies, if required.

3.1 Applicable DBAs The guidance in NSIR/DPR-ISG-01, section IV.C, On-Shift Staffing Analysis, states that a staffing analysis performed pursuant to 10 CFR Part 50, Appendix E, Section IV.A.9 should consider the postulated DBAs (Condition IV events) analyzed in the licensees UFSAR. In addition, NSIR/DPR-ISG-01 also states that to ensure that the on-shift staff can carry out its

assigned emergency response functions until the augmenting ERO arrives, each licensee should define the events that will be used in the staffing analysis.

In section 2.1, On-Shift Staffing, of enclosure 1 to PG&Es application, the licensee stated, in part:

To support reduced staffing following permanent cessation of operations and permanent removal of [fuel] from the reactor vessels, the [on-shift] staffing levels have been evaluated [, in part,] using the methodology in Nuclear Energy Institute (NEI) 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, which evaluates the postulated accidents that will be applicable in the permanently defueled condition.

The licensees post-shutdown on-shift staffing assessment considered the following accident scenarios:

Design basis threat FHA Aircraft probable threat Control room fire requiring evacuation and maintain SFP cooling Loss of SFP level requiring implementation of mitigation strategies General Emergency with radioactive release and protective action recommendation The licensee also stated that the primary events of concern in the immediate post-shutdown and defueled condition are an FHA or a loss of SFP cooling and/or water inventory. An FHA in the fuel handling building where the SFPs are located, as described in the Diablo Canyon UFSAR, Chapter 15, Accident Analyses, will remain applicable to Diablo Canyon in its permanently shutdown and defueled condition. Events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of normal and emergency SFP inventory makeup strategies and mitigating strategies required under 10 CFR 50.155(b)(2) and License Condition 2.I, Mitigation Strategy License Condition, for Unit 1, and License Condition 2.I, Mitigation Strategy, for Unit 2.

The NRC staff finds that applicable DBAs in PG&Es application are consistent with guidance in NSIR/DPR ISG 01.

3.2 On-shift and Augmented ERO Emergency Preparedness Functions The following sections provide the NRC staffs evaluation of the proposed changes to the major functional areas found in Table B-1 of NUREG-0654 for both on-shift and augmented ERO.

3.2.1 Major Functional Area: Plant Operations and Assessment of Operational Aspects The licensee stated that the on-shift staffing levels have been evaluated, in part, using the methodology in NEI 10-05 to support reduced staffing following permanent cessation of operations and permanent removal of fuel from the reactor vessels.

The licensee stated in section 2.1, On-Shift Staffing, of enclosure 1 to the application that the current on-shift staffing consists of the following:

One Shift Manager Two Unit Shift Supervisors (senior reactor operators (SROs))

Four Control Room Operators (reactor operators)

Five Non-Licensed Operators Two Shift Phone Talkers Two Radiation Protection (RP) Technicians One Work Control Shift Foreman/Shift Technical Advisor (STA)

Five Fire Department Personnel Security Personnel (per the Security Plan)

The licensees proposed post-shutdown on-shift staffing consists of the following:

One Shift Supervisor (renamed from Shift Manager; qualified as a Certified Fuel Handler (CFH))

One CFH Three Non-Certified Operators (NCOs)

Two RP Technicians Fire Department members (per the Fire Plan)

Security personnel (per the Security Plan)

To support the proposed ERO staffing changes following Diablo Canyons permanent cessation of operations and permanent removal of fuel from the reactor vessels, PG&E used the NEI 10-05 methodology to assess the post-shutdown on-shift staffing for the applicable postulated accidents. The licensee stated that the post-shutdown staffing analysis validated that in a permanently shutdown and defueled condition, with the postulated accidents that would be applicable to that condition, the proposed on-shift complement would be able to perform all required E-Plan functions in a timely manner and that there are no identified collateral duties that would prevent the timely performance of E-Plan functions. With the plant in a permanently shutdown and permanently defueled condition, the operations staff would only have to respond to events regarding an FHA in the fuel handling building, and loss of SFP cooling and/or water inventory or external events that could lead to a challenge to maintaining SFP cooling and/or water inventory. The control room continues to have indications, alarms, and controls for SFP parameters.

The licensee concluded that the proposed on-shift staffing continues to meet the applicable planning standards in 10 CFR 50.47(b) and requirements of Appendix E to 10 CFR Part 50, commensurate with the reduced spectrum of credible accidents with Diablo Canyon in the permanently shutdown and defueled condition, and that Diablo Canyon retains the ability to implement the SFP mitigation actions.

The NRC staff reviewed the licensees analysis of the proposed post-shutdown on-shift staffing.

As discussed in section 3.1 of this SE, the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor and the number and complexity of activities required for the safe storage of spent nuclear fuel is reduced, as compared to those at an operating nuclear power reactor facility. Based on this, the NRC staff determined the proposed level of onsite operations staffing will continue to provide for the direction and performance of actions to mitigate the remaining identified applicable events and the prompt

implementation of mitigating actions in response to events involving a loss of SFP cooling and/or water inventory or external events that could lead to a challenge to maintaining SFP cooling and/or water inventory.

NRC Staff Conclusion Based on the NRC staffs review of the information provided in licensees application, as supplemented, the NRC staff finds that the licensees proposed level of the on-shift staffing continues for this major functional area to meet the planning standards of 10 CFR 50.47(b)(1) for timely initial response capability, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50, to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition of the Diablo Canyon facility. As such, the NRC staff finds that the proposed changes to on-shift staffing are acceptable and do not impact the licensees ability to perform the required plant operations and assessment of operational aspects functions.

3.2.2 Major Functional Area: Emergency Direction and Control The licensee proposes no changes to the Diablo Canyon on-shift staffing or augmented ERO for this function, but proposes to rename the Shift Manager to the Shift Supervisor (qualified as a CFH). The Shift Supervisor assumes the responsibility as the Shift Emergency Director and implements the Diablo Canyon E-Plan and activates the ERO as appropriate. The Shift Emergency Director is relieved of command and control responsibilities to either the Technical Support Center (TSC) or Emergency Operations Facility (EOF) as soon as possible after activation of either facility. The NRC staff finds the proposed change to rename the Shift Manager to Shift Supervisor to be acceptable because the position functions remain the same as identified in the current Diablo Canyon E-Plan.

3.2.3 Major Functional Area: Notification and Communication For the Diablo Canyon post-shutdown on-shift staffing, the licensees current and proposed on-shift staffing is as follows:

The current on-shift ERO consists of two shift phone talkers.

The licensee proposes to eliminate the two shift phone talkers and replace them with either a CFH or NCO.

The licensee stated that the communication function is not full time for a plant in a permanently defueled and shutdown condition. Therefore, the resource commitment to support the communication function is not full time, so there is time to support collateral duties until staff augmentation can occur. The on-shift phone talkers (communicators) have advanced communications capabilities available such as the private network exchange. Communications with the NRC take place over dedicated telephone lines provided for and maintained by the NRC Emergency Notification System (ENS). The use of dedicated phone circuits and headsets enables these notifications to be performed by either an on-shift CFH or NCO who performs the State and local notifications.

Currently, the Shift Manager initially approves the content of the communication with the State and Federal agencies until relieved of this function by the TSC or EOF. The Diablo Canyon E-Plan requirement is to activate the EOF within approximately 90 minutes. The EOF assumes the communication responsibility concurrent with activation. Therefore, the current

communication protocol may remain within the control room for the first 90 minutes, regardless of the presence of any prior ERO augmentation.

The licensee stated that due to the permanent cessation of operations and removal of fuel from the reactor vessels, the CFH or NCO can perform this required E-Plan function in a timely manner. The licensee concluded that there are no collateral duties identified that would prevent the timely performance of the E-Plan function. The licensees post-shutdown staffing analysis validated that in a permanently defueled and shutdown condition, the CFH or NCO can perform this required E-Plan function in a timely manner and that there are no collateral duties identified that would prevent the timely performance of this E-Plan function.

The current augmented notification and communications function within the TSC consists of the following positions:

Agency/ENS Communicator with a 90-minute response Communications Advisor with a 90-minute response Operations Communicator with a 90-minute response The following position is staffed by the onsite ERO to support notification and communications in the Operational Support Center (OSC):

Team Coordinator with a 90-minute response The following positions are staffed by the offsite ERO to support notification and communications in the EOF:

Communications Coordinator with a 90-minute response Offsite Communicator with a 90-minute response Health Physics Network (HPN) Communicator with a 90-minute response Engineering Liaisons with a 90-minute response Advisor to the County with a 90-minute response Government Relations Coordinator with a 90-minute response General Office Technical Liaison with a 90-minute response The licensee proposes to change the augmented notification and communications positions for the post-shutdown condition as follows:

The following positions in the TSC will be eliminated:

Communications Advisor Operations Communicator The following position in the OSC will be eliminated:

Team Coordinator

The following positions in the EOF will be eliminated:

HPN Communicator One of the two Engineering Liaisons Offsite Communicator The following position will be removed from the Diablo Canyon E-Plan and be controlled in E-Plan implementing procedures (EPIPs) as full augmentation staff:

General Office Technical Liaison The following positions will be transferred from full augmentation to minimum staff positions:

Government Relations Coordinator Advisor to the County Remaining one Engineering Liaison The licensee stated that one of the main functions of the Communications Advisor is to oversee the TSC communications staff and maintain communications with the control room. Due to the reduced scope of information required to respond to an issue related to the management of an event in the SFPs, the dedicated staffing of the Communications Advisor position is not required. The Operations Advisor can obtain the required information directly from the Shift Supervisor. As a result, the licensee concluded that all the Communications Advisor essential responsibilities and tasks could be eliminated or reassigned, and as such, the Communications Advisor position can be eliminated without impacting Diablo Canyons ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor or cause undue impact to the performance of the Diablo Canyon E-Plan.

The licensee stated that the main function of the Operations Communicator is to keep the TSC informed of overall plant conditions and significant changes to system and equipment status.

Due to the reduced scope of information required to respond to an issue related to the management of an event in the SFPs, the licensee stated that dedicated staffing of the Operations Communicator position is not required and the Operations Advisor can obtain the required information directly from the Shift Supervisor.

The licensee stated that the main functions of the Team Coordinator are to relay requests from the control room and TSC for dispatching of the OSC teams, and apprise the TSC, OSC, and control room of the status of OSC repair team activities. The licensee concluded that due to the reduced scope of information required to respond to an issue related to the management of an event in the SFPs, dedicated staffing of the Team Coordinator is not required and the function will be maintained with communication from the OSC Director to the OSC teams.

The licensee stated that the HPN Communicator is tasked with providing updates to the NRC on radiological concerns. With the source term maintained in the SFPs, there are fewer release paths, reducing the scope of information related to a Diablo Canyon event. Due to the reduced scope of information, the licensee stated the HPN Communicator functions in the EOF will be reassigned to the Communications Coordinator.

The licensee stated that the main function of the EOF Engineering Liaisons is to provide the EOF with updates on plant status and provide technical support. Due to the reduced scope of

information required to respond to an issue related to the management of an event in the SFPs, the licensee determined that the dedicated staffing of two EOF Engineering Liaison personnel can be reduced to one. The licensee stated that this function will be maintained by the remaining EOF Engineering Liaison in the EOF as minimum staff. As such, the licensee concluded that one of the two EOF Engineering Liaison positions can be eliminated without impacting Diablo Canyons ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor or cause undue impact to the performance of the Diablo Canyon E-Plan.

The licensee stated that the Offsite Communicator and General Office Technical Liaison EOF positions provide the interface between Diablo Canyon personnel and governmental agencies and PG&E Corporate entities. The licensee concluded that due to the reduced scope of information required to respond to an issue related to the management of an event in the SFPs, dedicated staffing of each of these positions is not required. The licensee concluded that this position either has repeated tasks or tasks that can be reassigned to other positions that will be minimum staff (i.e., Communications Coordinator). As such, the licensee concluded that the Offsite Communicator can be removed from the Diablo Canyon E-Plan without impacting Diablo Canyons ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor.

The licensee stated that the General Office Technical Liaison full augmentation position is proposed to be removed from the Diablo Canyon E-Plan and will be managed and controlled by EPIPs. The licensee stated that this position performs support functions that are not required for staffing of the EOF.

The NRC staff reviewed the licensees analysis of the proposed post-shutdown on-shift staffing and determined that in a permanently shutdown and defueled condition, the designated on-shift staffing could perform this required Diablo Canyon E-Plan notification and communication functions in a timely manner. In addition, there were no collateral duties identified that would prevent the timely performance of these E-Plan functions and the licensee continues to maintain the same level of communications equipment capabilities to perform timely communications with the required offsite response organizations.

NRC Staff Conclusion Based on the NRC staffs review of the information provided in the licensees application, as supplemented, the NRC staff finds that the proposed level of the on-shift and augmented staffing for the notification and communication major functional area continues to meet the planning standards of 10 CFR 50.47(b)(1) and (2) for timely initial response and augmentation of response capabilities, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50, to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition of the Diablo Canyon facility. As such, the NRC staff finds the proposed changes to ERO staffing for this major functional area are acceptable and do not impact the licensees ability to perform the required notification and communication functions.

3.2.4 Major Functional Area: Radiological Assessment The purpose of conducting the offsite dose assessment is to review radiological conditions using data from available instrumentation, assess the impact of changing radiological conditions

on emergency classification, assist in accident assessments based upon those changing radiological conditions, and recommend appropriate offsite protective measures.

a. Major Task: Offsite Dose Assessment For the Diablo Canyon post-shutdown on-shift staffing, the licensees current and proposed on-shift staffing is as follows:

The current on-shift Diablo Canyon E-Plan provides for a Work Control Shift Foreman that is assigned as the on-shift Dose Assessor.

The licensee proposes to designate the on-shift dose assessment as a collateral duty to be assigned to available qualified on-shift personnel.

As discussed previously in section 3.2.1 of this SE, the Work Control Shift Foreman is proposed to be removed as part of this application. The licensee stated that RP Technicians and CFHs will be trained to perform dose assessment on shift. The licensee states that it will ensure a sufficient number of personnel are initially trained to support the on-shift positions prior to implementation of the proposed E-plan. The licensees post-shutdown staffing analysis evaluation of a loss of SFP level resulting in release requiring protective action recommendations employs a CFH to perform the dose assessment function. The licensee concluded that a CFH can perform the on-shift dose assessment for a permanently shutdown and defueled condition since many of the potential initiating conditions that would lead to an emergency declaration are no longer credible. The set of plant equipment involved in this condition is also greatly reduced, which also reduces the need for assessments and mitigation activities in the control room for an emergency.

The Augmented Offsite Dose Assessment function consists of the following positions:

One TSC Radiological Data Processor with a 90-minute response One EOF Radiological Manager with a 90-minute response One EOF Dose Assessor with a 90-minute response One EOF Dose Assessment Coordinator with a 90-minute response One EOF Unified Dose Assessment Coordinator (UDAC) Meteorologist with a 90-minute response.

The licensee proposes to change the augmented technicians for the post-shutdown permanently defueled condition as follows:

Eliminate TSC Radiological Data Processor, Eliminate EOF Dose Assessment Coordinator, and Remove EOF UDAC Meteorologist full augmentation position from the Diablo Canyon E-Plan and control in EPIPs.

The licensee stated that with the source term maintained in the SFPs, there are fewer release paths reducing the scope of information related to a Diablo Canyon event after the facility is permanently defueled and shutdown. The licensee concluded that due to the reduced scope of information, the dedicated staffing of the Radiological Data Processor and Dose Assessment Coordinator positions is not required. The Radiological Data Processor position is tasked with enabling RP devices and trending radiation levels at the plant. The licensee stated that a TSC

Radiological Advisor will assume any essential tasks conducted by the Radiological Data Processor position. The licensee also provided an assessment and disposition of specific responsibilities and tasks for the Dose Assessment Coordinator in a summary table Diablo Canyon Power Plant ERO Staffing Assessment Matrix, in attachment 4, Emergency Response Organization Task Analysis, to enclosure 1 of the licensees application. It concluded that this position can be reassigned to the Radiological Manager position that is minimum staff. As such, the licensee concluded that the Dose Assessment Coordinator can be removed from the Diablo Canyon E-Plan without impacting the licensees ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor. The UDAC Meteorologist is currently a full augmentation position not required to support facility activation.

The licensee stated that the UDAC Meteorologist position performs support functions and can be removed from the Diablo Canyon E-Plan and will be managed and controlled by EPIPs. The licensee concluded that the implementation of these proposed changes will not impact the ability of the augmented staff to provide timely and accurate dose assessment and will not cause undue impact to the performance of the Diablo Canyon E-Plan.

The NRC staff reviewed the licensees analysis of the post-shutdown staffing and determined that the proposed changes to offsite dose assessment are acceptable and do not impact the ability to perform the required offsite dose assessment functions.

b. Major Task: Offsite Surveys The licensee stated that there are no requirements for on-shift staffing for offsite surveys.

The augmented offsite survey task consists of the following positions:

Two Offsite Field Monitoring Teams (FMTs), each consisting of a Leader (RP Technician) and Driver with a 90-minute response One FMT Coordinator with a 90-minute response One FMT Communicator with a 90-minute response One Offsite Emergency Lab Analyst with a 90-minute response The licensee proposes to change the augmented staff for the offsite survey task for the post-shutdown permanently defueled condition as follows:

Transfer FMT Coordinator position from full augmentation to a minimum staff position, Eliminate FMT Communicator position, and Remove Offsite Emergency Lab Analyst position from the Diablo Canyon E-Plan and control in EPIPs.

The licensee stated that with the source term maintained in the SFPs, there are fewer release paths, reducing the scope of information related to a Diablo Canyon event after the facility is permanently defueled and shutdown. The licensee concluded that due to the reduced scope of information, the combination of dedicated staffing of the above positions is not required to perform the required offsite surveys functions. The licensee stated that the task of the FMT Communicator is to establish and maintain communications with the FMTs and to record and report field monitoring survey, sample, and exposure information. Those tasks will be assigned to the FMT Coordinator position that will be minimum staff. As such, the licensee concluded that the FMT Communicator can be removed from the Diablo Canyon E-Plan without impacting the

licensees ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor.

The Offsite Emergency Lab Analyst is currently a full augmentation position not required to support facility activation. The licensee stated that the Offsite Emergency Lab Analyst position performs support functions and can be removed from the Diablo Canyon E-Plan and will be managed and controlled by EPIPs. The licensee further stated that the position will still be assigned to ERO teams, be expected to maintain fitness-for-duty during assigned duty weeks, and be required to respond to the EOF at an Alert or higher emergency classification level. The licensee concluded that the implementation of these proposed changes will not impact the ability of the augmented staff to provide timely and accurate dose assessment and will not cause undue impact to the performance of the Diablo Canyon E-Plan.

The NRC staff reviewed the licensees analysis of the post-shutdown staffing and determined that the proposed changes to offsite surveys are acceptable and do not impact the ability to perform the required offsite surveys functions.

c. Major Tasks: Onsite (Out-of-Plant) Surveys The licensee stated that there are no requirements for on-shift staffing for onsite (out-of-plant) surveys.

The augmented onsite (out-of-plant) survey task consists of the following position:

One onsite FMT, consisting of a Leader (RP Technician) and Driver in the OSC, are full augmentation staff with a 60-minute response.

The licensee proposes to change the augmented staff for the onsite (out-of-plant) task for the post-shutdown permanently defueled condition as follows:

Eliminate onsite FMT.

The licensee stated that the scope of RP surveys is greatly reduced with the permanent cessation of operation of the reactors and the source term confined to the SFPs. The licensee concluded that one RP Technician will be adequate to perform both the onsite (out-of-plant) and in-plant surveys.

The NRC staff reviewed the licensees analysis of the post-shutdown staffing and determined that the proposed changes to onsite (out-of-plant) surveys are acceptable because they do not impact the licensees ability to perform the required onsite (out-of-plant) survey functions.

d. Major Tasks: In-Plant Surveys The licensee proposes no changes to the Diablo Canyon E-Plan on-shift staffing responsible for in-plant surveys. The licensee will continue to have two RP Technicians available to provide initial and continual information for accident assessment throughout the course of an event, including plant parameter displays systems, and area and process radiation monitoring systems.

The augmented staff tasked with in-plant surveys consists of the following positions:

Two RP Technicians with a 60-minute response Two RP Technicians with a 90-minute response The licensee proposes to change the augmented staff responsible for conducting in-plant surveys for the post-shutdown permanently defueled condition as follows:

Eliminate the two RP Technicians with a 90-minute response, Eliminate one RP Technician with a 60-minute response, and Maintain one RP Technician as minimum staff with a 60-minute response.

The licensee stated that the scope of the RP surveys will be greatly reduced with the permanent cessation of operation of the reactors and the source term confined to the SFPs. The licensee concluded that one RP Technician will be adequate to perform the surveys. However, if conditions warrant, additional personnel will be made available to be called in by the OSC Director.

The NRC staff reviewed the licensees analysis of the post-shutdown staffing and determined that the proposed changes to in-plant surveys are acceptable because they do not impact the ability to perform the required in-plant survey functions.

f. Major Task: Chemistry The licensee stated that there are no requirements for on-shift staffing for tasks involving chemistry.

The augmented staff responsible for tasks related to chemistry consists of the following position:

Chemistry Coordinator in the OSC with a 90-minute response The licensee proposes to change the augmented staff responsible for performing chemistry for the post-shutdown permanently defueled condition as follows:

Eliminate Chemistry Coordinator, and Add Radiological Advisor in the TSC as minimum staff with a 90-minute response.

The licensee stated that the need to perform complex chemistry sampling is greatly reduced with the permanent cessation of operation of the reactors and the source term confined to the SFPs. However, if conditions warrant, chemistry personnel are available to be called in by the OSC Director. The licensee also stated that the Radiological Advisor will be added as minimum staff in the TSC and will assume the tasks of the Chemistry Coordinator including directing radiological and chemical analysis of in-plant samples and maintaining proper chemistry records and logs. The licensee concluded that the Chemistry Coordinator position can be eliminated from the Diablo Canyon E-Plan without impacting Diablo Canyons ability to respond to the spectrum of credible accidents and operational events for permanently shutdown and defueled reactors.

The NRC staff reviewed the licensees analysis of the post-shutdown staffing and determined that the proposed changes to support the chemistry function are acceptable because they do

not impact Diablo Canyons ability to respond to the spectrum of credible accidents and operational events for permanently shutdown and defueled reactors.

NRC Staff Conclusion Based on the NRC staffs review of the information provided in the licensees application, as supplemented, the NRC staff finds that the proposed level of the augmented staffing for this major functional area continues to meet the planning standards of 10 CFR 50.47(b)(2) for augmentation of response capabilities, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition of the Diablo Canyon facility. As such, the NRC staff finds that the proposed changes to ERO staffing for this major functional area are acceptable and do not impact the licensees ability to perform the required radiological assessment functions.

3.2.5 Major Functional Area: Plant System Engineering, Repair, and Corrective Actions

a. Major Task: Plant System Engineering The licensee stated that the purpose of conducting plant system engineering during abnormal and emergency conditions is to monitor and evaluate changing core/thermal hydraulic conditions of the RCS that can support timely corrective action(s), classifications of emergencies, and subsequent protective action recommendations. For the Diablo Canyon post-shutdown tasks related to the on-shift technical support/accident analysis, the licensees current and proposed staffing is as follows:

The current on-shift Diablo Canyon E-Plan provides for a Work Control Shift Foreman who is required to have an STA qualification, and The licensee proposes to eliminate the Work Control Shift Foreman and the functional requirement for an STA from the on-shift staffing.

The licensee stated that the emergency planning function of the Work Control Shift Foreman (SRO/STA) is to perform assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations. The Work Control Shift Foreman (SRO/STA) also contributes to operations during normal plant conditions. By routine monitoring of equipment and plant operations, the Work Control Shift Foreman (SRO/STA) can focus on preventative actions to mitigate the consequences of an accident.

Additionally, the Work Control Shift Foreman (SRO/STA) performs the core/thermal hydraulics function of the E-Plan for the confirmation of adequacy of core cooling, maintenance of coolable core geometry, and to verify that actual plant response to the event is as expected until relieved by the TSC positions upon TSC activation. Because of the permanent cessation of operations and removal of fuel from the reactor vessels, the licensee proposes to eliminate the Work Control Shift Foreman (SRO/STA) position from the E-Plan, since this plant condition no longer makes the position necessary for technical and analytical assistance for plant operational concerns during abnormal and emergency situations, analysis of events and their effects, or the on-shift core/thermal hydraulics function of the Diablo Canyon E-Plan, as described previously.

The augmented staff responsible for technical support/accident analysis functions consist of the following positions in the TSC:

Engineering Advisor with a 90-minute response Radiological Advisor with a 90-minute response Reactor Engineer with a 90-minute response Mechanical Engineer with a 60-minute response Electrical Engineer with a 60-minute response Plant Process Computer (PPC) Operator with a 90-minute response.

The licensee proposes to change the augmented staff for the post-shutdown permanently defueled condition as follows:

Eliminate Reactor Engineer, Eliminate Mechanical Engineer, Eliminate Electrical Engineer, Eliminate PPC Operator, and Augment the Engineering Advisor with a 60-minute response in the TSC.

The licensee stated that the Engineering function will continue to be maintained by the TSC Engineering Advisor who will be qualified to provide engineering support in response to an FHA in the fuel handling building or an event resulting in damage to the SFP integrity or loss of SFP cooling or inventory. The licensee concluded that elimination of the TSC Reactor Engineer position will have no effect on emergency response in a permanently defueled condition because the position does not assess the condition of fuel in the SFPs during an emergency.

The dose assessment program utilized by the Radiological Manager includes fuel damage in the SFPs in its assessment. The TSC Reactor Engineer supports this dose assessment by providing needed information (age of fuel, location, etc.); however, the information is not specific to the TSC Reactor Engineer qualification and can be provided by the TSC Engineering Advisor.

As a result, the licensee concluded that the Reactor Engineer position within the TSC can be eliminated without increasing the risk to public health and safety because the major task of evaluating reactor hydraulics is not necessary in a permanently shutdown and defueled condition.

The licensee also proposes to eliminate the Mechanical and Electrical Engineer positions in the TSC. The TSC Engineers responsibilities include providing engineering support in response to an accident condition. The engineering function will continue to be maintained by the TSC Engineering Advisor. However, the TSC Engineering Advisor augmented position is proposed to be changed from 90-minute response to a 60-minute response. As such, the licensee concluded that the TSC Electrical and Mechanical Engineer positions can be eliminated without impacting Diablo Canyons ability to respond to the spectrum of credible accidents and operational events for permanently shutdown and defueled reactors. If additional engineering support is identified as being needed at any time during the response to the emergency condition, additional engineering support can be obtained through call-outs.

The licensee proposes to eliminate the PPC Operator position in the TSC. The PPC Operator position is tasked with preparing information used in dose assessments. The TSC Radiological Advisor will assume any essential tasks conducted by the PPC Operator position.

The NRC staff reviewed the licensees analysis of the post-shutdown permanently defueled engineering function for on-shift and augmented staffing and determined that the proposed elimination of the Work Control Shift Foreman (SRO/STA), the combining of the three augmented engineer staffing positions into the TSC Engineering Advisor, and the elimination of the PPC Operator position is acceptable because the changes do not impact the licensees ability to perform the required engineering functions and tasks during abnormal and emergency conditions for the Diablo Canyon post-shutdown permanently defueled condition.

b. Major Task: Repair and Corrective Actions The licensee stated that there are no requirements for on-shift staffing for tasks involving repair and corrective actions.

The augmented staff responsible for tasks related to repair and corrective actions consists of the following positions:

Maintenance Advisor with a 90-minute response in the TSC OSC Director with a 90-minute response in the OSC Mechanical Maintenance Coordinator with a 60-minute response in the OSC Electrical Maintenance Coordinator with a 60-minute response in the OSC Instrument and Control (I&C) Maintenance Coordinator with a 90-minute response in the OSC Operations Coordinator with a 90-minute response in the OSC Site RP Coordinator with a 60-minute response in the OSC The licensee proposes to change the augmented staff responsible for performing repair and corrective actions for the post shutdown, permanently defueled condition as follows:

Eliminate Maintenance Advisor, Eliminate Mechanical Maintenance Coordinator, Eliminate Electrical Maintenance Coordinator, Eliminate I&C Maintenance Coordinator, Eliminate Operations Coordinator, Eliminate Site RP Coordinator, Augment one Mechanical Maintenance Technician with a 60-minute response in the OSC, and Augment one Electrical Maintenance Technician with a 60-minute response in the OSC.

Revise the OSC Director to a minimum staff position with a 60-minute response.

The licensee proposes to maintain the OSC Director as a minimum staff 60-minute responder (i.e., within 60 minutes of the declaration of an Alert or higher emergency classification level). In addition, the licensee proposes to have one qualified Mechanical Maintenance Technician and one qualified Electrical Maintenance Technician as minimum staff 60-minute OSC responders.

The licensee states that because the set of plant equipment required in the permanently shutdown and defueled condition is also greatly reduced, the assessments and mitigation activities that the OSC must perform are also reduced. The licensee described that restoration of equipment supporting SFP cooling, and/or water inventory will be the primary focus of emergency mitigation actions for the TSC/OSC in a permanently shutdown and defueled condition. Because there are no longer any complex automatic control systems in service in the permanently shutdown and defueled condition, the licensee concluded that a dedicated I&C

maintenance technician is not needed. If conditions warrant, the OSC Director can call out I&C support as necessary.

The licensee stated that the primary events of concern in the immediate post-shutdown and defueled condition are an FHA in the fuel handling building and a loss of SFP cooling and/or water inventory. The licensee further stated that for events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of the SFP inventory makeup strategies, as required under License Condition 2.I, Mitigation Strategy License Condition, for Unit 1, and License Condition 2.I, Mitigation Strategy, for Unit 2, and 10 CFR 50.155(b)(2).

The licensee concluded that since OSC staff is not relied upon to implement SFP inventory makeup, the elimination of the Maintenance Advisor, Site RP Coordinator, Mechanical Maintenance Coordinator, Electrical Maintenance Coordinator, I&C Maintenance Coordinator, and Operations Coordinator positions will not impact the ability of the ERO to perform the required function based on the permanent shutdown and defueled condition of the facility.

The NRC staff reviewed the licensees analysis of the post-shutdown staffing and determined that the proposed changes to support the repair and corrective actions function are acceptable because they do not impact the licensees ability to perform the required repair and corrective actions functions during the Diablo Canyon post-shutdown permanently defueled condition.

NRC Staff Conclusion Based on the NRC staffs review of the information provided in the licensees application, as supplemented, the NRC staff finds that the proposed level of the augmented staffing for this major functional area continues to meet the planning standards of 10 CFR 50.47(b)(2) for augmentation of response capabilities, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition of the Diablo Canyon facility. As such, the NRC staff finds that the proposed changes to ERO staffing for this major functional area are acceptable and do not impact the licensees ability to perform the required plant system engineering, repair, and corrective action functions.

3.2.6 Major Functional Area: In-Plant Protective Actions For the Diablo Canyon post-shutdown on-shift staffing, the licensee proposes no changes to this function.

The current on-shift staffing consists of two RP Technicians.

The current Diablo Canyon E-Plan augmented staffing for the in-plant protective actions function consists of the following positions:

One RP Technician with a 60-minute response in the OSC One RP Technician with a 90-minute response in the OSC The licensee proposes to change the augmented staff responsible for in-plant protective actions for the post-shutdown permanently defueled condition as follows:

Eliminate RP Technician with a 90-minute response in the OSC.

The licensee stated that once the ERO is activated, the two on-shift RP Technicians will join the one augmented RP personnel providing a total of three RP personnel to support Diablo Canyon E-Plan activities. The licensee explained that in the past, radiological access control was a labor-intensive task. Dedicated RP Technicians would be required to check dose margins, training qualifications, and to ensure that workers had read and understood their radiation work permit. However, the licensee states that worker access control is now automated at the site because RP work processes have been computerized. Radiation work permit access control and electronic dosimeter computer systems work together to provide a fully integrated system, allowing workers to sign-in on their radiation work permit and to self-issue electronic dosimeters.

The licensee explained that access control is maintained because the worker must obtain an electronic dosimeter and enter a radiation work permit number into the access control computer system, prior to being allowed access into the radiologically controlled area (RCA). Additionally, the licensee stated personnel are required and trained to self-monitor for radioactive contamination whenever they exit the RCA. The licensee relies on the availability of computer systems, electronic dosimeters, and enhanced processes to relieve RP Technicians of access control, personnel monitoring, and dosimetry tasks; thereby, freeing the RP Technician to support emergency response activities.

The licensee stated that for a permanently shutdown and defueled condition, entry is expected to be limited to those areas where SFP cooling maintenance is required. The areas potentially affected by an accident involving the SFP are limited and there is a significant decrease in the areas potentially requiring RP coverage in a permanently shutdown and defueled condition.

Multiple repair teams can be covered by the on-shift RP personnel. If RP coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is still ensured since emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate set points) and because of the installed area radiation monitors that alarm locally and remotely at preset dose rates located throughout the plant. As a result, the licensee concluded that the three RP Technicians will be capable of providing adequate protective actions to support plant activities in the permanently shutdown and defueled conditions.

The NRC staff reviewed the licensees analysis of the in-plant protective actions for post-shutdown permanently defueled on-shift and augmented staffing and determined that the proposed elimination of the on-shift and augmented staffing positions, as described above, are acceptable because the three RP Technicians within the OSC will be capable of providing adequate protective actions to support plant activities involving radiological expertise in the permanently shutdown and defueled conditions.

NRC Staff Conclusion Based on the NRC staffs review of the information provided in the licensees application, as supplemented, the NRC staff finds that the proposed level of the on-shift and augmented staffing for this major functional area (in-plant protective actions) continues to meet the planning standards of 10 CFR 50.47(b)(1) and (2) for timely initial response and augmentation of response capabilities, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition of the Diablo Canyon facility. As such, the NRC staff finds that the proposed changes to ERO

staffing for this major functional area are acceptable and do not impact the licensees ability to perform the required in-plant protective action functions.

3.2.7 Major Functional Area: Site Access Control and Accountability

a. Major Task: Security and Accountability The current Diablo Canyon E-Plan states the on-shift security staff will perform the security and accountability function, reporting to the Shift Emergency Director (Shift Supervisor (CFH)), until relieved by the Security Advisor in the TSC.

The current Diablo Canyon augmented staffing for the site access control and accountability function consists of the following positions:

Security Advisor with a 90-minute response in the TSC Security Liaison with a 90-minute response in the EOF The licensee proposes to change the augmented staff responsible for site access control and accountability for the post-shutdown permanently defueled condition as follows:

Redesignate the Security Advisor as minimum staff with a 90-minute response in the TSC, and Eliminate Security Liaison in the EOF.

The licensee stated that the TSC Security Advisor will be designated as a minimum staffing to support the Site Emergency Coordinator in establishing accountability, site evacuation and responding to security or hostile action-based events. The EOF Security Liaison provides backup to the TSC Security Advisor, performs support functions, and is not required to support activation of the EOF. Therefore, the licensee proposes to eliminate the EOF Security Liaison full augmentation position.

The NRC staff reviewed the licensees analysis of the post-shutdown permanently defueled tasks pertaining to security and accountability for augmented staffing and determined that the proposed elimination of the augmented staffing position as described above is acceptable because the Shift Supervisor can perform the necessary tasks associated with this function until being relieved by the Security Advisor. The NRC staff finds that the implementation of these changes does not impact the overall effectiveness to perform the necessary emergency planning functions and will not cause undue impact to the performance of the Diablo Canyon E-Plan.

NRC Staff Conclusion Based on the NRC staffs review of the information provided in licensees application, as supplemented, the NRC staff finds that the proposed level of the augmented staffing for this major functional area continues to meet the planning standard of 10 CFR 50.47(b)(2) for augmentation of response capabilities, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition of the Diablo Canyon facility. As such, the NRC staff finds that the proposed changes to ERO staffing for this major functional area are acceptable and do not

impact the licensees ability to perform the required site access control and accountability functions.

4.0 ERO PROPOSED CHANGES - EMERGENCY RESPONSE FACILITY EVALUATION The licensee stated that all ERO staff is trained and required to respond directly to its emergency response facility, if available, and that the proposed revisions to the Diablo Canyon E-Plan will not change these requirements. The licensee also stated that the Diablo Canyon E-Plan procedures identify ERO positions assigned to each facility and the minimum staffing required before each facility can be declared operational and is available to perform its designed functions.

4.1 Augmented ERO The current Diablo Canyon E-Plan states that the TSC and an onsite OSC are activated upon declaration of an Alert or higher emergency classification level and until they become operational, required functions of these facilities are performed in the control room. The TSC, OSC, and EOF have an activation time of 60 minutes of declaration of an Alert or higher emergency classification level. Staffing of the Joint Information Center occurs within 90 minutes of declaration of an Alert or higher emergency classification level. The OSC is activated whenever the TSC is activated but need not remain activated at the Alert level if its use is judged unnecessary by the Emergency Director. At the Site Area Emergency and General Emergency classification levels, the OSC or an alternate OSC are activated at all times.

The licensee stated that the ERO activation/response time requirements are unchanged and that the elimination of credible accidents involving an operating power reactor provides additional time to plan and execute assessment and mitigation actions. The licensee maintains that the proposed changes do not impact the capability to assess and monitor actual or potential off-site consequences of a radiological emergency and the ability to promptly implement SFP mitigation actions.

The set of plant equipment required in the permanently defueled condition is reduced, which also reduces the assessments and mitigation activities that the ERO staff (TSC/OSC/EOF) must perform. Restoration of equipment supporting SFP cooling, and inventory will be the primary focus of emergency mitigation actions for the ERO staff in a permanently shutdown and defueled condition.

4.1.1 Technical Support Center The current Diablo Canyon E-Plan states that the TSC is the onsite location utilized to support the control room for assessment of plant status and potential offsite impact, and for implementation of emergency actions. The TSC provides technical data and information to the EOF. The licensee stated that given the elimination of credible accidents involving operating reactors, the proposed ERO minimum staff can continue to satisfactorily perform their existing emergency preparedness responsibilities as well as any transferred responsibilities. In addition, the licensee stated that the proposed changes to the TSC minimum staff do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency and that appropriate assessment and mitigation are well within the capabilities of the proposed TSC staff.

The following table illustrates the NRC staffs summary of the licensees proposed changes to the TSC minimum staffing positions:

Current Minimum TSC Staff Positions Proposed Minimum TSC Staff Positions Note: response times are 90 minutes unless otherwise noted Site Emergency Coordinator Site Emergency Coordinator Agency/ENS Communicator ENS Communicator Reactor Engineer (Position Eliminated)

Communications Advisor (Position Eliminated)

Radiological Data Processor (Position Eliminated)

N/A Radiological Advisor (Added as minimum staff)

N/A Operations Advisor with a 60-minute response (Added as minimum staff)

N/A Engineering Advisor with a 60-minute response (Added as minimum staff)

Security Coordinator Security Advisor (Added as minimum staff)

The NRC staffs discussion and evaluation of the Engineering Advisor position and the elimination of the Reactor Engineer is provided in section 3.2.5 of this SE. The licensee stated that the Communications Advisor position can be eliminated in the TSC because the performance of State/local notifications and protective action recommendations are no longer supported in the TSC. This function is directly transferred from on-shift to the EOF. The performance of NRC notification is assigned to the ENS Communicator. The licensee further stated that the Radiological Data Processor can be eliminated due to the reduced scope and consequences of accidents associated with defueled reactors, this task is adequately performed by the EOF Dose Assessor.

NRC Staff Conclusion Based on the NRC staffs review of the information provided in the licensees application, as supplemented, the NRC staff finds that the proposed level of augmented staffing continues to meet the planning standard of 10 CFR 50.47(b)(2) for augmentation of response capabilities, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition of the Diablo Canyon facility. As such, the NRC staff finds that the proposed changes to ERO staffing for this facility are acceptable and do not impact the licensees ability to perform the required facility functions.

4.1.2 Operations Support Center The current Diablo Canyon E-Plan states that the OSC is the onsite location to where station support personnel report during an emergency and from which they will be dispatched for assignments or duties in support of emergency operations. The OSC will be activated whenever the TSC is activated but need not remain activated at the Alert level if its use is judged

unnecessary by the Station Emergency Director. The OSC is equipped with communication links to the control room, the TSC and the EOF.

Restoration of equipment supporting SFP cooling, and inventory will be the primary focus of emergency mitigation actions for the TSC/OSC in the permanently shutdown and defueled condition. However, the applicant states that OSC staff is not relied upon to implement SFP inventory makeup. In the permanently shutdown and defueled condition, the primary functions of the OSC will be the dispatching of and accounting for, repair and corrective action teams. The OSC Director is responsible for ensuring adequate staffing of the OSC supporting the emergency, working with the TSC staff to set priorities for the OSC, and directing the activities of the OSC to support the emergency response. The OSC is equipped with communication links to the control room, the TSC and the EOF.

The following table illustrates the NRC staffs summary of the licensees proposed changes to the OSC minimum staffing positions:

Current Minimum OSC Staff Positions Proposed Minimum OSC Staff Positions Note: response times are 60 minutes unless otherwise noted OSC Director OSC Director RP Personnel #1 RP Personnel #1 RP Personnel #2 RP Personnel #2 RP Personnel #3 (Position Eliminated)

RP Personnel #4 with a 90-minute response (Position Eliminated)

RP Personnel #5 with a 90-minute response (Position Eliminated)

RP Personnel #6 with a 90-minute response (Position Eliminated)

Mechanical Maintenance Coordinator Mechanical Maintenance Technician Electrical Maintenance Coordinator Electrical Maintenance Technician l&C Maintenance Coordinator with a (Position Eliminated) 90-minute response Operations Coordinator with a 90-minute (Position Eliminated) response Site RP Coordinator (Position Eliminated)

Onsite Field Team #1 Personnel (on-site (Position Eliminated) surveys)

Onsite Field Team #1 Driver (on-site surveys) (Position Eliminated)

The NRC staffs evaluation of the post-shutdown Diablo Canyon E-Plan minimum staffing positions and staffing position eliminations is provided in sections 3.2.4.c, 3.2.4.d, 3.2.5.b, and 3.2.6 of this SE.

The NRC staff reviewed the licensees analysis of the OSC augmented staffing and determined that the proposed elimination of the augmented staffing is acceptable because it does not impact the licensees ability to perform the required E-Plan functions and tasks during the Diablo Canyon post-shutdown permanently defueled condition.

NRC Staff Conclusion Based on the NRC staffs review of the information provided in the licensees application, as supplemented, the NRC staff finds that the proposed level of augmented staffing continues to meet the planning standard of 10 CFR 50.47(b)(2) for augmentation of response capabilities,

and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition of the Diablo Canyon facility. As such, the NRC staff finds that the proposed changes to ERO staffing for this facility are acceptable and do not impact the licensees ability to perform the required facility functions.

4.1.3 Emergency Operations Facility The licensee stated that the proposed changes to the EOF minimum staff do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency. The licensee concluded that appropriate assessment and mitigation are well within the capabilities of the proposed EOF minimum staff.

The following table illustrates the NRC staffs summary of the licensees proposed changes to the EOF minimum staffing positions:

Current Minimum EOF Staff Positions Proposed Minimum EOF Staff Positions Note: response times are 90 minutes unless otherwise noted Emergency Director Emergency Director Communications Coordinator Communications Coordinator Offsite Communicator (Position Eliminated)

Radiological Manager Radiological Manager Dose Assessor Dose Assessor N/A Offsite Field Team #1 Personnel with a 60-minute response (Added as minimum staff)

N/A Offsite Field Team #1 Driver with a 60-minute response (Added as minimum staff)

N/A Offsite Field Team #2 Personnel (Added as minimum staff)

N/A Offsite Field Team #2 Driver (Added as minimum staff)

N/A EOF Director (Added as minimum staff)

N/A Advisor to the County (Added as minimum staff)

N/A FMT Coordinator (Added as minimum staff)

N/A Engineering Liaison (Added as minimum staff)

N/A Government Relations Coordinator (Added as minimum staff)

The licensee stated that the EOF currently has the following ERO non-minimum augmented staff:

EOF Director HPN Communicator

Engineering Liaisons Advisor to the County Emergency Operations Center Government Relations Coordinator General Office Technical Liaison Dose Assessment Coordinator UDAC Meteorologist FMT Coordinator Two Offsite FMTs, each consisting of one Leader (RP Technician) and one Driver Onsite FMT, consisting of one Leader (RP Technician) and one Driver FMT Communicator Offsite Emergency Lab Analyst Security Liaison EOF Security The licensee proposes to remove all the EOF non-minimum augmented staff except for one EOF Director, one Advisor to the County, one FMT Coordinator, one Engineering Liaison, four offsite FMT Leaders and Drivers, and one Government Relations Coordinator following permanent shutdown. These positions are proposed to be designated as minimum staff positions.

The following full augmentation positions are proposed to be removed from the Diablo Canyon E-Plan, and managed and controlled by EPIPs: Onsite FMT Leaders and Drivers, Offsite Emergency Lab Analyst, UDAC Meteorologist, and General Office Technical Liaison positions.

The Offsite Emergency Lab Analyst, UDAC Meteorologist, and General Office Technical Liaison positions are proposed to still be assigned to ERO teams, be expected to maintain fitness-for-duty during assigned duty weeks, and be required to respond to the EOF at an Alert or higher emergency classification level.

The licensee proposes to change the non-minimum augmented staff for the offsite survey task for the post-shutdown permanently defueled condition as follows:

FMT Coordinator position will be transferred from full augmentation to a minimum staff position; Eliminate FMT Communicator position, and Offsite Emergency Lab Analyst position will be removed from the Diablo Canyon E-Plan and controlled in EPIPs.

The licensee stated that with the source term maintained in the SFPs, there are fewer release paths, reducing the scope of information related to a Diablo Canyon event. The licensee concluded that due to the reduced scope of information, the combination of dedicated staffing of the above listed positions is not required. The licensee stated that the task of the FMT Communicator is to establish and maintain communications with the FMTs and to record and report field monitoring survey, sample, and exposure information. Those tasks are proposed to be assigned to the FMT Coordinator position that would be minimum staff. As such, the licensee concluded that the FMT Communicator can be removed from the Diablo Canyon E-Plan without impacting Diablo Canyons ability to respond to the spectrum of credible accidents and operational events for a permanently shutdown and defueled reactor.

The licensee stated the Offsite Emergency Lab Analyst is currently a full augmentation position not required to support facility activation. The licensee concluded that Offsite Emergency Lab Analyst position performs support functions and can be removed from the Diablo Canyon E-Plan and is proposed to be managed and controlled by EPIPs. The position would still be assigned to ERO teams, be expected to maintain fitness-for-duty during assigned duty weeks and be required to respond to the EOF at an Alert or higher emergency classification level. The licensee concluded that the implementation of these proposed changes will not impact the ability of the augmented staff to provide timely and accurate dose assessment and will not cause undue impact to the performance of the Diablo Canyon E-Plan.

The NRC staff reviewed the licensees analysis of the post-shutdown permanently EOF augmented staffing and determined that the proposed elimination of the augmented staffing is acceptable because the changes do not impact the ability of the licensee to perform the required E-Plan functions and tasks during the Diablo Canyon post-shutdown permanently defueled condition.

NRC Staff Conclusion Based on the NRC staffs review of the information provided in the licensees application, as supplemented, the NRC staff finds that the proposed level of the augmented staffing continues to meet the planning standard of 10 CFR 50.47(b)(2) for augmentation of response capabilities, and the requirements of Section IV.A of Appendix E to 10 CFR Part 50 to describe the organization for coping with radiological emergencies, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition of the Diablo Canyon facility. As such, the NRC staff finds that the proposed changes to ERO staffing for this facility are acceptable and do not impact the licensees ability to perform the required facility functions.

4.2 Assessment of Proposed Staffing Changes on Offsite Response Organizational Interfaces The licensee stated that the proposed changes to the Diablo Canyon E-Plan were evaluated for impacts on the ability of State and local response organizations to effectively implement their FEMA-approved Radiological Emergency Preparedness (REP) Plans. The licensee concluded that there were no interface or coordination impediments identified because of the proposed changes to the Diablo Canyon E-Plan. , Offsite Response Organization Concurrence Letters, to enclosure 1 of the licensees application dated October 8, 2021, provides letters of concurrence from:

California Governors Office of Emergency Services, and County of San Luis Obispo.

By letter dated May 4, 2022 (Reference 9), the NRC staff requested FEMAs review of the proposed licensee staffing changes against the current FEMA-approved State and local REP plans to verify that no potential adverse impacts exist that would preclude the effective implementation of State and local REP plans. In a letter dated June 15, 2022, (Reference 10),

FEMA stated:

FEMA Region 9 identified no concerns or deficiencies with the proposed licensee ERO staffing changes and recognizes no adverse impacts with the proposed

changes to DCPP EP [Emergency Plan] that would preclude the effective implementation of State and local radiological emergency response plans.

Correspondence with the State and Local Office of Emergency Services stated that their review of the PG&E license amendment request found no issues or concerns that affect their level of offsite response. Therefore, FEMA has no objections to the proposed changes and finds them adequate for reasonable assurance of off-site safety once DCPP operations cease and the reactors are de-fueled.

4.3 Summary Based on the above documented NRC staff evaluation of the licensees proposed post-shutdown E-Plan changes and revisions, the staff finds that the proposed Diablo Canyon E-Plan changes and revisions continue to meet the applicable planning standards in 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50, and continue to provide reasonable assurance that adequate protective measures can and will continue to be taken in the event of a radiological emergency, commensurate with the reduced spectrum of credible accidents in the permanently shutdown and defueled condition for the Diablo Canyon facility.

5.0 STATE CONSULTATION

In accordance with the Commissions regulations, the California State official was notified of the proposed issuance of the amendments on June 22, 2022. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change the site E-Plan. The amendments relate to changes in recordkeeping, reporting, or administrative procedures or requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, published in the Federal Register on December 28, 2021 (86 FR 73819), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

8.0 REFERENCES

1. Welsch, James M., Pacific Gas and Electric Company, letter to U.S. Nuclear Regulatory Commission, Certification of Permanent Cessation of Power Operations, dated November 27, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18331A553).

2. Zawalick, Maureen R., Pacific Gas and Electric Company, letter to U.S. Nuclear Regulatory Commission, License Amendment Request 21-04 Proposed Changes to Diablo Canyon Power Plant Emergency Plan for Post-Shutdown and Permanently Defueled Condition, dated October 8, 2021 (ML21284A003).

3. Zawalick, Maureen R., Pacific Gas and Electric Company, letter to U.S. Nuclear Regulatory Commission, Response to NRC Requests for Additional Information on License Amendment Request 21-04, Proposed Changes to Diablo Canyon Power Plant Emergency Plan for Post-Shutdown and Permanently Defueled Condition, dated March 23, 2022 (ML22083A116).

4. Pacific Gas and Electric Company, Diablo Canyon Power Plant Units 1 & 2 Updated Final Safety Analysis Report, Chapter 15, Accident Analysis, Revision 26, dated September 2021 (ML21305A094).

5. U.S. Nuclear Regulatory Commission, Emergency Planning and Preparedness for Nuclear Power Reactors, Regulatory Guide 1.101, Revision 2, dated October 1981 (ML090440294).

6. U.S. Nuclear Regulatory Commission and Federal Emergency Management Agency, NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980 (ML040420012).

7. U.S. Nuclear Regulatory Commission, Interim Staff Guidance-Emergency Planning for Nuclear Power Plants, NSIR/DPR-ISG-01, dated November 20, 2011 (ML113010523).

8. Nuclear Energy Institute, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, NEI 10-05, Revision 0, dated June 2011 (ML111751698).

9. Quichocho, Jessie F., U.S. Nuclear Regulatory Commission, letter to Warnock, Thomas K., Federal Emergency Management Agency, Federal Emergency Management Agency Review Requested of Revision to the Diablo Canyon Site Emergency Plan to Address the Permanently Shut Down and Defueled Condition, dated May 4, 2022 (ML22124A139).

10. Warnock, Thomas K., Federal Emergency Management Agency, letter to Quichocho, Jessie F., U.S. Nuclear Regulatory Commission, Federal Emergency Management Agency Review Requested of Revision to the Diablo Canyon Site Emergency Plan to Address the Permanently Shutdown and Defueled Condition, dated June 15, 2022 (ML22167A132).

Principal Contributor: Edward Robinson, NSIR Date: November 16, 2022

ML22187A025 *by email OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NSIR/DPR/RLB/BC* OGC*

NAME SLee PBlechman JQuichocho (MNorris for) JEzell DATE 7/6/2022 7/28/2022 6/22/2022 9/14/2022 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/D* NRR/D* NRR/DORL/LPL4/PM*

NAME JDixon-Herrity BPham (GSuber for) AVeil (MKing for) SLee DATE 9/28/2022 9/28/2022 11/16/2022 11/16/2022