ML25342A011
| ML25342A011 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/09/2025 |
| From: | Samson Lee NRC/NRR/DORL/LPL4 |
| To: | Gerfen P Pacific Gas & Electric Co |
| Lee S, NRR/DORL/LPL4 | |
| References | |
| EPID L-2025-LLL-0017 | |
| Download: ML25342A011 (0) | |
Text
December 9, 2025 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 - PROPOSED REVISION TO THE QUALITY ASSURANCE PROGRAM (EPID L-2025-LLL-0017)
Dear Ms. Gerfen:
By letter dated November 5, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25309A160), Pacific Gas and Electric Company (the licensee) submitted a request for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon), to revise the Diablo Canyon Quality Assurance Program Description (QAPD) pursuant to Title 10 of Code of Federal Regulations (10 CFR) 50.54(a)(4). Specifically, the licensee proposes to revise the QAPD to reflect the education and work experience requirements for the Radiation Protection Manager position to be consistent with Regulatory Guide (RG) 1.8, Revision 4, Qualification and Training of Personnel for Nuclear Power Plants, June 2019 (ML19101A395).
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the licensees request and identified Dominion Energy (Dominion) as a precedent. Dominion submitted a request on June 20, 2023 (ML23172A206), to use RG 1.8, Revision 4, and was approved by the NRC staff on October 2, 2023 (ML23230A050). This Dominion submittal is a wholesale change to use RG 1.8, Revision 4, for the Dominion QAPD, while the Diablo Canyon submittal is more specific to the use of RG 1.8, Revision 4, for the position of Radiation Protection Manager. However, the Dominion submittal and associated NRC staffs safety evaluation still apply.
The regulations in 10 CFR 50.54(a)(3) state, in part, that:
Each licensee described in paragraph (a)(1) of this section may make a change to a previously accepted quality assurance program description included or referenced in the Safety Analysis Report without prior NRC approval, provided the change does not reduce the commitments in the program description as accepted by the NRC. the following changes are not considered to be reductions in commitment:
(ii) The use of a quality assurance alternative or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility.
P. Gerfen Therefore, the NRC staff determined that the licensee does not need to submit the Diablo Canyon changes to the QAPD under 10 CFR 50.54(a)(4) but rather (a)(3), which does not require an NRC review.
If you have any questions, please contact me at 301-415-3168 or via email at Samson.Lee@nrc.gov.
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 cc: Listserv
ML25342A011 NRR-106 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DRO/IQVB/BC NAME SLee PBlechman KKavanagh DATE 12/8/2025 12/8/2025 12/4/2025 OFFICE NRR/DORL/LPL/BC NRR/DORL/LPL4/PM NAME TNakanishi SLee DATE 12/9/2025 12/9/2025