|
---|
Category:Exemption from NRC Requirements
MONTHYEARDCL-23-122, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-14014 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23026A1092023-03-0202 March 2023 Exemption ML23046A0982023-02-13013 February 2023 Letter from NEI to Dan Dorman, February 13, 2023. Nei'S Support for PG&E Exemption from 10 CFR 2.109(b) ML22196A3682022-07-25025 July 2022 Withdrawal Acknowledgement of Temporary Exemption from Annual Force on Force Exercise Requirement of 10 CFR Part 73, Appendix B, Section VI, Subsections C.3(I)(1) and A.7 (EPID L-2022-LLE-0023 (COVID-19) ML21067A0582021-04-0101 April 2021 Exemption from Select Requirements of 10 CFR Part 55 Operators' Licenses ML21047A2552021-03-0303 March 2021 Exemption from Annual Force-On-Force Exercise Requirement of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel, Subsection A.7 (EPID L-2021-LLE-0008 (COVID-19)) DCL-21-011, Request for One-Time Exemption from Select 10 CFR 55.59 Requirements2021-02-0404 February 2021 Request for One-Time Exemption from Select 10 CFR 55.59 Requirements ML20346A1202020-12-18018 December 2020 Exemption from Annual Firearms Tactical Qualification Course Requirement of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel, Subsection VI.F.5.(a) (EPID L-2020-LLE-0167 (Covid 19)) ML20346A0242020-12-17017 December 2020 Exemption from Annual Force-On-Force Exercise Requirement of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel, Subsection VI.C.3.(I)(1) (EPID L-2020-LLE-0166 (COVID-19)) ML20271A0002020-10-13013 October 2020 FRN - Notice of Issuance of Multiple Exemptions Regarding Various Parts of 10 CFR Due to COVID-19 Impacts for September 2020 ML20247J6512020-09-18018 September 2020 Temporary Exemption from Biennial Emergency Preparedness Exercise Frequency Requirements of 10 CFR Part 50, Appendix E, Sections IV.F.2.b and IV.F.2.c (EPID L-2020-LLE-0111 (COVID-19) ML20177A6452020-07-15015 July 2020 FRN - Notice of Issuance of Multiple Exemptions Regarding Various Parts of 10 CFR Due to COVID-19 Impacts for June 2020 DCL-20-058, Temporary Exemption Request from 10 CFR 50 Appendix E Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic2020-07-0909 July 2020 Temporary Exemption Request from 10 CFR 50 Appendix E Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic ML20170A3192020-06-24024 June 2020 Exemption Request from Certain Requirements of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel (EPID L-2020-LLE-0101 (COVID-19)) DCL-20-042, Request for One-Time Exemption from 10 CFR 50.71(e)(4) UFSAR and TS Bases Update Requirements2020-05-14014 May 2020 Request for One-Time Exemption from 10 CFR 50.71(e)(4) UFSAR and TS Bases Update Requirements ML19259A1112019-09-16016 September 2019 Exemption Spreadsheet ML19163A1362019-09-12012 September 2019 FRN Exemptions from the Requirements of 10 CFR Sections 50.82(a)(8)(i)(A) and 50.82(a)(8)(ii) ML19163A1142019-09-10010 September 2019 Units -Exemption Exemptions from the Requirements of 10 CFR Sections 50.82(a)(8)(i)(A) and 50.82(a)(8)(ii) ML19163A1042019-09-10010 September 2019 Letter Exemptions from the Requirements of 10 CFR Part 50 Sections 50.82(a)(8)(i)(A)And 50.82(a)(8)(ii) DCL-19-017, Request for Exemption from Operator Written Examination and Operating Test2019-03-0707 March 2019 Request for Exemption from Operator Written Examination and Operating Test DCL-18-108, Access to Nuclear Decommissioning Trust Fund2018-12-13013 December 2018 Access to Nuclear Decommissioning Trust Fund DCL-11-045, Request for Exemption from Specific 10 CFR Part 73 Requirements2011-04-13013 April 2011 Request for Exemption from Specific 10 CFR Part 73 Requirements ML1002102072010-03-0202 March 2010 Exemption from the Requirements of 10 CFR Part 73 ML1002101802010-03-0202 March 2010 Exemption from the Requirements of 10 CFR Part 73 DCL-10-006, Request for Exemption from Specific 10 CFR Part 73 Requirements2010-01-22022 January 2010 Request for Exemption from Specific 10 CFR Part 73 Requirements 2023-03-02
[Table view] Category:Letter type:DCL
MONTHYEARDCL-24-010, Nuclear Material Transaction Report for New Fuel2024-01-29029 January 2024 Nuclear Material Transaction Report for New Fuel DCL-24-009, Nuclear Material Transaction Report for New Fuel2024-01-17017 January 2024 Nuclear Material Transaction Report for New Fuel DCL-24-008, Schedule Considerations for Review of the DCPP License Renewal Application2024-01-17017 January 2024 Schedule Considerations for Review of the DCPP License Renewal Application DCL-24-004, Supplement to License Amendment Request 23-01 Revision to Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2024-01-15015 January 2024 Supplement to License Amendment Request 23-01 Revision to Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b DCL-23-129, Nuclear Material Transaction Report for New Fuel2023-12-27027 December 2023 Nuclear Material Transaction Report for New Fuel DCL-23-122, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-14014 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation DCL-23-128, Emergency Plan Update2023-12-13013 December 2023 Emergency Plan Update DCL-23-125, Core Operating Limits Report for Unit 1 Cycle 252023-12-0606 December 2023 Core Operating Limits Report for Unit 1 Cycle 25 DCL-23-121, Supplement to License Amendment Request 23-03, Revision to Technical Specification3.7.8, Auxiliary Saltwater System2023-11-16016 November 2023 Supplement to License Amendment Request 23-03, Revision to Technical Specification3.7.8, Auxiliary Saltwater System DCL-23-120, License Amendment Request 23-03 Revision to Technical Specification 3.7.8, Auxiliary Saltwater (Asw) System2023-11-14014 November 2023 License Amendment Request 23-03 Revision to Technical Specification 3.7.8, Auxiliary Saltwater (Asw) System DCL-23-118, License Renewal Application2023-11-0707 November 2023 License Renewal Application DCL-2023-520, Discharge Self-Monitoring at Diablo Canyon Power Plant (DCPP)2023-10-19019 October 2023 Discharge Self-Monitoring at Diablo Canyon Power Plant (DCPP) DCL-23-103, Independent Spent Fuel Storage Installation - Withdrawal of License Amendment Request 22-01, Request for Approval of Alternative Security Measures for Early Warning System2023-10-13013 October 2023 Independent Spent Fuel Storage Installation - Withdrawal of License Amendment Request 22-01, Request for Approval of Alternative Security Measures for Early Warning System DCL-23-092, Material Status Report for the Period Ending August 31, 20232023-09-28028 September 2023 Material Status Report for the Period Ending August 31, 2023 DCL-23-077, License Amendment Request 23-02 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-09-27027 September 2023 License Amendment Request 23-02 Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors DCL-23-083, Upcoming Meeting with Nuclear Security and Incident Response Staff2023-09-13013 September 2023 Upcoming Meeting with Nuclear Security and Incident Response Staff DCL-23-078, Nuclear Material Transaction Report for New Fuel2023-09-0606 September 2023 Nuclear Material Transaction Report for New Fuel DCL-23-070, Withdrawal of Request Regarding Senior Reactor Operator License Application2023-08-16016 August 2023 Withdrawal of Request Regarding Senior Reactor Operator License Application DCL-23-068, Nuclear Material Transaction Report for New Fuel2023-08-0909 August 2023 Nuclear Material Transaction Report for New Fuel DCL-23-066, Nuclear Material Transaction Report for New Fuel2023-08-0303 August 2023 Nuclear Material Transaction Report for New Fuel DCL-23-065, Letter DCL-23-065 Request That Exam Material Be Withheld from Public Disclosure2023-07-27027 July 2023 Letter DCL-23-065 Request That Exam Material Be Withheld from Public Disclosure DCL-23-064, Nuclear Material Transaction Report for New Fuel2023-07-26026 July 2023 Nuclear Material Transaction Report for New Fuel DCL-23-054, License Amendment Request 23-01 Revision to Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2023-07-13013 July 2023 License Amendment Request 23-01 Revision to Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b DCL-23-055, Nuclear Material Transaction Report for New Fuel2023-07-0606 July 2023 Nuclear Material Transaction Report for New Fuel DCL-23-042, Independent Spent Fuel Storage Installation, Submittal of Quality Assurance Program Description, Revision 02023-05-24024 May 2023 Independent Spent Fuel Storage Installation, Submittal of Quality Assurance Program Description, Revision 0 DCL-23-032, Independent Spent Fuel Storage Installation Docket No. 72-27, Materials License Number SNM-2514 Humboldt Bay Independent Spent Fuel Storage Installation - NRC Requested Notification of Withdrawal from Voluntary Program2023-05-22022 May 2023 Independent Spent Fuel Storage Installation Docket No. 72-27, Materials License Number SNM-2514 Humboldt Bay Independent Spent Fuel Storage Installation - NRC Requested Notification of Withdrawal from Voluntary Program DCL-23-041, 10 CFR 50.46 Annual Report of Emergency Core Cooling System Evaluation Model Changes for Peak Cladding Temperature for 20222023-05-22022 May 2023 10 CFR 50.46 Annual Report of Emergency Core Cooling System Evaluation Model Changes for Peak Cladding Temperature for 2022 DCL-23-038, Revision to the Unit 1 Reactor Vessel Material Surveillance Program Withdrawal Schedule2023-05-15015 May 2023 Revision to the Unit 1 Reactor Vessel Material Surveillance Program Withdrawal Schedule DCL-23-034, 2022 Annual Nonradiological Environmental Operating Report2023-05-0101 May 2023 2022 Annual Nonradiological Environmental Operating Report DCL-23-036, 2022 Annual Radiological Environmental Operating Report2023-05-0101 May 2023 2022 Annual Radiological Environmental Operating Report DCL-23-025, 2022 Annual Radioactive Effluent Release Report2023-05-0101 May 2023 2022 Annual Radioactive Effluent Release Report DCL-2023-512, Submittal of Receiving Water Monitoring Program 2022 Annual Report2023-04-27027 April 2023 Submittal of Receiving Water Monitoring Program 2022 Annual Report DCL-23-035, Response to Request for Additional Information on Request Regarding Senior Reactor Operator License Application2023-04-24024 April 2023 Response to Request for Additional Information on Request Regarding Senior Reactor Operator License Application DCL-23-028, Technical Specification Bases, Revision 142023-04-24024 April 2023 Technical Specification Bases, Revision 14 DCL-2023-511, Report on Discharge Monitoring for the First Quarter of 20232023-04-20020 April 2023 Report on Discharge Monitoring for the First Quarter of 2023 DCL-23-031, Submittal of Annual Report of Occupational Radiation Exposure for 20222023-04-19019 April 2023 Submittal of Annual Report of Occupational Radiation Exposure for 2022 DCL-23-024, Independent Spent Fuel Storage Installation, Response to Nrg Request for Additional Information for Revision to License Amendment Request 22-01 Request for Approval of Alternative Security Measures for Early Warning System2023-04-0404 April 2023 Independent Spent Fuel Storage Installation, Response to Nrg Request for Additional Information for Revision to License Amendment Request 22-01 Request for Approval of Alternative Security Measures for Early Warning System DCL-23-022, 2023 Annual Statement of Insurance for Pacific Gas and Electric Companys Diablo Canyon Power Plant2023-03-29029 March 2023 2023 Annual Statement of Insurance for Pacific Gas and Electric Companys Diablo Canyon Power Plant DCL-23-023, Decommissioning Funding Report for Diablo Canyon Power Plant, Units 1 and 22023-03-28028 March 2023 Decommissioning Funding Report for Diablo Canyon Power Plant, Units 1 and 2 DCL-23-021, Independent Spent Fuel Storage Installation, Emergency Plan Update2023-03-23023 March 2023 Independent Spent Fuel Storage Installation, Emergency Plan Update DCL-23-020, Responses to NRC Questions Regarding License Renewal Efforts2023-03-17017 March 2023 Responses to NRC Questions Regarding License Renewal Efforts DCL-23-009, Owner'S Activity Report for Unit 2 Twenty-Third Refueling Outage2023-02-22022 February 2023 Owner'S Activity Report for Unit 2 Twenty-Third Refueling Outage DCL-23-008, Request Regarding Senior Reactor Operator License Application2023-02-22022 February 2023 Request Regarding Senior Reactor Operator License Application DCL-2023-503, Annual Sea Turtle Report2023-01-26026 January 2023 Annual Sea Turtle Report DCL-2023-502, (DCPP) 4th Quarter 2022 Report on Discharge Self-Monitoring2023-01-18018 January 2023 (DCPP) 4th Quarter 2022 Report on Discharge Self-Monitoring DCL-22-091, Revised Steam Generator Tube Inspection Report for Twenty-First Refueling Outage2022-12-20020 December 2022 Revised Steam Generator Tube Inspection Report for Twenty-First Refueling Outage DCL-22-089, Core Operating Limits Report for Unit 2 Cycle 242022-12-20020 December 2022 Core Operating Limits Report for Unit 2 Cycle 24 DCL-22-085, Request to Resume Review of the License Renewal Application or, Alternatively, for an Exemption from 10 CFR 2.109(b), Concerning a Timely Renewal Application2022-10-31031 October 2022 Request to Resume Review of the License Renewal Application or, Alternatively, for an Exemption from 10 CFR 2.109(b), Concerning a Timely Renewal Application DCL-22-041, Site-Specific Decommissioning Cost Estimate, Revision 12022-10-12012 October 2022 Site-Specific Decommissioning Cost Estimate, Revision 1 DCL-22-042, Post-Shutdown Decommissioning Activities Report, Revision 12022-10-12012 October 2022 Post-Shutdown Decommissioning Activities Report, Revision 1 2024-01-29
[Table view] |
Text
Pacific Gas and Electric Company' James R.Becker Diablo Canyon Power Plant Site Vice President Mail Code 104/5/601 P.0. Box 56 Avila Beach, CA 93424 805.545.3462 January 22, 2010 Internal: 691.3462 Fax: 805.545.6445 PG&E Letter DCL-10-006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Request for Exemption from Specific 10 CFR Part 73 Requirements
Dear Commissioners and Staff:
In accordance with the requirements of 10 CFR 73.5, Pacific Gas and Electric Company (PG&E) requests the NRC approve an exemption from specific requirements of 10 CFR Part 73, "Physical Protection of Plants and Materials,' for the Diablo Canyon Power Plant (DCPP) by extending the deadline for the implementation of new security requirements issued by the NRC in a Final Rule dated March 27, 2009 (74 FR 13926).
Pursuant to the Final Rule, the new security requirements must be implemented by March 31, 2010. PG&E has evaluated these new requirements and determined that many can be implemented by the required date. However, specific parts of the new requirements will require more time to implement since'they involve significant upgrades to security systems. These changes involve physical modifications to include [ ]. Enclosure 1 requests exemption from certain physical security requirements contained in [ ] while Enclosure 2 provides the basis for the proposed exemption. Enclosure 3 provides an Environmental Assessment.
PG&E is requesting an extension from the March 31, 2010, implementation date to June 30, 2011, for these specific requirements based on the time typically required for design, procurement, and construction activities with modifications of this scope.
PG&E's current security program and the new security requirements that will be implemented by March 31, 2010, will provide continued assurance of public health and safety and common defense and security.
A member of the STARS (Strategic Teaming and Resource Sharing) ALliance Cattaway - Comanche Peak
Document Control Desk PG&E Letter DCL-10-006 January 22, 2009 Page 2 PG&E requests approval of this exemption request by February 5, 2010, to otherwise allow time to prepare and implement compensatory measures if the exemption is not granted. The proposed exemptions are requested to be effective upon issuance.
This submittal replaces a previous PG&E Letter, DCL-09-085-Public, dated December 4, 2009, in its entirety. A Security-Related version of this letter, DCL-09-085-SR, was signed and submitted to the NRC on December 4, 2009.
PG&E makes no regulatory commitments (as defined by NEI 99-04) in this letter.
This letter includes no revisions to existing regulatory commitments.
If you have further questions, or require additional information, please contact Tom Baldwin at (805) 545-4720.
Sincerely, James R. Becker Site Vice President swh/
Enclosures cc: Elmo E. Collins, NRC Region IV Alan B. Wang, NRC Project Manager cc/enc: Michael S. Peck, NRC Senior Resident Inspector A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Cattaway - Comanche Peak
PG&E Letter DCL-10-006 Enclosure 1 Request for Exemption from Specific Physical Security Requirements
Background
The NRC issued a Final Rule for new security requirements in the Federal Register dated March 27, 2009. Per the Final Rule, new security requirements must be implemented by March 31, 2010. Pacific Gas and Electric Company (PG&E) has evaluated these new requirements and determined that many can be implemented by the required date. However, PG&E has also determined that implementation of specific requirements will require additional time beyond March 31, 2010. PG&E has approved a plan to [ ]. The study phase has been completed and the design phase [ ] has begun. Construction will be completed for the entire-project by June 30, 2011.
Security System Upgrades DCPP is a two-unit facility located in San Luis Obispo County on the central coast of California. [ ]
Due to the amount of design, procurement and installation activities and in consideration of impediments to construction such as planned refueling outages on both Units 1 and 2 and winter weather conditions as shown in Figure 1 of Enclosure 2, '
completion of some of the new requirements contained in [ ] will require additional time beyond March 31, 2010.
Requested Exemptions PG&E requests an exemption', from the implementation deadline only, for the two items listed below. Implementation of the remainder of the modifications needed for compliance with the new [ ] requirements will proceed on a schedule to be completed by March 31, 2010.
PG&E's current security program, along with those modifications to be implemented by March 31, 2010, will provide continued assurance of public health and safety. The defensive strategy implemented in conjunction with the DCPP Physical Security Plan will not be impacted by the implementation activities associated with meeting the requirements of the new 10 CFR Part 73. Accordingly, the requested exemptions are authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest in accordance with 10 CFR 73.5.
Item 1 Regulation
[1]
1
PG&E Letter DCL-1 0-006 Enclosure 1 Issue
[I I Item 2 Requlation
[I Issue
[ ]
2
7 PG&E Letter DCL-10-006 Enclosure 2 Basis for Proposed Exemption Pacific Gas and Electric Company (PG&E) is requesting an exemption from [ ] and
[ ]. The basis for requesting an exemption of the March 31, 2010, date to June 30, 2011, is completion of [ ]to address the [ ] requirements of the new Part 73 Rule.
Using established processes, the duration (study, design, construction, testing, turnover) of a project of this magnitude is typically 18-24 months. Due to severe space limitations associated with the DCPP site and surrounding geological features, the required modifications to [ ] require extensive conceptual and detailed design efforts.
The modifications to [ ] also require extensive conceptual and detailed design and construction efforts, and must be concurrently coordinated with [ ] modifications. This timeframe is further challenged by resources and the logistical impacts of plant refueling outages at both Units 1 and 2. PG&E is continuing efforts to implement the remaining new Part 73 requirements identified in the March 27, 2009, Federal Register Notice (Final Rule) and associated Regulatory Guides issued in July 2009 by March 31, 2010.
The following is a more detailed description of the work activities associated with the physical modifications applicable to this exemption request.
Physical Modifications Overview The scope of the physical modifications associated with this exemption request involves
[ ].
Figure 1 provides the Project Milestone Schedule for the physical modifications associated with the specific exemptions requested. These milestones represent a schedule driven to comply with the new Part 73 requirements. The milestone schedule has been developed based on current information and anticipated impediments to construction such as planned refueling outages at both Units 1 and 2 and winter weather conditions which may impair construction due to inclement weather/storms.
1
PG&E Letter DCL-10-006 Enclosure 2 Figure 1 Milestone Schedule for New 10 CFR 73 Requirements Requiring Schedule Exemption
[1]
2
PG&E Letter DCL-10-006 Enclosure 3 Environmental Assessment
- 1. Describe any change to the types, characteristics, or quantities of non-radiological effluents discharged to the environment as a result of the proposed exemptions.
PG&E Response There are no expected changes in the types, characteristics, or quantities of non-radiological effluents discharged to the environment associated with the proposed exemptions. This application is associated with implementation of security changes.
These security changes will not result in changes to the design basis requirements for the structures, systems, and components (SSCs) at the Diablo Canyon Power Plant (DCPP) that function to limit the release of non-radiological effluents during and following postulated accidents. All the SSCs associated with limiting the release of offsite non-radiological effluents will therefore continue to be able to perform their functions. As a result, there is no significant non-radiological effluent impact. There will be no materials or chemicals introduced into the plant associated with the security.modifications that could affect the characteristics or types of non-radiological effluents. In addition, the method of operation of non-radiological waste systems will not be affected by these proposed exemptions.
- 2. Describe any changes to liquid radioactive effluents discharged as a result, of the proposed exemptions.
PG&E Response There are no expected changes to the liquid radioactive effluents discharged as a result of these proposed exemptions. The proposed exemptions will not interact to produce any different quantity or type of radioactive material in the reactor coolant system. These proposed exemptions will not result in changes to the design basis requirements for the SSCs at DCPP that function to limit the release of liquid radiological effluents during and following postulated accidents. All SSCs associated with limiting the release of liquid radiological effluents will therefore continue to be able to perform their functions. As a result, there is no significant liquid radiological effluent impact.
- 3. Describe any changes to gaseous radioactive effluents discharged as a result of the proposed exemptions.
PG&E Response For the same reasons as described in number 2 above, these proposed exemptions would have no effect on the characteristics of gaseous radioactive effluents.
1
PG&E Letter DCL-1 0-006 Enclosure 3
- 4. Describe any change in the type or quantity of solid radioactive waste generated as a result of the proposed exemptions.
PG&E Response These proposed exemptions will not result in changes to the design basis requirements for the SSCs at DCPP that function to limit the release of solid waste during and following postulated accidents. All SSCs associated with limiting the release of solid radioactive waste will therefore continue to be able to perform their function. Radiation surveys will be performed in accordance with plant radiation protection procedures on excavated dirt that could be contaminated, such as inside the protected area or radiation control areas, that will be disposed of offsite. Any contaminated dirt will be handled in accordance with plant procedures. DCPP has a radiation survey program and procedures to handle any contaminated excavated soil that is inside the protected area or radiation control areas.
- 5. What is the expected change in occupational dose as a result of the proposed exemptions under normal and design basis accident conditions?
PG&E Response Under normal power operation there would be no expected radiological impact on the workforce. There are no other expected changes in normal occupational operating doses. Control room dose is not impacted by the proposed exemptions and would not impact occupational dose.
- 6. What is the expected change in the public dose as a result of the proposed exemptions under normal and Design Basis Accident (DBA) conditions?
PG&E Response Dose to the public will not be changed by the proposed exemptions during normal operations or DBA conditions. As noted in items 2, 3, and 4 above, there is no basis to contemplate an increased source of liquid, gaseous or solid radiological effluents that could contribute to increased public exposure during normal operations and DBA conditions. The proposed security changes do not impact systems used during normal operation or systems used to detect or mitigate a DBA.
- 7. What is the impact to land disturbance for the proposed exemptions?
PG&E Response Surveys of the DCPP site have previously been performed, and environmentally sensitive areas identified. In addition, locations of cultural resources significanceare 2
PG&E Letter DCL-10-006 Enclosure 3 identified including the archeological site CA-SLO-2, which has been clearly delineated north of the protected area. A procedure is in place to ensure that the archeological site is protected and managed in accordance with the DCPP Archaeological Resources Management Plan.
The security modifications associated with the proposed exemptions involve only limited soil excavations. None of the planned excayations will occur in previously undisturbed areas. Specifically, the planned modifications do not involve land disturbance in environmentally sensitive areas, the archeological site CA-SLO-2, or any other location of cultural resources significance.
==
Conclusion:==
There is no significant radiological environmental impact associated with the proposed security changes at DCPP. These proposed changes will not affect any historical sites nor will they affect non-radiological plant effluents.
3