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| {{#Wiki_filter: 1Burkhardt, Janet From:Dave Lochbaum <DLochbaum@ucsusa.org> | | {{#Wiki_filter: 1 Burkhardt, Janet From: Dave Lochbaum <DLochbaum@ucsusa.org> |
| Sent:Tuesday, August 02, 2016 9:08 AM To:Watford, Margaret Cc:Singal, Balwant | | Sent: Tuesday, August 02, 2016 9:08 AM To: Watford, Margaret Cc: Singal, Balwant |
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| UCS | | UCS |
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| The NRC and Nuclear Power Plant Safety in 2 012TOLERATING THE INTOLERABLE THE NRC AND NUCLEAR POWER PLANT SAFETY IN 2012: THEY'VE LOST THAT SAFETY FOCUS l I The NRC and Nuclear Power Plant Safety in 2012: Tolerating | | The NRC and Nuclear Power Plant Safety in 2 0 1 2TOLERATING THE INTOLERABLE T HE NRC AND NUCLEAR P OWER PLANT SAFETY IN 2012: T HEY'VE LOST THAT SAFETY F OCUS l I The NRC and Nuclear Power Plant Safety in 2012: Tolerating |
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| the Intolerable DAVID LOCHBAUM | | the Intolerable DAVID LOCHBAUM |
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| March 2013 | | March 2013 |
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| II l UNION OF CONCERNED SCIENTISTS | | II l U NION OF C ONCERNED SCIENTISTS © 2013 Union of Concerned Scientists All rights reserved |
| © 2013 Union of Concerned Scientists All rights reserved
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| David Lochbaum is the director of the Nuclear Safety Project of the UCS Global Security Program. | | David Lochbaum is the director of the Nuclear Safety Project of the UCS Global Security Program. |
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| The Union of Concerned Scientists (UCS) is the leading science-based nonprofit working for a healthy environment and a safer world. UCS combines independent scientific research and citizen action to develop innovative, practical solutions and to secure responsible changes in government policy, corporate practices, and consumer choices. | | The Union of Concerned Scientists (UCS) is the leading science-based nonprofit working for a healthy environment and a safer world. UCS combines independent scientific research and citizen action to develop innovative, practical solutions and to secure responsible changes in government policy, corporate practices, and consumer choices. |
| The Global Security Program works to reduce some of the biggest security threats facing the world today, including the risks posed by nuclear weapons, nuclear terrorism, space weapons, and nuclear power. We work with scientists around the globe to increase international understanding of these issues and to foster and strengthen efforts to increase international security. | | The Global Security Program works to reduce some of the biggest security threats facing the world today, including the risks posed by nuclear weapons, nuclear terrorism, space weapons, and nuclear power. We work with scientists around the globe to increase international understanding of these issues and to foster and strengthen efforts to increase international security. |
| More information about UCS and the Nuclear Safety Project is available at the UCS website ( | | More information about UCS and the Nuclear Safety Project is available at the UCS website (www.ucsusa.org) |
| www.ucsusa.org) | |
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| The full text of this report is available on the UCS website (www.ucsusa.org/publications) or may be obtained from: | | The full text of this report is available on the UCS website (www.ucsusa.org/publications) or may be obtained from: |
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| 2 Brattle Square Cambridge, MA 02138-3780 Or email pubs@ucsusa.org or call 617-547-5552. Printed on recycled paper | | 2 Brattle Square Cambridge, MA 02138-3780 Or email pubs@ucsusa.org or call 617-547-5552. Printed on recycled paper |
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| 46 l UNION OF CONCERNED SCIENTISTS | | 46 l U NION OF C ONCERNED SCIENTISTS |
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| CHAPTER 5. NEGATIVE OUTCOMES | | CHAPTER 5. NEGATIVE OUTCOMES |
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| The NRC identified nine traits-a trait being "a pattern of thinking, feeling, and behaving"-associated with a positive nuclear safety culture: | | The NRC identified nine traits-a trait being "a pattern of thinking, feeling, and behaving"-associated with a positive nuclear safety culture: |
| Leadership Safety Values and Actions-Leaders demonstrate a commitment to safety in their decisions and behaviors. Problem Identification and Resolution-Issues potentially impacting safety are promptly identified, fully evaluated, and promptly addressed and corrected commensurate with their significance. | | Leadership Safety Values and Actions-Leaders demonstrate a commitment to safety in their decisions and behaviors. Problem Identification and Resolution-Issues potentially impacting safety are promptly identified, fully evaluated, and promptly addressed and corrected commensurate with their significance. |
| THE NRC AND NUCLEAR POWER SAFETY IN 2012: TOLERATING THE INTOLERABLE l 53 NRC documents about the hazard at Oconee and other nuclear plants were also inappropriately withheld from the public. And Senator Boxer certainly did not receive honest answers to her question during that Senate hearing on March 15, 2012, with the triple meltdown risk at Oconee known by the NRC but not yet resolved. The NRC's creditability is jeopardized when it improperly withholds information 11 from the public and Congressional oversight committees. If explicit details about the Jocassee Dam's failure modes and associated vulnerabilities at Oconee warrant being withheld for national security considerations (i.e., not providing those who wish us harm the blueprints for conducting successful attacks), by all means do so. But a detail-lite version of the hazard could be made public to balance the public's right to know with the need to guard some information.
| | T HE NRC AND NUCLEAR P OWER SAFETY IN 2012: TOLERATING THE INTOLERABLE l 53 NRC documents about the hazard at Oconee and other nuclear plants were also inappropriately withheld from the public. And Senator Boxer certainly did not receive honest answers to her question during that Senate hearing on March 15, 2012, with the triple meltdown risk at Oconee known by the NRC but not yet resolved. The NRC's creditability is jeopardized when it improperly withholds information 11 from the public and Congressional oversight committees. If explicit details about the Jocassee Dam's failure modes and associated vulnerabilities at Oconee warrant being withheld for national security considerations (i.e., not providing those who wish us harm the blueprints for conducting successful attacks), by all means do so. But a detail-lite version of the hazard could be made public to balance the public's right to know with the need to guard some information. |
| The NRC demonstrated achieving this balance in one area after 9/11. The NRC did not withhold all security information. Instead, it informed the public that it was taking steps to improve controls over access to nuclear plants and better protect against insiders and outsiders seeking to sabotage the plants. It quite properly withheld explicit information such as the height of security fences, locations of security cameras, and number of security force personnel at individual plants. But it publicly discussed the security threat and the general steps being taken to protect against it. And as described in Chapter 4, the NRC conducted an international conference on security that was open to the public, clearly demonstrating that it can discuss sensitive topics publicly while maintaining the proper balance of confidentiality. | | The NRC demonstrated achieving this balance in one area after 9/11. The NRC did not withhold all security information. Instead, it informed the public that it was taking steps to improve controls over access to nuclear plants and better protect against insiders and outsiders seeking to sabotage the plants. It quite properly withheld explicit information such as the height of security fences, locations of security cameras, and number of security force personnel at individual plants. But it publicly discussed the security threat and the general steps being taken to protect against it. And as described in Chapter 4, the NRC conducted an international conference on security that was open to the public, clearly demonstrating that it can discuss sensitive topics publicly while maintaining the proper balance of confidentiality. |
| Americans deserve comparable notification about flooding risks facing the nuclear plants. | | Americans deserve comparable notification about flooding risks facing the nuclear plants. |
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| permission to operate reactors at higher power levels and requests to reduce the frequency and scope of safety tests) by plant owners identifies additional information it needs to complete its evaluations, the NRC sends a request for additional information (RAI). Each RAI contains one or more questions that the NRC staff needs answered. A search of the NRC's record-keeping system (called ADAMS for Agencywide Documents Access and Management System) for documents containing the phrase "request for additional information" authored by the NRC and sent to nuclear plant owners returned over 1,000 records just in 2012 alone. The huge volume of RAIs during 2012-a number typical of prior years- clearly shows that the NRC staff has a questioning attitude. They literally asked thousands of questions of plant owners last year. | | permission to operate reactors at higher power levels and requests to reduce the frequency and scope of safety tests) by plant owners identifies additional information it needs to complete its evaluations, the NRC sends a request for additional information (RAI). Each RAI contains one or more questions that the NRC staff needs answered. A search of the NRC's record-keeping system (called ADAMS for Agencywide Documents Access and Management System) for documents containing the phrase "request for additional information" authored by the NRC and sent to nuclear plant owners returned over 1,000 records just in 2012 alone. The huge volume of RAIs during 2012-a number typical of prior years- clearly shows that the NRC staff has a questioning attitude. They literally asked thousands of questions of plant owners last year. |
| 11 The NRC classified the Jocassee Dam materials as Official Use Only, a classification with no legal basis and employed only to keep documents from the public. | | 11 The NRC classified the Jocassee Dam materials as Official Use Only, a classification with no legal basis and employed only to keep documents from the public. |
| 54 l UNION OF CONCERNED SCIENTISTS But they are apparently not asking one key question-did the owner violate §50.9 by failing in the first place to submit information that was complete and accurate in all material respects? The large number of RAIs submitted by the NRC staff constitutes prima facie evidence that violations may have occurred. But the NRC's RAI process does not include even a screening to evaluate formally whether a §50.9 violation is the reason for (or contributed to) the incomplete and/or inaccurate submittal prompting the need for the RAI. Not every RAI represents absolute evidence of a §50.9 violation. Yet it is foolhardy to assume that no RAI could ever be the result of a §50.9 violation. But that seems to be the basic assumption behind the NRC's RAI process. I know from personal experience that assumption is flawed. I worked as a consultant in the licensing departments at the Grand Gulf Nuclear Station (in Port Gibson, MS) and Hope Creek Generating Station (Hancocks Bridge, NJ). At Grand Gulf, the process for preparing documents being submitted to the NRC included speculating about any questions the NRC's reviewers might raise. This exercise was conducted so as to revise the draft to answer those potential questions. The objective was to submit material to the NRC that yielded no, or very few, questions from the agency. The process at Hope Creek was fundamentally different. There, the process was not to volunteer any information in material being submitted to the NRC. "Make them ask," was the phrase I heard over and over from licensing supervisors in explaining why they had lined through statements and paragraphs in draft documents. Consequently, an RAI to Grand Gulf was less likely to be a §50.9 violation and more likely to a question that honestly was not anticipated. Conversely, an RAI to Hope Creek might very well address material information that the owner had anticipated would be required but forced the agency to request. | | 54 l U NION OF C ONCERNED SCIENTISTS But they are apparently not asking one key question-did the owner violate §50.9 by failing in the first place to submit information that was complete and accurate in all material respects? The large number of RAIs submitted by the NRC staff constitutes prima facie evidence that violations may have occurred. But the NRC's RAI process does not include even a screening to evaluate formally whether a §50.9 violation is the reason for (or contributed to) the incomplete and/or inaccurate submittal prompting the need for the RAI. Not every RAI represents absolute evidence of a §50.9 violation. Yet it is foolhardy to assume that no RAI could ever be the result of a §50.9 violation. But that seems to be the basic assumption behind the NRC's RAI process. I know from personal experience that assumption is flawed. I worked as a consultant in the licensing departments at the Grand Gulf Nuclear Station (in Port Gibson, MS) and Hope Creek Generating Station (Hancocks Bridge, NJ). At Grand Gulf, the process for preparing documents being submitted to the NRC included speculating about any questions the NRC's reviewers might raise. This exercise was conducted so as to revise the draft to answer those potential questions. The objective was to submit material to the NRC that yielded no, or very few, questions from the agency. The process at Hope Creek was fundamentally different. There, the process was not to volunteer any information in material being submitted to the NRC. "Make them ask," was the phrase I heard over and over from licensing supervisors in explaining why they had lined through statements and paragraphs in draft documents. Consequently, an RAI to Grand Gulf was less likely to be a §50.9 violation and more likely to a question that honestly was not anticipated. Conversely, an RAI to Hope Creek might very well address material information that the owner had anticipated would be required but forced the agency to request. |
| 12 The NRC must take §50.9 seriously. When it issues RAIs to plant owners, the NRC must formally determine whether the reason for the RAIs might be §50.9 violations. That over 1,000 sets of RAIs were sent to plant owners during 2012 strongly suggests that some §50.9 violations were overlooked. The NRC sanction plant owners that deliberately seek to avoid compliance. Such behavior is part and parcel of a regulator's job. | | 12 The NRC must take §50.9 seriously. When it issues RAIs to plant owners, the NRC must formally determine whether the reason for the RAIs might be §50.9 violations. That over 1,000 sets of RAIs were sent to plant owners during 2012 strongly suggests that some §50.9 violations were overlooked. The NRC sanction plant owners that deliberately seek to avoid compliance. Such behavior is part and parcel of a regulator's job. |
| Observations on Ineffe ctive NRC Oversight It is laudable that the NRC wants plant owners to establish and maintain positive safety cultures at their nuclear plants. It is laughable that the NRC's own safety culture is so wanting. The U.S. Congress played a key role in compelling the NRC to improve safety cultures at nuclear power plants. The 2002 discovery of severe reactor vessel head degradation at Davis-Besse was attributed to its owner placing production ahead of safety. The NRC appeared before an oversight subcommittee of the Senate's Environment and Public Works Committee 12 I hasten to point out that I worked at Grand Gulf and Hope Creek years ago. Policies and practices could easily have changed at these plants since then. However, my more recent communications with colleagues working in licensing departments at U.S. reactors suggests that the "make them ask" approach is not yet extinct. | | Observations on Ineffe ctive NRC Oversight It is laudable that the NRC wants plant owners to establish and maintain positive safety cultures at their nuclear plants. It is laughable that the NRC's own safety culture is so wanting. The U.S. Congress played a key role in compelling the NRC to improve safety cultures at nuclear power plants. The 2002 discovery of severe reactor vessel head degradation at Davis-Besse was attributed to its owner placing production ahead of safety. The NRC appeared before an oversight subcommittee of the Senate's Environment and Public Works Committee 12 I hasten to point out that I worked at Grand Gulf and Hope Creek years ago. Policies and practices could easily have changed at these plants since then. However, my more recent communications with colleagues working in licensing departments at U.S. reactors suggests that the "make them ask" approach is not yet extinct. |
| THE NRC AND NUCLEAR POWER SAFETY IN 2012: TOLERATING THE INTOLERABLE l 55 outlining the many steps it was taking in response to the Davis-Besse debacle. It did not propose doing anything directly about the stated root cause-namely, the owner having lost the proper safety focus. Senator George Voinovich, chair of the subcommittee and representing Ohio where Davis-Besse is located, gave the NRC an option: either address safety culture issues itself or the Senate would do so by legislation. It was an option having only one choice and the NRC made the right choice. The NRC revised its reactor oversight process to include safety culture elements. It is imperative that the U.S. Congress compel the NRC to take steps to correct its safety culture problems and show marked improvement during the next work force survey in 2015. The common thread among the remaining negative outcomes involves inadequate enforcement of federal regulations. In the Waste Confidence Decision example, the court vacated the NRC's 2010 Waste Confidence Decision after determining that the NRC failed to comply with provisions of the National Environmental Protection Act. The court's action provides assurance that the agency will comply. In the future, the NRC should comply on its own. The NRC should emulate the court by making nuclear plant owners comply with federal regulations, too. Safety requirements prohibit reactors from operating for more than six hours with reactor coolant pressure boundary leaks; yet they do so again and again with NRC's tolerance. Federal regulations require plant owners to provide information to the NRC that is complete and accurate in all material respects. The NRC asked more than 1,000 sets of questions to plant owners just last year, strongly suggesting that the NRC is not getting complete and accurate information. Yet the NRC does not formally evaluate whether owners violated this federal regulation-and by not doing so, tolerates inadequate performance by plant owners. The NRC's job is more than just establishing safety standards at appropriate levels. It also involves consistently enforcing them. From a public health perspective, the only thing worsethan having safety standards set improperly is having them set properly but not followed. Setting safety standards properly means one knows what it takes to protect public health.
| | T HE NRC AND NUCLEAR P OWER SAFETY IN 2012: TOLERATING THE INTOLERABLE l 55 outlining the many steps it was taking in response to the Davis-Besse debacle. It did not propose doing anything directly about the stated root cause-namely, the owner having lost the proper safety focus. Senator George Voinovich, chair of the subcommittee and representing Ohio where Davis-Besse is located, gave the NRC an option: either address safety culture issues itself or the Senate would do so by legislation. It was an option having only one choice and the NRC made the right choice. The NRC revised its reactor oversight process to include safety culture elements. It is imperative that the U.S. Congress compel the NRC to take steps to correct its safety culture problems and show marked improvement during the next work force survey in 2015. The common thread among the remaining negative outcomes involves inadequate enforcement of federal regulations. In the Waste Confidence Decision example, the court vacated the NRC's 2010 Waste Confidence Decision after determining that the NRC failed to comply with provisions of the National Environmental Protection Act. The court's action provides assurance that the agency will comply. In the future, the NRC should comply on its own. The NRC should emulate the court by making nuclear plant owners comply with federal regulations, too. Safety requirements prohibit reactors from operating for more than six hours with reactor coolant pressure boundary leaks; yet they do so again and again with NRC's tolerance. Federal regulations require plant owners to provide information to the NRC that is complete and accurate in all material respects. The NRC asked more than 1,000 sets of questions to plant owners just last year, strongly suggesting that the NRC is not getting complete and accurate information. Yet the NRC does not formally evaluate whether owners violated this federal regulation-and by not doing so, tolerates inadequate performance by plant owners. The NRC's job is more than just establishing safety standards at appropriate levels. It also involves consistently enforcing them. From a public health perspective, the only thing worsethan having safety standards set improperly is having them set properly but not followed. Setting safety standards properly means one knows what it takes to protect public health. |
| Failing to enforce them means one really doesn't care if the public is protected or not. That is unacceptable.}} | | Failing to enforce them means one really doesn't care if the public is protected or not. That is unacceptable.}} |
Letter Sequence Supplement |
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Results
Other: ML16202A001, ML16259A001, ML16285A220, ML16285A239, ML16326A113, ML17108A552, ML17108A564, NRC-2016-0237, OEDO-16-00436 - FRN, Final Director'S Decision - David Lochbaum, Union of Concerned Scientists, Letter 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9 (CAC Nos. MF8123 and MF8124)
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MONTHYEARML16196A2942016-07-14014 July 2016
OEDO-16-00436 - David Lochbaum, Union of Concerned Scientist, Letter 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9
Project stage: Request
ML16202A0012016-07-19019 July 2016
OEDO-16-00436: Initial Contact with D. Lochbaum on 2.206 Petition Apparent 50.9 Violation at Diablo Canyon Nuclear Power Plant
Project stage: Other
ML16215A1092016-08-0202 August 2016
OEDO-16-00436 - Supplemental Information from Mr. Lochbaum 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9 at Diablo Canyon Nuclear Power Plant
Project stage: Supplement
ML16232A5702016-08-0202 August 2016
OEDO-16-00436: Transcript from Petition Review Board Meeting on Apparent 50.9 Violation at Diablo Canyon
Project stage: Meeting
ML16259A0012016-09-13013 September 2016
OEDO-16-00436 - Status of Petition, Email to D. Lochbaum on 2.206 Petition Apparent 50.9 Violation at Diablo Canyon Nuclear Power Plant
Project stage: Other
DCL-16-101, Response to NRC Request for Additional Information Regarding License Amendment Request 15-03, Application of Alternative Source Term2016-10-0606 October 2016
Response to NRC Request for Additional Information Regarding License Amendment Request 15-03, Application of Alternative Source Term
Project stage: Response to RAI
ML16285A2202016-11-0909 November 2016
OEDO-16-00436 - Letter, Acknowledgement to David Lochbaum, Union of Concerned Scientists, Petitioner, 2.206 Petition Related to Apparent 50.9 Violation at Diablo Canyon Nuclear Power Plant
Project stage: Other
ML16285A2392016-11-0909 November 2016
OEDO-16-00436 - FRN, Acknowledgement to David Lochbaum, Union of Concerned Scientists, Petitioner, 2.206 Petition Related to Apparent 50.9 Violation at Diablo Canyon Nuclear Power Plant
Project stage: Other
ML16326A1132016-11-21021 November 2016
OEDO-16-00436 - Email to Licensee Voluntary Response to Staff on Issues Identified in Union of Concerned Scientists Petition Re Apparent Violation of 10 CFR 50.9 at Diablo Canyon, Units 1 and 2
Project stage: Other
ML17031A2662017-03-15015 March 2017
OEDO-16-00436 - Proposed Directors Decision - David Lochbaum Union of Concerned Scientists, Letter 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9
Project stage: Acceptance Review
ML17031A2592017-03-15015 March 2017
OEDO-16-00436 - Licensee'S Letter - David Lochbaum, Union of Concerned Scientist Letter 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9
Project stage: Acceptance Review
ML17031A2642017-03-15015 March 2017
OEDO-16-00436 - Petitioner Letter - David Lochbaum Union of Concerned Scientists, Letter 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9
Project stage: Acceptance Review
ML17102A5242017-03-27027 March 2017
OEDO-16-00436 - David Lochbaum, Union of Concerned Scientists, Letter with Comments 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9
Project stage: Request
NRC-2016-0237, OEDO-16-00436 - FRN, Final Director'S Decision - David Lochbaum, Union of Concerned Scientists, Letter 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9 (CAC Nos. MF8123 and MF8124)2017-05-12012 May 2017
OEDO-16-00436 - FRN, Final Director'S Decision - David Lochbaum, Union of Concerned Scientists, Letter 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9 (CAC Nos. MF8123 and MF8124)
Project stage: Other
ML17108A5642017-05-12012 May 2017
OEDO-16-00436 - FRN, Final Director'S Decision - David Lochbaum, Union of Concerned Scientists, Letter 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9
Project stage: Other
ML17108A5902017-05-12012 May 2017
OEDO-16-00436 - Final Director's Decision - David Lochbaum, Union of Concerned Scientists, Letter Re: 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9 (CAC Nos. MF8123 and MF8124)
Project stage: Request
ML17108A5522017-05-12012 May 2017
OEDO-16-00436 - Letter with Final Director'S Decision - David Lochbaum, Union of Concerned Scientists, Letter 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9
Project stage: Other
2016-07-19
[Table View] |
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Category:E-Mail
MONTHYEARML23334A0912023-11-30030 November 2023
NRR E-mail Capture - Diablo Canyon 1 and 2 - Audit Questions for License Amendment Associated with TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b
ML23335A1012023-11-0606 November 2023
OEDO-23-00350-NRR - Screen-in Email - 10 CFR 2.206 Petition from Mother'S for Peace and Change.Org Regarding Diablo Canyon
ML23306A0422023-11-0202 November 2023
NRR E-mail Capture - Acceptance Review Diablo Canyon Request to Adopt 10 CFR 50.69, risk-informed Categorization and Treatment of SSCs
ML23230A0702023-08-18018 August 2023
NRR E-mail Capture - Acceptance Review - Diablo Canyon Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times RITSTF Initiative 4b
ML23165A2702023-06-14014 June 2023
NRR E-mail Capture - Acceptance Review - Diablo Canyon Revision to the Unit 1 Reactor Vessel Material Surveillance Program Withdrawal Schedule
ML23157A2392023-06-0505 June 2023
Limited Appearance Statement from Nina Babiarz in the Matter of the Diablo Canyon ISFSI License Renewal Application
ML23096A1792023-04-0606 April 2023
NRR E-mail Capture - Request for Additional Information Diablo Canyon Exemption Request Regarding Senior Reactor Operator License Application
ML23094A1032023-04-0404 April 2023
NRR E-mail Capture - Acceptance Review - Diablo Canyon Exemption Request Regarding Senior Reactor Operator License Application
ML23076A0932023-03-16016 March 2023
16-2023 Email - Estimate of Spent Nuclear Fuel in Tons
ML23067A0202023-03-0808 March 2023
NRR E-mail Capture - Diablo Canyon Nuclear Power Plant Evacuation Time Estimate Analysis Review
ML23046A1132023-02-13013 February 2023
Transmittal Email, Paul Bessette to Gibson, 2/13/23, Filing of Formal Opposition to PG&E Exemption Request
ML23046A1042023-02-13013 February 2023
Transmittal Email, Diane Curran to Gibson, 2/13/23, Filing of Formal Opposition to PG&E Exemption Request
ML23052A2042023-01-10010 January 2023
E-mail from Paul Bessette Dated 01/10/2023 Regarding Diablo Canyon
ML22326A1632022-11-21021 November 2022
Licensee Comment Email on Post-Shutdown Emergency Plan Amendment
ML22266A0012022-09-22022 September 2022
(External Sender) E-Mail Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Total Amount of Spent Nuclear Fuel Stored in Tons
ML22241A1142022-08-29029 August 2022
NRR E-mail Capture - Acceptance Review - Diablo Canyon Application to Revise Technical Specifications to Adopt TSTF-569, Revision of Response Time Testing Definitions
ML22194A8872022-07-11011 July 2022
September 2022 Emergency Preparedness Exercise Inspection - Request for Information Email
ML22187A2652022-07-0606 July 2022
NRR E-mail Capture - Request for Additional Information: Diablo Canyon Exemption Request for Part 73 force-on-force Training Due to COVID-19
ML22105A0702022-04-15015 April 2022
NRR E-mail Capture - Acceptance Review - Diablo Canyon Request to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections
ML22090A0832022-03-31031 March 2022
NRR E-mail Capture - Acceptance Review - Diablo Canyon Request for Approval of a Certified Fuel Handler Training and Retraining Program
ML22089A1672022-03-29029 March 2022
Email - Acknowledgement of NRC Receipt of Diablo Canyon ISFSI Renewal Application
ML22087A0412022-03-25025 March 2022
NRR E-mail Capture - Acceptance Review - Diablo Canyon Request for Approval of Alternative Security Measures for Early Warning System
ML22061A2192022-03-0202 March 2022
NRR E-mail Capture - Request for Additional Information - Diablo Canyon Proposed Changes to Emergency Plan for post-shutdown and Permanently Defueled Condition
ML21323A0652021-11-19019 November 2021
NRR E-mail Capture - Acceptance Review - Diablo Canyon Revision of Emergency Plan for post-shutdown Condition
ML21264A6722021-09-21021 September 2021
NRR E-mail Capture - Revised Schedule: Diablo Canyon Request to Revise Technical Specification to Reflect the Permanent Cessation of Reactor Operation
ML21215A3432021-08-0303 August 2021
NRR E-mail Capture - Request for Additional Information - Diablo Canyon Request to Revise Technical Specification 3.8.1, AC Sources - Operating to Support Diesel Fuel Oil Transfer System Component Planned Maintenance
ML21189A0462021-07-0707 July 2021
NRR E-mail Capture - Draft Request for Additional Information - Diablo Canyon Emergency Amendment Request to Revise Technical Specification 3.7.8, Auxiliary Saltwater (Asw) System
ML21188A0382021-07-0707 July 2021
(External_Sender) DCPP Draft Emergency LAR - Asw
DCL-21-046, Email for Emergency LAR for TS 3.7.8, Auxiliary Saltwater (Asw) System2021-07-0707 July 2021
Email for Emergency LAR for TS 3.7.8, Auxiliary Saltwater (Asw) System
ML21189A0662021-07-0707 July 2021
NRR E-mail Capture - Additional Draft Request for Additional Information - Diablo Canyon Emergency Amendment Request to Revise Technical Specification 3.7.8, Auxiliary Saltwater (Asw) System
ML21189A0442021-07-0707 July 2021
NRR E-mail Capture - Request for Additional Information - Diablo Canyon Emergency Amendment Request to Revise Technical Specification 3.7.8, Auxiliary Saltwater (Asw) System
ML21124A0612021-05-0404 May 2021
NRR E-mail Capture - Acceptance Review - Diablo Canyon Request to Revise Technical Specification 3.8.1, AC Sources - Operating to Support Diesel Fuel Oil Transfer System Component Planned Maintenance
ML21104A3642021-04-14014 April 2021
NRR E-mail Capture - Request for Additional Information - Diablo Canyon Proposed Technical Specifications and Revised License Conditions for the Permanently Defueled Condition
ML21062A0642021-03-0202 March 2021
NRR E-mail Capture - Request for Additional Information for Diablo Canyon Generic Letter 2004-02 Submittal (L-2017-LRC-0000)
ML21054A3112021-02-23023 February 2021
NRR E-mail Capture - Acceptance Review: Diablo Canyon Request for One-Time Exemption from Select 10 CFR 55.59 Requirements
ML21012A4432021-01-12012 January 2021
NRR E-mail Capture - Acceptance Review - Diablo Canyon Request to Revise Technical Specification to Reflect the Permanent Cessation of Reactor Operation
ML20328A3002020-11-23023 November 2020
Email from Cgnp to the NRC - Comment Diablo Canyon Nuclear Power Plant, Units 1 and 2 - Dcdep Public Meeting - November 24, 2020
ML20329A0692020-11-23023 November 2020
NRR E-mail Capture - Request for Additional Information: Diablo Canyon COVID-19 Exemption Request to Extend force-on-force Exercise
ML20323A4532020-11-18018 November 2020
NRR E-mail Capture - Request for Additional Information: Diablo Canyon COVID-19 Exemption Request to Extend Firearms Requalification
ML20261H4232020-09-17017 September 2020
NRR E-mail Capture - Request for Additional Information: Diablo Canyon Unit 2 Fall 2019 Steam Generator Tube Inspection Report
ML20239A9492020-08-26026 August 2020
(External Sender) E-Mail Comment by D. Lochbaum Regarding Diablo Canyon Unit 1 AFW System Piping
ML20239A7282020-08-24024 August 2020
(External-Sender) E-mail Comments on No Significant Hazards Determination for Diablo Canyon LAR
ML20239A7752020-08-24024 August 2020
(External-Sender) E-mail Comments on No Significant Hazards Determination for Diablo Canyon LAR
ML20240A2302020-08-23023 August 2020
(External-Sender) E-mail Public Comment by D. Lochbaum Regarding Diablo Canyon Safety Issue
ML20234A2422020-08-20020 August 2020
NRR E-mail Capture - Diablo Canyon Additional Request for Additional Information: Exigent License Amendment Request for Application to Provide a New Technical Specification 3.7.5, Auxiliary Feedwater System, Condition G EPID: L-2020-LLA-017
ML20233A8592020-08-19019 August 2020
Mothers for Peace Public Comment on Exigent LAR to Modify TS 3.7.5, Auxiliary Feedwater System
ML20233A3222020-08-18018 August 2020
Comment (4) e-mail from D. Lochbaum Regarding Diablo Canyon Exigent LAR
ML20231A2372020-08-17017 August 2020
NRR E-mail Capture - Diablo Canyon Additional Request for Additional Information: Exigent License Amendment Request for Application to Provide a New Technical Specification 3.7.5, Auxiliary Feedwater System, Condition G EPID: L-2020-LLA-017
ML20232C6482020-08-17017 August 2020
Lochbaum Public Comment 1 on Exigent LAR to Modify TS 3.7.5, Auxiliary Feedwater System
ML20230A0732020-08-14014 August 2020
NRR E-mail Capture - Diablo Canyon Request for Additional Information: Exigent License Amendment Request for Application to Provide a New Technical Specification 3.7.5, Auxiliary Feedwater System, Condition G
2023-08-18
[Table view]
Category:Report
MONTHYEARML23307A1622023-11-0303 November 2023
OIG-24-A-01 Inspector Generals Assessment of the Most Serious Management and Performance Challenges Facing the U.S. Nuclear Regulatory Commission in Fiscal Year 2024
ML23130A0052023-06-27027 June 2023
Report to Congress Regarding Diablo Canyon
ML22108A2892022-05-0303 May 2022
Enclosure - Response to Representative Carbajal Regarding OIG Report on Diablo
ML22108A1662022-05-0303 May 2022
Enclosure 1 - Assessment Event Inquiry Into the Nuclear Regulatory Commission Oversight of the Auxiliary Feedwater System at Diablo Canyon Nuclear
L-22-003, Independent Spent Fuel Storage Installation - License Renewal Application for the Diablo Canyon Independent Spent Fuel Storage Installation2022-03-0909 March 2022
Independent Spent Fuel Storage Installation - License Renewal Application for the Diablo Canyon Independent Spent Fuel Storage Installation
DCL-21-071, Federally Listed Species Affects Determination Memorandum2021-10-14014 October 2021
Federally Listed Species Affects Determination Memorandum
ML21188A0362021-07-0707 July 2021
Draft PG&E Letter DCL-21-046 - Diablo Canyon Unit 1: Emergency License Amendment Request 21-05, Revision to Technical Specification 3.7.8, Auxiliary Saltwater (Asw) System
ML21076A6142021-03-17017 March 2021
NRC Examination Report 05000275/2021301 and 05000323/2021301
ML20353A3972020-12-18018 December 2020
NRC Response to Public Comment Regarding Spent Fuel Canister Drop from 2019 Regcon
DCL-20-102, Nuclear Material Transaction Report for New Fuel2020-12-0909 December 2020
Nuclear Material Transaction Report for New Fuel
ML20335A0132020-11-30030 November 2020
NRC Response to Public Watchdogs November 2
ML20328A3012020-11-23023 November 2020
NERC Reliability Standards for the Bulk Electric System of North America Updated July 20, 2020 (Cgnp Public Comments on Diablo Canyon Nuclear Power Plant, Units 1 and 2 - Pre-submittal Meeting of 11/24/2020)
ML20239A9562020-08-26026 August 2020
Evaluation of the Potential Piping Degradation Safety Concern on the Auxiliary Feedwater System at Diablo Canyon Unit 1
DCL-19-054, Submittal of Acceptance Report Following the Installation of Structural Weld Overlay, REP-RHR-SWOL for Unit 12019-07-0101 July 2019
Submittal of Acceptance Report Following the Installation of Structural Weld Overlay, REP-RHR-SWOL for Unit 1
ML18254A0402019-01-22022 January 2019
Staff Review of Seismic Probabilistic Risk Assessment Associated with Reevaluated Seismic Hazard Implementation of the Near Term Task Force Recommendation 2.1: Seismic
DCL-18-050, Evaluation Documents in Support of Structural Weld Overlay, REP-RHR-SWOL, Unit 22018-09-11011 September 2018
Evaluation Documents in Support of Structural Weld Overlay, REP-RHR-SWOL, Unit 2
IR 05000275/20180052018-08-31031 August 2018
Updated Inspection Plan for Diablo Canyon Power Plant, Units 1 and 2 (Report 05000275/2018005 and 05000323/2018005)
DCL-18-058, Flaw Evaluation of Unit 2, ASME Code Class 2 Charging Pump Discharge Lines: Welds WIC-45A and RB-46-72018-08-0808 August 2018
Flaw Evaluation of Unit 2, ASME Code Class 2 Charging Pump Discharge Lines: Welds WIC-45A and RB-46-7
DCL-18-027, Seismic Probabilistic Risk Assessment for the Diablo Canyon Power Plant, Units 1 & 2 - Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1: Seismic of the Near-Term Task Force Review of Insight2018-04-24024 April 2018
Seismic Probabilistic Risk Assessment for the Diablo Canyon Power Plant, Units 1 & 2 - Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1: Seismic of the Near-Term Task Force Review of Insights
ML17024A2072017-12-18018 December 2017
Staff Assessment of Response to 10 CFR 50.54(F) Information Request Flood-Causing Mechanism Reevaluation
ML17341A0652017-11-30030 November 2017
Technical Evaluation Report Diablo Canyon Nuclear Power Plant Tsunami Hazard Reevaluation Review
ML17334A1052017-11-29029 November 2017
Reactor Coolant System Pressure and Temperature Limits Report
ML17229B6172017-08-17017 August 2017
Flaw Evaluation of Residual Heat Removal Suction Weld Joint
DCL-17-064, Plant Focused Evaluation Report for External Flooding2017-07-19019 July 2017
Plant Focused Evaluation Report for External Flooding
DCL-17-049, Flaw Evaluation of Unit 2 Residual Heat Removal Suction Weld Joint2017-05-18018 May 2017
Flaw Evaluation of Unit 2 Residual Heat Removal Suction Weld Joint
DCL-16-117, Reactor Coolant System Pressure and Temperature Limits Report, Revision 152016-11-10010 November 2016
Reactor Coolant System Pressure and Temperature Limits Report, Revision 15
DCL-16-124, Implementation of Alternative Source Term Summary of Dose Analyses and Results Revision 52016-11-0909 November 2016
Implementation of Alternative Source Term Summary of Dose Analyses and Results Revision 5
ML16314C6912016-11-0909 November 2016
Enclosure, Statement of the Problem Concerning PWR Primary Coolant System Pipe Rupture
ML16314B0822016-11-0909 November 2016
Criteria for Protection Against Dynamic Effects Associated with a Postulated Rupture of Piping
ML16287A7552016-10-0606 October 2016
Technical Assessment Implementation of Alternative Source Terms Summary of Dose Analyses and Results Revision 4
ML16215A1092016-08-0202 August 2016
OEDO-16-00436 - Supplemental Information from Mr. Lochbaum 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9 at Diablo Canyon Nuclear Power Plant
ML16169A2652016-05-18018 May 2016
Technical Report, Implementation of Alternative Source Terms Summary of Dose Analysis and Results, Revision 3
ML16146A0952016-04-21021 April 2016
54006-CALC-01, Diablo Canyon Power Plant: Evaluation of Risk Significance of Permanent ILRT Extension.
ML16238A1042016-03-31031 March 2016
15-0681-RTM-001, Revision 0, System Level Requirements Traceability Matrix (Rtm).
DCL-16-081, 15-0681-RTM-001, Revision 0, System Level Requirements Traceability Matrix (Rtm).2016-03-31031 March 2016
15-0681-RTM-001, Revision 0, System Level Requirements Traceability Matrix (Rtm).
ML16019A2242016-02-0101 February 2016
Record of Review, Dispositions to Diablo Canyon Nuclear Plant, Units 1 and 2, Internal Events, Internal Flooding, Seismic, and Fire PRA Facts and Observations
ML16061A4642016-01-15015 January 2016
Revision 3 to 993754-11-861-NP, V&V Design Phase Summary Report Ppsi
ML16061A4682016-01-15015 January 2016
9Revision 1 to 93754-12-862-NP, V&V Implementation Phase Summary Report PPSII-IV
DCL-16-020, Diablo Canyon, Units 1 and 2 - Revision 3 to 993754-11-861-NP, V&V Design Phase Summary Report Ppsi2016-01-15015 January 2016
Diablo Canyon, Units 1 and 2 - Revision 3 to 993754-11-861-NP, V&V Design Phase Summary Report Ppsi
DCL-16-020, Diablo Canyon, Units 1 and 2 - 9Revision 1 to 93754-12-862-NP, V&V Implementation Phase Summary Report PPSII-IV2016-01-15015 January 2016
Diablo Canyon, Units 1 and 2 - 9Revision 1 to 93754-12-862-NP, V&V Implementation Phase Summary Report PPSII-IV
ML16061A4592016-01-14014 January 2016
Revision 3 to 993754-11-854-1-NP, Protection Set I, Factory Acceptance Test Report
DCL-16-020, Diablo Canyon, Units 1 and 2 - Revision 3 to 993754-11-854-1-NP, Protection Set I, Factory Acceptance Test Report2016-01-14014 January 2016
Diablo Canyon, Units 1 and 2 - Revision 3 to 993754-11-854-1-NP, Protection Set I, Factory Acceptance Test Report
ML16048A2152015-12-15015 December 2015
Fleet Vehicle-Asset List
ML16048A2072015-12-15015 December 2015
Once Through Cooling
ML16004A3542015-12-11011 December 2015
Response to NRC Request for Additional Information Regarding License Amendment Request 15-03, Application of Alternative Source Terms Summary of Dose Analysis & Results, Revision 1
DCL-15-134, ISFSI - Submits 2014 Annual Commitment Change Summary Report2015-11-0505 November 2015
ISFSI - Submits 2014 Annual Commitment Change Summary Report
DCL-15-102, 10 CFR 71.95 Report Regarding Energy Solutions' Model 8-120B Shipping Cask2015-08-24024 August 2015
10 CFR 71.95 Report Regarding Energy Solutions' Model 8-120B Shipping Cask
ML15231A5712015-07-28028 July 2015
Holtec Information Bulletin (HIB) No. 67 (Rev. 0), VCT Restraint Strap Weld Failure
ML15160A2612015-07-0101 July 2015
Letter to NMFS Notice of Intent to Reinitiate Scoping Process for Diablo Canyon Power Plant Units 1 and 2 License Renewal Application
ML16048A2042015-06-30030 June 2015
Notice of Intent, General Permit to Discharge Storm Water
2023-06-27
[Table view]
Category:Miscellaneous
MONTHYEARML23130A0052023-06-27027 June 2023
Report to Congress Regarding Diablo Canyon
ML22108A2892022-05-0303 May 2022
Enclosure - Response to Representative Carbajal Regarding OIG Report on Diablo
ML22108A1662022-05-0303 May 2022
Enclosure 1 - Assessment Event Inquiry Into the Nuclear Regulatory Commission Oversight of the Auxiliary Feedwater System at Diablo Canyon Nuclear
DCL-21-071, Federally Listed Species Affects Determination Memorandum2021-10-14014 October 2021
Federally Listed Species Affects Determination Memorandum
ML21188A0362021-07-0707 July 2021
Draft PG&E Letter DCL-21-046 - Diablo Canyon Unit 1: Emergency License Amendment Request 21-05, Revision to Technical Specification 3.7.8, Auxiliary Saltwater (Asw) System
DCL-20-102, Nuclear Material Transaction Report for New Fuel2020-12-0909 December 2020
Nuclear Material Transaction Report for New Fuel
ML20335A0132020-11-30030 November 2020
NRC Response to Public Watchdogs November 2
ML20328A3012020-11-23023 November 2020
NERC Reliability Standards for the Bulk Electric System of North America Updated July 20, 2020 (Cgnp Public Comments on Diablo Canyon Nuclear Power Plant, Units 1 and 2 - Pre-submittal Meeting of 11/24/2020)
ML18254A0402019-01-22022 January 2019
Staff Review of Seismic Probabilistic Risk Assessment Associated with Reevaluated Seismic Hazard Implementation of the Near Term Task Force Recommendation 2.1: Seismic
IR 05000275/20180052018-08-31031 August 2018
Updated Inspection Plan for Diablo Canyon Power Plant, Units 1 and 2 (Report 05000275/2018005 and 05000323/2018005)
ML17024A2072017-12-18018 December 2017
Staff Assessment of Response to 10 CFR 50.54(F) Information Request Flood-Causing Mechanism Reevaluation
DCL-16-117, Reactor Coolant System Pressure and Temperature Limits Report, Revision 152016-11-10010 November 2016
Reactor Coolant System Pressure and Temperature Limits Report, Revision 15
ML16215A1092016-08-0202 August 2016
OEDO-16-00436 - Supplemental Information from Mr. Lochbaum 10 CFR 2.206 Petition on Apparent Violation of 10 CFR 50.9 at Diablo Canyon Nuclear Power Plant
ML16019A2242016-02-0101 February 2016
Record of Review, Dispositions to Diablo Canyon Nuclear Plant, Units 1 and 2, Internal Events, Internal Flooding, Seismic, and Fire PRA Facts and Observations
ML16048A2152015-12-15015 December 2015
Fleet Vehicle-Asset List
ML16048A2072015-12-15015 December 2015
Once Through Cooling
DCL-15-102, 10 CFR 71.95 Report Regarding Energy Solutions' Model 8-120B Shipping Cask2015-08-24024 August 2015
10 CFR 71.95 Report Regarding Energy Solutions' Model 8-120B Shipping Cask
ML15231A5712015-07-28028 July 2015
Holtec Information Bulletin (HIB) No. 67 (Rev. 0), VCT Restraint Strap Weld Failure
ML15160A2612015-07-0101 July 2015
Letter to NMFS Notice of Intent to Reinitiate Scoping Process for Diablo Canyon Power Plant Units 1 and 2 License Renewal Application
ML16048A2042015-06-30030 June 2015
Notice of Intent, General Permit to Discharge Storm Water
ML16048A2132015-06-22022 June 2015
Permit Renewal No. 49-1
ML15355A2972015-05-31031 May 2015
DCPP Fsaru R22 File a Drawings - Combined - (Redacted)
ML15355A0792015-05-31031 May 2015
DCPP Fsaru R22 File B Drawings - Combined (Redacted)
RIS 2014-07, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 3 of 52014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 3 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 4 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 5 of 5
RIS 2014-07, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 2 of 52014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 2 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 3 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 4 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 5 of 5
RIS 2014-07, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 4 of 52014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 4 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 5 of 5
RIS 2014-07, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 5 of 52014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 5 of 5
ML14189A5002014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 1 of 5
ML14189A5312014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 2 of 5
ML14189A5332014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 3 of 5
ML14189A5372014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 4 of 5
ML14189A5432014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 5 of 5
RIS 2014-07, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 1 of 52014-06-19019 June 2014
Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 1 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 2 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 3 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 4 of 5, Regulatory Issue Summary (RIS) 2014-07, Enhancements to the Vendor Inspection Program- Vendor Information Request. Part 5 of 5
DCL-14-030, Diablo, Units 1 and 2 - Report of 10 CFR 50.59, Changes, Tests and Experiments, for the Period of January 1, 2012 Through December 31, 20132014-04-17017 April 2014
Diablo, Units 1 and 2 - Report of 10 CFR 50.59, Changes, Tests and Experiments, for the Period of January 1, 2012 Through December 31, 2013
DCL-14-021, Reactor Coolant System Pressure and Temperature Limits Report for Units 1 and 22014-03-25025 March 2014
Reactor Coolant System Pressure and Temperature Limits Report for Units 1 and 2
ML13364A1922014-02-0303 February 2014
Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)
DCL-13-094, and Humboldt Bay Power Plant, 10 CFR 71.95 Reports Regarding Energysolutions' Model 8-120B Shipping Cask2013-09-30030 September 2013
and Humboldt Bay Power Plant, 10 CFR 71.95 Reports Regarding Energysolutions' Model 8-120B Shipping Cask
DCL-12-080, Nonroutine Report of Planned Disturbance of Archaeological Site SLO-22012-08-21021 August 2012
Nonroutine Report of Planned Disturbance of Archaeological Site SLO-2
ML12170A8402012-06-0606 June 2012
Attachment 16 to DCL-12-050, PGE-12-52 Np, Westinghouse Input to Diablo Canyon Digital Process Protection System Replacement Uncertainty Calculations Summary Lar.
DCL-12-050, Diablo Canyon, Units 1 and 2, Attachment 16 to DCL-12-050, PGE-12-52 Np, Westinghouse Input to Diablo Canyon Digital Process Protection System Replacement Uncertainty Calculations Summary Lar.2012-06-0606 June 2012
Diablo Canyon, Units 1 and 2, Attachment 16 to DCL-12-050, PGE-12-52 Np, Westinghouse Input to Diablo Canyon Digital Process Protection System Replacement Uncertainty Calculations Summary Lar.
DCL-12-023, Third Interval Snubber Program, Revision 12012-02-28028 February 2012
Third Interval Snubber Program, Revision 1
DCL-11-136, Annual Update to the DCPP License Renewal Application and License Renewal Application Amendment Number 452011-12-21021 December 2011
Annual Update to the DCPP License Renewal Application and License Renewal Application Amendment Number 45
ML1116803532011-06-18018 June 2011
Core Operating Limits Report for Cycle 17
DCL-11-073, Diablo Canyon, Unit 2 - Core Operating Limits Report for Cycle 172011-06-18018 June 2011
Diablo Canyon, Unit 2 - Core Operating Limits Report for Cycle 17
ML1109402692011-04-0505 April 2011
Evaluation Regarding the 2009 Steam Generator Tube Inspections Performed During the 15th Refueling Outage (2R15)
DCL-10-158, CFR 54.21(b) Annual Update to the DCPP License Renewal Application and Amendment No. 342010-12-29029 December 2010
CFR 54.21(b) Annual Update to the DCPP License Renewal Application and Amendment No. 34
ML1025810662010-08-0202 August 2010
Backup 60M Tower Data File, Calendar Year 2008, Part 2 of 5
DCL-10-081, Diablo Canyon, Units 1 and 2, Backup 60M Tower Data File, Calendar Year 2008, Part 2 of 52010-08-0202 August 2010
Diablo Canyon, Units 1 and 2, Backup 60M Tower Data File, Calendar Year 2008, Part 2 of 5
ML1025803172010-08-0202 August 2010
2009 Meteorological Data
DCL-10-081, Diablo Canyon, Units 1 and 2, 2005 Meteorological Data2010-08-0202 August 2010
Diablo Canyon, Units 1 and 2, 2005 Meteorological Data
2023-06-27
[Table view] |
Text
1 Burkhardt, Janet From: Dave Lochbaum <DLochbaum@ucsusa.org>
Sent: Tuesday, August 02, 2016 9:08 AM To: Watford, Margaret Cc: Singal, Balwant
Subject:
[External_Sender] Supplemental information for Diablo Canyon pre-PRB meeting Attachments:
20130300-ucs-tolerating-the-int olerable-excerpts.pdf Hello Ms. Watford:
Attached are excerpts from a report issued by UCS in Ma rch 2013. The excerpts are prim arily the section of the report where we point out that Request s for Additional Information (RAIs) represent prima facie evidence of 10 CFR 50.9 violations, yet the NRC's RAI process does not ev en include a checklist or screening to determine whether a violation of this federal regulation may be involved.
Following issuance of our report in Marc h 2013, I discussed this point with several NRC staffers and managers.
The general response was interest in the point, but little intere st in doing anything about it.
This material helps explain why we submitted the Diablo Canyon request under 2.206 -- we're seeking to have the NRC enforce federal regulations it has on the books but ap parently overlooks.
Our concern is heightened by the downsizing being undertak en via Project AIM. If th e NRC staff continues to inefficiently apply FTEs to reviews and re-reviews and re-re-reviews of licensee submittals until they finally obtain complete and accurate information, those will be FTEs unavailable for more productive safety work.
Thus, UCS's petition seeks to right a wrong before it becomes even wronger.
I intend to refer to this report a nd specifically these exce rpts during this afternoon's pre-PRB meeting and respectfully request that this material be included with the transcript and other records for the meeting.
- Thanks, Dave Lochbaum
UCS
The NRC and Nuclear Power Plant Safety in 2 0 1 2TOLERATING THE INTOLERABLE T HE NRC AND NUCLEAR P OWER PLANT SAFETY IN 2012: T HEY'VE LOST THAT SAFETY F OCUS l I The NRC and Nuclear Power Plant Safety in 2012: Tolerating
the Intolerable DAVID LOCHBAUM
March 2013
II l U NION OF C ONCERNED SCIENTISTS © 2013 Union of Concerned Scientists All rights reserved
David Lochbaum is the director of the Nuclear Safety Project of the UCS Global Security Program.
The Union of Concerned Scientists (UCS) is the leading science-based nonprofit working for a healthy environment and a safer world. UCS combines independent scientific research and citizen action to develop innovative, practical solutions and to secure responsible changes in government policy, corporate practices, and consumer choices.
The Global Security Program works to reduce some of the biggest security threats facing the world today, including the risks posed by nuclear weapons, nuclear terrorism, space weapons, and nuclear power. We work with scientists around the globe to increase international understanding of these issues and to foster and strengthen efforts to increase international security.
More information about UCS and the Nuclear Safety Project is available at the UCS website (www.ucsusa.org)
The full text of this report is available on the UCS website (www.ucsusa.org/publications) or may be obtained from:
UCS Publications
2 Brattle Square Cambridge, MA 02138-3780 Or email pubs@ucsusa.org or call 617-547-5552. Printed on recycled paper
46 l U NION OF C ONCERNED SCIENTISTS
CHAPTER 5. NEGATIVE OUTCOMES
FROM NRC OVERSIGHT This chapter describes situations where lack of effective oversight by the NRC led to negative outcomes. These outcomes are not necessarily the worst the NRC achieved last year. Rather, they shed light on practices and patterns that prevent the NRC from achieving the return it should from its oversight investment.
Safety Culture In 2011, the NRC issued a policy statement on safety culture that stated "The Commission expects the members of the regulated community to take the necessary steps to promote a positive safety culture by fostering the nine traits outlined in the policy statement as those traits apply to their specific activities" (NRC 2012w). The NRC stated:
"Safety culture" refers to the core values and behaviors resulting from a collective commitment, by leaders and individuals, to emphasize safety over competing goals to ensure protection of people and the environment.
The NRC identified nine traits-a trait being "a pattern of thinking, feeling, and behaving"-associated with a positive nuclear safety culture:
Leadership Safety Values and Actions-Leaders demonstrate a commitment to safety in their decisions and behaviors. Problem Identification and Resolution-Issues potentially impacting safety are promptly identified, fully evaluated, and promptly addressed and corrected commensurate with their significance.
T HE NRC AND NUCLEAR P OWER SAFETY IN 2012: TOLERATING THE INTOLERABLE l 53 NRC documents about the hazard at Oconee and other nuclear plants were also inappropriately withheld from the public. And Senator Boxer certainly did not receive honest answers to her question during that Senate hearing on March 15, 2012, with the triple meltdown risk at Oconee known by the NRC but not yet resolved. The NRC's creditability is jeopardized when it improperly withholds information 11 from the public and Congressional oversight committees. If explicit details about the Jocassee Dam's failure modes and associated vulnerabilities at Oconee warrant being withheld for national security considerations (i.e., not providing those who wish us harm the blueprints for conducting successful attacks), by all means do so. But a detail-lite version of the hazard could be made public to balance the public's right to know with the need to guard some information.
The NRC demonstrated achieving this balance in one area after 9/11. The NRC did not withhold all security information. Instead, it informed the public that it was taking steps to improve controls over access to nuclear plants and better protect against insiders and outsiders seeking to sabotage the plants. It quite properly withheld explicit information such as the height of security fences, locations of security cameras, and number of security force personnel at individual plants. But it publicly discussed the security threat and the general steps being taken to protect against it. And as described in Chapter 4, the NRC conducted an international conference on security that was open to the public, clearly demonstrating that it can discuss sensitive topics publicly while maintaining the proper balance of confidentiality.
Americans deserve comparable notification about flooding risks facing the nuclear plants.
Incomplete and In accurate Statements An NRC regulation, specifically §50.9 in Title 10 of the Code of Federal Regulations, requires that information submitted to the NRC by plant owners "be complete and accurate in all material respects" (NRC 1987). When the NRC staff reviewing applications for licensing action (e.g.,
permission to operate reactors at higher power levels and requests to reduce the frequency and scope of safety tests) by plant owners identifies additional information it needs to complete its evaluations, the NRC sends a request for additional information (RAI). Each RAI contains one or more questions that the NRC staff needs answered. A search of the NRC's record-keeping system (called ADAMS for Agencywide Documents Access and Management System) for documents containing the phrase "request for additional information" authored by the NRC and sent to nuclear plant owners returned over 1,000 records just in 2012 alone. The huge volume of RAIs during 2012-a number typical of prior years- clearly shows that the NRC staff has a questioning attitude. They literally asked thousands of questions of plant owners last year.
11 The NRC classified the Jocassee Dam materials as Official Use Only, a classification with no legal basis and employed only to keep documents from the public.
54 l U NION OF C ONCERNED SCIENTISTS But they are apparently not asking one key question-did the owner violate §50.9 by failing in the first place to submit information that was complete and accurate in all material respects? The large number of RAIs submitted by the NRC staff constitutes prima facie evidence that violations may have occurred. But the NRC's RAI process does not include even a screening to evaluate formally whether a §50.9 violation is the reason for (or contributed to) the incomplete and/or inaccurate submittal prompting the need for the RAI. Not every RAI represents absolute evidence of a §50.9 violation. Yet it is foolhardy to assume that no RAI could ever be the result of a §50.9 violation. But that seems to be the basic assumption behind the NRC's RAI process. I know from personal experience that assumption is flawed. I worked as a consultant in the licensing departments at the Grand Gulf Nuclear Station (in Port Gibson, MS) and Hope Creek Generating Station (Hancocks Bridge, NJ). At Grand Gulf, the process for preparing documents being submitted to the NRC included speculating about any questions the NRC's reviewers might raise. This exercise was conducted so as to revise the draft to answer those potential questions. The objective was to submit material to the NRC that yielded no, or very few, questions from the agency. The process at Hope Creek was fundamentally different. There, the process was not to volunteer any information in material being submitted to the NRC. "Make them ask," was the phrase I heard over and over from licensing supervisors in explaining why they had lined through statements and paragraphs in draft documents. Consequently, an RAI to Grand Gulf was less likely to be a §50.9 violation and more likely to a question that honestly was not anticipated. Conversely, an RAI to Hope Creek might very well address material information that the owner had anticipated would be required but forced the agency to request.
12 The NRC must take §50.9 seriously. When it issues RAIs to plant owners, the NRC must formally determine whether the reason for the RAIs might be §50.9 violations. That over 1,000 sets of RAIs were sent to plant owners during 2012 strongly suggests that some §50.9 violations were overlooked. The NRC sanction plant owners that deliberately seek to avoid compliance. Such behavior is part and parcel of a regulator's job.
Observations on Ineffe ctive NRC Oversight It is laudable that the NRC wants plant owners to establish and maintain positive safety cultures at their nuclear plants. It is laughable that the NRC's own safety culture is so wanting. The U.S. Congress played a key role in compelling the NRC to improve safety cultures at nuclear power plants. The 2002 discovery of severe reactor vessel head degradation at Davis-Besse was attributed to its owner placing production ahead of safety. The NRC appeared before an oversight subcommittee of the Senate's Environment and Public Works Committee 12 I hasten to point out that I worked at Grand Gulf and Hope Creek years ago. Policies and practices could easily have changed at these plants since then. However, my more recent communications with colleagues working in licensing departments at U.S. reactors suggests that the "make them ask" approach is not yet extinct.
T HE NRC AND NUCLEAR P OWER SAFETY IN 2012: TOLERATING THE INTOLERABLE l 55 outlining the many steps it was taking in response to the Davis-Besse debacle. It did not propose doing anything directly about the stated root cause-namely, the owner having lost the proper safety focus. Senator George Voinovich, chair of the subcommittee and representing Ohio where Davis-Besse is located, gave the NRC an option: either address safety culture issues itself or the Senate would do so by legislation. It was an option having only one choice and the NRC made the right choice. The NRC revised its reactor oversight process to include safety culture elements. It is imperative that the U.S. Congress compel the NRC to take steps to correct its safety culture problems and show marked improvement during the next work force survey in 2015. The common thread among the remaining negative outcomes involves inadequate enforcement of federal regulations. In the Waste Confidence Decision example, the court vacated the NRC's 2010 Waste Confidence Decision after determining that the NRC failed to comply with provisions of the National Environmental Protection Act. The court's action provides assurance that the agency will comply. In the future, the NRC should comply on its own. The NRC should emulate the court by making nuclear plant owners comply with federal regulations, too. Safety requirements prohibit reactors from operating for more than six hours with reactor coolant pressure boundary leaks; yet they do so again and again with NRC's tolerance. Federal regulations require plant owners to provide information to the NRC that is complete and accurate in all material respects. The NRC asked more than 1,000 sets of questions to plant owners just last year, strongly suggesting that the NRC is not getting complete and accurate information. Yet the NRC does not formally evaluate whether owners violated this federal regulation-and by not doing so, tolerates inadequate performance by plant owners. The NRC's job is more than just establishing safety standards at appropriate levels. It also involves consistently enforcing them. From a public health perspective, the only thing worsethan having safety standards set improperly is having them set properly but not followed. Setting safety standards properly means one knows what it takes to protect public health.
Failing to enforce them means one really doesn't care if the public is protected or not. That is unacceptable.
