ML19214A119

Regulatory Audit Summary for June 18 to June 19, 2019 Audit, Regarding License Amendment Request for Changes to the Intake Structure Physical Security Classification

ML19214A119
Person / Time
Site:	Diablo Canyon
Issue date:	08/15/2019
From:	Balwant Singal Plant Licensing Branch IV
To:	Welsch J Pacific Gas & Electric Co
Singal B, 301-415-3016
References
EPID L-2019-LLA-0029
Download: ML19214A119 (7)

Text

August 15, 2019 Mr. James M. Welsch Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Nuclear Power Plant P.O. Box 56, Mail Code 104/6 Avila Beach, CA 93424

SUBJECT:

DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 -

REGULATORY AUDIT

SUMMARY

REGARDING LICENSE AMENDMENT REQUEST FOR CHANGES TO THE INTAKE STRUCTURE PHYSICAL SECURITY CLASSIFICATION (EPID L-2019-LLA-0029)

Dear Mr. Welsch:

By letter dated February 14, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19045A698), Pacific Gas and Electric Company submitted a license amendment request for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon) proposing changes to the intake structure physical security classification.

To support its review of the license amendment request, the U.S. Nuclear Regulatory Commission staff conducted a regulatory audit at the Diablo Canyon site from June 18 to June 19, 2019, to verify information submitted by the licensee and the supporting documentation, including a site walkdown. The regulatory audit summary is enclosed with this letter.

If you have any questions, please contact me at 301-415-3016 or via e-mail at Balwant.Singal@nrc.gov.

Sincerely,

/RA/

Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

Regulatory Audit Summary cc: Listserv

REGULATORY AUDIT

SUMMARY

FOR JUNE 18-JUNE 19, 2019 AUDIT IN SUPPORT OF THE REVIEW OF LICENSE AMENDMENT REQUEST FOR CHANGES TO INTAKE STRUCTURE PHYSICAL SECURITY CLASSIFICATION PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50.323

1.0 BACKGROUND

By letter dated February 14, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19045A698), Pacific Gas and Electric Company (PG&E, the licensee) submitted a license amendment request (LAR) for Diablo Canyon Nuclear Power Plant, Units 1 and 2 (Diablo Canyon or DCPP) proposing changes to the intake structure physical security classification. The U.S. Nuclear Regulatory Commission (NRC) staff determined the need for an onsite regulatory audit to be conducted in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Regulatory Audits (ADAMS Accession No. ML082900195), for the NRC staff to examine the licensees non-docketed information on selected topics for the licensing basis associated with the physical protection systems described in the PG&E Security Plans (Physical Security Plan (PSP),

Training and Qualification Plan, and Safeguards Contingency Plan for Diablo Canyon. The NRC staff also reviewed the auxiliary saltwater system (ASW) design features as described in the security plans and in the LAR. The purpose of the audit was to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision. The audit also included a site walkdown to get a better understanding of the scope of the proposed change. The proposed amendment would revise the PG&Es PSP and associated implementing procedures.

The NRC staff reviewed the impact of devitalizing the intake structure in documents provided with the LAR, including the supporting documents available on site to identify the additional information needed to complete the review of the LAR. The regulatory audit was conducted to gain a better understanding of the licensees basis for the proposed change and other aspects of the LAR. An audit plan was issued by the NRC staff by letter dated May 23, 2019 (ADAMS Accession No. ML19141A021). The scope of the audit was primarily focused on changes to the Diablo Canyon licensing basis for the proposed devitalization of its intake structure. In addition to examining the audit documents, the NRC staff held discussions with the licensees staff to better understand the scope of the LAR.

2.0 AUDIT DATES AND LOCATION The regulatory audit was held at Diablo Canyon, Avila Beach, California, from June 18 to June 19, 2019. Additional in-office audit of supporting documents was performed at NRC Headquarters by the NRC technical staff members not able to attend the audit in person.

Enclosure

3.0 AUDIT TEAM MEMBERS The NRC audit team members consisted of:

Judy Petrucelli, Security Specialist, Office of Nuclear Security and Incident Response (NSIR)/Division of Physical and Cyber Security Policy (DPCP)/Reactor Security Branch (RSB) (Technical Team Lead)

David Diec, Senior Program Manager, NSIR/DPCP/RSB (Technical Reviewer)

Balwant Singal, Senior Project Manager, Office of Nuclear Reactor Regulation (NRR)/Division of Operating Reactor Licensing (DORL)/Plant Licensing Branch IV (LPL4)

Steve Jones, Senior Reactor System Engineer, NRR/Division of Safety Systems (DSS)/Containment and Plant Systems Branch (SCPB) (Participated from NRC headquarters)

The following PG&E and Contract Security Consultant staff (in support of the licensee) participated in the audit:

Michael Richardson - Regulatory Services Supervisor Jordan Tyman - Risk Management Manager Trevor Marks - Security Compliance Analyst Tim Graf - Security Compliance Analyst Bob Zimkowski - Security Strategy Manager Nathan Barber - Probabilistic Risk Assessment Chris Mehigan - Operations Supervisor Mark Mayer - Nuclear Fuels Purchasing Manager Barry Westreich - Contract Security Consultant Bonnie Schnetzler - Contract Security Consultant 4.0 DOCUMENTS AUDITED The following documents were reviewed during the Audit:

PG&E letter dated February 28, 1995, providing a response to 10 CFR 73.55, Requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage, and the NRC response by letter dated April 23, 1996 (References 10 and 11 of the Enclosure to the LAR);

Unattended Openings Intersecting or Traversing PAs-SP314A (this document is Official Use Only-Security Related Information and is not available for public access under the provisions of 10 CFR 2.390);

Compensatory Measures SP602, Met Tower During Outages, Intake Configurations (this document is Safeguards Information (SGI) and will require the correct access and need-to-know to review);

EQP-8822.11, Design Calculation (this document is SGI and will require the correct access and need-to-know to review);

DCPP PSP, Section 21, Compensatory Measures (this document is SGI and will require the correct access and need-to-know to review);

DCPP PSP, Appendix B, Security Training and Qualification Plan; Local Law Enforcement Agency commitments (these documents are SGI and will require the correct access and need-to-know to review):

- San Louis Obispo County Sherriffs Office

- San Louis Obispo Police Department

- California Highway Patrol; OP [Operating Procedure] AP SD-0, Loss of ASW, Loss of or Inadequate Decay Heat Removal; OP AP SD-4, Loss of Coolant Water, Revision 23; OP AP SD-4, Appendix D:

Agreement Memorandum of Understanding with Institute of Nuclear Power Operations:

Flex Support Guidelines, FSG 05, Initial Assessment and Flex Equipment Staging; and Diagram A-1-3, Feed and Bleed Options, Equipment Elevations for RCS [Reactor Coolant System] Flood-up and Drain-down.

List of Documents Reviewed via Online Portal for Audit OP AP SD-0, Loss of, or Inadequate Decay Heat Removal, Revision 13B OP AP-16, Malfunction of the RHR [Residual heat Removal] System, Revision 13A OP AP SD-3, Loss of Auxiliary Salt Water, Revision 13 OP AP SD-4, Loss of Component Cooling Water, Revision 23 5.0 AUDIT ACTIVITIES The audit consisted of the following activities:

Licensee presentation, review of the documents provided in support of the LAR, and discussions with the licensee staff for technical understanding of the scope of the LAR.

In-office audit of procedures addressing reactor heat removal capability and associated systems availability when steam generators are not available (Operational Modes 4, 5, and 6) by the NRR staff.

An onsite tour to get a better understanding of the intake structure, the reservoir ponds, and the FLEX equipment.

An exit briefing for NRC staff to present observations and discuss the potential request for additional information (RAI) questions.

6.0 AUDIT

SUMMARY

The purpose of the audit was to gain better understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision regarding the applicable regulation and the licensing basis of the plant.

The regulatory audit was conducted to determine if documentation provided by the licensee, support the bases for the proposed changes to the site intake structure physical security classification in accordance with all applicable sections and appendices of 10 CFR 73.55. Additionally, the areas of focus during the audit were the licensees intake structure; emergency operating procedures as discussed in the reference documents identified in the LAR dated February 14, 2019, and specific protective actions; current treatment of underground pathways as they applied to the ASW; and procedures addressing reactor heat removal capability and associated systems availability when steam generators are not available (Modes 4, 5, and 6).1 The NRC staff was also briefed on the licensees coordination with its local law enforcement agencies through its Memorandum of Understanding.

The licensee discussed all operational modes and identified cooling sources as part of plant defense-in-depth (licensed basis and longer terms cooling) approach, along with safety/security protection to ensure plant safe shutdown (during and after an adversary event).

The NRC staff conducted a walkdown of the pre-staged longer terms cooling equipment with the licensee, discussed the maintenance program for the equipment, and observed the overall plant layout.

Results of the Audit Based on the review of the licensee procedures, security plan, presentations and site walkdown, the NRC staff had a better understanding of the scope of the LAR.

The licensee will revise appropriate sections of the site security plan and associated site procedures that reflect the defense-in-depth and safety/security considerations per 10 CFR 50.54(p)(2), if the amendment is approved.

The NRC staff confirmed that multiple means of decay heat removal have been identified in required procedures, and availability of equipment for at least one decay heat removal path independent of the normal decay heat removal path is reasonably assured by technical specification requirements.

The NRC staff intends to issue RAIs for the licensee to supplement the original request with additional information identified during the audit and needed in support of the LAR 1

Related to analysis included in References 6 and 10 to the Enclosure to the LAR dated February 14, 2019.

7.0 EXIT BRIEFING As described in Section 6.0 of this summary, the exit discussion summarized the NRC staffs view and understanding of scope of the LAR and the potential for RAIs for documenting additional information identified during the audit.

The licensee was informed that the audit will be kept for open for additional 4-6 weeks for the NRC staff to complete its review of the additional information provided during the audit.

ML19214A119 via email dated OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NSIR/RSB/BC* NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME BSingal PBlechman MSampson RPascarelli BSingal DATE 8/15/19 8/15/19 7/30/19 8/15/19 8/15/19