ML20141L717

NRC-2019-000279 - Resp 4 - Interim, Agency Records Subject to the Request Are Enclosed. (Released Set of 2015-0071, Part 2 of 2)

ML20141L717
Person / Time
Site:	Diablo Canyon
Issue date:	05/14/2020
From:	NRC/OCIO
To:
Shared Package
ML20141L707	List: ML20141L708 ML20141L709 ML20141L710 ML20141L711 ML20141L712 ML20141L713 ML20141L714 ML20141L715 ML20141L716 ML20141L717 ML20141L718
References
FOIA, NRC-2019-000279
Download: ML20141L717 (282)

Text

something comes up.

From: John Bernetich [mailto:bemetichj@ayreslawgrouo.com)

Sent: Friday, November 21, 2014 4:59 PM To: Mullins, Charles Cc: Richard E. Ayres; Jessica Olson

Subject:

Re: My current view of the Record

Chuck, Thanks for sending this over. Are you free to talk about the record and scheduling matters on the phone at 2pm on Monday? You can call Dick at 202-452-9200 x I .

John Bemetich Associate Attorney Ayres Law Group LLP Ph: (202) 452-9200 Dir: (202) 416-0241 www .ayresiawi;:roup.com On Nov 21, 2014, at 4:36 PM, Mullins, Charles

<Charies.MuHins@nrc.iNv> wrote:

John; This reflects my current view of the record in this case

- the documents related to Rev 21 and the documents pending before the Commission.

Obviously, if you guys think I should add some more, I will take a look at them.

Have a good weekend .

Chuck

<14-1 213(0.C.Cir.)CurrentRecord.pdf.>

From: Mumns. Charles To: Marldev. Mjchae1

Subject:

Observation Date: Friday, November 21, 2014 5: 15:41 PM Michael; I went back and read the etition.

I will bring it down on Monday and you can read it

.__""".""'."'~=1?"""--------------1 yourse .

Have a great weekend.

Chuck

From: Sebrosky. Joseph To: RothCOGCl. Dayid: Harrjs. Brian: Young. Mitzi: Kanatas. Catherine Cc: Oesterle Ede Markley. MJchaeJ

Subject:

FW: Did PG&E and the NRC wort together to spin news on Diablo Canyon quake safety? attorney dlent Date: Friday, September 19, 2014 6:36:20 AM FYI - thought you ought to know about the recommendation to forward information to the IG office.

Joe From: Markley, Michael Sent: Thursday, September 18, 2014 2:02 PM To: Wertz., Trent Cc: Lund, Louise; Wilson, George; Sebrosky, Joseph; Oesterle, Eric

Subject:

FW: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?

Please share with Michele. Jennifer. and Dan.

From: Willis, Dori Sent: Thursday, September 18, 2014 1:28 PM To: Sebrosky, Joseph; Markley, Michael Cc: Kanatas, catherine; Roth(OGC), David; Oesterle, Eric; Uselding, Lara; Lund, Louise; Walker, Wayne

Subject:

RE: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?

Yes, I believe it should be sent to the IG as it is about NRC wrongdoing.

Thanks Dori From: Sebrosky, Joseph Sent: Thursday, September 18, 2014 12:22 PM l'o: Markley, Michael; Willis, Dori Cc: Kanatas, catherine; Roth(OGC), David; Oesterle, Eric; Uselding, Lara; Lund, Louise; Walker, Wayne

Subject:

RE: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?

Mike.

I believe it asserts collusion on part of the NRC, so should it be in JG space ?

Joe From: Markley, Michael Sent: Thursday, September 18, 2014 12:09 PM l'o: Willis, Dori Cc: Kanatas, catherine; Roth(OGC), David; Oesterle, Eric; Sebrosky, Joseph; Uselding, Lara; Lund, Louise

Subject:

FW: Did PG&E and the NRC work together to spin news on Diablo canyon quake safety?

Dori, Aside from the obvious handling of the FOIA, whenever it is received, this reads like an allegation? What is the OAC view on this?

Mike Markley, Acting Deputy Director DORUNRR 301-415-5723 From: Uselding, Lara Sent: Thursday, September 18, 2014 10:28 AM To: Walker, Wayne; Hipschman, Thomas; Reynoso, John; Buchanan, Theresa; Sebrosky, Joseph; Sebrosky, Joseph; Markley, Michael

Subject:

FW: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?

From: Dricks, Victor Sent: Thursday, September 18, 2014 9:16, AM To: Dapas, Marc; Kennedy, Kriss; Pruett, Troy; Uselding, Lara; Brenner, Eliot

Subject:

FW: Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?

FYI Victor Dncks Senior Public Affairs Officer U.S. Nuclear Regulatory Commission / Region IV 1600 E. Lamar Blvd.

Arlington, Texas 76011 817) 200-1128 (Office)

(bH6 l (Cell)

From: BillWalker[mailto:bw,deadline@gmajLcomJ Sent: Thursday, September 18, 2014 9:13 AM To: Dricks, Victor

Subject:

Did PG&E and the NRC work together to spin news on Diablo Canyon quake safety?

For Immediate Release: September 18, 2014 Expert Contacts:

Ben Schreiber, (202) 352-4223, bschrerber@foe org Dave Freeman, (310) 902-2147, greenoowboysdf@gmajl,com Communications Contacts:

EA Dyson, (202) 222-0730, edyson@foe org (East Coast)

Bill Walker, (510) 759-9911 , bw deadljne@gmail com (West Coast)

Did PG&E and the NRC work together to spin news on Dia blo Canyon quake safety?

Friends of the Earth files Freedom of Information Act request w ASH INGTON. D.C. - Last week the Nuclear Regulatory Commission denied a dissent by the

former chief inspector at the Diablo Canyon nuclear plant, who said new seismic data show the plant may be vulnerable to earthquakes of greater magnitude than allowed by its license. On the same day, Pacific Gas & Electric Co. released a long-awaited seismic study that, like the NRC's ruling , also claimed that Diablo Canyon is safe.

Was the timing a coincidence? Friends of the Earth doubts it.

Today, Friends of the Earth, joined by Public Employees for Environmental Responsibility, Mothers for Peace and the Santa Lucia Chapter of the Sierra Club filed a Freedom of

!nformatjon Act request to determine whether the NRC and PG&E improperly worked together on a public relations strategy to counteract widespread news coverage of the inspector's dissent.

According to the FOIA request, filed with the NRC in Washington:

The PG&E seismic report, released on the same day (as the decision on the inspector's dissent) indicates a possible relationship between the regulator and its licensee that has brought up widespread public concern regarding the independence of the regulator. There have been numerous concerns as to how the two documents could have been released simultaneously, given that [the handling of the inspector's dissent] has been kept secret.

The FOIA filing comes three days after three PG&E executives and a top staff member of the California Public Utilities Commission were removed for improperly working together to appoint the company's preferred judge to a case stemming from a September 2010 gas line explosion that killed eight people in San Bruno. California.

"You don't have to look any further than today's headlines to see that PG&E is capable of trying to improperly influence a government regulator when its profits are on the line," said Damon Moglen, Senior strategic advisor for Friends of the Earth. "Unfortunately, the NRC's track record on this issue shows an unfortunate tendency to put PG&E's interests before those of public safety. We want to find out to what extent PG&E and the NRC worked together to spin the story that Diablo Canyon is safe, despite the mounting evidence that it is vulnerable to quakes more powerful than it was built to withstand."

San Luis Obispo County supervisor Bruce Gibson. a seismologist and member of the Independent Peer Review Panel for Diablo Canyon appointed by the CPUC, also guest1oned the 1im.ing, of the release of PG&E's report.

"PG&E chose to finalize its entire report and release it to the public before it sought any comment from-or even contacted-the peer review panel," Gibson wrote in the San Luis Obispo Tribune. "It appears to me that PG&E's public relations staff advised them to get their story to the public before any detailed questions might be asked."

Dr. Michael Peck, the former chief inspector at Diablo Canyon, in June 2013 filed a dissent known as a Djffenng Profess,ona! Opinion . or DPO. raising concerns that the plant might not withstand an earthquake on one of several fault lines that were not known when it was designed

and built more than 40 years ago. Peck called for the shutdown of the plant until and unless PG&E could prove it is safe.

For more than a year, the NRC kept Peck's DPO secret and took no action on it. On August 25, 201 4, the Associated Press revealed the existence of Peck's document, prompting Sen. Barbara Boxer of California to call a hearing to examine NRC's handling of the dissent. On September 10, the NRC announced it had ruled against Peck. Within hours, PG&E released a seismic

~ study the NRC had ordered in the wake of the Fukushima nuclear disaster in March 2011 .

"PG&E's seismic safety study is one more example of its half-century history of trying to rationalize away the extreme earthquake hazards to the Diablo Canyon reactors," said Jane Swanson, San Luis Obispo Mothers for Peace. "Despite three earthquake faults identified near Diablo, the NRC has continued to allow this devil of a plant to continue to operate."

Under federal law, the NRC has 20 days to respond to the Freedom of Information Act request.

Bill Walker dba Deadline Now IJ.erkdcy, (' A (5 IO) 759-99 11 T " ittcl': (a:dcadlincnow F acebook: Deadline~O\\

Slkypc: deadlinenow http://www.deadlioenow com

Note: The attached email is From: Sebrosky, Joseph publicly available as part of To: Dudek, Michael Cc: Bowers, Anthony: Ma[lslev, Michael: Oesterte Ede documents D/25 and D/26 in

Subject:

RE: Proposed Questions to PG&E interim response #2 in FOIA-Date: Friday, September 19, 2014 6:35:22 AM 2014-0488 (ML14322A779)

Attachments: EW P!d PGE and tt,e NBC wons tooett,er to so,o news on Piabfo Canyon oyake safetv.msg Thanks i I (6)(6) I I will work with Tony to discuss the issue below, and to ensure the EDO staff is aware that in the attached email NRR DORL management has recommended to NRR senior management IG be informed of the assertion in the attached email that PG&E and NRC worked together to release the DPO the same day as the State of California report.

Joe From: Dudek, Michael Sent: Friday, September 19, 2014 6:18 AM To: Sebrosky, Joseph; Bowers, Anthony

Subject:

Re: Proposed Questions to PG&E lbll61 Morning Joe! o I will not be in the office. Tony Bowers will carry the ball for this. He'll be able to break down any barriers that you need.

Sent from an NRC Blackberry Michael I. Dudek (b)(6 )

From: Sebrosky, Joseph Sent: Thursday, September 18, 2014 05:20 PM Eastern Standard Time To: Dudek, Michael Cc: Walker, Wayne; OKeefe, Neil; Oesterle, Eric; Markley, Michael; Karas, Rebecca; Lupold, Timothy subject: FW: Proposed Questions to PG&E

Mike, I am going to give you a call on this. We need to confirm with the EDO's office that the position taken in the DPO appeal is that the operability determination for Diablo should have also included a comparison to tlhe DOE. The issue is important because we have a new operability determination for Diablo based on the new seismic information in the State of California report that we are reviewing .

I have been asked by my management to check with the EDO's office on this.

I will try to call you later tonight or early tomorrow to discuss.

Thanks, Joe

From: Sebrosky, Joseph Sent: Thursday, September 18, 2014 9:34 AM To: Hiland, Patrick Cc: Ake, Jon; Li, Yong; Markley, Michael; Lupold, nmothy; Karas, Rebecca; Ross-Lee, MaryJane; Oesterle, Eric; Wilson, George; Walker, Wayne; OKeefe, Neil; Hipschman, Thomas; Munson, Clifford; Manoly, Kamal; Hill, Brittain

Subject:

RE: Proposed Questions to PG&E Pat.

The purpose of this email is to provide you with the reference documents that I discussed with you this morning that serves as the basis for why I believe it is important to understand PG&E's position on whether or not in-structure motions (different damping values and comparisons) have been done. Specifically I referenced information that is in the DPO. The OPO case file can be found at: ML14252A743 lhe case file is 164 pages long. The most important portion of the case file to me is the last 5 pages (i.e., 159 - 164) that documents the EDO's appeal decision. The 5 page document provides a concise history of the issue and also includes the following discussion on page 4:

Nevertheless, your questioning attitude and perseverance were key to ensuring that the licensee and staff fully evaluated the! implications of the Shoreline fault zone. You correctly noted that the seismic hazard should be evaluated for not only comparison of the ground motion response spectra, but also the plants design and construction to ensure continued safe operation.

I understand that the in-structure motions calculations were not part of the basis for the operability determination that was made in the October 201 2 time frame. Nevertheless it would appear to me that the EDO agirees that they should have been done. Based on the need to support the new operability determination I would like to understand PG&E's position on the matter before we proceed. No position will be provided to PG&E during the phone call - we are in listening mode. I believe further robust internal discussion needs to take place and management may need to provide direction before a determination is made on what we need to do to support the review of PG&E's operability determination.

Please let me know if you have any questions, or if you think I am missing something.

Thanks, Joe From: Sebrosky, Joseph Sent: Thursday, September 18, 2014 5:38 AM l'o: Hill, Brittain; Manoly, Kamal; Munson, d ifford Cc: Ake, Jon; Li, Yong; Markley, Michael; Lupold, nmothy; Karas, Rebecca; Ross-Lee, MaryJane; Hiland, Patrick; Oesterle, Eric; Wilson, George; Walker, Wayne; OKeefe, Neil; Hipschman, Thomas

Subject:

RE : Proposed Questions to PG&E To all,

The purpose of this email is to clearly state the purpose of two meetings today regarding Diablo given the concerns raised by DE and NRO in the email chain below. The first meeting follows the agenda below and there is a followon meeting right after the PG&E discussion that is for the staff only. The purpose of agenda item Ill in the first meeting is to get PG&E's perspective on the issue. No decisions are being made. From DORL's perspective I believe we need to under~tand PG&E's position (i.e., whether or not they performed the calculations and if not the basis they believe the calculations are not necessary to demonstrate operability) to inform the internal discussion after the meeting.

If there is a problem with the sequence of the calls please let me know now. The bottom line is I believe PG&E's perspective is important to understand in supporting headquarters input to the assessment of operability. If you want to have a meeting before the PG&E call (given that we are having a meeting right after the call) please let me know so that I can schedule it.

Thanks, Joe I. PG&E provide a hi*level discussion of changes between the 2011 shoreline fault report and the information in the 2014 State of California report

a. During the discussion the staff would like PG&E to address the following

i. Basis for selection of the magnitude scaling relationship used in the State of California report ii. The basis for the changes in the geometry of the faults iii. The impact of using NGA*West2 based ground motion prediction equation (GMPEs) in the State of California report versus NGA.West GMPEs used in the PG&E 2011 Shoreline fault report

1. The report states the sensitivity analysis (Chapter 13) compares results from the CA 1632 bill (new CCSIP report the NRC is reviewing) and the new GMPEs from PEER NGA West2 project. Later it states the 4 NGAs are equally weighted (pgs 9, 18) by 25%, but other place*s it references 5 NGA West2 models (pages 10 & 19). Please explain the apparent discrepancy II. PG&E provide a discussion of the site.response approach used i1n the State of California report

a. Staff believes this is embedded in a 2014 Technical Evaluatiion Report entitled "Site Conditions Evaluation," which is reference in Chapter 13 as:

Technical Report GEO.DCPP.TR.14.06, June 2014 111. PG&E provide a discussion on whether or not in*structure motions (different damping values and comparisons) have been done IV. Next steps

v. Wrapup f'rom: Hill, Brittain

Sent: Wednesday, September 17, 2014 5:32 PM To: Manoly, Kamal; Munson, Olfford Cc: Ake, Jon; Li, Yong; Markley, Michael; Lupold, llmothy; Karas, Rebecca; Ross-Lee, MaryJane; Hiland, Patrick; Oesterle, Eric; Sebrosky, Joseph

Subject:

Re: Proposed Questions to PG&E Without the clarification on damping, we end up with the same confusing issues as 2 non concurrences, a DPO, the 2014 union Cone sci report, and recent petition by FOL If damping clarified, stops all this confusion in its tracks and gives clear basis for decisions. This is not a pure engineering exercise, and wha t you are portraying as "noise" 1s ano important considerat ion in clearly explaining why or why not we think DCPP is safe to operate. If t here still are dissenting views.

i suggest we discuss them al tomorrow's meeting before call.

Britt Sent from Brittain Hill's PDA (b)(6)

From: Manoly, Kamal Sent: Wednesday, September 17, 2014 04:58 PM Eastern Standard llme To: Hill, Brittain; Munson, Clifford Cc: Ake, Jon; Li, Yong; Markley, Michael; Lupold, llmothy; Karas, Rebecca; Ross-Lee, MaryJane; Hiland, Patrick; Oesterle, Eric; Sebrosky, Joseph

Subject:

RE: Proposed Questions to PG&E I mentioned RG 1.61 to illustrate a point. I know from my involvement with Oiablo since the mid-eighties that the plant was licensed to damping values that are different from RG 1.61 .

I also knew that some components are governed by DOE and others by hfosgri. From doing actual design of components in nuclear plants, designers know that some components may be governed by OBE and others by SSE. Still, the argument about damping should not be relevant to alt,ering the evaluation done by PG&E in 2011 except for the change of ground motion (old shoreline line vs. new shoreline hazard). That is the only variable of significance. The rest is in the noise level from an engineering standpoint.

Kamal Manoly Senior Level Technical Advisor for Structural Mechanics Division of Engineering Office of Nuclear Reactor Regulation 301-415-2765 From: Hill, Brittain Sent: Wednesday, September 17, 2014 4: 17 PM To: Manoly, Kamal; Munson, Oifford Cc: Ake, Jon; Li, Yong; Markley, Michael; Lupold, llmothy; Karas, Rebecca; Ross-Lee, MaryJane; Hiland, Patrick; Oesterle, Eric; Sebrosky, Joseph

Subject:

Re: Proposed Questions to PG&E Please read ch 2,3, and 5 in DCPP SAR to see that Hosgri 1s not limiting demand - can be either HE or ODE. PGE also didnt use RG 1.61 damping for all Catl SSCs. Please look at SAR for their mix. Unless they identify appropriate damping etc, we simply cannot state that new info is bounded by existing lie basis. If new Shoreline exceeds DOE, and ODE is the SSE and limiting GM (NOT Hosgrr !) for sorne SSCs, we certainly need PGE to state what damping is appropriate for new info: DOE, HE, RGl.61, or

something else.

Britt Sent from Brittain Hill's PDA (b)(6)

From : Manely, Kamal Sent: Wednesday, September 17, 2014 04:06 PM Eastern Standard Time To: Munson, Gifford Cc: Ake, Jon; Hill, Brittain; Li, Yong; Markley, Michael; Lupold, Timothy; Karas, Rebecca; Ross-Lee, MaryJane; Hiland, Patrick; Oesterle, Eric; Sebrosky, Joseph

Subject:

Proposed Questions to PG&E

Cliff, I see no relevance or value from asking PG&E question #5 about "In-structure motions (different damping values & appropriate comparisons)". The sole focus should be on confirming that PG&E new shoreline fault ground motion estimate is reasonable and acceptable to the staff. With such confirmation, then, the hazard from tlhe shoreline fault would be bounded by the "Old" Hosgri. That should be the end point of our assessment of the CA report.

Introducing a question as to whether the damping values to be used for the 2014 hazard estimate of the shoreline fault may be different from that used in the 2011 evaluation would be pointless and shifting the focus to a totally unrelated issue. You will never find any documented reference that correlates slight change in hazard vs damping values for structural materials. Remember, in RG 1.61 we prescribe (for a specific structural material) a single damping value to be used by ALL plants in the US for OBEs and another for ALL SSEs regardless of the location. The reason is based on acceptable understanding that viscous structural damping would generally be lower at lower deformation level. We know that ground motion estimates for OBEs and SSEs vary greatly from low seismic regions such as the Gulf States vs. high seismic regions such as CA. For this reasoning, asking the question about the effect of different damping values on in-structural response due to slight change in hazard would be worthless and totally distracting from the central issue in the CA report.

Kamal Manoly Senior Level Technical Advisor for Structural Mechanics Division of Engineering Office of Nuclear Reactor Regulation 301-415-2765

From: Oesterle Enc To: Whited. Jeffrey Cc: Markley. Michael: Lund Louse: Wilson, George

Subject:

Additional Q&As for Oiablo canycn Date: Tuesday, November 25, 2014 12:37:05 PM Attachments: AWJCIPATED QUESTIONS AND ANSWERS DCPP,docx Note: The 3-page attachment is withheld in its 1maae001.ooo entirety under FOIA exemption 5.

Jeff, I've incorporated Mike Markley's comments on the subject Q&As for EPW Hearing support and have provided the updated responses.

Er(o'R. o~z.e, NRC Project M anager Dia blo Canyon Power Pl ant Cooper Nuclear Station NRR/D0 RL/LPL4-1 301-415-1014

ANTICIPATED QUESTIONS AND ANSWERS DIABLO CANYON 1.

(b)(5) 2.

3.

4.

(b)(5)

5.

(b)(5)

From: pegersen, Renee To: Burne!L Scott: Markley, Micbaet: Scott. Michael: Oesterle. Enc: Screnci, Diane: Sheehan, Neil Cc.: Solorio, Dave: Sewell- Margaret: Sosa Belkvs: Holahan, Patricia SUbject: RE: Re: Dlablo Canyon Ask Management Date: Wednesday, November 12, 2014 10:56:42 AM Thanks for sharing this with OE. We s.upport the brief response from Scott, including that it i1s consistent with our agency guidance.

"Consistent with NRC guidance, the EDO's response to the DPO appeal is the final resolution to this matter."

We would appreciate it if OE could be copied on any responses related to the DPO.

(DPOPM.Resource@nrc,gov)

Renee Pedersen Sr. Differing Views Program Manager Office of Enforcement (301 ) 415-2742 From: Burnell, Scott Sent: Wednesday, November 12, 2014 8:22 AM To: Markley, Michael; Scott, Michael; Oesterile, Eric; Screnci, Diane; Sheehan, Neil Cc: Pedersen, Renee

Subject:

RE: Re: Diablo Canyon Ask Management This should particularly go through the RI OPA folks, and I'd offer the answer is "The EDO's response to the DPO is the final resolution to this matter."

From: Markley, Michael Sent: Wednesday, November 12, 2014 8:03 AM To: Scott, Michael; Oesterle, Eric Cc: Burnell, Scott; Pedersen, Renee

Subject:

RE: Re: Diablo Canyon Ask Management Mike Again , I think you need to go through OE and OPA. My preference is not to respond.

Mike From: Scott, Michael Sent: Monday, November 10, 2014 6:14 PM To: Markley, Michael; Oesterle, Eric

Subject:

Re: Diablo Canyon Ask Management Mike and Eric:

Thanks for the input you provided me. Hopefully the below would seem reasonable. If you have any concerns please let me know. If agreed by senior management here, this would be e-mail blasted to the Region 1 staff.

Q: On September 19, The Santa Barbara Independent ran an article, whiclh was also put The rest of this email string may be found as document B/36 in FOIA/PA-2015-0071 (ML15181A428).

From: Oesterle. Enc To: Scott Michael; Markle¥, Michael

Subject:

RE: Re: Oiablo canyon Ask Management Date: Wednesday, November 12, 2014 9:29:58 AM Understood. Your revised para seems reasonable.

Eric From: Scott, Michael Sent: Wednesday, November 12, 2014 9:02 AM To: Oesterle, Eric; Markley, Michael

Subject:

RE: Re: Diablo canyon Ask Management Problem is that was a direct quote. Hearing Mike's concern and yours. but being mindful of the need to be responsive to staff, I may go with:

On September 9. 2014, the EDO issued a decision on the appeal of DPO 2013-002, concerning seismic issues at the Diablo Canyon Nuclear Power Plant (DCNPP). The decision is summarized in the Commission Weekly Information Report dated September 19, 2014. We are not aware of any additional actions planned in response to the press article referenced in the question.

I will run this by OPA here as a matter of course.

Thanks again for your help.

Mike From: Oesterle, Eric Sent: Wednesday, November 12, 2014 6:24 AM To: Scott, Michael; Markley, Michael

Subject:

RE: Re: Diablo canyon Ask Management Mike.

It generally looks fine to me although I would scratch the text in red only because we've recently had some apparent issues with 50.59's performed for the OCPP steam generator and reactor vessel head replacement projects that involve questions about seismic and LOCA load combinations so until that gets ironed out I would just focus on the tech spec and safety aspects.

Eric from: Scott, Michael Sent: Monday, November 10, 2014 6:14 PM To: Markley, Michael; Oesterle, Eric

Subject:

Re: Diablo canyon Ask Management Mike and Eric:

Thanks for the input you provided me. Hopefully the below would seem reasonable. If you have any concerns please let me know. If agreed by senior management here, this would be e -mail blasted to the Region 1 staff.

The rest of this email string may be found as document B/36 in FOIA/PA-2015-0071 (ML16181A428).

From: Burnell Scott To: Markley. HidJael: Scott. HldJaef: Oesterle, Enc: Serena. Plane: Sheehan. Neil Cc: Pedersen. Renee SUbject: RE: Re: Diablo canyon As*. Management Date: Wednesday, November 12, 2014 8:22:08 AM This should particularly go through the RI OPA folks, and I'd offer the answer is "The EDO's response to the DPO is the final resolution to this matter."

From: Markley, Michael Sent: Wednesday, November 12, 2014 8:03 AM To: Scott, Michael; Oesterle, Eric Cc: Burnell, Scott; Pedersen, Renee SUbject: RE: Re: Diablo canyon Ask Management Mike A,gain, I think you need to go through OE and OPA. My preference is not to respond .

Mike From: Scott, Michael Sent: Monday, November 10, 2014 6:14 PM To: Markley, Michael; Oesterle, Eric

Subject:

Re: Diablo canyon Ask Management Mike and Eric:

Thanks for the input you provided me. Hopefully the below would seem reasonable. If you have any concerns please let me know. If agreed by senior management here, this would be e-mail blasted to the Region 1 staff.

Q: On September 19, The Santa Barbara Independent ran an article, which was also put on the R1 website, about the former Diablo Canyon SRI who had a concern about how Diablo Canyon's new seismic information was handled and did not feel that is DPO about this concern was adequately addressed. Does the NRC plan to do any thing additional to address his concern in light of the recent article? If so, please inform us of the resolution to this when it is concluded .

Proposed Response:

The following is quoted from the Commission Weekly Information Report dated September 19, 2014: "On September 9, 2014, the EDO issued a decision on the appeal of DPO 2013-002, concerning seismic issues at the Diablo Canyon Nuclear Power Plant (DCNPP).

The EDO's decision on the appeal supported both the DPO panel's independent technical conclusions and subsequent Office of Nuclear Reactor Regulation Director's decision that there was not a significant or immediate concern with seismic safety at DCPP, and that the licensee and staff had followed appropriate processes for technical specification operability of plant equipment and Title 1O Code of Federal Regulations 50.59 evaluations with a reasonable technical and safety rationale. The EDO noted that the DPO raised awareness of the complexity of the DCNPP seismic licensing basis, but also illustrated the need for the agency to ensure there are clear guidelines for staff and licensees regarding how changes in natural hazards should be evaluated for all licensees. The public records for

this DPO are available in the DPO case file package in the Agencywide Document Access and Management System, Accession No. ML14252A743."

According to the cognizant NRR licensing staff, no specific additional actions are planned in response to the referenced article. There has been substantial press coverage of the DPO, and numerous correspondence from stakeholders, including members of Congress and the public. The staff is handling inquiries in accordance with established processes.

From: Sebrgsl\y Joseph To: Klett, Audrev Cc: MarkJey, Michael: Oesterle, Enc: Wilson George

Subject:

thanks fOI' developing TER shell for Oiablo canyon Date: Thursday, October 23, 2014 7:42:12 AM Atudlments: PfabJo canyon ooerabjhtv evaluaoon 2011 seisrmc lofQrmatjon tecbocial evaiuatjon,docx path forward toe PiabJo operability assessroeot,msg Audrey, The purpose of this email is to thank you for developing the outline for the Diablo Canyon seismic TER. I used it to develop the attached TER which was used as a strawman for management discussions yesterday. Attached is a summary of the outcome of the meeting. Although it looks like the attached TER is going to be heavily revised it did serve a purpose as the basis for a starting point to get the ball rolling on the evaluation. It also appears to me that the general outline for the TER (which you developed) is going to be used.

I just thol)ght you should know that I very much appreciated not having to start from scratch on developing the TER and how I used what you developed.

Thanks again for the help.

Joe From: Sebrosky, Joseph Sent: Tuesday, October 21, 2014 8:10 AM To: Wilson, George; Oesterle, Eric; Markley, Michael

Subject:

info: latest version of Diablo canyon TER To all, Atlached is the latest version of the Oiablo Canyon TER. It incorporates comments from Eric and has other minor editorial changes from previous versions. Per direction from George I have stopped work on the effort pending the outcome of the meeting later today.

Thanks, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph sebrosky@nrc.gov 301 -415-1132

TECHNICAL EVALUATION REPORT BY THE OFFICES OF NEW REACTORS, RESEARCH , AND NUCLEAR REACTOR REGULATION CENTRAL COASTAL CALIFORNIA SEISMIC IMAGING PROJECT PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNITS 1 AND 2 October 21 , 201 4, 8:00 am version

1.0 INTRODUCTION

1.1 Purpose This evaluation provides the results of the U.S. Nuclear Regulatory Commission (NRC) staffs assessment of the new seismic hazards information developed by Pacific Gas and Electric Company (PG&E, the licensee) for the Diablo Canyon Power Plant, Units 1 and 2 (DCPP) and provided to the NRC in PG&E letter dated September 10, 2014, "Central Coastal California Seismic Imaging Project, Shoreline Fault Commitmenr(Reference 1). The staffs from the NRC's Office of New Reactors (NRO), Office of Research (RES), Region IV, and Office of Nuclear Reactor Regulation (NRR) evaluated the information provided in the licensee's September 10, 2014, letter. In addition, this evaluation provides the results of the NRC's review of PG&E's operability determination found in PG&E Notification 50652361 , "Preliminary new seismic information," completed on August 21 , 2014, (Reference 2) against NRC guidance found in NRC Inspection Manual Chapter (IMC) 0326, "Operability Determination and Functionality Assessments for Conditions Adverse to Quality or Safety," dated January 31 , 2014 (Reference 3) to determine what affect, if any, the new seismic information has on the capability of seismically qualified systems, structures, and components (SSCs) to perform their specified safety functions.

1.2 Background Pursuant to Title 10 of the Code of Federal Regulations, Part 50 (10 CFR), Section 50.54(f), and by letter dated March 12, 2012, (Reference 4) the NRC requested information concerning, in part, the seismic and flooding hazards at operating reactor sites to enable the NRC staff to determine whether operating licenses should be modified, suspended, or revoked. The "Required Response" section of Enclosure 1 to the letter indicated that licensees should provide a Seismic Hazard Evaluation and Screening report within 3 years for western United States (WUS) plants. The process outlined in the March 12, 2012, request for information related to seismic hazards was also discussed in NRC letters dated October 12, 2012, (Reference 5) and February 20, 2014 (Reference 6). The October 12, 2012, letter, specifically discusses NRC's review of the Shoreline fault near DCPP, and places the NRC's review of the Shoreline fault into context with the process for developing and assessing seismic information found in the March 12, 2012, request for information. The October 12, 2012, letter states in part:

The NRC staff understands that the seismic evaluations described in the March 12, 2012, request for information are currently in progress at DCPP, and PG&E plans to acquire new offshore and onshore two-and three-dimensional seismic reflection data to identify and characterize faults in the vicinity of DCPP.

If during the collection of the data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, the staff expects that the licensee will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic 1

hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staff's March 12, 2012, request for information.

California Assembly Bill (CAB) 1632 (Blakeslee, Chapter 722, Statutes of 2006) (Reference 7) directed the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, including Diablo Canyon Power Plant, to a major disruption caused by a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio.

Based on the California Assembly Bill, the California Energy Commission compiled a report in 2008 (Reference 8) that included the recommendation that PG&E perform additional seismic studies to supplement the original and ongoing seismic studies performed as part of the licensee's Long Term Seismic Program (LTSP), and that those studies be conducted using advanced technologies such as three-dimensional (30 ) seismic-reflection mapping. During 2011 through 2014, the licensee conducted the recommended studies and further data analysis, and compiled the report entitled, "Central Coastal California Seismic Imaging Project" (CCCSIP) and provided this report to the NRC via letter dated September 10, 2014. Following internal completion of the CCCSIP Report, the licensee performed an operability determination documented in Notification 50652361 completed on August 21 , 2014 (Reference 2) based on the report and its data.

PG&E's September 10, 2014, letter transmitting the report provides an interim evaluation consistent with the guidance found in the NRC's October 12, 2012, letter. PG&E's letter states in part:

The additional offshore seismic studies revealed that the Shoreline fault is longer by extending farther south than in the Shoreline fault report, and therefore, more capable as described in the enclosure. PG&E concluded that the ground motions from updated shoreline fault and other regional faults remain less than the 1977 Hosgri design ground motions, for which the plant was evaluated and demonstrated to have reasonable assurance of safety. This interim evaluation is consistent with the conclusions of the Research Information Letter 12-01 ,

"Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone,* dated September 2012 [Reference 9].

PG&E's September 10, 2014, states that the CCCSIP will support the NRC-mandated seismic hazard risk assessment for the DCPP that is being performed in accordance with the March 12, 2012, request for information (Reference 4). PG&E will use the Senior Seismic Hazard Analysis Committee (SSHAC) process to incorporate and evaluate existing and new seismic information to update the seismic hazard for DCPP.

The DCPP seismic hazard based on the SSHAC process is due to the NRC in March 2015.

The staff's previous assessment of the Shoreline Fault found in RIL 12-01 was based on a deterministic approach. As described in RIL 12-01 the conservative deterministic (scenario-based) viewpoint was intended to allow the NRC staff to determine if a safety concern exists as a result of the identification of the Shoreline fault. By their nature, deterministic approaches do not explicitly account for the likelihood of a particular earthquake scenario occurring, or the rate at which earthquakes can occur on known seismic sources. Therefore. deterministic results 2

cannot be used for a quantitative assessment of the overall risk to the plant from the Shoreline fault. Instead, deterministic approaches focus only on the safety margin that exists for a specific earthquake scenario, in this case for the Shoreline fault.

The response to the March 12, 2012, request for infonnation is based on a a probabilistic seismic hazard assessment (PSHA) approach. As described above PG&E is scheduled to provide a detailed PSHA by March 2015. The results of the PSHA will strengthen the understanding of the relative importance of the Shoreline fault and other faults evaluated in the CCCSIP to the seismic hazard at this site.

2.0 REGULATORY ANALYSIS

Because the detailed PSHA is due shortliy to the NRC (i.e., March 2015), the NRC staff's evaluation is limited to reviewing PG&E's detenninistic evaluation that is provided in the CCCSIP. The NRC staff's evaluation takes advantage of insights gained from the development of RIL 12-01 , but does not update the RIL. Instead, the staff's evaluation relies on the new information found in PG&E's September 10, 2014, submittal and PG&E's operability determination regarding the following fault scenarios:

• Hosgri and San Simeon faults (the step-over between the Hosgri and San Simeon is small enough that the two faults are assumed to rupture together with an assumed magnitude of 7.3)

• Los Osos fault (assumed magnitude of 6.7)

• San Luis Bay fault (assumed magnitude 6.4)

• Shoreline fault (assumed magnitude of 6.7)

• Hosgri, San Simeon and Shoreline linked fault sensitivity study(assumed magnitude 7.3)

The purpose of the NRC staff's evaluation is to detennine if a safety concern or operability concern exists as a result of the new infonnation provided in PG&E's September 10, 2014 CCCSIP report. A more thorough review of the seismic faults around DCPP will be completed by t he staff in the future based on PG&E's PSHA to be provided by March of 2015.

In performing its evaluation the NRC staff also reviewed how a recent Differing Professional Opinion (DPO) was resolved. The resolution of the DP0-2013-002, "Diablo Canyon Seismic Issues" is documented in a case file (Reference 10) that includes the following information:

• DPO Submittal

• Memo from NRR Office Director Establishing the DPO panel

• DPO Panel Report

• DPO Decision

• DPO Appeal Submittal

• NRR Office Director's Statement of Views

• DPO Submitter's Appeal Presentation to OEDO

• DPO Appeal Decision 3

3.0 EVALUATION

3. 1 Method of Review The NRC staffs review is broken into thr,ee parts:

• The NRC's deterministic evaluation of the faults described in the 2014 CCCSIP report

• An update to the DPO assessment based on the information in the 20114 CCCSIP

• An assessment of the results of the NRC staffs deterministic evaluation regarding safety and operability of DCPP SSCs based on ergodic treatmen of uncertainties.

3.2 NRC Staffs Deterministic Evaluation of the Faults Described in the 2014 CCCSIP Report Summary of PG&E Information Chapter 13 of the CCCSIP, "Hazard Sensitivity and Impact Evaluation," provides a discussion of the differences between the deterministic evaluation provided in PG&E's 2011 Shoreline Fault Zone Report (Reference 11) and the 201 4 CCCSIP studies. RIL 12-01 is based in large part on PG&E's 2011 Shoreline Fault Zone Report. CCCSIP Chapter 13 Table 1-1 , which compares the, source characterization for the deterministic ground motion evaluation, is reproduced below.

2011 Shoreline Report Updated Parameters Fault - - -

Maxirn.im Minimum Mag.

Maximum Minimum Mag.*

Length Dip (90th Length Dip (km) (degrees) fractile) (km) (degreest Shoreline 23 90 6.5 45 90 6.7 Hosgri 110 80 7.1 171 75 7.3 Los Osos 36 45 6.8 36 55 6.7 San Luis 16 50 6.3 16 50 6.4 Bay PG&E describes in CCCSIP Chapter 13 that the Shoreline fault was found to extend an additional 22 km to the south thereby increasing the fault length from 23 km used in the 2011 Shoreline Fault Zone Report to 45 km. With this increased length the magnitude of the Shoreline fault increased from 6.5 to 6.7.

For the Hosgri fault, PG&E describes in the CCCSIP Chapter 13 that the length of the combined Hosgri and San Simeon faults, 171 km, was defined using the Hosgri fault length from the U.S. Geological Survey (Petersen et al., 2008, Table 1-3) which treated the San Simeon and Hosgri faults as a single fault called the Hosgri fault. This increased length leads to a magnitude of 7.3.

PG&E describes in CCCSIP Chapter 13 that studies for the Los Osos fault found that the minimum dip consistent with the newly collected data is 55 degrees, as compared to 4

a minimum dip of 45 degrees used in the 2011 Shoreline Fault Zone Report. The steeper dip leads to a smaller fault area, and the magnitude is reduced from 6 .8 to 6 .7.

The CCCSIP studies did not provide new information for the San Luis Bay fault length or dip. Using the length and dip from the 2011 Shoreline Fault Zone Report leads to a magnitude of 6.4. The increase from the 2011 magnitude of 6 .3 results from using the bounding length and dip rather than the full logic tree to define the rupture area.

PG&E also describes in CCCSIP Chapter 13 that for the Shoreline fault rupture developed in the 2011 Shoreline Fault Zone Report the Shoreline fault was assumed to intersect with the Hosgri fault, but a linked rupture involving the full Shoreline fault and the full Hosgri fault was not included because the geometry of the two faults was unfavorable to allow such a rupture. PG&E states that the new information collected on the geometry of the Shoreline and Hosgri faults shows that within a resolution of a few hundred meters, the two faults intersect. This new information indicates that the fault may rupture together, but it does not change the unfavorable geometries for a linked rupture. Nevertheless, PG&E performed a sensitivity analysis assuming that the full Shoreline fault rupture is linked to a rupture of the Hosgri fault, extending north to the end of the San Simeon fault.

PG&E's CCCSIP Chapter 13 assesses the new information described above using a new ground-motion prediction equation (GMPE) as part of the Pacific Earthquake Engineering Research (PEER) Center's Next Generation Attenuation (NGA) West2 project. These GMPEs are different that the NGA West GMPEs used in the 2011 Shoreline Fault Zone Report (Note:

need something from NRO regarding assessment of new GMPEs)

Figure 1 of this evaluation provides a plot of the deterministic response spectrum using the source characteristics of various faults and the NGA West2 GMPEs for the power block (Note:

need to confirm if these NRC generated [Plots are for the power block or the turbine foundations)

PG&E concludes in the CCCSIP report and reiterates in the September 10, 2014, cover letter transmitting the report that the ground motions from the updated shoreline fault and other reg1ional faults remain less than the 1977 Hosgri Design ground motions for which the plant was evaluated and demonstrated to have reasonable assurance of safety.

NRC Evaluation Diablo Canyon Licensing Basis In 1968, when the OCPP Unit 1 Construction Permit was issued to Pacific Gas and Electric (PG&E), the seismic evaluation had been completed under the Atomic Energy Commission's requirements. Based on the information available at the time, the design earthquake (DE) was defined as having a peak ground acceleration of 0.2 g, and the double design earthquake (ODE) was a doubling of the DE earthquake to ensure safety-related structures, systems, and components would function as expected after the earthquake, 0.4 g. In 1973, PG&E became aware of the Hosgri fault. PG&E evaluat,ed the Hosgri fault using Regulatory Guide 1.61 ,

"Damping Values for Seismic Design of Nuclear Power Plants," October 1973 (Reference 12).

Though not included in the construction application, NRC reviewed PG&E's evaluation of the Hosgri fault and required PG&E to make plant modifications to be able to withstand the 0. 75 g 5

peak ground acceleration associated with the Hosgri fault. The operating license for Unit 1, issued in 1984, was based on review of the Final Safety Analysis Report Update which included two different seismic methodologies, the DOE and the Hosgri evaluation, as documented in NUREG-0675, UEvaluation Report Related to the Operation of Diablo Canyon Power Plant, Units 1 and 2, " Supplement No. 7, dated May 1978 (Reference 13).

Deterministic Response Spectrum and Use of Single Station Sigma Correction In the 2011 Shoreline Fault Report PG&E addressed uncertainty in the GMPE using a ergodic approach (an approach that accounts for both epistemic (model uncertainty) and the aleatory (natural) variability). The 2011 Shoreline Fault Report documented an effort to separate the uncertainty into its component parts, including the uncertainty that comes from the seismic source, the path through which the waves travel in the crust, and the site response. If high-quality data from a modern seismographic network are available, some of the uncertainty for a specific location can be reduced. The single-station-sigma adjustment has the potential to remove uncertainty in the application of the GMPEs by determining a station term from a set of earthquakes recorded at the site.

The NRC staff noted in RIL 12-01 Section 5.9 that:

The single-station-sigma adjustment represents advancement in the field of engineering seismology and could be a useful approach in the assessment of seismic hazard at NPPs that install a modern seismographic system, such as that at DCPP. The single-station-sigma correction applied by PG&E was developed based on daita from two earthquakes. Generally a larger number of earthquakes would be needed to develop confidence in the correction factor.

This correction was applied by PG&E but was not required for the confirmatory analysis that the NRC conducted as documented in RIL 12-01. The curves found in CCCSIP Chapter 13 found in Figure 1 of this evaluation are based on a single station correction and do not reflect ergodic uncertainty. As a result of questions raised during the inspection of PG&E's operability determination PG&E provided the following information relative to its use of the single-station-sigma correction on September 25, 2014:

• Processed Earthquake Recordings for Onsite Monitor ESTA 27 - 2003 Deer Canyon Earthquake

• Processed Earthquake Recordings for Onsite Monitor ESTA 27 - 2003 San Simeon Earthquake

• Processed Earthquake Recordings for Onsite Monitor ESTA 27 - 2004 Parkfield Earthquake

• Processed Earthquake Recordings for Onsite Monitor ESTA 28 - 2004 Parkfield Earthquake

• Shear Wave (VS30) Profiles for Power Block - Onsite Monitor ESTA 27

• Shear Wave (VS30) Profiles for Turbine Building - Onsite Monitor ESTA 27 6

• Shear Wave (VS30) Profiles for Power Block - Onsite Monitor ESTA 28

• Shear Wave (VS30) Profiles for Turbine Building - Onsite Monitor ESTA 28 Using the information provided by PG&E, the NRC staff developed the ergodic curves found in Figure 2 of this document.

The NRC staff concludes that PG&E's characteristics of the faults based on the new information revealed from the 20 and 30 analysis performed in accordance with CAB 1632 is reasonable.

The NRC staff also concludes that the use of the NGA West2 GMPE is appropriate for the evaluations performed by PG&E. (Note need more of a basis for this being OK). Therefore, the NRC staff concludes that the DCPP ground motions from the faults evaluated in the CCCSIP 2014 report (i.e., Hosgri-San Simeon, Shoreline, Los Osos, San Luis Bay, and Hosgri-Shoreline linked) using the single-station-sigma treatment of uncertainty are at or below those for the 1977 Hosgri earthquake (HE) ground motion and the long-term seismic program (LTSP) ground motion. The 1977 HE ground motion and the LTSP ground motion are those for which the plant was evaluated previously and demonstrated to have reasonable assurance of safety.

However, the NRC staff notes that based on the NRC staff developed ergodic curves found in Figure 2 , below that there are exceedance in the 10 Hz to 100 Hz range for the ground motions from the earthquakes evaluated in the CCCSIP 2014 report. The evaluation of the exceedances in this range can be found in Section 3.4 of this document.

3.3 Update of Differing Profession Opinion Assessment Based on the Information in the 2014 CCCSIP Report Summary of PG&E Information As a result of questions asked during the inspection of PG&E's operability determination, PG&E provided the following calculation:

• Long Term Seismic Program Update Shoreline Fault Zone Studies: Hypothetical Comparison of Damped In-Structure Response Spectra at the Top Surface of the Containment Basemat for the Design Basis Double Design and Hosgri Earthquakes with Postulated Earthquakes on the Shoreline, San Luis Bay, Los Osos, and Linked Hosgri-San Simeon Faults" [PROPRIETARY], Revision 1, dated 09/25/2014 (Reference 14)

NRC Staff Evaluation

As stated in the Diablo Canyon NPP Updated Final Safety Analysis Report Revision 21 , Section 2.5.3.9 (Design and Licensing Basis Earthquakes), the Design Earthquake (DE), Double Design Earthquake (DOE), and the Hosgri Evaluation (HE) are design bases earthquakes and the Long-Term Seismic Program is a licensing bases earthquake. Consequently, any new information that is being compared to the Diablo Canyon NPP design basis (e.g., Allen, 2012 (Reference 15)) should make appropriate comparisons to both the DOE and HE. Both the DOE and HE should be considered because each of these design-basis earthquakes use different methods and assumptions in the design and qualification of seismic Category 1 structures, systems and components (SSCs). The most significant differences are in the amount of damping assumed for the engineering analyses (Table 1). As a result of these different assumptions, the DOE creates maximum loads on some Category 1 SSCs, whereas the HE 7

creates maximum loads on other Category 1 SSCs (e.g., FSARU Section 5.2.1.15 (Reference 16)). Neither ground motion creates the bounding demand for all Category 1 SSCs.

The new ground motions in the 2014 California Coastal Commission report are shown for free-field responses with 5% damping. However, as shown in Table 1, a range of d ifferent damping values were used in the design basis calculations for Diablo Canyon NPP. In addition, PG&E did not specify what amount of damping would need to be used in comparing the 2014 ground motions with the design-basis ground motions.

Table 1. Damping factors used in PG&E analyses.

Percentage Damping Type of SSC DOE HE 2014 Containment structures 5 7 7 Welded structural steel assemblies 1 4 4 Bolted or riveted steel assemblies 2 7 7 Mechanical components 2 4 4 Vital piping systems (except RCL) >12" 0.5 3 3 Vital piping systems (except RCL) <12" 0.5 2 2 Reactor Coolant Loop 1 4 4 Steam Generators 4 4 4 Integrated Head Assembly 6 .85 6.85 6.85 Control Rod Drive Mechanisms 5 5 5 In September 2014, NRC staff discussed this issue of ground-motion comparability with PG&E staff, and outlined the need to compare the new ground motions with the seismic design bases for Diablo Canyon NPP. PG&E agreed to perform additional calculations for the 2014 ground motions, so that the results of these analyses would be directly comparable to the inputs used in the* Diablo Canyon NPP design bases rat her than an alternative metric such as the LTSP.

NRC staff reviewed the additional calculations that were developed by PG&E to allow for direct comparison of potential ground-motions in the 2014 report to the Diablo Canyon NPP seismic design bases. PG&E calculated in-structure acceleration response spectra as the basis for com parison, as these spectra already were available for the DOE and HE from FSARU section 3.7 analyses (Reference 14).

To convert the 2014 ground-motion spectra to in-structure acceleration response spectra, PG&E developed a scaling relationship from the LTSP analyses that compares the calculated free-surface ground motion to an in-structure response spectrum. This scaling relationship accounts for the effects of processes such as soil-structure interaction and the presence of building foundations. PG&E applied this scaling factor to the 2014 ground-motion spectra to calculate in-structure response spectra for 5% damping. To account for the different damping values used to analyze the seismic performance of different SSCs, PG&E used analytical methods in Rezaeian et al. (2012) (Reference 17) to develop scaling factors. PG&E applied these scaling factors to the 5% damped in-structure response spectra for the 2014 ground motions, to develop response spectra for the different damping values shown in Table 1.

Based on these calculations, the NRC staff verified that the in-structure response spectra for the reanalyzed 2014 ground motions (single station) were all lower than the ODE and HE response spectras. As a result, the NRC staff concludes that ground motions from the 2014 report have been compared reasonably with the Diablo Canyon NPP design basis, and that these re-8

analyzed ground motions do not exceed the demands already considered in the design and qualification of seismic Category 1 SSCs.

3.4 An Assessment of the Results of the NRC Staff's Deterministic Evaluat ion Regarding Safety and Operability of OCPP SSCs Based on Ergodic Treatment of Uncertainties

NRC Staff Evaluation

As stated above, PG&E's 2014 CCCSIP report included an evaluation of the ground motion response spectrum compared to the 1977 HE ground motion based on the single-station-sigma approach. While the staff concludes that the single-station-sigma approach has its benefits, the staff nevertheless also developed on its own the ground motion response spectrums for the faults that were analyzed in the 2014 CCCSIP report using the more traditional treatment of uncertainties (i.e., the ergodic approach). The ground motion response curves for the various fault scenarios based on the ergodic approach can be found in Figure 2 of this document.

Ground Motion Response Spectra Below 10 Hz The staff notes that the ergodic curves for the faults analyzed in the 2014 CCCSIP are below those for the 1977 HE ground motion and the long-term seismic program (LTSP) ground motion.

The 1977 HE ground motion and the LTSP ground motion are those for which the plant was evaluated previously and demonstrated to have reasonable assurance of safety. Therefore, the staff concludes that there is not a safety or operability issue for ground motions below 10 Hz.

Ground Motion Response Spectra Greater than 10 Hz PG&E's letter dated October 11 , 2011 , "Evaluation Process for New Seismic Information and Clarifyinq the Diablo Canyon Power Plant Safe Shutdown Earthquake," (Reference 18) includes as part of the application Chapter 6 of the 1988 Long Term Seismic Program Final Report. Although the October 11 , 2011 , license amendment application was withdrawn the NRC staff finds the information that is duplicated from Chapter 6 of the 1988 Long Term Seismic Program instructive because it contains a probabilistic risk assessment to determine the adequacy of seismic margins. The NRC staff assessment of the LTSP including the seismic margins can be found in NUREG-0675 Supp 34, "Safety Evaluation Report Related to Operation of Diablo Canyon, Units 1 & 2 ," (Reference 19).

The 1988 LSTP Chapter 6 Table 6-24 included high confidence of low probability of failure (HCLPF) data for various SSCs. The HCLPF capacity is defined as a 95 percent confidence of less than 5 percent probability of failure. The 1988 LTSP Chapter 6 Tables 6-23 and 6-24 included HLCPF values for structures and systems and component. Tables 6-23 for structures and Table 6-24 for systems and components are repeated at the end of this evaluation for ease of reference.

PG&E October 11 , 2011 , submittal provides a discussion of the changes to the seismic margins since the 1988 LTSP report. This included an evaluation of the seismic margins associated with the integrated head assembly (IHA). The IHAs were installed in Units 1 and 2 during refueling outage nos. 2R15 and 1R16, respectively. The IHAs are classified as new components which could impact the seismic margins of existing safety-related structures, since they are attached to the reactor vessel closure heads and provide support to the control rod drive mechanisms (CRDMs), small bore piping, instrumentation, and cables. PG&E calculated the HCLPF 9

capacity associated with the limiting element of the CRDMS lateral support function of the IHAs.

developed based on the deterministic failure margins method is 2.40 g.

The staff notes that the HCLPF values for SSCs are above the ground motion response spectrum the NRC staff calculated using the ergodic treatment of uncertainties. (Need to assess the 230 kV switchyard). In general the staff also notes that components that are susceptible to failure at higher frequencies (i.e., greater than 20 Hz) have been the subject of recent testing . The preliminary test results indicate that these components ar;e more robust than originally thought. The testing is documented in a report dated September 15, 2014, by the Electric Power Research Institute, titled, "High Frequency Program: High Frequency Testing Summary," (Reference 20).

Based on the HCLPF values for OCPP SSCs and the preliminary results of the EPRI testing, the staff concludes that the exceedances of the ground motion response spectras for the faults analyzed in the 2014 CCCSIP using the ergodic treatment of uncertainties does not cause the staff to believe that there is a safety concern that would require PG&E to deviate from its current course of action to evaluate the faults using the PSHA method described in the March 12, 2012, request for information. In addition, the staff concludes that based on the HCLPF values for OCPP SSCs and the preliminary results of the EPRI testing, the staff does not have a basis to conclude that any SSCs at DCPP are inoperable.

Note: does the high frequency ergodic exceedances need to be addressed in DPO section

4.0 CONCLUSION

The NRC staff reviewed the new seismic information found in PG&E's 2014 CCCSIP report and PG&E's operability determination and concludes that there is not a safety concern that would require PG&E to deviate from its current course of action to evaluate the faults around OCPP using the PSHA method described in the NRC staff's March 12, 2012, request for information.

In addition, the staff reviewed PG&E's operability determination and the NRC staff concludes that there is not a basis for declaring any DCPP SSC inoperable based on the information found in the 2014 CCCSIP report. The staff also evaluated the information in the 2014 CCCSIP report to determine if a change to the recommendations associated with OPO 2013-002, "Diablo Seismic Issues," should be revisited and has determined that a change to recommendation associated with this DPO are not necessary.

5.0 REFERENCES

1. Halpin, Edward D., Pacific Gas and Electric Co., letter to U.S. Nuclear Regulatory Commission, "Central Coastal California Seismic Imaging Project, Shoreline Fault Commitment," dated September 10, 2014, (ADAMS Package Accession No. ML14260A106)

2. Pacific Gas and Electric, Notification 50652361 . "Preliminary new seismic information,"

completed on August 21 . 2014,

3. U.S. Nuclear Regulatory Commission, Inspection Manual Chapter, "Operability Determination and Functionality Assessments for Conditions Adverse to Quality or Safety,"

dated January 31 . 2014, (ADAMS Accession No. ML13274A578) 10

4. U.S. Nuclear Regulatory Commission, "Request for Information Pursuant To Title 10 of The Code Of Federal Regulations 50.54(f) Regarding Recommendations 2.1 ,

2.3, and 9 .3 , of the Near-Term Task Force R_ e view of Insights from the Fukushima Oai-lchi Accident," dated March 12, 2012 (ADAMS Accession No. ML12053A340)

5. Sebrosky, Joseph M., U.S. Nuclear Regulatory Commission, letter to E. Halpin, Pacific Gas and Electric, "Diablo Canyon Power Plant, Unit Nos. 1 And 2 - NRC Review of Shoreline Fault (TAC NOS. ME5306 AND ME5307)," dated October 12, 2012 (ADAMS Accession No. ML120730106)

6. Leeds, Eric J., U.S. Nuclear Regulatory Commission, letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Supplemental Information Related to Request for Information Pursuant to Title 10 of The Code Of Federal Regulations 50.54(f) Regarding Seismic Hazard Reevaluations For Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident,* dated February 20, 2014 (ADAMS Accession No. ML14030A046)

7. California Assembly Bill No. 1632, Chapter 722 (AB 1632, Blakeslee, Energy: planning and forecasting) approved by the Governor September 29, 2006

8. California Energy Commission (CEC), 2008. "An Assessment of California's Nuclear Power Plants: AB 1632 Commission Report," CEC-100-2008-009-CMF, adopted November 20, 2008

9. U.S. Nuclear Regulatory Commission, "Research Information Letter (RI L) 12 Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone," September 2012 (ADAMS Accession No. ML121230035)

10. U.S. Nuclear Regulatory Commission, Case File for Differing Professional Opinion 2013-002, "Diablo Seismic Issues,* September 9, 2014 (ADAMS Accession No. ML14252A743) 11 . Becker, James R. , Pacific Gas and Electric, letter to U.S. Nuclear Regulatory Commission, "Report on the Analysis of the Shoreline Fault Zone, Central Coastal California, "

January 7, 2011 {ADAMS Package Accession No. ML110140431 )

12. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.61 , "Damping Values for Seismic Design of Nuclear Power Plants," October 1973

13. U.S. Nuclear Regulatory Commission, NUREG-0675, "Evaluation Report Related to the Operation of Diablo Canyon Power Plant, Units 1 and 2, " Supplement No. 7 , dated May 1978 (ADAMS Accession No. ML14279A129)

14. Pacific Gas and Electric, "Long Term Seismic Program Update Shoreline Fault Zone Studies: Hypothetical Comparison of Damped In-Structure Response Spectra at the Top Surface of the Containment Basemat for the Design Basis Double Design and Hosgri Earthquakes with Postulated Earthquakes on the Shoreline, San Luis Bay, Los Osos, and Linked Hosgri-San Simeon Faults" [PROPRIETARY], Revision 1, dated 09/25/2014 11

15. Allen, B.S., Pacific Gas and Electric Co., letter to Nuclear Regulatory Commission, uw ithdrawal of License Amendment Request 11-05,* October 2012. (ADAMS Accession No. ML12300A105)

16. Diablo Canyon Power Plant Units 1 & 2 FSAR Update, Revision 21 , September 2013 (ADAMS Accession No. ML13280A390)

17. Rezaeian , S., and others, "Spectral Damping Scaling Factors for Shallow Crustal Earthquakes in Active Tectonic Regions," Pacific Earthquake Engineering Research Center Report 2012/01 , July 2012.

18. Becker, James R., Pacific Gas and Electric, letter to U.S. Nuclear Regulatory Commission, uucense Amendment Request 11-05, "Evaluation Process for New Seismic Information and Clarifyinq the Diablo Canyon Power Plant Safe Shutdown Earthquake," October 11 ,

2014 (ADAMS Accession No. ML11298A247)

19. U.S. Nuclear Regulatory Commission, NUREG-0675 Supp 34, "Safety Evaluation Report Related to Operation of Diablo Canyon, Units 1 & 2," dated June 1991 (ADAMS Package Accession No. ML14279A124)

20. Electric Power Research Institute, "High Frequency Program: High Frequency Testing Summary," September 15, 2014.

12

Table 6-13 DIABLO CANYON STRUCTU1tE FltAGILmES (Based on bazard derlned over J to 8.S hertz range.)

ll'wadament.al Spectral Acceler ation Capacity Structure Freq u~ney Hert& Failure Mode s,

.x (1) _!a_ .!u_ HCLPF (1)

CoDt&mmul BllDdlq 4. 1 Bxsator Sbtll Shur 1. 42 0 .26 0 . 30 3.34 CODc:1ete Internal Stnu:tun 1. 9 l.Dlcnw Stnacture Shur 6.91 0 .20 0 .31 2. 98

[J:ltakt Struc:lln 23.3 Nonb Wall Sbau 1 *.5.5 0 . 21 0.31 3.23 Auxllla,y 8u1ldlna TlubiDe Bulldln& ..,

1.2 9.0 Nonb/South Slleuwalll Sbeat WIll, ColulllJI 31 Block Wall

.5.79 4.17

>10:0 0.21 0 .26 0.26 0 .33 2.66 1.84 ldlltllq Water Storap T~ 7 .6 Coacreta/Bedroc:t Flexure 9.92 0 .29 0.36 3.40 Colldan.satt Stoiap T&nlc Com,adlon 10 RWST >10.0 DO P\MJ-Ol1 Storaae Tut Bwi.d bplW't >10.0 Auxiliuy Sallwalfl Plpina Buried hplme 9.23 0 . JI 0 .21 4.85 13

21 ir Table 6-2A DIABLO CANYON EQUIPMENT FRAGILITIES (8Hed o n haaard d e r l n ed*o-,er :S to I . S herta ran &**>

9 "Cl ij l °'

Spociral I Accelcrellon ca!!clly Pundemcnlel Method of Sel1onlc lnfo nnallon ll( HCLPF Setem end Comeonent LaulllHI Precauenci guallrtcallon l'e llure Mode Source s1u> -1.&. _!u. _w__

f _,..

lllalAI m.6111 lllm.r ,

• • -a.-*-

- . . , lel* tr Yal'rto

- o,.,-* hllol Yolno a.-,c-e........

Qo---- - (111')

c:..... .... c11r>

c:...i-... (141')

c....,_..

• C!o...ia-M c..a,_ _ -_ ,,.,.,

c:......... - (114')

(140') .

(Ur)

IJ..U Ka {IC) 1i.11:111a M

• Ila (K) u ** CK) n,aar.i.1aa l Ila 00 0,-i.Aaai,,1, D,ualc4MIJ*lf o,--,eAM17,lo 0-""Aaal"lt IUtle Aeat,oWTnt fuUoAMt,.ttn...

o,...i,, ,\aatylll Soe,.n P1it AMt k

a..w.,c- ......

o.---*-

v,,.,

i t -1.Mwol 0.*Nle-llM a-., ...1Ml18H ws,,....,,,...

Ws,-rrD11a

~*-ry-ws.....,,Dau

"'"*..... wu, NJ'1, .....

IJSS, MUI, f . 71

10. 14 11.4'

>II. I

,.u

, .n O. JS O. tel o.u O. Jt o.,o O. J7 O. JJ D, 1' o.a, o.o I . JI I . JC

,.u 2.ss J .JS J ,Jt 1.1)

, O!!Mf'!I~~

NIU ...laa c:.......... .

c.......... .

(141')

(14f')

7-11 Kl (JQ

, _, Ka (Jl&Y) o,....ieAulyolo o,-acAaat,,lo .......

lfoad MaplH Tllld s-*rrDII*

w *-*"" Dale

\1 . 71

>10.1

0. 41 0. '4 J . 41

• nrnU61. lll6I 1nttw6&.

an"'-

uu ..............

Malllor, (JI' )

"8dllery (Ito')

n IC& Otl liaU&"-IJ*'"

.... ..... 0........

........... Uno-,

'j_,_...,._

'WS---,Dau, ..,.,,.. 0 . ))

O. JC o.u o.u ,...

) . JS Laloral ....... MUJ, W04 JI--

l6PIJJ 9HIIS10N

, _, . s- ..,,

...... "-!Pl* w1--,0a... o. n a,.., lefoctloa 1'aal

~ - l l ( t l ')

-lory(aJ' )

Amdller,(11' )

U -J4 Ila ( K)

>JJ . . (K)

If-If Ka (II)

...... .,....,.,, Allder lalU

!O"

• • -*110.ta Ws-.r,n...

10, 0I

......... O. IC o.u I . II O. lf J . tl mt.11:QNWJft COOUNg !£6111

.a:w,-

a:w ...............

CX:W ...... Tn,

~t.Mtr.61. 6HD voun.o. c.amm.

AIWllory(U')

~ l.. (IJ'l Aulllory (II>')

...... ,. "*IDc n Ka <Kl U 111 CH)

...... -11,1,.,...

lutle Aaoly,ta hMplfoldO.Wohka h loalcte..... * -

woo,, "'101, WJII woet, MIU, MOS Nllf I .SJ I.JI

,.n 0 . 1t o.i, o.u

o. u o.u o.u J .U Cbr&IAa ,,._ (Olwlto&*ll Clio,...,, ....., (,.c'-90 AaluU.ry (JJ') >l) R& (If) Stlllc ......,,It s,.... .,....,,,, ,,.,,. ...wo-, ,..,.

W.io,Kaldl:N.... hlll ~ . -. .,.,0.11 ws....fYO***

...., O. JI 0. " 4.41 ii Aadlluy(JJ' ) ,,, Ka (lll >11.0 ii l'i If tYU resx WaD¥tDI Aulllllry S* lt-cr " ' -

CQWTAINMnff s..A.Y 1111au (J' -J*) 4J IU (H) SU1lc.Aut,1h ............u....,..

- >IO.O l2 II arv.,..

Sprar Addllloe Taol

.,...11111,,. ,,..,

Aullllly cu')

>JJ Ka 01) 1 4 Kt CH)

Sulk """IJ*lt Italic Aaolrtll ~hd/SMII

~ s--, Dela ws...a ryData '*"

I . Jf O. JO o.n

0. 11 J . IS J . 01 I!.

~

14

a ir Table 6-24 (Contlnutd)

DlABLO CANYON EQUIPMENT FllAGILfflES (Baaed on haaard denned onr 3 LO l,S hens ran1c. ) 1 fl l Spaclral °'

i

i.

n B!!t*m *!!I Coml!!nant Loc9tlon Punda manlal Fre9uan!:I Melhod or SaJ1mlc guaurtcatlon P*ll*re Mode lnrormaUon Sou~

X Acecleratlon Caeacllz:

S.,(t) _!a_ ~

H C LPP

_!IL r

J MWIIl+N WI ...IMINV-Ill .....,, """"

Owt&N* CNlal.l9o..

(lff' )

MIIMwr (HO*)

P'lu. . . . . . ..

r-.

>>,Male AM""'""'

....... -,Y.11/T...

Ael--~

Otaerte . . . . .

MM1, M4U, 114'9 >II.I ID'7 >11,1

... '°"" .......,CHI*) '11.dWo _ . . -,,Oi.tnM O..Off& Pliacdta I0'1 O. JI II. SI O.H I . fl 6&am&6a ....a-.111 A11W ..... ( N - _ ,

,.,. ..... ow...., - . ,

_,,,110*)

-.,.oto*1

, 41 . . (I()

0 111 (ff) lllllc"-""'

.....Kel<I-- IOIIIA w,ac, w:n1

>10,0 f ,11 0 . 1t o.u ) . $1 IHIRJ CilNIIAJPI

,,...,, .....,,,It ...._.,... _,....

IINaM D, 0. l'llel OIi DaJ -

D, 0 , """1 Oil . . _ , , . . . . u.,u...-v'* m*, ,i.-,

~ (IJ' ) Slalle

...,1c AatlJtll K ..., Pllte1Aa~-

u.,

IOU lfJIA, IIUH

>10.0 l ,>J 0 .2' 1. U ,.u

-**-""""m*>

...K'*'*,141_...,_

D, O, _ . Oii lMteff V.,.,. D_ . .,. >10 .0 D. 0 , NI lkall c..a,,._, 'l'otltlot (IJ') >UK& 00 IOU >Ill.I a..- AMhn.... """"'"

D. O, NI &wt._ ...,

_,o..c.-. ~ ( I S' )

~ - ( I J' )

26 IQ Of)

" ... (K)

D,.....-...,.

D,..alcAa.... lt UW.o\adtr-1 M.12' N4U* W*H

>11.0

'*" o.u O.H

,,.u o.u "Ka (K) 1>. 0 . -r/Wo1e,....,. .,.,.... ( II' ) .,...... Aa...... AMW*o11la1

'*" O. Jf D, 0 , I - lllo...,//Jr flhor T-'IM (IH') P1cai.1........ DJuMkAaatrtlt Pillu S - ' 1 lid Wt 14 M111 , ...., >U. O D, O , IIIIClia11MO.Wool .,.,.... (U' > U*OI) T"'I a...,., ..,..,'°'* , . 40 o.u

• JJ 1 , ST D, 0 , C......hMI ......... (U' )

• Ka (II) 'he\ llllO, W)U, W.14, 1. 14 o.o. lftla i..,, ,..,....,,... 1'1nlM (lf' I 10 Na (H)

Till Clallc A..i,, 1, S1nte1e,.1 A l l * - ** Plllol .,... ..,..

W'll

>10.0

0. :141 o.u 1. 24 s : a ~ 1111Qllta v.Nf'IL4Dllf o.* ..i-., ... C:.olar c-,....... (1~* ) ,, Kt (II) Oyu..tc.\a11),ol, FMI Plalt,._4, Wtl4 W>t,, MO,, M420, 1 . 10 O. JI o.n 1.n 1111421 , .....

fl .,...,,_

ttlN'1"aftL laalil VlnfflLlflntt

,,.,, ,.n ,.n

... f

~ ~

Uako/C...,.,..oon c:..,,..

At:.

caw-11 AllldllorJ (IH'-41")

MWlltrJ (IS4'-4"')

Aallllr7 (II>

>U Ka (K)

.,, lb (N) 21 Ka (K) llolla AH1Jtl4 s-nklllq Mdle< ....

s,-,.,.1 MOU IOU, WU 1 MOS .....

t . 7'

>II. I 0 , 14 11I tl

• m ~°'aW191VDn'W:atm:

hffOl0&61ClfJIADll:la annw ltZKlll~mlli

-~fflll uf 1Jp,1-0tf D1a,.n AIMllluy (16> ' )

Aoldl-, ( 1'J' )

>U IC& (H}

>U Its (Kl S111k Alll"lo 11-Aalllytlo .............

~ -. IOII II. II

>10. 0 o.n D, JO

'3

°'

....I

'° 15

a l Table '-24 (<An1i,11,ttl)

~

I DIABLO CANYON EQUIPMENT FRAGILITIES

! (BH ed on haaanl defined over l lo I . S herts J'anl**> l..

I... Spectr*I Accelera&Jon Cap*chy f l'llnd*m*n&al Melhod or S.l1mlc lnronnallon J: HCLPF ii BJ!l*m and Co!!!l!onenl Location Presuencz g 1talll1ca lion Pellure Made Source ..u, _!a. _!u_ _!IL I

,c tl41Y MJ'Hl V ICTIPC r9ICII

_ . ... (llt') 71Ca 00 TtM 0.11u MN,, MJU, IOU, J.U o.u *.u I II

__,...., ,.u o.i. _ ,,.....

.. aau. w,n-, ...

Slalk:Allol,olo 0. )1 1.U

_ ... _ , _.. c-,, ~cu**> u Ka (II) ....,. MJU, M41f, 0 . )1 ) ,H

• * - iui-,,.1o w.w ""'*

10. 11

................. (aNO A K)

......... (IH' )

Jf Ila or)

II Ma (IC)

...... All.,,..

St-AIIIIJ*

N Mt, MnJ, wue

-..If, >11,f Nll2. NJl J, .......

111100 II.Tl ,.,. O. H >.n Ill~ K nacng ~

la&..- Allaa., (1U' ) >U . . (11) TNI WHO, MOf4, IIIN4

.... ..,o ....

,.n J .1'

~ ( I U' ) >II II& (M) S1u1o Allol,.. ~11a, IIAU, .<<tU, Ml.le,

..... ... II . ti 0 . 11 J . 40 u *I II RI (N) T*** ...J*. .,,... ...,,, , .u ,.u ****

~~ Auillaty (I J , t)

• -*o,tal'UbthNII Aull..., (I U") 7 Ila 00 Ton .__ ....1

..u . WIJI, WU4 0. )1 0. 11 J .H llllltlJJC.ll~MWWll

• -- Aullla,JIIIS' I

- - ~ ( I I S' )

>20 Na (H)

' Ila (II)

Stodc Allol,_

Tnt

• • - loallA MIU, WOii. IOSS, ICUJ, W4Jf, MU I,

>II.I

,.n e . JI ,.u J.H tlll! N'n'il\ ~l:TltlC ~

a.u 4UIY141WTn-rt INallf CIMN&a a-, C.e lm)

Aealllory (Ito*)

Aulllely (110' )

J Ito (H)

UH&OO All.,,.

Aecht Sllld WtW 1an. w -...

1,(111, ..,* * >10,t O. H

1. IO Allll*'r(lfO' ) 1' ... (H) ltl&lc "'""" IOU, w,u l ,U o.n J , Jl Ae-.Yhl*rhal CPKJIQI IOON

r. ' .,_ea....,,....

rfi'"

Aullar (UO') >U Ha (ll)

TMI Wk-l'JD*...

>11.t

,, ,.n ff*l - *-1 Aua., (100') >JJ Ha (H) 11>),-le AMlr,11 lladc_,,olo 11.ntet*rwl

, ~ "'- lf4H.M41l IU11, wu,, IOU, M4n,W4U 1 .40 1 .11 O. JI o.u 0.)0 0.11 O.J .S 0 . 14 1 , tl

,.n

, .n

.,,. AulllAIY lele. . . . . a.lMt Au-,.(IU' ) , _., lb 00 1'to4 s,..- MJ11, MU4, NUt >10.t It I!00 0

16

a ,-2" (Contlruud)

I...e Table DIABLO CANYON EQUIPMENT FRAGILITIES (Bued on ba1ard derlned o"er 3 to 1 .5 herta ranae. )

9 i..

I Spaclral °'

!I! Acceleretlon Cae*c:lly I Setc,a and Comeonant L!c:atJon Fundamen..l PM9uencz McUlod of Sclamlc

!c*llrlcaUon Pallure Mode lnformaUon Soul"Ce lea> II

_& u c LPF

__lJL_

i **-~ _.,.._,

pgp CDfffl)L

..,_o._, ..............,...*

s.u.ia.... ,.._....,,,,_

.-..-,.cur)

Aualu7 cur) 1-10 lb 00 1*11 tta 00 Te11 Tnt ,,,. ....

s,.........i IOll. lOJS IOIT, IOH "*"

U .f>

'*" o.,..

O. J, o.u o.u o.u ,...

J .H 4 .n

.U-,(1tr) a"- Ot) IO i ,* IOJt T"' l1NC&wat

,,.....aA*T-talt""

Ao-.,. (140')

0 . o - (IIT') >JJ 1k (If)

TUl T* .... .....

l1rec,.,.1 ID4f 1'041

>II.I

,, 0.1' o.a. t : 11 MIIQlll6taa:11* ~

~*l&a,--

AiiiWliilY llili' lidl

....... o...a-*.._.,,.

ValNU-.1.......

i.,...u.u c..tot-11,,.,..v..._,

AUIHUt (IU')

A uilleo7 (II r)

Aulllol7 (Vo -)

C.otolaae.. (YorlMr) c......... 11,1*)

lt-21111 (If) 11 Ha (1()

,,, 1k (ff)

>JI Ila (MAV)

S-10 Ila (NAY)

>JJ Ka (ll&V) llidi Ailr,oli T'°'

Teet NaN AiltW l ilU O...rlo'-ctJ..

_.,.,Altlld.-

W4U IUll 1044 Dela-IUJI

""'* wu,

>It. I

>11. e

'*" l ,U O. H 1.U

>11.0 mu.n1111m ftalffW"

- 0.--.. . -- ..,,

ott.Sho ,.._, UO&V Yard 0c. ., . . . .,.... D111 a..e I .J4 O. H o.u

--y- , 0...rtc_,.,

J*&V ' I .U O. b o.--..ou*> 14 Na (JC) IGS4 I . JI o.u a.u 90t'1.......... . . _

lfN., l t llof, * ......_, &

vai-

,*v.-

a..ct v-PlulWo~

~

0,-.lc Aaotftlll DJ* - lo A..l),tlo o...rtr .._ .

o...,.. _ ....

WtH. 1011 11.0,

>H.t 0,40 o.,, J ,00 AJ1,. . - .. o,....

CMla Tro11 u4 . . _ . . vv.....

Pie,,_ T,.,.

OW*-k ANl,tlo St&lk AMI,._ 0n...... _ .

WOl1, llttl

,00,*WJI)

11. 10

>10,0

,.,. ,.u

,.u 0. 60 lfVM:-1. . . . . . . _ . . Pl*dM* Dllc,lal lmle ANI,... a....... ..,_. MJU- MJII o. ** J ***

,~

!-t IF

... 'I ti o.;

°'I Of 17

25 1 PG&E Single Station Sigma Approach 2 1 I

l .S ~I Hosgri LosOsos B

IV Ill - San Luis Bay 1 1 - Shoreline

-Shoreline-Hosgri Linked

- Design 0.5 o I 0.1 1 10 100 Frequency (Hz)

Figure 1 - Deterministic Response Spectrum Single Station Approach 2.5 NRC Developed Ergodic Approach 2

- Hosgri l .S

- LosOsos BIV Ill - San Luis Bay 1 - shoreline

-Shoreline-Hosgri Linked I

- Design o.s 0.1 1 10 100 Frequency (Hz)

Figure 2 - Deterministic Response Spectrum NRC Developed Ergodic Approach 18

From: Oesterle, Eric Sent: Wednesday, October 22, 2014 3:55 PM To: Wilson, George Cc: Alexander, Ryan; Walker, Wayne; Sebrosky, Joseph; Markley, Michael Subje ct: Path forward for Diablo operability assessment

George, As you know, members of NRO/DSEA and NRR/DE met this afternoon to discuss a proposed path forward. Everyone agreed that there is no immediate safety concern and that whatever approach we take only needs to be able to provide reasonable assurance until the NRC completes its review of the 50.54(f) response following the March 2015 submittal. The 50.54(f) response will still be the information that NRC ultimately hangs its hat on with respect to additional actions, if necessary, because it is expected to provide more accurate information.

The proposal from Nilesh Chokshi was to allow staff to consider all available and recognized methodologies for assessing response and not be limited to either single station correction (SSC) or Ergodic. This would also allow the staff to take into account knowledge gained from assessments of CEUS plants and develop a sort of averaged approach between SSC and Ergodic. The seismologists are on board with this approach and in fact had even considered at one point previously. This approach would result in curves that would tend to fall more to the right of the PG&E developed SSC curves and more to the left of the NRC back*-calculated Ergodic curves. The resultant curves would be compared against Hosgri and also LTSP, if needed, and would factor in some quailitative discussions about fragility and capacity that were included in SSER 34. Everyone was in agreement with Nilesh's approach. Kamal was OK with it if the results still showed that the new curves were at or below Hosgri.

It was agreed that we need to get Region IV on board with this approach before we brief it to Jennifer. I am providing this email to Ryan Alexander and Wayne Walker as well.

Er-io'R. 0e.¢er~

NRC Project Manager Diablo Canyon Power Plant Cooper Nuclear St ation NRR/ D0Rl/ LPL4-1 301-415-10 14

From: Oesterte. Ede To: Scott Michael Cc: Pedec;en, Renee: W,tson, George: Markley. Michael: Broaddus. Doug

Subject:

RE: New AskManagement Submission Date: Monday, November 10, 2014 8:20:05 AM Attachments: Mio;-comm Piao on ocrr PPQ Oaa1.docx Mike, We prepared a mini Comm-plan associated with the EDO Decision on the Appeal of the DPO (see attached) and the release of the DPO Case file for public availability. Perhaps the attached will address the question. like Mike Marl<ley indicated, there is no indication that we will be responding directly to the 9/19 article.

Eric R. Oesterle NRC Project Manager Diablo Canyon Power Plant Cooper Nudear Station NRR/DORL/LPL4-1 301-415-1014

---

Original Message-----

From: Markley, Michael Sent: Monday, November 10, 2014 8:10 AM To: Scott, Michael; Broaddus, Doug Cc: Oesterle, Eric; Pedersen, Renee; Wilson, George

Subject:

RE: New AskManagement Submission

Mike, We had all kinds of stuff going at the time of the DPO Director's Decision and EDO Appeal. The DCPP PM, Eric Oesterle can provide you with the information subject to our communications plan, but OE owns the DPO process. Rene Pedersen would be the right person to discuss the DPO. I do not believe there is a Sharepoint link.

There were a lot of articles. Some making assertions about how the DPO was handled and timing. We have referred some to the OIG. In DCPP space, September 19 is a long time ago. We are responding to about 10 DCPP Congressional/concerned citizen items right now. I will have the PM, Eric Oesterle take a look, but my guess Is we are not responding explicitly to the September 19 article.

Mike

---

Original Message-----

From: Scott, Michael Sent: Friday, November 07, 2014 5:42 PM To: Markley, Michael; Broaddus, Doug

Subject:

FW: New AskManagement Submission Gentlemen:

Can whichever of you has cognizance of Diablo Canyon please help me out? Can you please ask the PM to send me a link to a Sharepoint site or wherever else that we have compiled information on the Diablo Canyon seismic DPO and the Agency's review and response to it? The below question was submitted

anonymously by someone on the Region I staff. I would like to answer it with a simple link to wherever the info can be found, if such a link exists.

Thanks in advance for your help.

Michael (Mike) Scott Deputy Director Division of Reactor Projects Region I (6,10) 337-5126

---

Original Message-----

From: rlaskmanagement@nrc.gov [majlto:rlaskmanagement@nrc.goy]

Sent: Friday, October 31, 2014 7:29 AM To: RlASKMANAGEMENT RESOURCE

Subject:

New AskManagement Submission On September 19, The Santa Barbara Independent ran an article, which was also put on the Rl website, about the former Diablo Canyon SRI who had a concern about how Diablo canyon's new seismic information was handled and did not feel that is DPO about this concern was adequately addressed. Does the NRC plan to do anything additional to address his concern in light of the recent article? If so, please inform us of the resolution to this when it is concluded.

e1-F1e1,ct ttSE ONLY S!NS1Trt1E INTEl'tNtct INfiOl'tMtcTION - NOT FOl't Pt:JBL10 RELEASE Communications Plan -

Oiablo Canyon Power Plant Topics of Interest Differing Professional Opinion and Appeal

Background

The former SRI at the Diablo Canyon Power Plant (DCPP) submitted non-concurrence papers (NCPs) in January 2011 and January 2012, followed by a Differing Professional Opinion (DPO) in July 2013 detailing a disagreement with the NRC about how new seismic information should be compared to the plant's current seismic license requirements. DPO 201 3-02 restated the issues presented in NCP 2012-01 and added a concern that a license amendment was needed incorporate the Shoreline fault into Diablo Canyon's FSAR as described in the RIL 12-01 cover letter. The added concern was that the NRC did not review or take action on the Los Osos and San Luis Bay faults. In accordance with Management Directive 10.159, a DPO Ad Hoc Review Panel was established to review the DPO submittal, meet with DPO submitter, and issues a DPO report including conclusions and recommendations regarding disposition of the issues presented in the DPO. The panel completed its report in May 2014 and a decision on the DPO was rendered in letter dated May 29, 2014, to the DPO submitter. The DPO submitter appealed the decision to the EDO in accordance with the NRCs DPO process. The EDO completed his consideration of the DPO appeal on September 9, 2014, concluding that he was in agreement with the original decision.

The purpose of this communication plan is to provide key messages associated with the EDO's decision on the DPO appeal and public release of the DPO Case File.

Key Messages:

1. NRC strives to establish and maintain an environment that encourages all NRC employees and contractors to raise concerns and differing views promptly without fear of reprisal through various mechanisms. The free and open exchange of views or ideas conducted in a non-threatening environment provides the ideal forum where concerns and alternative views can be considered and addressed in an efficient and timely manner that improves decision making and supports the agency's safety and security mission.

2. The NRC appreciates members of the staff bring issues like this to its attention

3. The NRC encourages the use of non-concurrences and the Differing Professional Opinion (DPO) process

4. The NRC reviews all non-concurrences and DPOs thoroughly and in accordance with agency guidance (MD 10.158, MD 10.159) and believes that this is a healthy and necessary part the regulatory process

5. The NRC believes that, in the end, all of our regulatory decisions are better because of this process

Ol'PICIAL t:JS! ONLY SENSl'flVE IN'fE"NAL INP6"MATl6N - Ne'f f'O" filt::J8LIC "ELEASE

6. The NRC does not tolerate retaliation against employees who engage in our processes for raising differing views (i.e., Open Door Policy, NCP, and DPO Program).

7. Persons serving on the DPO Panels are independent of the issues raised in the DPO

8. Upon disposition of the DPO via a Director's decision, the DPO submitter has appeal rights to the EDO

9. While the DPO is under review or appeal, NRC is prohibited from engaging in discussions with external stakeholders regarding the specifics of the of the DPO submittal

10. After the EDO's decision on the appeal, the DPO submitter can request that the DPO Case File be made public. Management performs a review consistent with agency policies to support discretionary release. Regarding the DPO for Diablo Canyon, the NRC has been and will continue to be as open and scrutable as possible while protecting the privacy rights of the individual 11 . The NRC does not know the source of the public release of the Diablo Canyon DPO submittal prior to the EDO rendering a decision on the appeal

12. The NRC can, however, comment on a few aspects of the DPO appeal review o A Director's Decision has been made and the DPO appeal to the EDO has been finalized o The EDO and the DPO submitter have both agreed that the issues raised in the DPO do not present an immediate safety concern for Diablo Canyon o The NRC has sought permission from the DPO submitter to allow tihe DPO case file to be made publicly available and the DPO submitter has agreed o We would expect the public release of the DPO case file to be within a few days of the EDO's appeal decision

13. Regarding the operational status of Diablo Canyon Power Plant, Units 1 and 2 o The plant remains within its approved design and licensing basis o There are no current operability concerns resulting from the DPO o The recent earthquake in the Napa Valley did not reach Diablo Canyon - it was neither felt nor detected Communication Team The primary responsibility of the communication team is to ensure that it conveys a consistent, accurate, and timely message to all stakeholders. The team consists of the project management, technical, and communication staff named below.

Team Member Position Organization Telephone Troy Pruett Division Director (Acting) RIV/ DRP 817-200-1291 Wayne Walker Branch Chief R-IV/DRP/RPB-A 817-200-1148 Ryan Alexander Sr. Project Engineer R-IV/DRP/RPB-A 817-200-1195

erf 1e1At tJ9E 6NLY 9EN91Tlt/E INTERNAL INFORM>'<TION - NeT reR litJ8tle RELEASE Sr. Resident !Inspector -

Thomas Hipschman R-IV/DRP/RPB-A 805-595-2354 DCPP Resident Inspector -

John Reynoso R-IV/DRP/RPB-A 805-595-2354 DCPP Thomas Farnholtz Branch Chief RIV/DRS/EB1 817-200-1243 Jon Ake Senior Seismologist RES/DE/SGS EB 301 -251 -7695 Eric Oesterle Acting Branch Chief NRR/DORULPLIV 301-415-1014 Balwant Singal DCPP Project Manager NRR/DORULPLIV 301-415-3016 Renee Pedersen DPOPM OE/CRB 301-415-2742 Scott Burnell Public Affairs Officer OPA 301-415-8204 Angel Moreno Congressional Affairs OCA 301-415-1691 Amy Powell Associate Director OCA 301-415-1673 Victor Dricks Public Affairs. Officer RIV 817-200-1128 Lara Uselding Public Affairs Officer RIV 817-200-1519 Bill Maier State Liaison Officer RIV 817-200-1267 Non-concurrence and DPO Questions

[NOTE - this information is generally NON-PUBLIC, but is provided as background only]

NOTE: General FAQs on the DPO Program are included on the DPO Web site (look under Employee Resources-Employee Concerns.

1. Was the former DCPP SRI reassigned because he filed two non-concurrences?

No. Michael Peck was not reassigned. He applied for an instructor position in his area of expertise at the NRC's technical training center in Chattanooga, TN, at about t he time he submitted his non-concurrence in accordance with the Non-Concurrence Process described in MD 10.158. He was competitively selected for this sought-after position, and reported to his new assignment in September 2012. Resident inspector assignments are limited to 7 years to ensure objectivity. It is common for resident inspectors to apply for their next job when a desirable position comes open.

2. When were the non-concurrences filed?

Two non-concurrences were filed by the DCPP SRI.

11/ 7/11. The DCPP SRI submitted NCP 2011-103, on inspection report 05000275; 323/201104.

OP'PICIAL t:f !! ONLY SENSITIVE INTERNAL INFORMATION - NOT FOR PtlBL16 RE,LEASE 1/26/12. The DCPP SRI submitted NCP 2012-01 , on inspection report 05000275; 323/201105.

3. What were the non-concurrences?

Both non-concurrences involve the same subject; regulatory actions in response to the discovery of the Shoreline Fault.

NCP 2011-103 was filed by the DCPP SRI on the basis that no violation was issued (as he had submitted in the draft report) related to operability evaluation of the Shoreline fault in Report 2011-04. NCP 2011-103 was dispositioned finalizing the violation in IR 2011-05 issued on 2/14/12. (The employee requested that the NCP be non-public.)

NCP 2012-01 was filed by the DCPP SRI because the SRI believed the violation in NRC IR 2011-05 should be for an inadequate operability evaluation of the Shoreline Fault rather than not doing an operability evaluation until June 2012. The SRI believed the facility should be shutdown or the license amended to reflect the Shoreline fault. NCP 2012-01 was discussed with NRC stakeholders representing NRR/DE, NRR/DORL, RIV, and RES. NCP 2012-01 was dispositioned as a multi-office staff position which concluded that a violation for having no operability evaluation from January 2011 to June 2011 existed because the licensee completed the RIS 2005-020 immediate (interim) operability evaluation in June 2011 . Additionally, the off1ices involved in NCP 2012-01 acknowledged that a final operability evaluation could not be completed by the licensee until the NRC decided what requirements and methods should be applied to new seismic information. At the time of Inspection Report 2011-05 issuance it was expected that the requirements and methods would be addressed in a License Amendment Request that was under consideration. However, by 3Q/2012, enough progress had been made on RIL 2012-01 for NRR and RES to conclude that the LTSP method of analysis used in the immediate operability assessment was sufficient to evaluate the Shoreline fault and that the Shoreline Fault should be considered a lesser included case of the Hosgri event. (The employee supported public release of the NCP ADAMS ML 121 A 173.)

4. When was the OPO filed?

July 18, 2013. The former DCPP SRI filed Differing Professional Opinion (DPO) 2013-02 associated with the regulatory response following the discovery of the Shoreline Fault.

NRC employees are encouraged to file a DPO if they believe an agency decision is in error. The DPO process is in keeping with the agency's open and collaborative working environment.

5. What is the DPO?

DPO 2013-02 restated the issues presented in NCP 2012-01 and added a concern that a license amendment was needed incorporate the shoreline fault into Diablo Canyon's FSAR as

6f'fle1AL tJSE 6NLY

!!NSITl't! INTEftNAL INf6ftMATl6N - N6T 1'0~ fltJ8LIC ftE.L!A!E described in the RIL 12-01 cover letter. The added concern was that the NRG did not review or take action on the Los Osos and San Luis Bay faults.

6. What is the status of the DPO?

A decision on the DPO was issued by the Office Director for NRR on May 29, 2014 consistent with the NRC's process included in MD 10.159. The DPO submitter appealed this decision to the EDO on June 23, 2014, and the appeal was thoroughly evaluated by the EDO and decision on the appeal was rendered on September 9, 2014.

As part of the agency's open and collaborative work environment, the NRC has established the DPO program as a means for employees to have their concerns reviewed by high level managers. The DPO Program is a formal process that allows all employees and contractors to have their differing views on established, mission-related issues considered by the highest level managers in their organizations, i.e., Office Directors and Regional Administrators. The process also provides managers with an independent, three-person review of the issue (one person chosen by the employee). After a decision is issued to an employee, he or she may appeal the decision to the Executive Director for Operations (or the Chairman for those offices reporting to the Commission).

7. Will the decision regarding the DPO be made public?

The NRC supports openness and will include a summary of the disposition of the DPO in the Commission's Weekly Information Report included on the NRC Web site (see Commission Documents under the Document Collections in the NRC Library). The DPO submitter has been contacted regarding the EDO's decision on the DPO appeal and has communicated support for the public release of the DPO Case File (with appropriate redactions). The DPO Case File should be publicly available within a few days of the EDO's DPO appeal decision.

8. Was the SRI wrongfully reassigned after filing two non-concurrences and a DPO?

No . As noted in Q&A #1 above, the SRI applied for and was selected to a highly sought instructor position at the NRC's Technical Training Center. The NRC does not tolerate retaliation for engaging in the NCP or the DPO Program and both MDs reiterate this policy and direct employees to resources in the event they believe that they have been retaliated against.

9. Would the DPO panel's conclusions or the DPO appeal decision change based on the new seismic information found in the State of California report?

PG&E, the licensee for Diablo Canyon, is providing a report to the State of California that includes the results of its most recent evaluation of the seismic hazards for the Diablo Canyon facility. The NRC understands that the report will be provided to the State of California on September 10, 2014, and that a copy will be provided to the NRC as well. Prior to performing a detailed review of this report, the NRC is not able to ascertain whether the new seismic

OP'fllelAL t:JS! ONLY SENSITl'IE IN'fERNAL INFORMA'flON - NOT reR Pt:JBUe RELEASE information contained in the report would change the DPO panel's conclusions or the DPO appeal decision. The NRC understands that PG&E plans to incorporate the findings from this report into their ongoing probabilistic seismic hazards analysis required by the NRC Post-Fukushima task force recommendations that are due in March 2015. The NRC believes this more rigorous analysis will provide the most accurate assessment of faults affecting the DCPP.

In addition, the NRC staff's review of the new seismic information in the report notes that PG&E's evaluation concludes that the ground motions resulting from the faults discussed in the report (i.e., Shoreline, Hosgri, San Simeon, Los Osos, and San Luis Bay) continue to be bounded by the Hosgri analysis that was used during licensing of the plant.

NRC Resident Inspectors and Region IV staff looked at the licensee's corrective action process assessment of new preliminary information concerning DCPP seismic and licensing bases. The licensee's information indicates reasonable assurance of public health and safety after a seismic event.

The NRC staff will review the new information provided in the report in accordance with the NRC's inspection process. The NRC wm take additional regulatory action as appropriate if the new information associated with the Faults around DCPP cause NRC to question PG&E's conclusions.

From: Qesterte. Ede To: Luoo!d. nmothy: Ross-Lee MarvJane: Manoly Kamai:~ Karas. Rebecca: Kock. Andrea Cc: Sebrosky. Joseph: Alexaoder. Ryan: walker. Wayne: Markley. Michael: Wilson. George

Subject:

FW: Info: latest version of Oiablo Canyon TER Note: This is the same D*a te: Tuesday, October 21, 2014 12:16:40 PM attachment that is attached to Attachments: Plablo Canyon ooerablHty evaluation 2011 sejsinJC Information techocfal evatuatjon.docx

maoe001.ono document C/26 in FOIA/PA-Importance

High 2015-0071 (ML15181A428).

To all, Attached is the draft report which was discussed in the 11AM briefing today. It provides a proposed path forward for addressing the various issues associated with the OCPP operability evaluation. It is a rough draft but it should help with the actions identified in the briefing.

Evio'R. Oeftu~

NRC Project Manager Diablo Canyon Power Plant Cooper Nuclear Station NRR/D0RL/LPL4-1 301-415-1014 From: Sebrosky, Joseph Sent: Tuesday, October 21, 2014 8 :10 AM To: Wilson, George; Oesterle, Eric; Marl<ley, Michael

Subject:

info: latest version of Dlablo canyon TER To all, Attached is the latest version of the Diablo Canyon TER. It incorporates comments from Eric and has other minor editorial changes from previous versions. Per direction from George I have stopped work on the effort pending the outcome of the meeting later today.

Thanks, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph sebrosky@nrc gov

301-415-1132 From: Sebrosky, Joseph To: Wilson, George: Oesterle, Enc Markley Michael

Subject:

Info: latest version of Dlablo canyon TER Date: Tuesday, October 21, 2014 8:10:23 AM Attachments: Diablo canyon ooerablhtv evaluation 2011 seismic information technaa1eva1uation,docx To all, Attached is the latest version of the Diablo Canyon TER. It incorporates comments from Eric and has other minor editorial changes from previous versions. Per direction from George I have stopped work on the effort pending the outcome of the meeting later today.

Thanks, Joe Sebrosky Senior Project Manager Japan Lessons-Learned Division Office of Nuclear Reactor Regulation joseph.sebrosky@nrc.gov 301-415-1132

TECHNICAL EVALUATION REPORT BY THE OFFICES OF NEW REACTORS, RESEARCH, AND NUCLEAR REACTOR REGULATION CENTRAL COASTAL CALIFORNIA SEISMIC IMAGING PROJECT PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNITS 1 AND 2 October 21 , 2014, 8:00 am version

1.0 INTRODUCTION

1.1 Purpose This evaluation provides the results of the U.S. Nuclear Regulatory Commission (NRC) staff's assessment of the new seismic hazards information developed by Pacific Gas and Electric Company (PG&E, the licensee) for the Diablo Canyon Power Plant, Units 1 and 2 (DCPP) and provided to the NRC in PG&E letter dated September 10, 2014, "Central Coastal California Seismic Imaging Project, Shoreline Fault Commitment"(Reference 1). The staffs from the NRC's Office of New Reactors (NRO}, Office of Research (RES}, Region IV, and Office of Nuclear Reactor Regulation (NRR) evaluated the information provided in the licensee's September 10, 2014, letter. In addition, this evaluation provides the results of the NRC's review of PG&E's operability determination found in PG&E Notification 50652361 , "Preliminary new seismic information," completed on August 21 , 2014, (Reference 2) against NRC guidance found in NRC Inspection Manual Chapter (IMC) 0326, "Operability Determination and Functionality Assessments for Conditions Adverse to Quality or Safety," dated January 31 , 2014 (Reference 3) to determine what affect, if any, the new seismic information has on the capability of :seismically qualified systems, structures, and components (SSCs) to perform their specified safety functions.

1.2 Background Pursuant to Title 1O of the Code of Federal Regulations, Part 50 (1 O CFR), Section 50.54(f), and by letter dated March 12, 2012, (Reference 4) the NRC requested information concerning, in part, the seismic and flooding hazards at operating reactor sites to enable the NRC staff to determine whether operating licenses should be modified, suspended, or revoked. The "Required Response" section of Enclosure 1 to the letter indicated that licensees should provide a Seismic Hazard Evaluation and Screening report within 3 years for western United States (WUS) plants. The process outlined in the March 12. 2012, request for information related to seismic hazards was also discussed in NRC letters dated October 12, 2012, (Reference 5) and February 20, 2014 (Reference 6). The October 12, 2012, letter, specifically discusses NRC's review of the Shoreline fault near DCPP. and places the NRC's review of the Shoreline fault into context with the process for developing and assessing seismic information found in the March 12, 2012, request for information. The October 12, 2012, letter states in part:

The NRC staff understands that the seismic evaluations described in the March 12, 2012, request for information are currently in progress at DCPP, and PG&E plans to acquire new offshore and onshore two-and three-dimensional seismic reflection data to identify and characterize faults in the vicinity ,of DCPP.

If during the collection of the data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, the staff expects that the licensee will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic 1

hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information.

California Assembly Bill (CAB) 1632 (Blakeslee, Chapter 722, Statutes of 2006) (Reference 7) directed the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, including Diablo Canyon Power Plant, to a major disruption caused by a seismic event or plant aging ; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio.

Based on the California Assembly Bill, the California Energy Commission compiled a report in 2008 (Reference 8) that included the recommendation that PG&E perform additional seismic studies to supplement the original and ongoing seismic studies performed as part of the licensee's Long Term Seismic Program (LTSP), and that those studies be conducted using advanced technologies such as three-dimensional (30 ) seismic-reflection mapping. During 2011 through 2014, the licensee conducted the recommended studies and further data analysis, and compiled the report entitled, "Central Coastal California Seismic Imaging Project" (CCCSIP) and provided this report to the NRC via letter dated September 10, 2014. Following internal completion of the CCCSIP Report. the licensee performed an operability determination documented in Notification 50652361 completed on August 21 , 2014 (Reference 2) based on the report and its data.

PG&E's September 10, 2014, letter transmitting the report provides an interim evaluation consistent with the guidance found in the NRC's October 12, 2012, letter. PG&E's letter states in part:

The additional offshore seismic studies revealed that the Shoreline fault is longer by extending farther south than in the Shoreline fault report, and therefore, more capable as described in the enclosure. PG&E concluded that the ground motions from updated shoreline fault and other regional faults remain less than the 1977 Hosgri design ground motions, for which the plant was evaluated and demonstrated to have reasonable assurance of safety. This interim evaluation is consistent with the conclusions of the Research Information Letter 12-01 ,

"Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone: dated September 2012 [Reference 9).

PG&E's September 10, 2014, states that the CCCSIP will support the NRG-mandated seismic hazard risk assessment for the DCPP that is being performed in accordance with the March 12, 2012, request for information (Reference 4). PG&E will use the Senior Seismic Hazard Analysis Committee (SSHAC) process to incorporate and evaluate existing and new seismic information to update the seismic hazard for DCPP.

The DCPP seismic hazard based on the SSHAC process is due to the NRC in March 2015.

The staff's previous assessment of the Shoreline Fault found in RIL 12-01 was based on a deterministic approach. As described in RIL 12-01 the conservative determin1istic (scenario-based) viewpoint was intended to allow the NRC staff to determine if a safety concern exists as a result of the identification of the Shorelline fault. By their nature, deterministic approaches do not explicitly account for the likelihood of a particular earthquake scenario occurring, or the rate at which earthquakes can occur on known seismic sources. Therefore, deterministic results 2

cannot be used for a quantitative assessment of the overall risk to the plant from the Shoreline fault. Instead, deterministic approaches fo~us only on the safety margin that exists for a specific earthquake scenario, in this case for the* Shoreline fault.

The response to the March 12, 2012, request for information is based on a a probabilistic seismic hazard assessment (PSHA) approach. As described above PG&E is scheduled to provide a detailed PSHA by March 2015. The results of the PSHA will strengthen the understanding of the relative importance of the Shoreline fault and other faults evaluated in the CCCSIP to the seismic hazard at this site.

2.0 REGULATORY ANALYSIS

Because the detailed PSHA is due shortly to the NRC (i.e., March 2015), the NRC staff's evaluation is limited to reviewing PG&E's deterministic evaluation that is provided in the CCCSIP. The NRC staff's evaluation takes advantage of insights gained from the development of RIL 12-01 , but does not update the RIL. Instead, the staff's evaluation relies on the new information found in PG&E's September 10, 2014, submittal and PG&E's operability determination regarding the following fault scenarios:

• Hosgri and San Simeon faults (the step-over between the Hosgri and San Simeon is small enough that the two faults are assumed to rupture together with an assumed magnitude of 7.3)

• Los Osos fault (assumed magnitude of 6.7)

• San Luis Bay fault (assumed magnitude 6.4)

• Shoreline fault (assumed magnitude of 6.7)

• Hosgri, San Simeon and Shoreline linked fault sensitivity study(assumed magnitude 7.3)

The purpose of the NRC staff's evaluation is to determine if a safety concern or operability concern exists as a result of the new information provided in PG&E's September 10, 2014 CCCSIP report. A more thorough review of the seismic faults around DCPP will be completed by the staff in the future based on PG&E's PSHA to be provided by March of 2015.

In performing its evaluation the NRC staff also reviewed how a recent Differing Professional Opinion (DPO) was resolved. The resolution of the DP0-2013-002 , "Diablo Canyon Seismic Issues" is documented in a case file (Reference 10) that includes the following information:

• DPO Submittal

• Memo from NRR Office Director Establishing the DPO panel

• DPO Panel Report

• DPO Decision

• DPO Appeal Submittal

• NRR Office Director's Statement of Views

• DPO Submitter's Appeal Presentation to OEDO

• DPO Appeal Decision 3

3.0 EVALUATION 3.1 Method of Review The NRC staffs review is broken into three parts:

• The NRC's deterministic evaluation of the faults described in the 2014 CCCSIP report

• An update to the DPO assessment based on the information in the 2014 CCCSIP

• An assessment of the results of the NRC staffs deterministic evaluation regarding safety and operability of DCPP SSCs based on ergodic treatmen of uncertainties.

3.2 NRC Staffs Deterministic Evaluation of the Faults Described in the 2014 CCCSIP Report Summary of PG&E Information Chapter 13 of the CCCSIP, "Hazard Sensitivity and Impact Evaluation," provides a discussion of the differences between the deterministic evaluation provided in PG&E's 2011 Shoreline Fault Zone Report (Reference 11 ) and the 2014 CCCSIP studies. RIL 12-01 is based in large part on PG&E's 2011 Shoreline Fault Zone Report. CCCSIP Chapter 13 Table 1-1 , which compares the source characterization for the deterministic ground motion evaluation, is rreproduced below.

2011 Shoreline* Report Updated Parameters Fault ,--

Mag.

- - *-~ -

Maximum Mnimum Maximum Mnimum Mag.*

Length Dip (90th Length Dip (km) (degrees) fractile) (km) (degrees)

Shoreline 23 90 6.5 45 90 6.7 Hosgri 110 80 7.1 171 75 7.3 Los Osos 36 45 6.8 36 55 6.7 San Luis 16 50 6.3 16 50 6.4 Bay PG&E describes in CCCSIP Chapter 13 that the Shoreline fault was found to extend an additional 22 km to the south thereby increasing the fault length from 23 km used in the 2011 Shoreline Fault Zone Report to 45 km. With this increased length the magnitude of the Shoreline fault increased from 6.5 to 6.7 .

For the Hosgri fault, PG&E describes in the CCCSIP Chapter 13 that the length of the combined Hosgri and San Simeon faults, 171 km, was defined using the Hosgri fault length from the U.S. Geological Survey (Petersen et al., 2008, Table 1-3) which treated the San Simeon and Hosgri faults as a single fault called the Hosgri fault. This increased length leads to a magnitude of 7.3.

PG&E describes in CCCSIP Chapter 13 that studies for the Los Osos fault found that the minimum dip consistent with the newly collected data is 55 degrees, as compared to 4

a minimum dip of 45 degrees used in the 2011 Shoreline Fault Zone Report. The steeper dip leads to a smaller fault area, and the magnitude is reduced from 6 .8 to 6 .7 .

The CCCSIP studies did not provide new information for the San Luis Bay fault length or dip. Using the length and dip from the 2011 Shoreline Fault Zone Report leads to a magnitude of 6.4. The increase from the 2011 magnitude of 6.3 results from using the bounding length and dip rather than the full logic tree to define the rupture area.

PG&E also describes in CCCSIP Chapter 13 that for the Shoreline fault rupture developed in the 2011 Shoreline Fault Zone Report the Shoreline fault was assumed to intersect with the Hosgri fault, but a linked rupture involving the full Shoreline fault and the full Hosgri fault was not included because the geometry of the two faults was unfavorable to allow such a rupture. PG&E states that the new information collected on the geometry of the Shoreline and Hosgri faults shows that within a resolution of a few hundred meters, the two faults intersect. This new information indicates that the fault may rupture together, but it does not change the unfavorable geometries for a linked rupture. Nevertheless, PG&E performed a sensitivity analysis assuming that the full Shoreline fault rupture is linked to a rupture of the Hosgri fault, extending north to the end of the San Simeon fault.

PG&E's CCCSIP Chapter 13 assesses the new information described above iusing a new ground-motion prediction equation (GMPE) as part of the Pacific Earthquake Engineering Research (PEER) Center's Next Generation Attenuation (NGA) West2 project. These GMPEs are different that the NGA West GMPEs used in the 2011 Shoreline Fault Zone Report (Note:

need something from NRO regarding assessment of new GMPEs)

Figure 1 of this evaluation provides a plot of the deterministic response spectrum using the source characteristics of various faults and the NGA West2 GMPEs for the power block (Note:

need to confirm if these NRC generated plots are for the power block or the turbine foundations)

PG&E concludes in the CCCSIP report and reiterates in the September 10, 2014, cover letter transmitting the report that the ground motions from the updated shoreline fault and other regional faults remain less than the 1977 Hosgri Design ground motions for which the plant was evaluated and demonstrated to have reasonable assurance of safety.

NRC Evaluation Diablo Canyon Licensing Basis In 1968, when the DCPP Unit 1 Construction Permit was issued to Pacific Gas and Electric (PG&E), the seismic evaluation had been completed under the Atomic Energy Commission's requirements. Based on the information available at the time, the design earthquake (DE) was defined as having a peak ground acceleration of 0.2 g, and the double design earthquake (DDE) was a doubling of the DE earthquake to ensure safety-related structures, systems, and components would function as expected after the earthquake, 0.4 g. In 1973, PG&E became aware of the Hosgri fault. PG&E evaluated the Hosgri fault using Regulatory Guide 1.61 ,

"Damping Values for Seismic Design of Nuclear Power Plants," October 1973 (Reference 12).

Though not included in the construction application, NRC reviewed PG&E's evaluation of the Hosgri fault and required PG&E to make plant modifications to be able to withstand the 0. 75 g 5

pe*ak ground acceleration associated with the Hosgri fault. The operating license for Unit 1, issued in 1984, was based on review of the Final Safety Analysis Report Update which included two different seismic methodologies, the DOE and the Hosgri evaluation, as documented in NUREG-0675, "Evaluation Report Related to the Operation of Diablo Canyon Power Plant, Units 1 and 2, "Supplement No. 7, dated May 1978 (Reference 13).

Deterministic Response Spectrum and Use of Single Station Sigma Correction In the 2011 Shoreline Fault Report PG&E addressed uncertainty in the GMPE using a ergodic approach (an approach that accounts for both epistemic (model uncertainty) and the aleatory (natural) variability). The 2011 Shoreline Fault Report documented an effort to separate the uncertainty into its component parts, including the uncertainty that comes from the seismic source, the path through which the waves travel in the crust, and the site response. If high-quality data from a modern seismographic network are available, some of the uncertainty for a specific location can be reduced. The single-station-sigma adjustment has the potential to remove uncertainty in the application of the GMPEs by determining a station term from a set of earthquakes recorded at the site.

The NRC staff noted in RIL 12-01 Section 5.9 that:

The single-station-sigma adjustment represents advancement in the field of engineering seismology and could be a useful approach in the assessment of seismic hazard at NPPs that install a modern seismographic system. such as that at DCPP. The single-station-sigma correction applied by PG&E was developed based on data from two earthquakes. Generally a larger number of earthquakes would be needed to develop confidence in the correction factor.

This correction was applied by PG&E but was not required for the confirmatory analysis that the NRC conducted as documented in RIL 12-01. The curves found in CCCSIP Chapter 13 found in Figure 1 of this evaluation are based on a single station correction and do not reflect ergodic uncertainty. As a result of questions raised during the inspection of PG&E's operability determination PG&E provided the following information relative to its use of the single-station-sigma correction on September 25, 2014:

• Processed Earthquake Recordings for Onsite Monitor ESTA 27 - 2003 Deer Canyon Earthquake

• Processed Earthquake Recordings for Onsite Monitor ESTA 27 - 2003 San Simeon Earthquake

• Processed Earthquake Recordings for Onsite Monitor ESTA 27 - 2004 Parkfield Earthquake

• Processed Earthquake Recordings for Onsite Monitor ESTA 28 - 2004 Parkfield Earthquake

• Shear Wave (VS30) Profiles for Power Block - Onsite Monitor ESTA 27

• Shear Wave (VS30) Profiles for Turbine Building - Onsite Monitor ESTA 27 6

• Shear Wave (VS30) Profiles for Power Block - Onsite Monitor ESTA 28

• Shear Wave (VS30) Profiles for Turbine Building - Onsite Monitor ESTA 28 Using the information provided by PG&E, the NRC staff developed the ergodic curves found in Figure 2 of this document.

The NRC staff concludes that PG&E's characteristics of the faults based on the new information revealed from the 20 and 30 analysis performed in accordance with CAB 1632 is reasonable.

The NRC staff also concludes that the use of the NGA West2 GMPE is appropriate for the evaluations performed by PG&E. (Note need more of a basis for this being OK). Therefore, the NRC staff concludes that the DCPP ground motions from the faults evaluated in the CCCSIP 2014 report (i.e., Hosgri-San Simeon, Shoreline, Los Osos, San Luis Bay, and Hosgri-Shoreline linked) using the single-station-sigma treatment of uncertainty are at or below those for the 1977 Hosgri earthquake (HE) ground motion and the long-term seismic program (LTSP) ground motion. The 1977 HE ground motion and the LTSP ground motion are those for which the plant was evaluated previously and demonstrated to have reasonable assurance of safety.

However, the NRC staff notes that based on the NRC staff developed ergodic curves found in Figure 2, below that there are exceedance in the 10 Hz to 100 Hz range for the ground motions from the earthquakes evaluated in the CCCSIP 2014 report. The evaluation of the exceedances in this range can be found in Section 3.4 of this document.

3.3 Update of Differing Profession Opinion Assessment Based on the Information in the 2014 CCCSIP Report Summary of PG&E Information As a result of questions asked during the inspection of PG&E's operability determination, PG&E provided the following calculation:

• Long Term Seismic Program Update Shoreline Fault Zone Studies: Hypothetical Comparison of Damped In-Structure Response Spectra at the Top Surface of the Containment Basemat for the Design Basis Double Design and Hosgri Earthquakes with Postulated Earthquakes on the Shoreline, San Luis Bay, Los Osos, and Linked Hosgri-San Simeon Faults" [PROPRIETARY], Revision 1, dated 09/25/2014 (Reference 14)

NRC Staff Evaluation

As stated in the Diablo Canyon NPP Updated Final Safety Analysis Report Revision 21 , Section 2.5 .3.9 (Design and Licensing Basis Earthquakes}, the Design Earthquake (DE). Double Design Earthquake (DOE), and the Hosgri Evaluation (HE) are design bases earthquakes and the Long-Term Seismic Program is a licensing bases earthquake. Consequently, any new information that is being compared to the Diablo Canyon NPP design basis (e .g ., Allen , 2012 (Reference 15)) should make appropriate comparisons to both the ODE and HE. Both the ODE and HE should be considered because each of these design-basis earthquakes use different methods and assumptions in the design and qualification of seismic Category 1 structures, systems and components (SSCs). The most significant differences are in the amount of damping assumed for the engineering analyses (Table 1). As a result of these different as.sumptions, the ODE creates maximum loads on some Category 1 SSCs, whereas the HE 7

creates maximum loads on other Category 1 SSCs (e.g., FSARU Section 5.2.1.15 (Reference 16)). Neither ground motion creates the bounding demand for all Category 1 SSCs.

The new ground motions in the 2014 California Coastal Commission report are shown for free-fielld responses with 5% damping. However, as shown in Table 1, a range of different damping values were used in the design basis calculations for Diablo Canyon NPP. In addition, PG&E did not specify what amount of damping would need to be used in comparing the 2014 ground motions with the design-basis ground motions.

Table 1. Damping factors used in PG&E analyses.

Percentage Damping Type of SSC ODE HE 2014 Containment structures 5 7 7 Welded structural steel assemblies 1 4 4 Bolted or riveted steel assemblies 2 7 7 Mechanical components 2 4 4 Vital piping systems (except RCL) >12" 0.5 3 3 Vital piping systems (except RCL) <12" 0.5 2 2 Reactor Coolant Loop 1 4 4 Steam Generators 4 4 4 Integrated Head Assembly 6.85 6.85 6.85 Control Rod Drive Mechanisms 5 5 5 In September 2014, NRG staff discussed this issue of ground-motion comparability with PG&E staff, and outlined the need to compare the new ground motions with the seismic design bases for Diablo Canyon NPP. PG&E agreed to perform additional calculations for the 2014 ground motions, so that the results of these analyses would be directly comparable to the inputs used in the Diablo Canyon NPP design bases rather than an alternative metric such as the LTSP.

NRG staff reviewed the additional calculations that were developed by PG&E to allow for direct comparison of potential ground-motions in the 2014 report to the Diablo Canyon NPP seismic design bases. PG&E calculated in-structure acceleration response spectra as the basis for comparison, as these spectra already were available for the DOE and HE from FSARU section 3.7 analyses (Reference 14).

To convert the 2014 ground-motion spectra to in-structure acceleration response spectra, PG&E developed a scaling relationship from the LTSP analyses that compares the calculated free-surface ground motion to an in-structure response spectrum. This scaling relationship accounts for the effects of processes such as soil-structure interaction and the presence of building foundations. PG&E applied this scaling factor to the 2014 ground-motion spectra to calculate in-structure response spectra for 5% damping. To account for the different damping values used to analyze the seismic performance of different SSCs, PG&E used analytical methods in Rezaeian et al. (2012) (Reference 17) to develop scaling factors. PG&E applied these scaling factors to the 5% damped in-structure response spectra for the 2014 ground motions, to develop response spectra for the different damping values shown in Table 1.

Based on these calculations, the NRG staff verified that the in-structure response spectra for the reanalyzed 2014 ground motions (single station) were all lower than the ODE and HE response spectras. As a result, the NRG staff concludes that ground motions from the 2014 report have been compared reasonably with the Diablo Canyon NPP design basis, and that these re-8

analyzed ground motions do not exceed the demands already considered in the design and qualification of seismic Category 1 SSCs.

3.4 An Assessment of the Results of the NRC Staff's Deterministic Evaluation Regarding Safety and Operability of DCPP SSCs Based on Ergodic Treatment of Uncertainties

NRC Staff Evaluation

As stated above, PG&E's 2014 CCCSIP report included an evaluation of the ground motion response spectrum compared to the 1977 HE ground motion based on the single-station-sigma approach. While the staff concludes that the single-station-sigma approach has its benefits, the staff nevertheless also developed on its own the ground motion response spectrums for the faults that were analyzed in the 2014 CCCSIP report using the more traditional treatment of uncertainties (i.e., the ergodic approach) . The ground motion response curves for the various fault scenarios based on the ergodic approach can be found in Figure 2 of this document.

Ground Motion Response Spectra Below 10 Hz The staff notes that the ergodic curves for the faults analyzed in the 2014 CCCSIP are below those for the 1977 HE ground motion and the long-term seismic program (LTSP) ground motion.

The 1977 HE ground motion and the LTSP ground motion are those for which the plant was evaluated previously and demonstrated to have reasonable assurance of safety. Therefore, the staff concludes that there is not a safety or operability issue for ground motions below 10 Hz.

Ground Motion Response Spectra Greater than 1O Hz PG&E's letter dated October 11 , 2011 , "Evaluation Process for New Seismic !Information and Clarifyinq the Diablo Canyon Power Plant Safe Shutdown Earthquake," (Reference 18) includes as part of the application Chapter 6 of the 1988 Long Term Seismic Program Final Report. Although the October 11, 201 1, license amendment application was withdrawn the NRC staff finds the information that is duplicated from Chapter 6 of the 1988 Long Term Seismic Program instructive because it contains a probabilistic risk assessment to determine the adequacy of seismic margins. The NRC staff assessment of the LTSP including the seismic margins can be found in NUREG-0675 Supp 34, "Safety Evaluation Report Related to Operation of Diablo Canyon, Units 1 & 2 ," (Reference 19).

The 1988 LSTP Chapter 6 Table 6-24 included high confidence of low probability of failure (HCLPF) data for various SSCs. The HCLPF capacity is defined as a 95 percent confidence of less than 5 percent probability of failure. The 1988 LTSP Chapter 6 Tables 6-23 and 6-24 included HLCPF values for structures and systems and component. Tables 6-23 for structures and Table 6-24 for systems and components are repeated at the end of this evaluation for ease of reference.

PG&E October 11 , 2011 , submittal provides a discussion of the changes to the seismic margins since the 1988 LTSP report. This included an evaluation of the seismic margins associated with the integrated head assembly (!HA). The IHAs were installed in Units 1 and 2 during refueling outage nos. 2R15 and 1R16, respectively. The IHAs are classified as new components which could impact the seismic margins of existing safety-related structures, since they are attached to the reactor vessel closure heads and provide support to the control rod drive mechanisms (CRDMs), small bore piping, instrumentation. and cables. PG&E calculated the HCLPF 9

capacity associated with the limiting element of the CRDMS lateral support function of the IHAs, developed based on the deterministic failure margins method is 2.40 g.

The staff notes that the HCLPF values for SSCs are above the ground motion response spectrum the NRC staff calculated using the ergodic treatment of uncertainties. (Need to assess the 230 kV switchyard). In general the staff also notes that components that are susceptible to failure at higher frequencies (i.e., greater than 20 Hz) have been the subject of recent testing . The preliminary test results indicate that these components are more robust than originally thought. The testing is documented in a report dated September 15, 2014, by the Electric Power Research Institute, titled, "High Frequency Program: High Frequency Testing Summary," (Reference 20).

Ba1sed on the HCLPF values for DCPP SSCs and the preliminary results of the EPRI testing, the staff concludes that the exceedances of the ground motion response spectras for the faults analyzed in the 2014 CCCSIP using the ergodic treatment of uncertainties does not cause the staff to believe that there is a safety concern that would require PG&E to deviate from its current course of action to evaluate the faults using the PSHA method described in the March 12, 2012, request for information. In addition, the staff concludes that based on the HCLPF values for DCPP SSCs and the preliminary results of the EPRI testing, the staff does not have a basis to conclude that any SSCs at DCPP are inoperable.

Note: does the high frequency ergodic exceedances need to be addressed in DPO section

4.0 CONCLUSION

The NRC staff reviewed the new seismic information found in PG&E's 2014 CCCSIP report and PG&E's operability determination and concludes that there is not a safety concern that would require PG&E to deviate from its current course of action to evaluate the faults around DCPP using the PSHA method described in the NRC staff's March 12, 2012, request for information.

In addition, the staff reviewed PG&E's operability determination and the NRC staff concludes that there is not a basis for declaring any DCPP SSC inoperable based on the information found in the 2014 CCCSIP report. The staff also evaluated the information in the 2014 CCCSIP report to determine if a change to the recommendations associated with DPO 2013-002, "Diablo Seismic Issues," should be revisited and has determined that a change to recommendation associated with this DPO are not necessary.

5.0 REFERENCES

1. Halpin, Edward D., Pacific Gas and Electric Co., letter to U.S. Nuclear Regulatory Commission, "Central Coastal California Seismic Imaging Project, Shoreline Fault Commitment/ dated September 10, 2014, (ADAMS Package Accession No. ML14260A106)

2. Pacific Gas and Electric, Notification 50652361 , "Preliminary new seismic information,"

completed on August 21 , 2014,

3. U.S. Nuclear Regulatory Commission, Inspection Manual Chapter, "Operability Determination and Functionality Assessments for Conditions Adverse to Quality or Safety,"

dated January 31 , 2014, (ADAMS Accession No. ML13274A578) 10

4. U.S. Nuclear Regulatory Commission, "Request for Information Pursuant To Title 10 of The Code Of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2 .3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," dated March 12, 2012 (ADAMS Accession No. ML12053A340)

5. Sebrosky, Joseph M., U.S. Nuclear Regulatory Commission, letter to E. Halpin, Pacific Gas and Electric, "Diablo Canyon Power Plant, Unit Nos. 1 And 2 - NRC Review of Shoreline Fault (TAC NOS. ME5306 AND ME5307)," dated October 12, 2012 (ADAMS Accession No. ML120730106)

6. Leeds, Eric J., U.S. Nuclear Regulatory Commission, letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Supplemental Information Related to Request for Information Pursuant to Title 1O of The Code Of Federal Regulations 50.54(f) Regarding Seismic Hazard Reevaluations For Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident,* dated February 20, 2014 (ADAMS Accession No. ML14030A046}

7. California Assembly Bill No. 1632, Chapter 722 (AB 1632, Blakeslee, Energy: planning and forecasting} approved by the Governor September 29, 2006

8. California Energy Commission (CEC), 2008. "An Assessment of California's Nuclear Power Plants: AB 1632 Commission Report," CEC-100-2008-009-CMF, adopted November 20, 2008

9. U.S. Nuclear Regulatory Commission, "Research Information Letter (RIL} 12 Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone," September 2012 (ADAMS Accession No. ML121230035)

10. U.S. Nuclear Regulatory Commission, Case File for Differing Professional Opinion 2013-002, "Diablo Seismic Issues,* September 9, 2014 (ADAMS Accession No. ML14252A743) 11 . Becker, James R. , Pacific Gas and Electric, letter to U.S. Nuclear Regulatory Commission, "Report on the Analysis of the Shoreline Fault Zone, Central Coastal California,"

January 7 , 2011 (ADAMS Package Accession No. ML110140431 }

12. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.61 , "Damping Values for Seismic Design of Nuclear Power Plants," October 1973

13. U.S. Nuclear Regulatory Commission, NUREG-0675, "Evaluation Report Related to the Operation of Diablo Canyon Power Plant, Units 1 and 2, " Supplement No. 7, dated May 1978 (ADAMS Accession No. ML14279A129)

14. Pacific Gas and Electric, "Long Term Seismic Program Update Shoreline Fault Zone Studies: Hypothetical Comparison of Damped In-Structure Response Spectra at the Top Surface of the Containment Basemat for the Design Basis Double Design and Hosgri Earthquakes with Postulated Earthquakes on the Shoreline, San Luis Bay, Los Osos, and Linked Hosgri-San Simeon Faults" [PROPRIETARY], Revision 1, dated 09/25/2014 11

15. Allen, B.S., Pacific Gas and Electric Co., letter to Nuclear Regulatory Commission, "Withdrawal of License Amendment Request 11-05," October 2012. (ADAMS Accession No. ML12300A105)

16. Diablo Canyon Power Plant Units 1 & 2 FSAR Update, Revision 21 , September 2013 (ADAMS Accession No. ML13280A390)

17. Rezaeian , S., and others, "Spectral Damping Scaling Factors for Shallow Crustal Earthquakes in Active Tectonic Regions," Pacific Earthquake Engineering Research Center Report 201 2/01 , July 2012.

18. Becker, James R. , Pacific Gas and Electric, letter to U.S. Nuclear Regulatory Commission, "License Amendment Request 11-05, "Evaluation Process for New Seismic Information and Clarifyinq the Diablo Canyon Power Plant Safe Shutdown Earthquake," October 11 ,

2014 (ADAMS Accession No. ML11298A247)

19. U.S. Nuclear Regulatory Commission, NUREG-0675 Supp 34, "Safety Evaluation Report Related to Operation of Diablo Canyon, Units 1 & 2," dated June 1991 (ADAMS Package Accession No. ML14279A124)

20. Electric Power Research Institute, "High Frequency Program: High Frequency Testing Summary," September 15, 2014.

12

Table 6-23 DIABLO CANYON STRUCTURE FRAGILmES (Based on hazard derined over 3 to 8.S her tz range.)

ll'undu nentai Spectral Acceleration Capacity Prequ~ncy Structure Herta Failure Mode

~

s, (1) _!a_ .!JL HCLPF (1)

Co~t&l.AmftltBlllJdln, 4. 1 Eztedor Shell Sbeu 1.42 0 .26 0 .30 3.3' Co111:ie1e lnlernal Structure 1. 9 1ateruJ SINctwe SbUI 6.91 0 .20 0 .31 2.98 l#l&ke StNdme 23.3 North Wall Sheu 8.55 o.:u 0. 31 3.23 Awdlla,y BulJdln& 8.2 North/Sooth Shearwalll 5.1' 0.21 0 .26 2,66 Turbine Bulldln& 1. 6 Shear Wall, Colwlm 31 4 .17 0 .26 0 .33 1.84 9 .0 Bloclt Will >10:0 llduelln& Water Storap T~ 7.6 Concrete/Beclrotl: Flexure 9.92 0 .29 0 . 36 3. 40 CoDde111aia SIOrap Tant Comp&rt.on 10 RWSJ' >10.0 DO P'uel-Ol1 Stonp Tut Boned P.u;tun > 10.0 AUJdliaty Saltwater Plplna Buried Rvpem. , .2, 0. 11 0 .21 4. 85 13

a.. Table 6-24 K 9 if

• DIABLO CANYON EQUIPMENT FRAGILITIES (BaHd on haurd derlned *oyer J to 1.5 hens ranaa.) ..

'a Ii l °'

Speccral Acceleration Capacity n

,: Fundamental Method of Sel1mlc larormaUon lt'. (&) j! j! H CLPF Sz:atem and Comeonanl Logllon Fra!!uenc~ guallrtcallon Failure Mode Source ..L _!1. ~ -11.L I 1111a 1:61 maw sunt_x auc.., ......... v....1 c....,-..

• c:.-,_ .. - (117') 12-U II& (10 o,,_i. AMIJ*II ,.,,... Pla-r WS-11'0.la , .11

.... O. lJ O. JJ J. H (lit') l'-20 Na M OraN,lc AMl,*11 i:..on,c:-,._ w s-.,. Dlola 10. u o... o.u J .H

---

11

• lcua0..aral41ft

_,11111,v.i.11

• - O.Oroi.* .. v,1- u.,

Clo_..__

c._,_

c:..ao.i..... * (Ur)

(I. .' ) .

eo...,_ .. - (Ur) fNaOO u

II& (H)

D,_Aaalr,11 D,-lc Aaal,.11 SU1teAaoi,11oftfl&

au, .. Aut,,,Wl'ul U,,.r !Monl ,.,...,

k l - ............

o...............

o...,i.-,...

~-,YO.la ws-1,yi.ia ann, ..... wu, inn, NIOI

>11,t

,.u 1.H t . JI o.,o O, H o.u 2.u

) , JJ 2.n

0. 0 7 Ha (K) i:..on, .....,, ..14 , .n a.n ,.n

• -

• c..toal , - _ C.1MllaalM * (I I t*)

o,..--,,...

~Aaalylll 1101, 1.11

, Ooe1n11b4 D.....

NIU ""81 c.,eoi-... (llt'l c....,..... . (140')

'*2' Ka 00

, _, Ila (Jl&Y) 0,MmlcMllytll .......

..... .w..,.. Tkl4 :1,-..,,0o..

Wl****'l' Dela 11.11

>IG .I o.u 0. )4 1111111161. II&&[ 1DfflV61, an ... _

UilHN lbc.......

Aadllery ( fl')

M&lllerr (IIO')

12 IC& (M)

DraoalcAMl,111

..... Aaa!Jo&.

~,...!'De**-*

Lalllal ........

~s-,,,.o.ia W s-..... 0.11, w**2....,,

1,H O. )J o.u o.u o.n

,.u J . 41 IMIJY PYISIJPN IIAccu-....

II....,.

a.-1e1-1.. , ..,

mwii2~ a'lOLINg Jt.Am CO.Illa-** (JI ")

AD.llle,y(I.S' )

_ ...., (lJ')

U

• J4 Ha (ff)

. , , ... (lf) u-u Ka (ff)

• • • • le ,....,,,.

l111k Aulytl, ,---*-

Aacws.-

AadiM lolll w,....,,o.....

!U" ws-r,oau, w.._.,,.o...

'°*"

10.u o.n 0 . )4 o.n o.u

4. U ccw,-

ccwa-a.c-.*n Alwllary (1J' ) Ploall>la ,.,i.c °"'... ,_.,....

.........i,.11 -.11ewo_...,.. ),1004, woo,, Wlll

,_,. oo.u

1. U o.n Cl.JI ). ,.

ccw""'" ,.., ~(I.J')

Aa&Ular, (16>')

U K .1 (N) u lu(M) Cutle AMl,11*

1-......... , . ........

S.lta k 1.111..1 a,-

'WOOi, IOU, MOJ

I IJlf O. H o.u '*"

atblH:61. Alm YOWUE Ci21fDS21, C..relfif h-,, (ouu ttapl) Atwlllry (lJ' ) >lJ K& (H) S11UcAulyill Metor Neid O.""' llelt, ~s......, 0,11 11.1, Q. JI o. " 1. 41 Cllorp,1 .,..,,, (rocl-1) ....Ula,y(lJ') >J) Ka (11) S111k "-'J*I* ........ Kal4D-*lobl WSttaaary Dtll >11. 0 I~ aua 1a1i SA.l.l'Wam i i' Aulllery S,11.,.llr .....,, hmp w...11101 Bolu 11 lnMll* (J'*J") U Ill.CH) Smlc: Aut,,h M009 >lt.O CIJ:NTMNMWNI" ffRA.Y

.. j Ii csr.-

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Aullllry en*>

AalU.,,, ('rJ' I

>JJ 1k 011 U HR CK)

SlllkAMl,111 s,.... Aaalralil

-...11Nh111 S--n Pad/Sl,ell 3i:,._..., 1><o11 W S****fY Data '*"

1.11

0. 2' O. )O o.zo

0. 11 J. U J .OJ I!...

14

a i Table 6-24 (ContlnMtd) p n

r DlABLO CANYON EQUIPMENT FRACILfflES (Baaed on heunl derlned over J IO 1,5 herts ran1e, ) 1..

Ica. SpeClnl "'

f Acceleratlon Ca~clll

~ Pu11deman1et Method or Sel1mlc lntormellon X HCLPI' n Sp&em and component Loc1Uo11 l'nquency 9uattnc:a&1on Failure Mode SoUffe S.(I} _!&_ _!st __JJ}_

• )fl NAR<<Ul6N Ad. . .,,.,,...

11111,1.u..v....., Onlff~** PlldW. Plplaa DJM*lc AMl)'l1o/TVI ""'1, W4U, W4't >IO.e llllatoiy-(111')

_ . . , (140') ....... ,i,.., l),...

.,,..... Aal111o/T1ot o-tlel'IIMdea WJt7 ,u.,

Oeeenc Pucuo* o.u la totlV'I AudlMy (141') Plc&Ale ....... lo ~ l c m H NJU II. fl O. H 611XD 16U ...nwau1

,,,. , . _ (W- -*>

,,,_ . _ (Tllf.,. . Dttoea)

.-...,,0111*1

/llldluy(l" ' J

.. . . . (1()

Olla (H)

Sllllo Aaat,.lc Sllllo Aut,olc ......

...., K*lo o.wa a.tt, IOIOA WJ20, NUI

>11. 0 f . 71 o.u 0 .ll DfBIJI QINPU91

"'°' ..._,iP_ u...._.v,91t cn*J ,,............

,-,.IM (U')

SIIIII Aaai,olc ...._............ lfJIJ >10.D OIi Z., -

D, O. ,_I OIi " . . (V)

, .u D.O.

Ila....,_, v, ..

,u,** ~ ..... 11ll4. MJH o ....... '*" O.Jf

-*a.. . . .

D. O . ...IOIIA-IV..... (71') PIMIWt LIit >10 .0 D. O. N, lcan C l a - r l\NW.0 (U') . , , Ka (Jf) o,..11o AacMn.. ,....,..,

Kold DoWa . .1\6 IIIJJJ >10.0 D. O. AJr - bulw, T'IIIIM (U ' ) UK&(K) 0 , -... Aeai,.11 .... o......... WJH >11.0

,.,...... (&f' ) uw AK-, a.Ill If Ill& (K) 11141)-IIUI

'*" O. H O.H o.o. * - * , _ ..., .....

D. O . INU l lllaut/Alr FIiter

........ (U * )

'hlllloe (IM ' )

IT Ka (K) 0,....,.. ,....,.

l)paoak D,aa*lc AalllJolo

"'"'"" AMliaf .......

Pil111 ,,..,_" lad Wchl IOU Mlfl. M40 '*"

>10 .0 O. Jt

0. 14 o.u

o. o . ..o1u,1oa Oololotl o.o. C...,.l hecl Tnlal (U ' )

~ a o (U' )

II Ila (HI

& Ka 00 Teo Tl" Ttat IINClotol C..ltcr S1rvc1*,.I Nt4', IIH*

WJO, WH4, WC'4, f .40

• .u O. Jt o.u 0 . )0 o.u J.n l .U D. O. w* Le*f Tcral..llJoa ,_.... (If' ) 10 Na (II) Mallo II M IJI I, Allochtato1- P1lle1 W.W >11.0 ggNT.-,M9'N'I' IIIIQIJ!IQ VftlnL6JJQa.

C.aLaleacot Paa Coolo, C..t.iaa*ao (UO' ) ,, ,... (ft) l)yM,olc Mol,olc PMI No111. - o. WclU lb (K)

. , , lb (H)

...... Aatl,ol, lllllk Ao..,.t, ....

S-nlolll..

~

MOU MUI , WJI I '*"

>II . II O.JJ o.u ,.n J t" Ota1191C.Wecll M&IJllty (I '7') II Ha (If) Tt tl St NC1unl wus >11. 0 11 *m D1Icasa*1a111NWNTDtRS:

~--""'*

rwm:HOl4111HP6Mffl IMH YD"D#eDOH

~I s..,1,"-......

_ _.,.,. aa.i lhl-011 Daapcn

-llluy ( l 6J' )

Aoolllll* l'f (Iii' )

>U It& (K)

>JJ ltt (11)

Sled<: AH!ytlc

. . . ... Aalllyolc Sl_.onl 11110 lolJII 11.u o.u O. JO J .U il

>10. 0

°'

..a I

,a 15

a l Table '-2A (Ccn1l11iud) e1 i

fl DIABLO CANYON EQUIPMENT FRAGJLfflES (B***d on hasard dennad ovar J to I.S hens ranee.) ..

'2

...I C1\

Spectral Accelen, tlon C.paclly I

L Fundameaul McllMld or Sel1mlc Information X (I) p ~ H CLP*'

" Setem and Coml!oftent Location Prc~uencz guallllc* llon P*llura Mod* Source ~ --!:.B.. _$.IL

-I fl4CIY MJ'N) fllCD!C rav1 lwl1d11-

,_....,,-,-*roC-P)

........ ,11,*)

....... , 11,*1

' Na (II)

JI Ha (N)

Tu,

• • -~

I I - Aaol,alo

~*~**-*

c:..,...

w.w M04t. MUS. MJU.

MJTJ. 1un-no.

M049, MJ 11 , MUC,

.o 10.u

o. u

0. 11 0 . )1 o.u I .U I . JI J,U J . fl IUJI

~O&N> -.......o,r> UKa(lf) lt_Aa..,.. .._"".,_* wao. ""'* w,i,, >11.e

""..... , ...., II Na (II) Stauc.u, i,.-

WcN AM.lte,W.lb wu, Nln.M,n, 110,. 10.11 o.u O. H J .n 1123£ m: m.amas: ~

_...,,,11,*1

,........,,. (IU")

>JJ . . 00

>U IC& (N)

S11dc Aa*lll"M

~

MISI, MIJ4, IIN4 MOU, IIIU, 110,., ****

11.,1 O.JO O. JI I . II

,.n

.... ,2.,..**

..... ,,a..... Aua111otJ (IIS' ) II Ha OI) Tt11 MOJ4, WJt4, M*Sl. t .U 1 .U Aull..., (IU") ' Ka (K) Too MM2 11114, ...,. , 11) '4

'*" o.u o.u J . Jt lllll!ACll~1t..own Aala.,, (I U *) >JI Na (H) St olle,.., .., . ... .Nu, ....... IIOIIA >11. D lawrun _ ...,,, (IIS' ) s IC& (K) T"1 s,..c......a MDU, MOH. IOU, ,.n

• Jt e. u 2. H auu. wu,. wu1.

M..,

tm MIW ILICJilC ~

4UtYloev Tn_,.,_,.

,..__,....,. ..... ..... w..,,,,...

.-....m*.,, (too*> **-tw&J ,., . o.n JKa ( N) l tllkMllyolo wen. w - - e .JO J . *1

' " "'" Cll>!Nta OM* CUUII) ,...._,,, )

JJ )Is (II) 2t lb OC) l ta tlc Toot

""""'* _..,SUldlWtW auu. w.1u IOU, MHt

>JO. I

,.u o.n , .u J . '7 fl <PKJJQl, IOOH

..... c...... ,_.. AIUIJltocy ( 140') >JJ Ha (11) TNt Switch 111oc.-e ws.......,.,.... >Jt.*

f" si

!f AlmllMW - ..... ~....

Aaalllat7

~ O J I ")

(JOO") >U Ka (II)

,_., Hz (K)

Dr**S. Aaai,.i.

Tt1l liatlc AMlyolo Tott 1,-tenl s.,~._

s--.i MU6, MUJ WJl1, MllJ, MJO ,

Mtlt, M412 Mn,. w,u ..., ,,

,.,o

,.1,

,,o.o D.JI

,.n O. JO e.u 0 . 14 2.H

, .n

, .n Il '...

C1\

0 I

16

a ,-u (Contlnu~d)

.,...~

~

Table DIABLO CANYON EQUIPMENT FRAGILITIES

( 8 . . .d on haaard dtrlned over l to 1.5 hcrta nnae.) ...

/")

~

l Speclral °'

!!! Accaleno tlon <=-e*clly I Setem end Comeonenl Locallon Fundamental Pre9ucncz:

Mclllod or Sc i.mlc

~allrtcaUon Palluno Mode lllformellon Source l.,w

- - _!:L p ~ II CLPF

. -.!IL_

f..* MIPCD<<DQL

• • --,.,..~

• - c...... -* ...........,....

s.u, * * - p,...., ...., ****

l u - A"h_,...,. . .,....,.

,_,.&APT-.1*"

Au*orJ (111')

Aulll17 (140')

All....,(111')

~(141')

C o o - ( I I T' )

1- 10 lb (N) 1-11 Ha (N)

I Ka (K)

>J> II& (IC)

Tt1&

,Tm Tut TNC Stnct.,.I l1NC1. .,

1e...,. . .

. . .......1 ao1,:"aon

!Oil, II.US

!Oil, IOU IOO MUI

12. 6)

>II'*"

.I 1.U o.u o.n o.u o.u D. H o.,o J .n

4. U

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....... a..a-11 ........

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2.5 I PG&E Single Station Sigma Approach I

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I'll VI - San Luis Bay

- Shoreline 1 1 -Shoreline-Hosgri Linked

- Design 0.5 0 +------- - --

0.1 1 10 100 Frequency (Hz)

Figure 1 - Deterministic Response Spectrum Single Station Approach 25 1 NRC Developed Ergodic Approach 2 1 I - Hosgri 1.5

- LosOsos BI'll VI - San Luis Bay 1 - Shoreline I -Shoreline-Hosgrl Linked 0.5 1I - - Design 0

I 0.1 1 10 100 Frequency (Hz)

Figure 2 - Deterministic Response Spectrum NRC Developed Ergodic Approach 18

From: Qesterte, Enc To: Sebroskv, Joseoh: Maf1stev Michael: Lupold. JimottJy: Wilson George Cc: Karas Rebecca

Subject:

Final Briefing Slides Date: Tuesday, October 21, 2014 10:04: 17 AM Attachments: Eioal pjabk> Canyon Seismic Status Brjefjng 210c:t2011,ootx 1mage001,ono Attached are the finalized briefing slides for the 11 AM briefing. Thanks everyone for your inputs!

Er-lc/ R.. O~le; NRC Project Manager Diablo Canyon Power Plant Cooper Nuclear Station NIRR/D0RL/LPL4-1 301-415- 1014

~U.S.NRC Un ited States Nuclear Regu la tory Com missio n Protecting People and the Environment Assessment of PG&E Operability Determination for New Seismic Information NRR, NRO and Region IV Status Briefing October 21, 2014 Contacts: J. Sebrosky (NRR/JLD), T. Lupold (NRR/DE), R. Alexander (RIV), W . Walker (RIV),

M. Markley (NRR/DORL), and E. Oesterle (NRR/DORL) 1

~ U.S.NRC Uniced S1.1rc< 1'11clear Rcg11!J1ory Commiss ion Protecting Peopk and the Enviromnmt Briefing Agenda

• Purpose

• Expected Outcomes

• Background

• PG&E Seismic Report

• NRC Responses/Actions

• Current Status

• Potential Outcomes

• Next Steps

• Decisional Environment 2

~ U.S.NRC Uni1.:d Su1e< 1':ucle~r Regularn ry ComnHH ion Protecting Peopk and the Enviro11ment Purpose

• Inform NRR, NRO, and Region IV management of status on NRC activities/actions that respond to new seismic information for Diablo Canyon that indicates the Shoreline Fault discovered in 2008 is more capable than previously evaluated by licensee and confirmed by NRC to be bounded by the Hosgri evaluation described in the licensing basis 3

~ U.S.NRC U ni ted St Arcs N udea r Regu la tory C om missio n Protecting People and the Enviromrumt Expected Outcomes

• Alignment of NRC HQ and Region IV activities, plan, and next steps

• Clear understanding of current status and potential implications of outcomes

• Enhanced perspectives on environmental context in which NRC actions/decisions will be made 4

~ U.S.NRC lln11<"d :>r~*<"s ~ucleu R.-gula10ry Com missio n Protecting Peopk and the Environment

Background

• Current licensing basis for Diablo Canyon seismic hazard includes DE, DDE, Hosgri (HE), & Long Term Seismic Program (LTSP)

• DE = OBE (0.2g); ODE = SSE (0.4g); HE = additional case evaluated in 1977 during OL review (0.75g); LTSP was a License Condition completed and reviewed in SSER 34

• Shoreline fault discovered in 2008 and evaluated by PG&E to be bounded by HE - operability assessment performed by licensee (PG&E Shoreline Report dated January 2011)

• Independent confirmatory deterministic evaluation of the Shoreline fault performed by NRC concluded it was< HE (RIL 12-01 dated September 19, 2012) 5

~ U.S.NRC l_;nitc,1 .'>t~u< 1'uclcar R~gul.tory Commi,sion Protecting Peopk and the E11viro11ment NRC Response Spectra from RIL 12-01 2.5 1

HO$Ql'I Spedrum

-- 0)

C 2.0 ~

LTSP Spectrum NRC M6 7

• 84%

NRC M$.9

• 84%

• -l!

0 1.5

-uG)

G) u

-...l!

ct 1.0 u

G)

C. 0.5 U) 0.0 "'--~-----------------.......~----~----------........---~----------------~

0.1 1 10 100 Frequency (Hz) 6

~U.S.NRC United Sr.ates 1'udear Rq;ulJiory ,0111n11(<ion Protecting Peopk and the Environment Background (continued)

• NRC issues 50.54(f) letter on March 12, 2012, to all licensees requesting seismic and flooding hazards re-evaluation

• NRC issues letter to PG&E (Oct. 12, 2012) documenting review of PG&E Shoreline Fault Report and placing its assessment in the context of the 50.54(f) process

- ... if new faults are discovered or information is uncovered that would suggest th.e Shoreline fault is more capable than currently believed , the staff expects that the licensee will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information. The staff will use this information to independently assess whether the new fault or new information related to the Shoreline fault challenges or changes the staffs current position that the motions associated with the Shoreline fault are at or below those levels of the HE and LTSP ground motions.

7

~ U.S.NRC U n i1c*d Sr.ires ~uclcu Rri.u!J rc,ry Commissio n Protecting Peopk and the Environment PG&E Seismic Report

• Geologic investigations underway to support requirement of AB1632 for report to CA when NRC issued Oct. 12, 2012, letter

• PG&E used new state of the art 20 and 30 onshore and offshore seismic reflection mapping

• PG&E informed NRC of preliminary results at drop-in meeting on August 22, 2014, and committed to provide report to NRC 2011 Shoreline Report Updated Parameters Fault Maximum Minimum Mag. Maximum Minimum Mag.*

Length Dip (90th Length Dip (km) (degrees) fractile) (km) (degrees)

Shoreline 23 90 6.5 45 90 6.7 Hosgri 110 80 7.1 171 75 7.3 Los Osos 36 45 6.8 36 55 6.7 San Luis 16 50 6.3 16 50 6.4 Bay

• Report provided to CA and NRC on September 10, 2014 8

~ U.S.NRC l)nuc.l Sr~res 1':uclc:ir R~gul~rory Comn11ss io n Protecting People and the E11viro11ment NRC Responses/Actions

• Approach - determine if PG&E operability determination is reasonable and there is no reason to deviate from 50.54(f) process

• Develop project plan and communication plan

• Region IV - initiate inspection of licensee's operability assessment (IR-2014-008)- request technical assistance from HQ

• HQ - develop technically defensible position to support inspection

• HQ - draft letter to licensee documenting inspection outcome and outlining next steps

• NRC and State of CA access to seismic report provided by PG&E several days prior to official issuance of report

• NRC initiated review of preliminary PG&E seismic report and developed requests for additional information 9

~ U.S.NRC Un11ed St;lte5 :-;uclear Rcgubrory Commi>sio n Prottcti11g Peopk and the E11viro11ment NRC Responses/Actions (continued)

• Region led telecons held with licensee to provide requests for additional information and for licensee to communicate requested information

• PG&E provided access to NRC yia electronic reading room to review calculations, data, and graphs

• Based on review of the PG&E seismic report and additional information no one believes there is an immediate safety concern

• NRO assessment of PG&E seismic information (single station vs.

Ergodic)

• NRO assessment of PG&E damping factors used for determining in-structure responses

• NRR assessment of licensee approach for use in operability determination 10

~ U.S.NRC l :n 11c:.I Statt*s :S:udeu R~,.11la1o ry Commission Protecting People and the Enviromnmt f- 2.5 PG&E Single Station Sigma Approach 2

1.5

- - Hosgri

- - Lo s Osos

~

.,i San Lu is Bay

- - Shoreline

- - Shoreline-H osgri Linked

- - Design 0 .5 0

0 .1 10 100 Frequency (Hz) 11

~ U.S.NRC llnitc:d !>1.:11 cs 1':ucl~:ar Rcgul.unry Co m mission Protecting Peopk and the Environment

1 .5 NRC Developed Ergodic using PG&E Data 2

1.5

- - Hosg ri

- - Lososos

B

~ - - San Luis Bay

- - shoreline

- - Shoreline-Hosgrl Linkl'd

- - Design 0 .5 0

0.1 1 10 100 Frequency (Hz) 12

~ U.S.NRC U 1111.:,f S1 ~1.-, N uclc:ir R.-gubrory Co111m1H io n Protecting People and the Environment Current Status

• PG&E expressed unwillingness to consider Ergodic approach and identify SSCs that may be impacted by HE exceedance

• Insufficient time and resources to investigate PG&E single station sigma approach to develop sufficient confidence level

• NRC expects to see the PG&E single station sigma approach combined with seismic risk information in 50.54(f) response in March 2015

• NRC approach to support operability inspection is to discuss the response spectra provided by the licensee, explain how uncertainty associated in these spectra is treated and conclude that the approach is acceptable for use in an operability determination

• The licensee's approach will be investigated further when it is submitted as part of the March 2015 response to 50.54(f) letter 13

~U.S.NRC U11i1c,I S1~1e* Nuclear Rcgub1ory Com mission Protecting People and the Environmmt Potential Outcomes

1. NRC is able to conclude that licensee's single station sigma approach is acceptable for use in their operability determination

- NRC letter to licensee documenting results of inspection and continued operability until NRC completes its review of 50.54(f) responses

- NRC concludes that the results from the new seismic information is insufficient to require deviation from the 50.54(f) process

2. NRC is not able to conclude that licensee's single station sigma approach is acceptable for use in their operability determination

- NRC letter to licensee documenting results of inspection that there is no reasonable assurance of operability

- NRC concludes that DCPP units must either be shutdown or restricted from returning to operation following refueling outage until N RC approval following review of 50.54(f) responses due in March 2015 and completion of any required actions to ensure safety 14

~ U.S.NRC Unile(I Sures 1':11cle3r Reg11IJrory Commission Protecting Peopk and the Environment Next Steps

• NRR/DE complete review of licensee approach for use in operability determination and provide input/review of writeup to support inspection report

• NRO/DSEA & RES review of writeup

• NRR/DORL consolidate write-up to provide report to Region IV for use in completing IR-2014-008

• NRR provides concurrence on IR-2014-008

• NRC management briefing to gain alignment and concurrence on follow-up actions for licensee

• Region IV complete IR-2014-008 and schedule Exit with licensee

• NRC finalize letter to licensee providing assessment on operability and 50.54(f) process and issue to licensee 15

~ U.S.NRC li nit<"d Sta res Nuclear RcgulJtor y Commi ssio n Protecting Peopk and the Environmmt Decisional Environment

• FOE Hearing Request - de facto license amendment

• FOIA- release of Sewell Report

• Sen. Markey Questions on 50.59s for SGR at Diablo

• FOE Hearing Request - license renewal LAR

• FOIA - timing of PG&E issuance of seismic report and NRC EDO decision on DPO appeal

• PDR request for release of DCPP FSARU Rev. 21

• Leak of DPO and publication in Press

• IG Report on SONGS 50.59s for SGR

• December 2014 Hearings - Senate & House 16

From: St>brpsky Jpscch To: w,tson George; Martllcv MIChaef* <>ester!c Enc

Subject:

FW: Info: rough drat\ of OCPP seismic evaluation Date: Tuesday, October 21, 2014 5:50:12 AM Attachments: P,cbta canyon APWlbflfLY ttolYOl!AD 2014 se,smc mfonnaoon 11:d}ncoa! evaruoii9o,docx jmageQO I AD9 George. Mike and Eric The purpose of this email is to ask for help from people who understand seismic margins better than me on whether or not the attached technical evaluation should include references to how SSER 34 confirmatory items were resolved . and the HCLPF values found in PG&E's IPEEE submittal. The references are provided below. Any insights on whether or not this information should also be included would be appreciated - thanks joe Note: ML14279A132 is publicly 4/17/92 letter available in ADAMS.

View ADAMS P8 Propertjes Mll4279A132 Open ADAMS Pa Document {Forwards Safety Evaluation Closing Out Plant Long-Term se,sm1c Peogam Staff finds That Confirmatory Item from SSER 34 Has Been Satisfactorily Resolved I I am also not sure if the IPEEE HCLPF values should be included in the discussion. The IPEEE can be found at:

View ADAMS P8 Properties Ml.073600371 Open ADAMS P8 Document CDiablo Canyon Units I & 2, Response to Generic Leiter 88-20, Supplement 4 "Individual Plant Examination of External Events for Severe Accident Vu lnerabilities">

The IPEEE contains HCLPF values for Component and Structures. Below is an example table from the IPEEE

Table 3 -8 . OCPP Component 9'ld Strue1Ure Fraglity and HCLPF Vllluts IIISICMAN 1.0 Oescnption Medi. .

Accl.lol HCt..Pf .....

A u

Feilu,.. Mode afld Source of ~ agility

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~

2*

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c -___....,.,_

JIIISTII *T Ml STlluc:T\.91C

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...v_ , .....

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lOGC,trj OC. CONTIIOl *.&N1l .... 2-2, O.lC Q_IJ f- **-

From: Sebrosky, Joseph Sent: Monday, October 20, 2014 8:55 PM To: Oesterle, Eric; Wilson, George; Markley, Michael

Subject:

info: rough draft of DCPP seismic evaluation George, Mike, and Eric, Attached is a very rough draft of the Technical Evaluation of the 2014 California Coastal Commission Seismic Imaging Project for DCPP Units 1 and 2. It is a very rough draft which Eric and I intend to develop further in the morning. We hope to have a more refined product to you by 9:00 am.

Please let me know if you have any questions on the approach.

Thanks, Joe

TECHNICAL EVALUATION REPORT BY THE OFFICES OF NEW REACTORS, RESEARCH , AND NUCLEAR REACTOR REGULATION CENTRAL COASTAL CALIFORNIA SEISMIC IMAGING PROJECT PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNITS 1 AND 2 October 20, 2014, 6:00 pm version

1.0 INTRODUCTION

1.1 Purpose This evaluation provides the results of the U.S. Nuclear Regulatory Commission (NRC) staff's assessment of the new seismic hazards information developed by Pacific Gas and Electric Company (PG&E, the licensee) for the Diablo Canyon Power Plant, Units 1 and 2 (DCPP) and provided to the NRG in PG&E letter dated September 10, 2014, "Central Coastal California Seismic Imaging Project, Shoreline Fault Commitment"(Reference 1). The staffs from the NRC's Office of New Reactors (NRO), Office of Research (RES), Region IV, and Office of Nuclear Reactor Regulation (NRR) evaluated the information provided in the licensee's September 10, 2014, letter. In addition, this evaluation provides the results of the NRC's review of PG&E's operability determination found in PG&E Notification 50652361 , "Preliminary new seismic information," completed on August 21 , 2014, (Reference 2) against NRC guidance found in NRC Inspection Manual Chapter (IMC) 0326, "Operability Determination and Functionality Assessments for Conditions Adverse to Quality or Safety," dated January 31 , 2014 (Reference 3) to determine what affect, if any, the new seismic information has on the capability of seismically qualified systems, structures, and components (SSCs) to perform their specified safety functions.

1.2 Background Pursuant to Title 1O of the Code of Federal Regulations, Part 50 (10 CFR), Section 50.54(f), and by letter dated March 12, 2012, (Reference 4) the NRC requested information concerning, in part, the seismic and flooding hazards at operating reactor sites to enable the NRG staff to determine whether operating licenses should be modified, suspended, or revoked. The "Required Response" section of Enclosure 1 to the letter indicated that licensees should provide a Seismic Hazard Evaluation and Screening report within 3 years for western United States (WUS) plants. The process outlined in the March 12, 2012, request for information related to seismic hazards was also discussed in NRC letters dated October 12, 2012, (Reference 5) and February 20, 2014 (Reference 6). The October 12, 2012, letter, specifically discusses NRC's review of the Shoreline fault near DCPP, and places the NRC's review of the Shoreline fault into context with the process for developing and assessing seismic information found in the March 12, 2012, request for information. The October 12, 2012, letter states in part:

The NRC staff understands that the seismic evaluations described in the March 12, 2012, request for information are currently in progress at DCPP, and PG&E plans to acquire new offshore and onshore two-and three-dimensional seismic reflection data to identify and characterize faults in the vicinity of DCPP.

If during the collection of the data, new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, the staff expects that the licensee will provide the NRG with an interim evaluation that describes actions taken or planned to address the higher seismic 1

hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information.

California Assembly Bill (CAB) 1632 (Blakeslee, Chapter 722, Statutes of 2006) (Reference 7) directed the California Energy Commission to assess the potential vulnerability of California's largest base-load power plants, including Diablo Canyon Power Plant, to a major disriuption caused by a seismic event or plant aging; to assess the impacts of such a disruption on system reliability, public, safety, and the economy; to assess the costs and impacts from nuclear waste accumulating at these plants; and to evaluate other major issues related to the future role of these plants in the state's energy portfolio.

Based on the California Assembly Bill, the California Energy Commission compiled a report in 2008 (Reference 8) that included the recommendation that PG&E perform additional seismic studies to supplement the original and ongoing seismic studies performed as part of the licensee's Long Term Seismic Program (LTSP), and that those studies be conducted using advanced technologies such as three-dimensional (3D) seismic-reflection mapping. During 2011 through 2014, the licensee conducted the recommended studies and further data analysis, and compiled the report entitled, "Central Coastal California Seismic Imaging Project" (CCCSIP) and provided this report to the NRC via letter dated September 10, 2014. Following internal completion of the CCCSIP Report, the licensee performed an operability determination documented in Notification 50652361 completed on August 21 , 2014 (Reference 2) based on the report and its data.

PG&E's September 10, 2014, letter transmitting the report provides an interim evaluation consistent with the guidance found in the NRC's October 12, 2012, letter. PG&E's letter states in part:

The additional offshore seismic studies revealed that the Shoreline fault is longer by extending farther south than in the Shoreline fault report, and therefore, more capable as described in the enclosure. PG&E concluded that the ground motions from updated shoreline fault and other regional faults remain less than the 1977 Hosgri design ground motions, for which the plant was evaluated and demonstrated to have reasonable assurance of safety. This interim evaluation is consistent with the conclusions of the Research Information Letter 12-01 ,

"Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone," dated September 2012 [Reference 9].

PG&E's September 10, 2014, states that the CCCSIP will support the NRG-mandated seismic hazard risk assessment for the DCPP that is being performed in accordance with the March 12, 2012, request for information (Reference 4). PG&E will use the Senior Seismic Hazard Analysis Committee (SSHAC) process to incorporate and evaluate existing and new seism information to update the seismic hazard for DCPP.

The DCPP seismic hazard lbased on the SSHAC process is due to the NRC in March 2015.

The staffs previous assessment of the Shoreline Fault found in RIL 12-01 was based on a deterministic approach. As described in RIL 12-01 the conservative deterministic (scenario-based) viewpoint was intended to allow the NRC staff to determine if a safety concern exists as a result of the identification of the Shoreline fault. By their nature, deterministic approaches do not explicitly account for the likelihood of a particular earthquake scenario occurring, or the rate at which earthquakes can occur on known seismic sources. Therefore, deterministic results 2

cannot be used for a quantitative assessment of the overall risk to the plant from the Shoreline fault. Instead, deterministic approaches focus only on the safety margin that exists for a specific earthquake scenario, in this case for the Shoreline fault.

The response to the March 12, 2012, request for information is based on a a probabilistic seismic hazard assessment (PSHA) approach. As described above PG&E is scheduled to provide a detailed PSHA by March 2015. The results of the PSHA which will strengthen the understanding of the relative importance of the Shoreline fault and other faults evaluated in the CCCSIP to the seismic hazard at this site.

2.0 REGULATORY ANALYSIS

Because the detailed PSHA is due shortly to the NRC (i.e., March 2015), the NRC staffs evaluation is limited to reviewing PG&E's deterministic evaluation that is provided in t1he CCCSIP. The NRC staffs evaluation takes advantage o,f insights gained from the development of RIL 12-01 , but does not update the RIL. Instead, the staffs evaluation relies on the new information found in PG&E's September 10, 2014, submittal and PG&E's operability determination regarding the following fault scenarios:

• Hosgri and San Simeon faults (the step-over between the Hosgri and San Simeon is small enough that the two faults are assumed to rupture together with an assumed magnitude of 7.3)

• Los Osos fault (assumed magnitude of 6.7)

• San Luis Bay fault (assumed magnitude 6.4)

• Shoreline fault (assumed magnitude of 6.7)

• Hosgri, San Simeon and Shoreline linked fault sensitivity study(assumed magnitude 7.3)

The purpose of the NRC staff's evaluation is to determine if a safety concern or operability concern exists as a result of the new information provided in PG&E's September 10, 2014 CCCSIP report. A more thorough review of the seismic faults around DCPP will be completed by the staff in the future based on PG&E's PSHA to be provided by March of 2015.

In performing its evaluation the NRC staff also reviewed how a recent Differing Professional Opinion (DPO) was resolved. The resolution of the DP0-2013-002, "Diablo Canyon Seismic Issues" is documented in a case file (Reference 10) that includes the following information:

• DPO Submittal

• Memo form NRR Office Director Establishing the DPO panel

• DPO Panel Report

• DPO Decision

• DPO Appeal Submittal

• NRR Office Director's Statement of Views

• DPO Submitter's Appeal Presentation to OEDO

• DPO Appeal Decision 3

3.0 EVALUATION 3.1 Method of Review The NRC staff's review is broken into three parts:

• The NRC's deterministic evaluation of the faults described in the 2014 CCCSI P report

• An update to the DPO assessment based on the information in the 2014 CCCSIP

• An assessment of the results of the NRC staff's deterministic evaluation regarding safety and operability of DCPP SSCs based on ergodic treatmen of uncertainties.

3.2 NRC Staff's Deterministic Evaluation of the Faults Described in the 2014 CCCSIP Report Summary of PG&E Information Chapter 13 of the CCCSIP, "Hazard Sensitivity and Impact Evaluation," provides a discussion of the differences between the deterministic evaluation provided in PG&E's 2011 Shoreline Fault Zone Report (Reference 11) and the 2014 CCCSIP studies. RIL 12-01 is based in large part on PG&E's 2011 Shoreline Fault Zone Report. CCCSIP Chapter 13 Table 1-1 which compares the source characterization for the deterministic ground motion evaluation is reproduced below.

2011 Shoreline Report Updated Parameters Fault -

Maximum Minimum Mag. Maximum Minimum Mag.*

Length Dip (90th Length Dip (km) (degrees) fractile) (km) (degrees)

S horeline 23 90 6.5 45 90 6.7 Hosgri 110 80 7.1 171 75 7.3 Los Osos 36 45 6.8 36 55 6.7 San Luis 16 50 6.3 16 50 6.4 Bay PG&E describes in CCCSIP Chapter 13 that the Shoreline fault was found to extend an additional 22 km to the south thereby increasing the fault length from 23 km used in the 2011 Shoreline Fault Zone Report to 45 km. With this increased length the magnitude of the Shoreline fault increased from 6.5 to 6.7.

For the Hosgri fault, PG&E describes in the CCCSIP Chapter 13 that the length of the combined Hosgri and San Simeon faults, 171 km, was defined using the Hosgri fault length from the U .S. Geological Survey (Petersen et al., 2008, Table 1-3) which treated the San Simeon and Hosgri faults as a single fault called the Hosgri fault. This creased length leads to a magnitude of 7.3.

PG&E describes in CCCSIP Chapter 13 that studies for the Los Osos fault found that the minimum dip consistent with the newly collected data is 55 degrees, as compared to 4

a minimum dip of 45 degrees used in the 2011 Shoreline Fault Zone Report. The steeper dip leads to a smaller fault area, and the magnitude is reduced from 6.8 to 6.7.

The CCCSIP studies did not provide new information for the San Luis Bay fault length or dip. Using the length and dip from the 2011 Shoreline Fault Zone Report leads to a magnitude of 6.4. The increase from the 2011 magnitude of 6.3 results from using the bounding length and dip rather than the full logic tree to define the rupture area.

PG&E also describes in CCCSIP Chapter 13 that for the Shoreline fault rupture developed in the 2011 Shoreline Fault Zone Report the Shoreline fault was assumed to intersect with the Hosgri fault, but a linked rupture involving the full Shoreline fault and the full Hosgri fault was not included because the geometry of the two faults was unfavorable to allow such a rupture. PG&E states that the new information collected on the geometry of the Shoreline and Hosgri faults shows that within a resolution of a few hundred meters, the two faults intersect. This new information indicates that the fault may rupture together, but it does not change the unfavorable geometries for a linked rupture. Nevertheless, PG&E performed a sensitivity analysis assuming that the full Shoreline fault rupture is linked to a rupture of the Hosgri fault, extending north to the end of the San Simeon fault.

PG&E's CCCSIP Chapter 13 assesses the new information described above using a new ground-motion prediction equation (GMPE) as part of the Pacific Earthquake Engineering Research (PEER) Center's Next Generation Attenuation (NGA) West2 project. These GMPEs are different that the NGA West GMPEs used in the 2011 Shoreline Fault Zone Report (Note:

need something from NRO regarding assessment of new GMPEs)

Figure 1 of this evaluation provides a plot of the deterministic response spectrum using the source characteristics of various faults and the NGA West2 GMPEs for the power block (Note:

need to confirm if these NRC generated plots are for the power block or the turbine foundations)

PG&E concludes in the CCCSIP report and reiterates in the September 10, 2014, cover letter transmitting the report that the ground motions form the updated shoreline fault and other regional faults remain less than the 1977 Hosgri Design ground motions for which the plant was evaluated and demonstrated to have reasonable assurance of safety.

NRC Evaluation Diablo Canyon Licensing Basis In 1968. when the OCPP Unit 1 Construction Permit was issued to Pacific Gas and Electric (PG&E), the seismic evaluation had been completed under the Atomic Energy Commission's requirements. Based on the information available at the time, the design earthquake (DE) was defined as having a peak ground acceleration of 0.2 g, and the double design earthquake (DOE) was a doubling of the OE earthquake to ensure safety-related structures, systems. and components would function as expected after the earthquake, 0.4 g. In 1973. PG&E became aware of the Hosgri fault. PG&E evaluated the Hosgri fault using Regulatory Guide 1 61 "Damping Values for Seismic Design of Nuclear Power Plants," October 1973 (Reference 12)

Though not included in the construction application, NRC reviewed PG&E's evaluation of the Hosgri fault and required PG&E to make plant modifications to be able to withstand the 0. 75 g 5

peak ground acceleration associated with the Hosgri fault. The operating license for Unit 1, issued in 1984, was based on review of the Final Safety Analysis Report Update which included two different seismic methodologies, the DOE and the Hosgri evaluation, as documented in NUREG-0675 , "Evaluation Report Related to the Operation of Diablo Canyon Power Plant Units 1 and 2, " Supplement No 7, dated May 1978 (Reference 13).

Deterministic Response Spectrum and Use of Single Station Sigma Correction In the 2011 Shoreline Fault Report PG&E addressed uncertainty in the GMPE using a ergodic approach (an approach that accounts for both epistemic (model uncertainty) and the aleatory (natural) variability. The 2011 Shoreline Fault Report documented an effort to separate the uncertainty into its component parts, including the uncertainty that comes from the seismic source, the path through which the waves travel in the crust, and the site response. If high-quality data from a modern seismographic network are available, some of the uncertainty for a specific location can be reduced . The single-station-sigma, adjustment has the potential to remove uncertainty in the application of the GMPEs by determining a station term from a set of earthquakes recorded at the site.

The NRC staff noted in RIL 12-01 Section 5.9 that:

The single-station-sigma adjustment represents advancement in the field of engineering seismology and could be a useful approach in the assessment of seismic hazard at NPPs that install a modern seismographic system, such as that at DCPP. The single-station-sigma correction applied by PG&E was developed based on data from two earthquakes. Generally a larger number of earthquakes would be needed to develop confidence in the correction factor.

This correction was applied by PG&E but was not required for the confirmatory analysis that the NRC conducted as documented in RIL 12-01 . The curves found in CCCSIP Chapter 13 found in Figure 1 of this evaluation are based on a single station correction and do not reflect ergodic uncertainty. As a result of questions raised during the inspection of PG&E's operability determination PG&E provided the following information relative to its use of the single-station-sigma correction on September 25, 2014:

• Processed Earthquake Recordings for Onsite Monitor ESTA 27 - 2003 Deer Canyon Earthquake

• Processed Earthquake Recordings for Onsite Monitor ESTA 27 - 2003 San Simeon Earthquake

• Processed Earthquake Recordings for Onsite Monitor ESTA 27 - 2004 Parkfield Earthquake

• Processed Earthquake Recordings for Onsite Monitor ESTA 28 - 2004 Parkfield Earthquake, provided 9/25/2014

• Shear Wave (VS30) Profiles for Power Block - Onsite Monitor ESTA 27

• Shear Wave (VS30) Profiles for Turbine Building - Onsite Monitor ESTA 27 6

• Shear Wave (VS30) Profiles for Power Block - On site Monitor ESTA 28

• Shear Wave (VS30) Profiles for Turbine Building - Onsite Monitor ESTA 28 Using the information provided by PG&E, the NRC staff developed the ergodic curves found in Figure 2 of this document.

The NRC staff concludes that PG&E's characteristics of the faults based on the new information revealed from the 20 and 30 analysis performed in accordance with CAB 1632 is reasonable.

The NRC staff also concludes that the use of the NGA West2 GMPE is appropriate for the evaluations performed by PG&E. (Note need more of a basis for this being OK). Therefore, the NRC staff concludes that the DCPP ground motions from the faults evaluated in the CCCSIP 2014 report (i.e., Hosgri-San Simeon, Shoreline, Los Osos, San Luis Bay, and Hosgri-Shoreline linked) using the single-station-sigma treatment of uncertainty are at or below those for the 1977 Hosgri earthquake (HE) ground motion and the long-term seismic program (LTSP) ground motion. The 1977 HE ground motion and the LTSP ground motion are those for which the plant was evaluated previously and demonstrated to have reasonable assurance of safety.

However, the NRC staff notes that based on the NRC staff developed ergodic curves found in Figure 2, below that there are exceedance in the 10 Hz to 100 Hz range for the ground motions from the earthquakes evaluated in the CCCSIP 2014 report. The evaluation of the exceedances in this range can be found in Section 3.4 of this document.

3.3 Update of Differing Profession Opinion Assessment Based on the Information in the 2014 CCCSIP Report Summary of PG&E Information As a result of questions asked during the inspection of PG&E's operability determination, PG&E provided the following calculation:

• Long Term Seismic Program Update Shoreline Fault Zone Studies: Hypothetical Comparison of Damped In-Structure Response Spectra at the Top Surface of the Containment Basemat for the Design Basis Double Design and Hosgri Earthquakes with Postulated Earthquakes on the Shoreline, San Luis Bay, Los Osos, and Linked Hosgri-San Simeon Faults" [PROPRIETARY], Revision 1, dated 09/25/2014 (Reference 14)

NRC Staff Evaluation

As stated in the Diablo Canyon NPP Safety Analysis Report Revision 21 , Section 2.5.3.9 (Design and Licensing Basis Earthquakes), the Design Earthquake (DE), Double Design Earthquake (DOE), and the Hosgri Evaluation (HE) are design bases earthquakes and the Long-Term Seismic Program is a licensing bases earthquake. Consequently, any new information that is being compared to the Diablo Canyon NPP design basis (e.g., Allen, 2012) must make appropriate comparisons to both the DOE and HE. Both the ODE and HE must be considered because each of these design-basis earthquakes use different methods and assumptions in the design and qualification of seismic Category 1 structures, systems and components (SSCs). The most significant differences are in the amount of damping assumed for the engineering analyses (Table 1). As a result of these different assumptions, the ODE creates maximum loads on some Category 1 SSCs, whereas the HE creates maximum loads 7

on other Category 1 SSCs (e.g., FSARU Section 5.2.1.15). Neither ground motion creates the bounding demand for all Category 1 SSCs.

The new ground motions in the 2014 California Coastal Commission report are shown for free-field responses with 5% damping. However, as shown in Table 1, a range of different damping values were used in the design basis calculations for Diablo Canyon NPP. In addition, PG&E did not specify what amount of damping would need to be used in comparing the 2014 ground motions with the design-basis ground motions.

Table 1. Damping factors used in PG&E analyses.

Percentaoe Dampino Type of SSC DOE HE 2014 Containment structures 5 7 7 Welded structural steel assemblies 1 4 4 Bolted or riveted steel assemblies 2 7 7 Mechanical components 2 4 4 Vital piping systems (except RCL) >12" 0.5 3 3 Vital piping systems (except RCL) <12" 0.5 2 2 Reactor Coolant Loop 1 4 4 Steam Generators 4 4 4 Integrated Head Assembly 6.85 6.85 6.85 Control Rod Drive Mechanisms 5 5 5 In September 2014, NRC staff discussed this issue of ground-motion comparability with PG&E staff, and outlined the need to compare the new ground motions with the seismic design bases for Diablo Canyon NPP. PG&E agreed to provide additional calculations for the 2014 ground motions, so that the results of these analyses would be directly comparable to the inputs used in the Diablo Canyon NPP design bases rather than an alternative metric such as the LTSP.

NRC staff reviewed the additional calculations that were developed by PG&E to allow for direct comparison of potential ground-motions in the 2014 report to the Diablo Canyon NPP seismic design bases. PG&E calculated in-structure acceleration response spectra as the basis for comparison, as these spectra already were available for the ODE and HE from FSARU section 3.7 analyses.

To convert the 2014 ground-motion spectra to in-structure acceleration response spectra, PG&E developed a scaling relationship from the LTSP analyses that compares the calculated free-surface ground motion to an in-structure response spectrum. This scaling relationship accounts for the effects of processes such as soil-structure interaction and the presence of building foundations. PG&E applied this scaling factor to the 2014 ground-motion spectra to calculate in-structure response spectra for 5% damping. To account for the different damping values used to analyze the seismic performance of different SSCs, PG&E used analytical methods in Rezaeian et al. (2012) to develop scaling factors. PG&E applied these scaling factors to the 5%

damped in-structure response spectra for the 2014 ground motions, to develop response spectra for the different damping values shown in Table 1.

Based on these calculations, the NRC staff verified that the in-structure response spectra for the reanalyzed 2014 ground motions (single station) were all lower than the DDE+HE response spectrum. As a result, the NRC staff concludes that ground motions from the 2014 report have been compared reasonably with the Diablo Canyon NPP design basis, and that these re-8

analyzed ground motions do not exceed the demands already considered in the design and qualification of seismic Category 1 SSCs.

3.4 An Assessment of the Results of the NRC Staff's Deterministic Evaluation Regarding Safety And Operability of DCPP SSCs Based on Ergodic Treatment of Uncertainties

NRC Staff Evaluation

As stated above PG&E's 2014 CCCSIP report included an evaluation of the ground motion response spectrum compared to the 1977 HE ground motion based on the single-station-sigma approach. While the staff concludes that the single-station-sigma approach has its benefits, the staff nevertheless also developed on its own the ground motion response spectrums for the faults that were analyzed in the 2014 CCCSIP report using the more traditional treatment of uncertainties using the ergodic approach. The ground motion response curves for the various fault scenarios based on the ergodic approach can be found in Figure 2 of this document.

Ground Motion Response Spectra Below 10 Hz The staff notes that the ergodic curves for the faults analyzed in the 2014 CCCSIP are below those for the 1977 HE ground motion and the long-term seismic program (LTSP) ground motion.

The 1977 HE ground motion and the LTSP ground motion are those for which the plant was evaluated previously and demonstrated to have reasonable assurance of safety.

Ground Motion Response Spectra Greater than 10 Hz PG&E's letter dated October 11 , 2011 , "Evaluation Process for New Seismic Information and Clarifyinq the Diablo Canyon Power Plant Safe Shutdown Earthquake," (Reference 18) includes as part of the application Chapter 6 of the 1988 Long Term Seismic Program Final Report. Although the October 11 , 2011 , license amendment application was withdrawn the N RC staff finds the information that is duplicated from Chapter 6 of the 1988 Long Term Seismic Program instructive because it contains a probabilistic risk assessment to determine the adequacy of seismic margins. The NRC staff assessment of the LTSP including the seismic margins can be found in NUREG-0675 Supp 34, "Safety Evaluation Report Related to Operation of Diablo Canyon, Units 1 & 2," (Reference 19).

The 1988 LSTP Chapter 6 Table 6-24 included high confidence of low probability of failure (HCLPF) data for various SSCs. The HCLPF capacity is defined as a 95 percent confidence of less than 5 percent probability of failure. The 1988 LTSP Chapter 6 Tables 6-23 and 6-24 that included HLCPF values for structures and SSCs. Tables 6-23 and Table 6-24 are repeated at the end of this evaluation for ease of reference.

PG&E October 11 , 2011 , submittal provides a discussion of the changes to the seismic margins since the 1988 LTSP report. This included an evaluation of the seismic margins associated with the integrated head assembly (IHA). The IHAs were installed in Units 1 and 2 during refueling outage nos. 2R15 and 1R16, respectively. The IHAs are classified as new components which could impact the seismic margins of existing safety-related structures, since they are attached to the reactor vessel closure heads and provide support to the control rod drive mechanisms (CRDMs) , small bore piping, instrumentation, and cables. PG&E calculated the HCLPF capacity associated with the limiting element of the CRDMS lateral support function of the IHAs, developed based on the deterministic failure margins method is 2.40 g 9

The staff notes that the HCLPF values for SSCs are above the ground motion response spectrum the NRC staff calculated using the ergodic treatment of uncertainties. (Need to assess the 230 kV switchyard). In general the staff also notes that components that are susceptible to failure at higher frequencies (i.e., greater than 20 Hz) have been the subject of recent testing . The preliminary test results indicate that these components are more robust than originally thought. The testing is documented in a report dated September 15, 2014, by the Electric Power Research Institute, titled, "High Frequency Program: High Frequency Testing Summary," (Reference 20).

Based on the HCLPF values for DCPP SSCs and the preliminary results of the EPRI testing , the staff concludes that the exceedances of the ground motion response spectras for the faults analyzed in the 2014 CCCSIP using the ergodic treatment of uncertainties does not cause the staff to believe that there is a safety concern that would require PG&E to deviate from its current course of action to evaluate the faults using the PSHA method described in the March 12, 2012, request for information. In addition, the staff concludes that based on the HCLPF values for DCPP SSCs and the preliminary results of the EPRI testing , the staff does not have a basis to conclude that any SSCs at DCPP are inoperable.

Note: does the high frequency ergodic exceedances need to be addressed in DPO section

4.0 CONCLUSION

The NRC staff reviewed the new seismic information found in PG&E's 2014 CCCSIP report and PG&E's operability determination and concludes that there is not a safety concern that would require PG&E to deviate from its current course of action to evaluate the faults around DCPP using the PSHA method described in the NRC staff's March 12, 2012, request for information.

In addition, the staff reviewed PG&E's operability determination and the NRC staff concludes that there is not a basis for declaring any DCPP SSC inoperable based on the information found in the 2014 CCCSIP report. The staff also evaluated the information in the 2014 CCCSIP report to determine if a change to the recommendations associated with DPO 2013-002, "Diablo Seismic Issues," should be revisited and has determined that a change to recommendation associated with this DPO are not necessary.

5.0 REFERENCES

1. Halpin, Edward D., Pacific Gas and Electric Co., letter to U.S. Nuclear Regulatory Commission, "Central Coastal California Seismic Imaging Project, Shoreline Fault Commitment," dated September 10, 2014, (ADAMS Package Accession No. ML14260A106)

2. Pacific Gas and Electric, Notification 50652361 , "Preliminary new seismic information,"

completed on August 21 , 2014,

3. U.S. Nuclear Regulatory Commission, Inspection Manual Chapter, "Operability Determination and Functionality Assessments for Conditions Adverse to Quality or Safety,"

dated January 31 , 2014, (ADAMS Accession No. ML13274A578)

4. U.S. Nuclear Regulatory Commission, "Request for Information Pursuant To Title 1O of The Code Of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima 10

Dai-lchi Accident." dated March 12, 2012 (ADAMS Accession No. ML12053A340)

5. Sebrosky, Joseph M., U.S. Nuclear Regulatory Commission , letter to E. Halpin, Pacific Gas and Electric, "Diablo Canyon Power Plant, Unit Nos. 1 And 2 - NRC Review of Shoreline Fault (TAC NOS. ME5306 AND ME5307)," dated October 12, 2012 (ADAMS Accession No. ML120730106)

6. Leeds, Eric J., U.S. Nuclear Regulatory Commission, letter to All Power Reactor Licensees and Holders of Construction Permits in Active or Deferred Status, "Supplemental Information Related to Request for Information Pursuant to Title 10 of The Code Of Federal Regulations 50.54(f) Regarding Seismic Hazard Reevaluations For Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-lchi Accident," dated February 20, 2014 (ADAMS Accession No. ML14030A046)

7. California Assembly Bill No. 1632, Chapter 722 (AB 1632, Blakeslee, Energy: planning and forecasting) approved by the Governor September 29, 2006

8. California Energy Commission (CEC), 2008. "An Assessment of California's Nuclear Power Plants: AB 1632 Commission Report," CEC-100-2008-009-CMF, adopted November 20, 2008

9. U.S . Nuclear Regulatory Commission, "Research Information Letter (RIL) 12 Confirmatory Analysis of Seismic Hazard at the Diablo Canyon Power Plant from the Shoreline Fault Zone," September 2012 (ADAMS Accession No. ML121230035)

10. U.S . Nuclear Regulatory Commission , Case File for Differing Professional Opinion 2013-002, "Diablo Seismic Issues," September 9, 2014 (ADAMS Accession No. ML14252A743) 11 . Becker, James R., Pacific Gas and Electric, letter to U.S . Nuclear Regulatory Commission, "Report on the Analysis of the Shoreline Fault Zone, Central Coastal California,"

January 7, 2011 (ADAMS Package Accession No. ML110140431 )

12. U.S. Nuclear Regulatory Commission, Regulatory Guide 1 61 , "Damping Values for Seismic Design of Nuclear Power Plants," October 1973

13. U.S. Nuclear Regulatory Commission, NUREG-0675, "Evaluation Report Related to the Operation of Diablo Canyon Power Plant, Units 1 and 2, " Supplement No 7, dated May 1978 (ADAMS Accession No. ML14279A129)

14. Pacific Gas and Electric, "Long Term Seismic Program Update Shoreline Fault Zone Studies: Hypothetical Comparison of Damped In-Structure Response Spectra at the Top Surface of the Containment Basemat for the Design Basis Double Design and Hosgri Earthquakes with Postulated Earthquakes on the Shoreline, San Luis Bay, Los Osos, and Linked Hosgri-San Simeon Faults" [PROPRIETARY], Revision 1, dated 09/25/2014

15. Allen, B.S., Pacific Gas and Electric Co., letter to Nuclear Regulatory Commission, "Withdrawal of License Amendment Request 11 -05," October 2012. (ADAMS A ccession No. ML12300A105) 11

16. Diablo Canyon Power Plant Units 1 & 2 FSAR Update, Revision 21 , September 2013 (ADAMS Accession No. ML13280A390)

17. Rezaeian , S., and others, "Spectral Damping Scaling Factors for Shallow Crustal Earthquakes in Active Tectonic Regions," Pacific Earthquake Engineering Research Center Report 2012/01 , July 2012.

18. Becker, James R. , Pacific Gas and Electric, letter to U.S. Nuclear Regulatory Commission, "License Amendment Request 11-05, "Evaluation Process for New Seismic Information and Clarifyinq the Diablo Canyon Power Plant Safe Shutdown Earthquake," October 11 ,

2014 (ADAMS Accession No. ML11298A247)

19. U.S. Nuclear Regulatory Commission, NUREG-0675 Supp 34, "Safety Evaluation Report Related to Operation of Diablo Canyon, Units 1 & 2 ," dated June 1991 (ADAMS Package Accession No. ML14279A124)

20. Electric Power Research Institute, "High Frequency Program: High Frequency Testing Summary," September 15, 2014.

12

Table 6-23 DIABLO CANYON STRUCTURE FRAGILmES (Based on hazard defined over 3 to 8.5 hertz range.)

Fundamentai Spectral Acceleration Capacity Frequ,ncy l:.

Structure Herl~ Failure Mode s1 <a> ~ .!\L.. HCLPF (R)

Contal.o.mentBuDdlDa ... 1 Exterior Shell Sheu a...2 0.26 0.30 3.34 Concrete Internal Structure 8. 9 lDlcru.J Structure Shear 6.91 0.20 0.31 2. 98 Intake Structure 23.3 North Wall Shear 8.SS 0.28 0. 31 3.23 Awdlla.ry Bulldini a.2 North/South Sb1uwalll 5.19 0.21 0.26 2.66 Turbine BuildlDi a.6 Shear Wall, Column 31 4.17 0.26 0.33 1. 84 9.0 Blo4k Wall >10:0 R.efllell.Da Water Storap T~ 7.6 Concrete/Bedrock Flexure 9.92 0.29 0.36 3.40 CondtnH.te Storaae Tant Comparison to R.WST >10.0 DO Fuel-OU Stora&* Tank Burled R11i,ture >10.0 Auxllia.ry Saltwater Plping Buried Rupture 9.23 0.18 0.21 4.8.5 13

a..

,c Table 6-24 9

=

R" DlABLO CANYON EQUlPMENT FRAGILITIES *

'O

~

...e (Baaed on hazard der1ned*oyer 3 to 9.5 ham ranae.)

°'

l Spectral C: Pundarnenlal Method or Sel1 mlc Quellflcatlon Failure Mode lnforrnatlon SoUJ"Ce JI:

s.<a>

Accolcrello n Capacity

....!!IL ~

HCLPF Frequency

~

Syatom end Component Location

...'I.. eo-*--

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Co11aia-.a - (Ht')

fkdllal't,lq PlcJdblc Plplq 7 H& (K)

,.,. K& (R)

,_, H& (BaV)

Sutic AaalJllll1'ftl SUtlo AaaJJwWTat o,,,u,1c Aulylll l)ro,unJc Aul1tll Oyumlc Aaal71b Oc--*'-

Oourlc hactloa i..owcr W:11or Staacl lte..S Aclap1cr Tklcl llupterc WJ'1, 1ol4DI Wl'1. W401 W:JS5, WU.I, wu,

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Pl&Jdblel'tplq n H&(H) l>ya.l llllk Aaalytla Soallc Aaa)J ...

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M41J, 1,H14 1.)1 D. JJ o.u o.u 0 . 2,

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a Table 6-24 (Continued) n i

n DIABLO CANYON EQUIPMENT FRAGILmES .....

~

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I (Bued o n haurd denned o""'r 3 to 1.5 her1s r*nae.)

a.

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n S:[!tem and Come!!nent LocaUon Fundamental Fr-eguen2 Method or Sel1mlc

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CkMrlc: l'lm,;tioa Nff7. WUJ, MUI 11Dt7 Kitt

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.I DIABLO CANYON EQUIPMENT FRAGILITIES

( Based on huard d*rlned over- 3 to t . S hens nn1*-> .

"O ft

°'

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M4'7 f;IIC!l C4t6Ll m.ECT"alC ~

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16

IC a.... Table 6-24 (Conrinutd) (')

r S: DJABLO CANYON EQUIPMENT FRAGILITIES ~

f! (Bued on hazard defined over 3 to I.S hertz re111e,)

Spectral

~

°'

i.

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_!:.B.. . -i!L Sptcm and Componenl "n

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2.5 PG&E Single S~ation Sigma Approach 2

-Hosgri 1.5

-LosOsos

§ Ill - San Luis Bay 1 -Shoreline

- shoreline-Hosgri Linked

- Design 0.5 0 .I I 0.1 1 10 100 Frequency (Hz)

Figure 1 - Deterministic Response Spectrum Single Station Approach 2.5 PG&E Ergodic

-Hosgri 1.5

-LosOsos

§ I'll Ill - San Luis Bay 1 -shoreline

- shoreline-Hosgri Linked

- Design 0.5 0.1 1 10 100 Frequency (Hz)

Figure 2 - Deterministic Response Spectrum Ergodic Approach 18

From: Oesterle. Ede To: Lupold, Timothy; Alexander. Ryan: Karas. Rebecca: Markley. Michael; walker. Wayne Cc: JJ...:l'.QllO.; Maoolv, Kamal: WIison. George: Sebrosky. Joseph

Subject:

RE: Ora~ Briefing package for 10/21 Date: Tuesday, October 21, 2014 6:53:07 AM Attachments: draft Piablo canyon Sejsmjc Status Bdefina 210ct2011 optx 1maaeoo1.ono Importance: High Thanks Timi I appreciate your input on the briefing slides. This new approach has been incorporated into the slides.

Everyone - Please review the attached updated briefing slides based on DE's input. The changes have been denoted in RED. Please get back to me with any changes no than 9AM. Thanks!

Eric From: Lupold, Timothy Sent: Monday, October 20, 2014 6:04 PM To: Oesterle, Eric; Alexander, Ryan; Karas, Rebecca; Markley, Michael; Walker, Wayne Cc: Li, Yong; Manoly, Kamal

Subject:

RE: Draft Briefing package for 10/21 Last bullet on slide 13 is no longer the approach that will be used. The current plan is to discuss the curve developed by the licensee and note that it is enveloped by the Hosgri curve. An explanation of how uncertainty is treated will be included along with words that indicate the licensees approach is acceptable for use in an operability determination without addressing individual components for an exceedance at the higher frequencies, and that the approach will be further investigated under the review of the 2.1 information to be provided.

Slide 14 and 15 should be altered also. A seismic margin evaluation will not be completed.

From: Oesterle, Eric Sent: Monday, October 20, 2014 10:31 AM To: Alexander, Ryan; Karas, Rebecca; Lupold, Timothy; Markley, Michael; Walker, Wayne

Subject:

FW: Draft Briefing package for 10/21 Good morning, Just in case my email from home ended up in your spam or trash folder, I wanted to make sure everyone knew that I sent out a draft briefing package for the briefing on 10/21 .

Please also refer to email below. Thanks.

f y{,c; 'R. ()e,fte,yl,e, NRC ProJect Manager Diablo Canyon Power Plant Cooper Nuclear Station NRR/D0RL/LPL4-l

301-415-1014 From: ERIC OESTERLE [majlto:! . '>) b Sent: Sunday, October 19, 2014 7:53 AM To: Sebrosky, Joseph; Alexander, Ryan; Karas, Rebecca; Lupold, Timothy; Markley, Michael; Oesterle, Eric; Walker, Wayne

Subject:

Draft Briefing package for 10/21 Hey Folks, The purpose of this email is to provide you with a draft of the briefing package for the 10/21 breifing of NRR, NRO and Region IV management. I figured that they only way I could get this out for your review and comment in a timely manner was to cobble something together over the weekend. Attached please find the draft that I've prepared and please provide me your comments by COB Monday. Thanks for all your help and support!

Eric

From: Oesterte. Enc To: Lupold, Timothy: Alexander. Ryan: Karas. Rebecca: Madslev. Michael: Walker wavne Cc: ~ Maootv Kamal: w ,lsQn, Georoe* 5ebroskv Joseph

Subject:

RE: Draft Bliefing package for 10/ 21 Date: Tuesday, October 21, 2014 6:53:07 AM Attachments: draft Diablo Canyon Seismjc Status Brjefing 210ct2014,ootx

mage001.ong Importance

High Thanks Tim! I appreciate your input on the briefing slides. This new approach has been incorporated into the slides.

Everyone - Please review the attached updated briefing slides based on DE's input. The changes have been denoted in RED. Please get back to me with any changes no than 9AM. Thanks!

Eric From: Lupold, Timothy Sent: Monday, October 20, 2014 6:04 PM To: Oesterle, Eric; Alexander, Ryan; Karas, Rebecca; Markley, Michael; Walker, Wayne Cc: Li, Yong; Manoly, Kamal SUbject: RE: Draft Briefing package for 10/ 21 Last bullet on slide 13 is no longer the approach that will be used. The current plan is to discuss the curve developed by the licensee and note that it is enveloped by the Hosgri curve. An explanation of how uncertainty is treated will be included along with words that indicate the licensees approach is acceptable for use in an operability determination without addressing individual components for an exceedance at the higher frequencies, and that the approach will be further investigated under the review of the 2.1 information to be provided.

Slide 14 and 15 should be altered also. A seismic margin evaluation will not be completed.

From: Oesterle, Eric Sent: Monday, October 20, 2014 10:31 AM To: Alexander, Ryan; Karas, Rebecca; Lupold, Timothy; Markley, Michael; Walker, Wayne SUbject: FW: Draft Briefing package for 10/ 21 Good morning, Just in case my email from home ended up in your spam or trash folder, I wanted to make sure everyone knew that I sent out a draft briefing package for the briefing on 10/21 .

Please also refer to email below. Thanks.

f ,,-£,o R . o~ie, NRC Project Manager D1ablo Canyon Power Plant Cooper Nuclear Station NRR/D0RL/ LPL4 -1

301-415-1014 From: ERIC OESTERLE [mailto:I (b"6J ~

Sent: Sunday, October 19, 2014 7:53 AM To: Sebrosky, Joseph; Alexander, Ryan; Karas, Rebecca; Lupold, Timothy; Markley, Michael; Oesterle, Eric; Walker, Wayne

Subject:

Draft Briefing package for 10/21 Hey Folks, The purpose of this email is to provide you with a draft of the briefing package for the 10/21 breifing of NRR, NRO and Region IV management. I figured that they only way I could get this o ut for your review and comment in a timely manner was to cobble something together over the weekend. Attached please find the draft that I've prepared and please provide me your comments by COB Monday. Thanks for all your help and support!

Eric

~U.S.NRC United Sta tes N ucl ear Reg ula t ory Comm issio n Protecting People and the Environment Assessment of PG&E Operability Determination for New Seismic Information NRR, NRO and Region IV Status Briefing October 21, 2014 Contacts: J. Sebrosky (NRR/JLD), T. Lupold (NRR/DE), R. Karas (NRO/DSEA), R. Alexander (RIV),

W . Walker (RIV), M. Markley (NRR/DORL), and E. Oesterle (NRR/DORL) 1

~ U.S.NRC lJnit,*J S1.,1cs Nude2 r RC'1'111Jtory Commis~ ion Protecting People and th~ Environment Briefing Agenda

• Purpose

• Expected Outcomes

• Overview of Issue

• PG&E Seismic Report

• NRC Response/Action

• Current Status

• Next Step

• Decisional Environment 2

~ U.S.NRC Un iiccl ~1a 1~s N ude~ r Rt*g" l.u ory Com m i,sion Protecting People and the Envfro11me11t Purpose

• Inform NRR, NRO, and Region IV management of status on NRC activities/actions that respond to new seismic information for Diablo Canyon that indicates the Shoreline Fault discovered in 2008 is more capable than previously evaluated by licensee and confirmed by NRC to be bounded by the Hosgri evaluation described in the licensing basis 3

~ U.S.NRC li n itc d Scar.*, i-:ud car R~gula co ty Commi ssion Protecti1lg People and the E11viro11ment Expected Outcomes

• Alignment of NRC HQ and Region IV activities, plan, and next steps

• Clear understanding of current status and potential implications of outcomes

• Enhanced perspectives on environmental context in which NRC actions/decisions will be made 4

~ U.S.NRC Uni1cd S1.i1c, Nudca r Regul.11orr Co mm i.<sion Protecting Peopu and the E11uiro11mmt

Background

• Current licensing basis for Diablo Canyon seismic hazard includes DE, DOE, Hosgri (HE), & Long Term Seismic Program (LTSP)

• = = =

DE OBE (0.2g); ODE SSE (0.4g); HE additional case evaluated in 1977 during OL review (0. 75g); LTSP was a License Condition completed and reviewed in SSER 34

• Shoreline fault discovered in 2008 and evaluated by PG&E to be bounded by HE - operability assessment performed by licensee

• Independent confirmatory evaluation of Shoreline fault performed by NRC (RIL 12-01) concluded it was < HE 5

~ U.S.NRC lJni1cd Sra11*s l\:uclcar Rq;11IJ 1ory C:omm i,~ion Protecting Peopk a11d the E,wironnum t NRC Response Spectra from RIL 12-01 2.s 1 Hosg,1Spee1rum

- en C

2.0 ~

LTSP Spectrum NRC M6 7

• 84%

NRC M59

• 84%

• -..,e 0

1.5 ..

-u G>

G>

u

-..,e c( 1.0 u

G>

c.. 0.5 u,

0.0 ~-------------------------'--------------------------1---~------------------_J 0.1 1 10 100 Frequency (Hz) 6

~ U.S.NRC United S1,11c< 1'udear Rt>gulJwry Comm iss ion Protecting People a1td the Environmeut Background (continued)

• NRC issues 50.54(f) letter on March 12, 2012, to all licensees requesting seismic and flooding hazards re-evaluation

• NRC issues letter to PG&E (Oct. 12, 2012) documenting review PG&E Shoreline Fault Report and placing its assessment in the context of the 50 .54(f) process

- ... if new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed , the staff expects that the licensee will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staff's March 12, 2012, request for information. The staff will use this information to independently assess whether the new fault or new information related to the Shoreline fault challenges or changes the staff's current position that the motions associated with the Shoreline fault are at or below those levels of the HE and LTSP ground motions.

7

~ U.S.NRC Unit,*,! S1.1tc-, :sluclt'~r R~gubtory Co mmission Protecting People and the E11viro11ment PG&E Seismic Report

• geologic investigations underway to support requirement of AB1632 for report to CA when NRC issued Oct. 12, 2012, letter

• PG&E used new state of the art 20 and 30 onshore and offshore seismic reflection mapping

• PG&E informed NRC of preliminary results at drop-in meeting on August 22, 2014, and committed to provide report to NRC 2011 Shoreline Report Updated Parameters Fault Maxirn.im Minimum Mag. Maximum Minimum Mag.*

Length Dip (90th Length Dip (km) (degrees) fractile) (km) (degrees)

Shoreline 23 90 6.5 45 90 6.7 Hosgri 110 80 7.1 171 75 7.3 Los Osos 36 45 6.8 36 55 6.7 San Luis 16 50 6.3 16 50 6.4 Bay

• Report provided to CA and NRC on September 10, 2014 8

~ U.S.NRC Uni te<I State~ N uclear Rci:ul.1tory Cornmi,sion Protecting People and the E11vironme11t NRC Responses/Actions

• Approach - determine if PG&E operability determination is reasonable and there is no reason to deviate from 50.54(f) process

• Develop project plan and communication plan

• Region IV - initiate inspection of licensee's operability assessment (IR-2014-008) - request technical assistance from HQ

• HQ - develop technically defensible position to support inspection

• HQ - draft letter to licensee documenting inspection outcome and outlining next steps

• NRC and State of CA access to seismic report provided by PG&E several days prior to official issuance of report

• NRC initiated review of preliminary PG&E seismic report and developed requests for additional information 9

~ U.S.NRC lJ11i1cd ~1.11<*s J\: udear Rellulawry Commissio n Protecting Peopk and the E nvironment NRC Responses/Actions (continued)

• Region led telecons held with licensee to provide requests for additional information and for licensee to communicate requested information

• PG&E provided access to NRC via electronic reading room to review calculations, data, and graphs

• Based on review of the PG&E seismic report and additional information no one believes there is an immediate safety concern

• NRO developing assessment of PG&E seismic information (single station vs. Ergodic)

• NRO developing assessment of PG&E damping factors used for determining in-structure responses

• NRR developing assessment of licensee approach for use in operability determination 10

~ U.S.NRC lJnitcd Srar,:, Nuclear R~gul.,ory Comn,i.~s ion Protecti'1g People and the E 1111fro11ment 2.5 PG&E Single Station Sigma Approach 2

1.5

- -Hosgri

- - Los O!.os 3

~ San Luis Bay

- -Shoreline 1 --Shor eline-Hosgrl Linked

- - Design 0.5 0

0 .1 1 10 100 Frequency (Hz) 11

~ U.S.NRC l_;ni1 cJ S 1J t<CS 1'ud,*M Rc:i;ulJtcH)' Co m m1s, io 11 Protecting Peopk and the Enviro11me11t 2.5 PG&E Ergodic 2

1 .5

- - Hoi.gri

3 - - Lo~ Osos

~ - - s.an luis 8.ay

- - Sh o relin e 1 --ShorPline-Hosgri Lin ked

- - Design 0 .5 0

0 .1 1 10 1 00 Frequ ency (Hz) 12

~ U.S.NRC United Sr.tics Nuclear R,*gulaiory Com miss ion Protecting Peopk and the Environment Current Status

• PG&E expressed unwillingness to consider Ergodic approach and identify SSCs that may be impacted by HE exceedance

• Insufficient time and resources to investigate PG&E single station sigma approach to develop sufficient confidence level

• NRC expects to see the PG&E single station sigma approach combined with seismic risk information in 50.54(f) response in March 2015

• NRC approach to support operability inspection is to discuss the response spectra provided by the licensee, explain how uncertainty associated in these spectra is treated and conclude that the approach is acceptable for use in an operability determination

• The licensees approach will be investigated further when it is submitted as part of the March 2015 response to 50.54(f) letter 13

~ U.S.NRC United S1.1t<'S i':uclc:.ir lhcgulJco ry Com m i, ., io n Protecting People and the Envil'onmmt Potential Outcomes

1. NRC is able to conclude that licensees single station sigma approach is acceptable for use in their operability determination

- NRC letter to licensee documenting results of inspection and continued operability until NRC completes its review of 50.54(f) responses

- NRC concludes that the results from the new seismic information is insufficient to require deviation from the 50.54(f) process

2. NRC is not able to conclude that licensees single station sigma approach is acceptable for use in their operability determination

- N RC letter to licensee documenting results of inspection that there is no reasonable assurance of operability

- NRG concludes that DCPP units must either be shutdown or restricted from returning to operation following refueling outage until NRC approval following review of 50.54(f) responses due in March 2015 and completion of any required actions to ensure safety 14

~ U.S.NRC l,;ni1ed S1.11t*s :--:ucle~r Rq;ubrory C:ommi>sion Protecting People and the Environment Next Steps

• NRO/DSEA & RES complete seismic report technical assessment and provide input/review of writeup to support inspection report

• NRR/DE complete review of licensee approach for use in operability determination and provide input/review of writeup to support inspection report

• NRR/DORL consolidate write-ups to provide report to Region IV for use in completing IR-2014-008

• NRR provides concurrence on IR-2014-008

• Region IV complete IR-2014-008 and schedule Exit with licensee

• NRC management briefing to gain alignment and concurrence on follow-up actions for licensee

• NRC finalize letter to licensee providing assess1ment on operability and 50.54(f) process and issue to licensee 15

~ U.S.NRC U1111ccl State, Sudt,ar Rt'gul.11o ry Com m i,sio n Protecting Peopk and the E1111iro11ment Decisional Environment

• FOE Hearing Request - de facto license amendment

• FOIA- release of Sewell Report

• Sen. Markey Questions on 50.59s for SGR at Diablo

• FOE Hearing Request - license renewal LAR

• FOIA - timing of PG&E issuance of seismic report and NRC EDO decision on DPO appeal

• PDR request for release of DCPP FSARU Rev. 21

• Leak of DPO and publication in Press

• IG Report on SONGS 50.59s for SGR

• December 2014 Hearings - Senate & House 16

From: Oesterte. Eric To: Alexander. Ryan: Karas. Rebecca: Luootd. Timothy: Markley. Michael; Waiker. Wayne

Subject:

FW: Draft Briefing padcage fOf 10/ 21 Date: Monday, October 20, 2014 10:31:28 AM Attachments: QiabJo canyon se,smic Status Briefing 210ct2014,ootx imaae001.ono Good morning, Just in case my email from home ended up in your spam or trash folder, I wanted to make sure everyone knew that I sent out a draft briefing package for the briefing on 10/21.

Please also refer to email below. Thanks.

E vi& 'R. Oe¢e-vle,-

N RC Project Manager Diablo Canyon Power Plant Cooper Nuclear Slatton NRR/DO RL/LPL4-1 301-415- 1014 From: ERIC OESTERLE [mailto:1 Cbl(6) b Sent: Sunday, October 19, 201 7:53 AM To: Sebrosky, Joseph; Alexander, Ryan; Karas, Rebecca; Lupold, Timothy; Markley, Michael; Oesterle, Eric; Walker, Wayne

Subject:

Draft Briefing package for 10/21 Hey Folks.

The purpose of this email is to provide you with a draft of the briefing package for the 10/21 breifing of NRR, NRO and Region IV management. I figured that they only way I could get this out for your review and comment in a timely manner was to cobble something together over the weekend. Attached please find the draft that I've prepared and please provide me your comments by COB Monday. Thanks for all your help and support!

Eric

From: Oestede, Ede To: Sebrosky. Joseph Cc: Karas. Rebecca: Alexander. Ryan: Lupold. Timothy; waJker Wayne: MarkJey. MlchaeJ; w;1son. George

Subject:

Briefing slides Date: Monday, October 20, 2014 11:00:22 AM Attachments: PiabJo canyon Seismic Status Briefing 210ct2011.ootx 1maae001.ona Joe.

Thanks for your comments this morning on the briefing slides. l"ve updated the slides to incorporate your comments and include some other minor tweaks. All changes except for table added on slide 8 are in RED.

£y-[,o 'R. 0~1../

NRC Project Manager Diablo Canyon Power Plant Cooper Nuclear Station NRR/DORL/LPL4-1 301-415-1014

~U.S.NRC U n ired St ares Nuclear Regulato ry Co mmi ssion Protecting People and the Environment Assessment of PG&E Operability Determination for New Seismic Information NRR, NRO and Region IV Status Briefing October 21, 2014 Contacts: J. Sebrosky (NRR/JLD), T. Lupold (NRR/DE), R. Karas (NRO/DSEA), R. Alexander (RIV),

W. Walker (RIV), M. Markley (NRR/DORL), and E. Oesterle (NRR/DORL) 1

~ U.S.NRC l initcd !)rarrs Nuck,r R,*gul, rory Co111111 i.sio 11 Protecting Peopl.c 1111d the E11viro11ment Briefing Agenda

• Purpose

• Expected Outcomes

• Overview of Issue

• PG&E Seismic Report

• NRC Response/Action

• Current Status

• Next Step

• Decisional Environment 2

~ U.S.NRC l.Joitt*io n Protecting Peopu and the E11viro11me111

Background

• Current licensing basis for Diablo Canyon seismic hazard includes DE, DDE, Hosgri (HE), & LTSP (some difference of opinion of whether HE is also considered as SSE)

• DE =OBE (0.2g); DDE =SSE (0.4g); HE =additional case evaluated in 1977 during OL review (0. 75g); LTSP was a License Condition completed and reviewed in SSER 34

• Shoreline fault discovered in 2008 and evaluated by PG&E to be bounded by HE - operability assessment performed

• Independent confirmatory evaluation of Shoreline fault performed by NRC (RIL 12-01) concluded it was< HE 5

~ U.S.NRC United .~ oat<'< Nuclear Regulatory Commissio n Protecting People and the E11viro111ne11t NRC Response Spectra from RIL 12-01 2.s 1 Hosgr1Spectrum

--a, C

2.0 ~

LTSP Spectrum NRC M6 7

• 84%

NRC M5.9

• 84%

0

"' 1.5 *-

- Q)

C>

0 0

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0.0 ......__________________._....._....________~-----------....----------------------------

0.1 1 10 100 Frequency (Hz) 6

~ U.S.NRC l 'ni1c.! .Srare, Nudear Rq;ul.tor y Cnmnti,<ion Protecting People and the E1111fro11ment Background {continued)

• NRC issues 50.54(f) letter on March 12, 2012, to all licensees requesting seismic and flooding hazards re-evaluation

• NRC issues letter to PG&E (Oct. 12, 2012) documenting review PG&E Shoreline Fault Report and placing its assessment in the context of the 50.54(f) process

- .. . if new faults are discovered or information is uncovered that would suggest the Shoreline fault is more capable than currently believed, the staff expects that the licensee will provide the NRC with an interim evaluation that describes actions taken or planned to address the higher seismic hazard relative to the design basis, as appropriate, prior to completion of the evaluations requested in the NRC staffs March 12, 2012, request for information . The staff will use this information to independently assess whether the new fault or new information related to the Shoreline fault challenges or changes the staffs current position that the motions associated with the Shoreline fault are at or below those levels of the HE and LTSP ground motions.

7

~ U.S.NRC United Scat<"> Nuc lc:ar R..gubrory C:0111,ni"io n Protecting People and the Em,iromnml PG&E Seismic Report

• geologic investigations underway to support requirement of AB1632 for report to CA when NRC issued Oct. 12, 2012, letter

• PG&E used new state of the art 20 and 30 onshore and offshore seismic reflection mapping

• PG&E informed NRC of preliminary results at drop-in meeting on August 22, 2014, and committed to provide report to NRC

- Increased capabilities of Shoreline fault (6.7M vs. 6.5M)

- Changes to fault lengths (lengthened)

- Faults connected (Hosgri + San Simeon)

- Soil characteristics changed attention of seismic forces

- Damping factors for in-structure responses

• Report provided to CA and NRC on September 10, 2014 8

~ U.S.NRC L;nitcd Srares 1':u..:kar Rq;u!Jwry Commi>>1o n Protecting Peopk and the E11viro11mmt NRC Responses/Actions

• Approach - determine if PG&E operability determination is reasonable and there is no reason to deviate for 50.54(f) process

• Develop project plan and Communication plan

• Region IV - initiate inspection of licensee's operability assessment (IR-2014-008) - request technical assistance from HQ

• Develop technically defensible position to support inspection

• Draft letter to licensee documenting inspection outcome and outlining next steps

• NRC and State of CA access to seismic report provided by PG&E several days prior to official issuance of report

• NRC initiated review of preliminary PG&E seismic report and developed requests for additional information 9

~U.S.NRC l,;nitcJ ~rare< 1'ucl<*ar Rri:ul;wry Comnti,sion Protecting People and the Environment NRC Responses/Actions (continued)

• Region led telecons held with licensee to provide requests for additional information and for licensee to communicate requested information

• PG&E provided access to NRC via electronic reading room to review calculations, data, and graphs

• Based on review of the PG&E seismic report and additional information no one believes there is an immediate safety concern 10

~ U.S.NRC t :nitcJ \t.11("< Nuclc:ar Rcg11IJ101y Cornmi,sio n f'rotecti11g People and the Environment 2.S PG&E Single Station Sigma Approach 2

1.S

- - Hosgri

- -Los0$os

~

~ San Luis Bay

- - Shoreline

--Shoreline-Hosgri Linked *

- - Design Il o.s I

I i

0 0 .1 l 10 100 I Frequency (Hz)

_J 11

~ U.S.NRC Gni:cd S1~1<:< 1':ucle.ir Rei;ul.u ory Commission Protecting People and the E11viro11ment 2 .5 PG&E Ergodic 2

1.5

- -Hosgri

- - Los Osos

~

~ - - S.in Luis Bay

• - - Shoreline

\

1

~\.. - -Shorel ine-Hosgri Linked

-~ -- - - Design

'" ==

0 .5 0

0.1 1 10 100 Frequency {Hz) 12

~U.S.NRC U nited Srarc:< N uclc ;ir Regu latory Commi.<sio n Protecting People and the Environment Current Status

• PG&E expressed unwillingness to consider ergodic approach and identify SSCs that may be impacted by HE exceedance

• Insufficient time and resources to investigate PG&E single station sigma approach to develop sufficient confidence level

• NRC expects to see the PG&E single station sigma approach combined with seismic risk information in 50.54(f) response in March 2015

• NRC approach to support operability inspection is to determine whether there is sufficient seismic margin for SSCs impacted at frequency range that exceeds HE based on previous licensee evaluations and NRC reviews 13

~ U.S.NRC Un i1c,I .<;r;uc< l\:u d e:ir Reg,1lawry C om m i> sio n Protecting People and the E nvironment Potential Outcomes

1. NRC is able to conclude that sufficient seismic margin exists for SSCs impacted by HE exceedances in frequency ranges of concern to support operability inspection

- NRC letter to licensee documenting results of inspection and continued operability until NRC completes its review of 50.54(f) responses

- NRC concludes that the results from the new seismic information is insufficient to require deviation from the 50.54(f) process

2. NRC is not able to conclude that sufficient seismic margin exists for SSCs impacted by HE exceedances in frequency ranges of concern to support operability inspection

- NRC letter to licensee documenting results of inspection that there is no reasonable assurance of operability

- NRC concludes that DCPP units must either be shutdown or restricted from returning to operation following refueling outage until NRC approval following review of 50.54(f) responses due in March 2015 and completion of any required actions to ensure safety (CAL?)

14

~ U.S.NRC l,;nitnl S1a1c, Nuclear Rq;ul.11nry Co m111bs in n Protecting People and the E11viro11111e111 Next Steps

• NRO/DSEA & RES complete seismic report technical assessment and provide writeup to support inspection report

• . NRR/DE complete structural assessment of seismic margins and provide writeup to support inspection report

• NRR/DORL consolidate write-ups to provide technical report to Region IV for use in completing IR-2014-008

• NRO and NRR provide concurrence on IR-2014-008

• Region IV complete IR-2014-008 and schedule Exit with licensee

• NRR/DORL finalize letter to licensee providing follow-up actions

• NRC management briefing to gain alignment and concurrence on follow-up actions for licensee

• NRC issue letter to licensee 15

~ U.S.NRC Un ited State< Nudl':tr R~gul.1tor)* Commission Pmtecti11g People and the E ,wiromnem Decisional Environment

• FOE Hearing Request - defacto license amendment

• PDR request for release of DCPP FSARU Rev. 21

• FOIA - timing of PG&E issuance of seismic report and NRC EDO decision on DPO appeal

• Leak of DPO and publication in Press

• FOIA- release of Sewell Report

• Sen. Markey Questions on 50.59s for SGR at Diablo

• FOE Hearing Request - license renewal LAR

• IG Report on SONGS 50.59s for SGR

• December 2014 Hearings - Senate & House 16

From: Oest:edr Ede To: StovatL Scott: Munson. CJifford: Williams. Meoan; Li...1Qng; Hioschman. Thomas; Walker Wayne:~

~ George. AQdcea : Jackson Diane: p;francesco, N,chojas: Whaley. Sheena: Useldma. Lara : Ake...lQn; Burnell, Scott: OKeefe Neil* Farnholtz Thomas: Manoly KamaJ: Reynoso. John: HiJI Bnttaln: Harr;s. Brian:

Klett, Audrey: Dudek Michael: John Stamatakos: Stirewalt. Gerry: Burnanan. Theresa: weaver. Thomas:

Karas. Rebecca: Grajzer, Vladimir: Hiland Pamck: Ross-Lee Marylane* Lupofd. Timothy: Wilson. George:

Bowers Anthony: Alexander. Ryan: Hay. Mjchaef: Pruett Troy: Kock Andrea

Subject:

Status of Diablo Canyon Actlvlties Date: Thursday, October 09, 2014 7:02:34 AM Attachments: Status Update on ocpp toe Jenn ifec UhJe.docx 1maae003 ona The purpose of this email is to provide a status on the multitude of Oiablo Canyon activities that staff has been working on this week.

I. Status briefing provided to Jennifer Uhle on 10/6 (see attached agenda)

a. Based on review of PG&E seismic report and licensee responses to staff questions. additional information was determined to be needed to more fully understand licensee's application of single station correction (SSTC) methodology

b. Three additional questions were developed (total of 6 questions conveyed) and communicated to licensee on 10/3 - licensee understood questions 4 and 6 and indicated they can answer - question 5 required some rework and that will be communicated today or tomorrow

c. Outcome of briefing was an understanding that staff should be able to develop technically defensible position based on review of PG&E seismic report and licensee responses to the 6 staff questions without further "research" or visit to site to fully explore additional details of licensee application of SSTC methodology

d. Telecon held on 10/8 with Region IV and HQ technical staff to get alignment on path forward - NRO staff to develop writeup for technical evaluation report (TER) addressing adequacy of new PG&E seismic information to support operability determination - NRR to develop writeup for TER addressing ability of SSCs to withstand new seismic loading in high frequency ranges (i e . approx. 12 - 100 Hz) where there are minor exceedances of Hosgn spectra based on NRC developed ergodic curves)

e. Region IV concurred that above TER approach will provide adequate technical support for IR 201 4-008 which addresses licensee's operability evaluation based on new seismic information

f. Letter from NRC to licensee also being developed to refer to results of IR 2014-008 and to indicate that previously established path for seismic reevaluation per 50.54(f) response remains valid - timing of IR issuance and letter to licensee is critical and should be concurrent - goal for completion of TER. IR. and letter is near end of October

g. Briefings will be provided to OEDOs together with NRR front office:

Communications likely with individual Commissioners - to be reflected in Comm Plan that is under development and maintained current II. FOIA Request for public release of Sewell Report

a. Previous direction from Commission to not release Sewell Report was documented in Feb. 27, 2006. memo for M. Mayfield - because of this previous direction, new direction was needed from current Commission

b. COMSECY has been developed which informs Commission of staffs intent to release Sewell Report along with several other documents which puts Sewell Report into appropriate context - COMSECY is currently being routed for commenUconcurrence at Division Director level (NMSS, NRO/DSEA, NRR/DE, NRR/DORL) - goal is to issue today (10/9/10) -

outreach on COMSECY performed with CNRWA, Region IV, OPA, OCA and other stakeholders

c. Comm Plan concurrently in development to support release of Sewell Report and associated documents - being coordinated with Region IV, OPA. and OCA

d. FOIA request completion targeted for 10/16 but prepared to request extension to support Commission action - discussed with FOIA Coordinator Ill. Filings associated with Friends of the Earth (FOE) Hearing Request

a. NRC response to FOE hearing request filed 10/6

b. Additional filings also made by PG&E. NEI. and PG&E Senior Civil Engineer on 10/6

c. Next steps - FOE response within 7 days and, also within 10 days of the PG&E's answer and NEl's motion and brief, everybody else (NRC Staff included) can file a motion asking the Commission to take some action against the other filings (e.g. strike part of the answer) - review of the other 3 filings underway IV. FOE FOIA request on timing of PG&E Seismic Report and DPO Appeal decision

a. Information from various offices received by FOIA coordinator - going through duplication review

b. Expected release of documents in packages - first one expected this week

c. Review of remaining packages for withholding to be performed to support releases expected week of 10/13.

V. EPW Questions - DORL staff continues to work with Region IV and NRR/DE on finalizing draft responses - coordinating with OCA - target issuance by 10/22 There continues to be a lot of activity associated with Diablo Canyon and I appreciate everyone's support. We are making good progress on these challenging issues and have completed some tasks associated with making portions of the DCPP UFSAR publicly available and getting two very important SSERs into the main ADAMS library. If I have missed something that you are particularly interesting in please don't hesitate to contact me. Thanks!

CYI.OR. C)~le, NRC Project Manager Diablo Canyon Power Plant Cooper Nuclear Station NRR/D0RL/LPL4- l 301-415-1014

llAII' * ~-. ' * * ..,

~/~ *~

. *.. v.*"

Status Update on NRC Activities associated with Diablo Canyon Seismic Report I. NRC is in inspection space - Inspection Report 2014-008

a. technica l evaluation report summarizing HQ staff assessment to support IR

b. NRC letter to license - continue w/ 50.54(f) or alternate approach

c. Communication Plan development to support issuance of IR and NRC letter to licensee

d. Project Plan updates II. NRC assessment of AB1632 seismic report

a. Licensee provides overview 9/18 - discusses deltas from 2011 Shoreline fault report

b. NRC identifies need for addit ional information - communicates 3 Q's to licensee on 9/22

c. Licensee provides addition information on 9/29

d. NRC develops comparison spectra - requests additional information 3 Q' s on 10/3

e. Follow-up telecom w/ licensee later part of week of 6 Oct 2014 (potential for site visit)

- PG&E Shore' ne l onked Shoreline Linked t:reod1C - Hose r, 2.5 2

• l 5

• 0.5 0  !

01 10 100 Frequency (Hz)

Ill. Schedule

a. Expect TER completion - end of October

b. Expect IR 2014-008 completion - end of October

c. Expect NRC letter to Licensee on 50.54(f) process - end of October

d. Timing of TER, IR, and Letter to Licensee critical - must follow sequence above IV. Other Activities and Schedule considerations

a. PG&E held open house 10/2/14 to discuss results of seismic report - no NRC attendance

b. PG&E has decided there will not be another public SSHAC meeting

c. Region IV considering NRC public meeting- tentative December 2014 timeframe

d. Congressional Hearings - tentatively December 2014 timeframe

V. Additional NRC st aff activities (5 - 6 PMs currently supporting DCPP activities)

a. Friends of the Earth FOIA response - in process

b. EPW Congressional Question response - in process

c. PDR request for release of latest DCPP FSAR update - complete

d. Support for response to FOE hearing request - complete (expect issuance 10/6)

e. FOIA request for release of Sewell Report - in process

f. Place SSER 7 into ADAMS main library - in process

g. Place SSER 34 into ADAMS main library- in process

h. Assignment of new NRC PM for DCPP (10/6/14)

i. Bill Dean briefing (tentatively 3 rd week Oct.)- request feedback from J. Uhle

j. DEDO Briefing (tentatively 3 rd week of Oct.)- request feedback from J. Uhle

k. CA Briefing (tentatively 3rd week of Oct.)- request feedback from J. Uhle

From: wnsan George To: Eyans, HidJele: Lund. Loyise Cc: Markley Michael: Broaddus, pgug: Khanna, Meena: Beasley. Benjamin: Ennis, B1ck : Schaaf, Robert Subject 084s items for Monday"s meeting Date: Monday, October" 06, 2014 8:34:50 AM Region 1 Non-Responsive Record Non-Responsive Record Non-Responsive Record Non-Responsive Record Non-Responsive Record Region 4 Diablo Canyon -

• Briefing with Jennifer Uhle on the status of analysis to support RIV inspection of the new seismic report provided by PG&E to the State of California. Questions prepared by NRR/NRO/RES for RIV to ask licensee. Outcome is expected to be an assessment of operability in the RIV inspection report and a technical evaluation report summarizing the Headquarters assessment at 0130.

• Friends of the Earth request for hearing - petition response due to Commission 10/6 (today) (DORL comments sent to OGC, OGC recommends not granting hearing)

• Friends of the Earth FOIA- alleging collusion between the NRC and PG&E on DPO and AB1632 report to California expected to be finalized between OIS and NRR this week.

• Response to EPW questions still progressing with expected response to be provided by 10/22

• Two Commission votes are in for the release of the Sewell tsunami hazards report which has been withheld for approximately 10 years. The reports was requested by former NRC RES Director, Bob Budnitz on behalf of the California Energy Commission View ADAMS PS Properties MLJ4276A548 Open ADAMS P8 Packa~e (Sewall Report Release.) Lots of coordination to communicate with OPA, OCA, and NMSS. Likely to have major resource impacts.

Non-Responsive Record Non-Responsive Record Non-Responsive Record George Wilson Acting Deputy Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation USNRC 301-415-1711 Office 08E4

(0)(5)

Neil From: Roth(OGC), David Sent: Wednesday, October 01, 2014 2:37 PM To: OKeefe, Nell; Sebrosky, Joseph; Manely, Kamal; Li, Yong Cc: Wachutka, Jeremy; Lindell, Joseph; Young, Mitzi; Roth(OGC), David; Mizuno, Beth; Tibbetts, John

Subject:

RE: DER master do not edit without dave's pemission 2012 09 22 NRC Staff Answer to FOE Diablo Petition to Intervene Good afternoon tech staff.

I heard from Joe (thank you) but nobody else. Attached please find the revised filing.

Please review it for tech accuracy and respond back to your legal team by tomorrow morning (10:00 is fine) .

As a reminder. do not re-distribute attorney-client information (including this e -mail and attachment). Please see Yellow Announcement 2014-102 for more information. shouldn't re-send the document.

Margaret M. Doane DISSEMINATION OF DOCUMENTS ISSUED BY THE General Counsel OFFICE OF THE GENERAL COUNSEL Posted: August 29. 2014 David Roth 5

NRC Blackberry! (ll ( >

HQ Office (301) 415-2749 TR is FRessa~e A-lay eeAtBiFI sc: :sili cc ii 1tc1, ,al i, 1fo1,, 1atio1, eo, 1side1 ed to be Official ase e1119

A~C~-or roorrieywor From: Roth(OGC), David Sent: Wednesday, October 01, 2014 2:43 PM To: OKeefe, Nell; Sebrosky, Joseph; Manoly, Kamal; Li, Yong Cc: Roth(OGC), David SUbject: RE: DER master do not edit without dave's pemisslon 2012 09 22 NRC Staff Answer to FOE Diablo Petition to Intervene Good afternoon, We have created an updated version of the Staffs (your) position on the Friends of the Earth request for a hearing in Diablo. The actual filing date is Monday. Neil, Joe, Kamal, Yong, are you in the office today (Wednesday)?

David Roth 61 NRC Blackber~ <b <

HQ Office (301) 415-2749

~ :: se11siti,e i11le11 ,al i11fo1111alio11 co11sid111Pt1 II! tie From: OKeefe, Neil Sent: Monday, September 22, 2014 4:25 PM To: Roth(OGC), David; Sebrosky, Joseph; Manoly, Kamal; Li, Yong

Subject:

RE: DER master do not edit without dave's pemission 2012 09 22 NRC Staff Answer to FOE Diablo Petition to Intervene Importance: High Dave, I have reviewed the document, and find no technical errors or concerns.

Neil O'Keefe Chief, Branch B DRP, RIV 1817) 200-1141 (o)

(bJ(6J l(c)

From: Roth(OGC), David Sent: Monday, September 22, 2014 11:20 AM To: Sebrosky, Joseph; Manoly, Kamal; OKeefe, Neil; LI, Yong SUbject: Fw: DER master do not edit without dave's pemission 2012 09 22 NRC Staff Answer to FOE Diablo Petition to Intervene

Please review attached immediat ely for tech accuracy. We need a very fast turnaround before 2:00 today. Sorry for the short not ice. Do not forward this email or the attached document.

David Roth Ofrice of the General Counsel Office (301 415-2749 Work Cell {b)(6)

Sear (corn NBC BlackBerry I (b)(6) I From : Roth(OGC), David Sent: Monday, September 22, 2014 12:07 PM To: Tibbetts, John Cc: Mizuno, Beth; Young, Mitzi; Lindell, Joseph; Wachutka, Jeremy; Roth(OGC), David

Subject:

DER master do not edit without dave's pemission 2012 09 22 NRC Staff Answer to FOE Diablo Petition to Intervene

John, As we discussed, I'm done and you now have permission finalize (for Ed) the filing.

Please work from the DER master in the G: drive, so everyone knows that you have it locked for editing.

(0)(5)

John, the file has auto TOC and uses styles for footnotes and for heading levels 1 to 3.

I didn't add a TOA there might be one footnote with TOA hypertext markup.

From: Sebrgsky Joseph To: w;,son George Cc: Oestede, Enc: Markley. M,chaeJ

Subject:

FW: draft agenda for status update for j. uhle Date: Monday, October 06, 2014 5:59:JS AM Attachments: Status update on QCPP for Jem,ter Vble,doc;x dtablo pm wor1c assjgnmeot.dooc Draft Questions for pGE

• RIV compiJabon.d()(J(

imaaeoo1pna George.

Per our discussion this morning, I sent you the scheduler for the 1:30 pm briefing of Jennifer later today. Attached is the draft agenda that Eric developed over the weekend for the briefing. In Eric's email below he mentions a plot (below is the plot that he will include in the agenda). Also per our discussion, attached is a list of diablo pm assignments that provides a description of the various items that have been released and will be released to the public (including the Sewell report) shortly. Lastly. I included the 3 questions that were verbally provided to PG&E on Friday with the expectation that there will be a phone call later this week.

Let me or Eric know if you have any questions.

Thanks, Joe

- PG&E Shoreline Linked - - Shoreline Linked Ergod;c - Hosgri I 2 1

1.5 1,_ __

1 -

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0 0 .1 1 10 100 i Frequency (Hz)

From: ERIC OESTERLE [mailto~ (b 5

> b Sent: Sunday, October OS, 201...

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To: Sebrosky, Joseph; Markley, Michael

Subject:

draft agenda for status update for j. uhle

Guys, Attached is the draft agenda for the status update to Jennifer Uhle that has been scheduled for 1 :30PM on 10/6/14. Thought it would be good to send out prior to tomorrow. The only thing that I wanted to add to the agenda but can't do until I get back to office is the Shoreline linked ergodic spectra developed by NRC staff comparison to PG&E Shoreline linked SSTC and Hosgri. I beleive that Jennifer will appreciate that level of detail. Please let me know ASAP if you have any comments on draft agenda. Thanks.

Eric

From: sebrosky. Joseph To: Vaidya Bhalchandra: Klett. Audrey: Harris. Brtan Cc: Oesterle. Eric: Markley, Michael: Alexander. Ryan: Walker. Wayne; Hloschman. Thomas

Subject:

info: cancellation of 9:00 am diablo canyon pm meeting Date: Tuesday, October 07, 2014 7:08:06 AM Attachments: dlablo om work assjonment.docx Bhalchandra. Audrey, and Brian, I sent you a scheduler cancelling the 9:00 am (eastern) Diablo Canyon meeting today.

The reason that it was cancelled is that Jennifer Uhle requested that Eric and I attend the 9:00 am Commission meeting on Fukushima seismic issues in the event questions regarding Diablo Canyon are asked. Attached is the latest Diablo status table. We expect to hear back from Paris So today on the FOE FOIA and someone will be provided with the opportunity to review documents to determine whether or not they can be released. In addition, the path forward on the FOIA for the Sewell report has changed. We had received direction from the Commission to release the report after we had developed a communication plan to ensure that we are prepared for the questions associated with the release of the report. It now appears that the Commission would like to have a COM-SECY written on the release of the report and the Commission formally vote prior to it being released. More details are to follow.

Ryan and Wayne - Eric or I will give you a call filling you in on the background for why we were requested to attend the Commission meeting and the latest direction on release of the Sewell report.

Let me know if you have any questions.

Thanks, Joe

Diablo PM Work ASSI. Jnmen1it ,f 10/6/14

1. Work assignment PM(s) !Status - 10/6/14 Date Information Released to the Public 1 Public document room request to release Bhalchandra Vaidya tomplete - 10/1/14 portions of latest Diablo FSAR ML14269A007 Publicly available in ADAMS las of 10/1/14

~ Support for response to FOE hearing request Eric Oesterle, Joe In process - target issuance 10/6/14 10/6/14 - tentative Sebrosky 3 FOIA review of Sewell report Eric Oesterle In process - target date for issuance is 10/6/14 - tentative 10/6/14 14 SSER 7 placed in ADAMS main library Alan Wang , Eric In process - document has been recalled 10/6/14 - tentative Oesterle rrom storage and will be placed in the

~DAMS main library ETA for document being in main library is 10/1/14 5 SSER 34 placed in ADAMS main library Eric and Joe !Version already exists in ADAMs but not 10/6/14 - tentative isure the veracity of the main library document (no cover letter with the SSER).

May need to recall from storage.

6 Friends of the Earth (FOE) FOIA response - Eric Oesterle, Joe In process - staff collecting information. 10/8/14, partial timing of release of DPO coincident with Sebrosky, Balwant FOIA coordinator would like to begin release with more release of State of California report Singal, Peter Bamford, releasing information around 10/8 in a information to follow and Bhalchandra staggered fashion as redactions are Vaidya . completed 7 EPW congressional question response Eric Oesterle and Joe In process - internal meeting on 10/2 to NIA will not be Sebrosky !discuss draft response. Target for NRR/DE released to the public input is 10/10/14. Targeting providing response to OCA around 10/17 or 10/24 a Continuing support of RIV operability Eric Oesterle and Joe In process (see project plan) End of Ocotober determination Sebroskv

~ Development of communication plans for Brian Harris In process - draft communication plan NIA will not be release of operability inspection report and issued on 10/2 released to the public NRR letter to licensee including identification of management briefings and possibility of Commissioners Assistant note 10 Development of format for TER to be Audrey Klett In process - Audrey to work with Ryan N/A will not be referenced/included in inspection report and Alexander. Rebecca Karas, and Tim Lupold released to the public NRR letter to the licensee. NRR letter will also reference inspection report

10/2/2014 Questions for PG&E Concerning Operability Determination

1. Provide the bases for use of the Empirical Site-Specific methodology to estimate the site response amplification for OCPP since:

a. Only two earthquakes (2003 San Simeon and 2004 Parkfield) are available to implement the approach. In particular, both of these earthquakes occurred at source-to-site distances (35 km for San Simeon and 85 km for Parkfield) and at azimuths that differ from the postulated deterministic scenario events, which occur at much closer source-to-site distances and generally offshore of OCPP.

b. A comparison of the response spectrum calculated from the strong motion free-field record of 2003 Deer Canyon earthquake at DCPP with the predicted response spectrum from the NGA-West 2 GMPEs modified with the Empirical Site-Specific Term (ESST) shows a large under prediction of the spectral accelerations over a wide range of frequencies.

2. The 2011 PG&E Shoreline Fault Zone Report showed the 84th percentile response spectra from the postulated deterministic scenario events using both the Analytical Generic and Empirical Site-Specific site response methodologies to estimate the site response amplification. Provide the basis for using only the Empirical Site-Specific site response methodology to estimate the site response amplification for the 2014 Central Coastal California Seismic Imaging Project (CCCSIP) Report.

a. In addition, if the Analytical Generic site response methodology was used rather than the Empirical Site-Specific methodology to develop the 841h percentile response spectra from the deterministic scenario events, would there be any effect on the operability of any safety-related SSCs. and if so which SSCs?

b. If there would not be any effect on operability, then explain why not, including whether the 841h percentile response spectra for any of the postulated deterministic scenario events would exceed the 1977 Hosgri spectrum, and for what frequency ranges.

3. Were the fault rupture scenarios listed in Table 1-1 of Chapter 14 developed based on the definition of a capable fault, per 10 CFR Part 100, Appendix A or are they worst-case scenarios adopted from the current PSHA seismic source evaluation study?

If the former, what is the technical bases supporting the deterministic fault rupture scenarios listed in Table 1-1 of Chapter 14?

i. How do these technical bases correspond to the capable fault criteria?

ii. In particular, is there any evidence beyond the possible offset of one of the multiple paleo-stream channels in San Luis Bay for fault displacement on the Shoreline Fault within the last 35,000 years per criteria 1 of the Appendix A definition?

iii. Is there any geological or seismological evidence to support a linked rupture on the Hosgri and San Simeon faults or the Hosgri and Shoreline faults, per criteria 3 of the Appendix A definition?

Status Update on NRC Activities associated with Diablo canyon Seismic Report I. NRC is in inspection space - Inspection Report 2014-008

a. technical evaluation report summarizing HQ staff assessment to support IR

b. NRC letter to license - continue w/ S0.54(f) or alternate approach

c. Communication Plan development to support issuance of IR and NRC letter to licensee

d. Project Plan updates II. NRC assessment of AB1632 seismic report

a. Licensee provides overview 9/18 - discusses deltas from 2011 Shoreline fault report

b. NRC identifies need for additional information - communicates 3 Q's to licensee on 9/22

c. Licensee provides addition information on 9/29

d. NRC develops comparison spectra - requests additional information 3 Q's on 10/3

e. Follow-up telecom w/licensee later part of week of 6 Oct 2014 (potential for site visit)

Ill. Schedule

a. Expect TER completion - end of October

b. Expect IR 2014-008 completion - end of October

c. Expect NRC letter to Licensee on 50.54(f) process - end of October

d. Timing of TER, IR, and Letter to Licensee critical - must follow sequence above IV. Other Activities and Schedule considerations

a. PG&E held open house 10/2/14 to discuss results of seismic report - no NRC attendance

b. PG&E has decided there will not be another public SSHAC meeting

c. Region IV considering NRC public meeting- tentative December 2014 timeframe

d. Congressional Hearings - tentatively December 2014 timeframe V. Additional NRC staff activities (S - 6 PMs currently supporting DCPP activities)

a. Friends of the Earth FOIA response - in process

b. EPW Congressional Question response - in process

c. PDR request for release of latest DCPP FSAR update - complete

d. Support for response to FOE hearing request - complete

e. FOIA request for release of Sewell Report - in process

f. Place SSER 7 into ADAMS main library- in process

g. Place SSER 34 into ADAMS main library - in process

h. Assignment of new NRC PM for DCPP (10/6/14)

i. DEDO Briefing (tentatively 3rd week of Oct.)

j . CA Briefing (tentatively 3*d week of Oct.)

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To: UtJ!e lcno:f@r* MMh!ex M@Kt* ~ W*kon @w CC: ~ ~ t!illllUu,}Q Subje<t: RE: Ooablo cafl)OO Date: Monday, September 29, 201* S:S.:09 AM Ati.dunents: info status ol diablo mrabtlitv CC'OCW 9*25*11 msg lmog@Jona Jennifer.

Attached is the latest on the status of Diablo Canyon issues. There are two issues that the staff believes it needs to address before it can provide you with a recommendation on how to proceed (i.e., single station approach and updating calculations used to resolve the DPO). We received data from PG&E on 9/26 on the single station approach and expect to receive more data today on the DPO calculations. There is a tech staff meeting on 10/1 at which time we hope to be able to make a decision on whether or not we have enough information to make a recommendation or if we need more information or more time. The two issues are discussed in greater detail below. You should also know that Audrey Klett and Brian Harris (JLD PM) have been brought in to help to develop the recommendation letter on whether or not the licensee should proceed with assessing new seismic information using the 50.54(1) process and the communication plan associated with the issuance of an inspection report and the letter back to the licensee based on the data in the 2014 State of California report.

Single station approach - PG&E provided ground motion response spectrums that used a single station sigma correction

{see plots below). The single station approach is discussed in RIL 12-01 (see ML121230035). The single station approach can be used to address some of the uncertainty in the ground motion predication equations if high-quality data from a modern seismographic network are available. The single station approach at Diablo was developed based on data from three earthquakes. Although the RIL discusses the single station approach the NRC's deterministic evaluation did not rely on the single station approach so the 2012 RIL curves do not look like the curves below. Jon Ake and Cliff do not think this is a problem. At the time of the RIL the single station approach was new. The approach has since received wider peer reviews and is generally accepted today If you look at the attached status the first two questions that we asked (which PG&E subsequently provided the data on 9/26) have to do with the single station approach. We have asked for the raw data from three earthquakes to independently verify aspects of the single station approach. If Jon and Cliff are comfortable with how the curves below were developed based on the data from these three earthquakes then their recommendation will be to proceed with the 50.54(1) process. If they are not comfortable then a different recommendation from them will be possible. We just received the raw data and there 1s a meeting scheduled on Wednesday (10/1) for the technical experts to discuss the issue and determine the following:

,, We have enough information to make a recommendation o We need more information o We need more time

• Rerunning of DPO calculations - PG&E is in the process of rerunning calculations used to support the resolution of the DPO (see description in DPO case file pdf page 62 of 164 at ML14252A743 which discusses the scaling factors used in the March 2014 PG&E analysis). PG&E indicated that 1t did not beheve that the analysis was needed to demonstrate operability. Nevertheless, PG&E is rerunning the analysis with the data from the 2014 State of California report. We expect to see the results of these calculations today (i.e ., 9/29). There 1s great disagreement with in the technical staff as to whether or not these calculations have merit. On 9f19 it was decided by Division Directors (i.e ., Pat Hiland (DE), Mike Markley (DORL), Andrea Kock (NROIDSEA), and Mike Hay (RIVIDRPJ). that we would request the calculations as part of our information needs because similar calcula,tions were key to resolving the OPO and the DPO appeal. This issue will also be discussed at Wednesday's technical staff meeting.

Please let me know if you have any questions or 1f you want me to arrange a briefing for you on the current status

Thanks, Joe

1977 HE spectrum 1991 LTSP/SSEA34 spectrum PB - Linked Hosgri and San Simeon (M 7 .3)

PB - Los Osos (M 6.7)

PB - San Luis Bay (M 6.4)

PB - Shoreline (M 6.7)

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From: Uhle, Jennifer Sent: Friday, September 26, 2014 6:37 PM To: Markley, Michael; Sebrosky, Joseph; Lund, Louise; W~SOll1, George

Subject:

[)jablo canyon HI guys. I meant to get an update on where we were with regard to our documenting our *analysis/revew" of the information the licensee provided to the State. I know we cannot use the delta-CDF approach. I wanted to ensure that we are not over doing our review. If the seismic experts take a look at the information and do a review and conclude that little if any change In the hazard results from the new discovery of a lengthened shoreline fault, then they can document that. That would mean there is nothing that would make us change the date of the March submittal for the licensee's reevaluation. Is that where we are and has that been communicated to the seismic guys? Thanks. Jennifer

From: Sebrosky, Joseph Sent: Thursday, September 25, 2014 12:51 PM To: Stovall, Scott; Munson, Clifford; Williams, Megan; Li, Yong; Hipschman, Thomas; Walker, Wayne; Oesterle, Eric; Singal, Balwant; Markley, Michael; Jackson, Diane; DiFrancesco, Nicholas; Whaley,, Sheena; Uselding, Lara; Ake, Jon; Burnell, Scott; OKeefe, Neil; Farnholtz; Thomas; Manoly, Kamal; Reynoso, John; Hill, Brittain; Dudek, Michael; John Stamatakos Ostam@swri.org); Stirewalt. Gerry; Buchanan, Theresa; Weaver, Thomas; Karas, Rebecca; Graizer, Vladimir; Hiland, Patrick; Ross-Lee, MaryJane; Lupold, Timothy; Wilson, George; Bowers, Anthony; Alexander, Ryan; Hay, Michael; Pruett, Troy; Kock, Andrea; Harris, Brian; Vaidya, Bhalchandra; Klett, Audrey; Smith, Chris

Subject:

info: status of diablo operability review 9-25-14 To all, The purpose of this email is to provide you with updated status regarding the Diablo Canyon operability review.

This email includes updates on the status of NRC inspection information requests and the assignment of additional headquarters PMs to help with the workload.

• Based on discussions RIV had with PG&E today, PG&E is targeting providing information that was requested on 9/22 either late today or sometime tomorrow to support the NRC's review of the operability determination. The information that RIV requested was in the following 3 areas:

1) Provide, as available, the earthquake recordings (time histories and response spectrum ordinates) from the 2003 San Simeon, 2003 Deer Canyon, and 2004 Parkfield earthquakes as recorded at stations ESTA 27 and ESTA 28. These data should reflect the final processed values as used by PG&E in the CEC report.

2) Provide the Vs profiles for the power block and turbine building as well as stations ESTA 27 and ESTA 28 as described in the first paragraph of Section 3. 2 of the technical report GEO.DCPP. TR. 14.06, Rev. O (also Ch 11 of the AB1632 CEC Report) . Each of the profiles should indicate the starting elevation point for the top of the profile.

3) Provide the results of the calculations that were rerun based on the calculations used to support the resolution of the DPO (see description in DPO case file pdf page 62 of 164 at ML14252A743 which discusses the scaling factors used in the March 2014 PG&E analysis). PG&E indicated that it did not believe that the analysis was needed to demonstrate operability. Nevertheless.

PG&E was rerunning the analysis with the data from the 2014 State of California report.

o Access to the information will be via certrec. The following individuals should have received emails yesterday explaining how to access the information (if you have not received an email please inform Ryan Alexander):

NRC HQ Brittain Hill Brittain.Hill@nrc.gov Kamal Manely Kamal.Manoly@nrc.gov Yong Li Yong.Li@nrc.gov Clifford Munson Clifford.Munson@nrc.gov Jon Ake Jon.Ake@nrc.gov NRC Region IV Megan Williams Meqan.Williams@nrc.gov 1

Chris Smith Chris.Smith@nrc.gov Ryan Alexander Ryan.Alexander@nrc.gov

• Lastly there are now 5 headquarters PMs helping with the Diablo workload. The PMs include me, Eric Oesterle (acting branch chief - future Diablo PM), Bhlachandra Vaidya, Audrey Klett and Brian Harris.

Attached is the list of the PM assignments. Each activity has its own support needs so the attached list is not meant to include a list of the support from RIV. NRR/DE. NRO, and RES. The purpose of sharing this information is to ensure you are aware of the PMs that are new to the project so that in the event that they give you a call you will not be surprised.

diablo pm work assignment.doc ...

In the near term Bhalchandra is helping with processing of a Friends of the Earth (FOE) FOIA and redacted portions of the Diablo FSAR for public release. Audrey is developing an outline for the technical evaluation input that will be provided as a feeder to the inspection report and the NRR letter, and Brian Harris is developing the communication plan to support the issuance of the inspection report and the NRR letter.

• As a gentle reminder the project plan has been updated. The latest version of the project plan can be found at: View ADAMS PB Properties Ml14260A102 Open ADAMS PB Document (Project Plan for NRC Staff Review of PG&E's Report to the State of California Regarding Seismic Faults Near the Diablo Canyon Power Plant.}

Please let me know if you have any questions.

Thanks, Joe 2

Work assignment PM(s) Status - 9/25/14 Friends of the Earth (FOE) FOIA Eric Oesterle, Joe Sebrosky, In process - staff response Balwant Singal, Peter Bamford, ~ollecting information and Bhalchandra Vaidya.

EPW congressional question Eric Oesterle and Joe In process - target for response Sebrosky providing draft to RIV 10/1/ 14 Continuing support of RIV Eric Oesterle and Joe n process (see project operability determination Sebrosky plan)

Development of communication Brian Harris n process - target for plans for release of operability clraft early week of 9/29 inspection report and NRR letter to licensee including identification of management briefings and possibility of Commissioners Assistant note Development of format for TER to Audrey Klett In process - Audrey to be referenced/included in work with Ryan inspection report and NRR letter ~lexander, Rebecca to the licensee. NRR letter will Karas, and Tim Lupold also reference inspection report Public document room request to Bhalchandra Vaidya In process - expect release portions of latest Diablo release of portions of the FSAR FSAR week of 9/29 Support for response to FOE Eric Oesterle, Joe Sebrosky In process hearinQ request

from: MaoolY Kamal To: Sebrosky. Joseph Cc: HIii. Brittain: Munson. Clifford: Ll....:lim; Markley, Michael: Hiland. Patrick: Ross-Lee. MaryJane: ~

Karas Rebecca: weaver, Thomas: John stamatkos: Whaley. Sheena: Young. Mitzi: OKeefe. Neil; Roth/OGCl,

~ I upgtd J)mothy: Williams Megan

Subject:

RE: info: stal\Js or dlablo operability review 9*D* 14 Date: Wednesday, September 24, 201'1 2:58:48 PM Joe, With regard to the third bullet in your email below about PG&E rerunning the calculation used to support the resolution of the DPO, I concur with PG&E's assertion that such analysis was not really needed to demonstrate operability. The reason is that the threshold to demonstrate operability is based on fundamentally different basis than that used to establish compliance with the licensing basis.

Nonetheless, we will have the opportunity to review the re-evaluation to validate the original conclusion.

Kamal Manoly From: Sebrosky, Joseph Sent: Tuesday, September 23, 2014 6:05 AM To: Stovall, Scott; Munson, Clifford; Williams, Megan; Li, Yong; Hipschman, Thomas; Walker, Wayne; Oesterle, Eric; Singal, Balwant; Markley, Michael; Jackson, Diane; DiFrancesco, Nicholas; Whaley, Sheena; Uselding, Lara; Ake, Jon; Burnell, Scott; OKeefe, Neil; Farnholtz, Thomas; Kanatas, catherine; Roth(OGC), David; Manoly, Kamal; Reynoso, John; Hill, Brittain; Dudek, Michael; John Stamatakos (jstam@swri.org); Stirewalt, Gerry; Buchanan, Theresa; Weaver, Thomas; Karas, Rebecca; Graizer, Vladimir; Hiland, Patrick; Ross-Lee, MaryJane; Lupold, Timothy; Wilson, George; Bowers, Anthony; Alexander, Ryan; Hay, Michael; Pruett, Troy; Kock, Andrea; Young, Mitzi; Harris, Brian

Subject:

RE: info: status of diablo operability review 9-23-14 To all, The purpose of this email is to provide you with the results of an inspection phone call with the licensee yesterday (9/22) regarding the Diablo Canyon operability review.

Yesterday (9/22) RIV led a call with the licensee to discuss information needs to support the Diablo Canyon operability review. The following two information needs were verbally discussed with the licensee:

1) Provide, as available, the earthquake recordings (time histories and response spectrum ordinates) from the 2003 San Simeon, 2003 Deer Canyon, and 2004 Parkfield earthquakes as recorded at stations ESTA 27 and ESTA 28. These data should reflect the final processed values as used by PG&E in the CEC report.

2) Provide the Vs profiles for the power block and turbine building as well as stations ESTA 27 and ESTA 28 as described in the first paragraph of Section 3.2 of the technical report GEO.DCPP. TR.14.06, Rev. 0 (also Ch 11 of the AB1632 CEC Report). Each of the profiles should indicate the starting elevation point for the top of the profile.

The rest of this string may be found as document C/39 in FOINPA-2015-0071 (ML15181A428).

From: Sebrosky Joseph To: Hill. Brittain Cc: Alexander. Ryan: Walker. Wayne: Karas Rebecca: Munson Clifford:~ .!.!....YP.asl.; Manoly. Kama!;

Oesterle. Enc: MarkJev. Michael: Williams. Megan: H1Qschman. Thomas S ubject: question: status of Olablo DOE calcs associated with operability review 9*23* 14 Date: Tuesday, September 23, 2014 6:36:17 AM

Britt, To answer your question below regarding the Diablo DOE calcs that should be available by the end of the week associated with the operability determination, I expect that the calcs will be made available in an electronic reading room for RIV and headquarters staff to review.

Rebecca.

From my perspective not everyone on the review team will need access to the calcs in the electronic reading room. The following is the list of individuals that I believe need access to the ODE calcs discussed in the email chain below: Britt Hill, Kamal Manoly. Yong Li, Cliff Munson, Jon Ake, and Megan Williams (RIV).

Can you please adjust the list as you see fit and let Ryan Alexander know who should have access to the calcs.

Ryan.

I believe that once you receive the email from Rebecca with the list of individuals that should have access to the calcs, RIV can amend it based on their needs (e.g .. if someone other than Megan also needs access) and that you will pass the list onto PG&E so that they can get the electronic reading room access prepared and quickly load the documents when they are available.

Please let me know if I am missing something.

Thanks.

Joe From: Hill, Brittain Sent: Tuesday, September 23, 2014 6:27 AM To: Sebrosky, Joseph

Subject:

RE: info: status of diablo operability review 9*23-14 That's good news for the last bullet - if RIV is going to review the calcs, I have some supporting info that might help with the review.

Thanks-Britt

From: Sebrosky, Joseph Sent: Tuesday, September 23, 2014 6:05 AM To: Stovall, Scott; Munson, Clifford; Williams, Megan; Li, Yong; Hipschman, Thomas; Walker, Wayne; Oesterle, Eric; Singal, Balwant; Markley, Michael; Jackson, Diane; DiFrancesco, Nicholas; Whaley, Sheena; Uselding, Lara; Ake, Jon; Burnell, Scott; OKeefe, Neil; Farnholtz, Thomas; Kanatas, catherine; Roth(OGC), David; Manoly, Kamal; Reynoso, John; Hill, Brittain; Dudek, Michael; John Stamatakos (jstam@swrj.org); Stirewalt, Gerry; Buchanan, Theresa; Weaver, Thomas; Karas, Rebecca; Graizer, Vladimir; Hiland, Patrick; Ross-Lee, MaryJane; Lupold, Timothy; Wilson, George; Bowers, Anthony; Alexander, Ryan; Hay, Michael; Pruett, Troy; Kock, Andrea; Young, Mitzi; Harris, Brian

Subject:

RE: info: status of diablo operability review 9-23-14 To all, The purpose of this email is to provide you with the results of an inspection phone call with the licensee yesterday (9/22) regarding the Diablo Canyon operability review.

Yesterday (9/22) RIV led a call with the licensee to discuss information needs to support the Diablo Canyon operability review. The following two information needs were verbally discussed with the licensee:

1) Provide, as available, the earthquake recordings (time histories and response spectrum ordinates) from the 2003 San Simeon, 2003 Deer Canyon, and 2004 Parkfield earthquakes as recorded at stations ESTA 27 and ESTA 28. These data should reflect the final processed values as used by PG&E in the CEC report.

2) Provide the Vs profiles for the power block and turbine building as well as stations ESTA 27 and ESTA 28 as described in the first paragraph of Section 3.2 of the technical report GEO.DCPP. TR.14.06, Rev. 0 (also Ch 11 of the AB1632 CEC Report). Each of the profiles should indicate the starting elevation point for the top of the profile.

During the call PG&E provided the following information:

• PG&E will discuss the information needs internally and get !back to Region IV when they have a schedule to provide the information. PG&E believes that the information is readily accessible but they need to check with some technical staff before they get back to the region with a schedule.

• Region IV asked whether or not PG&E had determined if it would have a public SSHAC meeting based on the information in the State of California report.

PG&E indicated that"it is no longer considering a public SSHAC meeting and it will let the NRC know if this position changes. PG&E indicated that it would still most likely proceed with a public outreach meeting on 10/2/14 and that there may be interactions with the State appointed independent peer review panel (IPRP), but a public SSHAC meeting is not considered necessary at this point to support the March 2015 seismic reevaluation submittal.

• PG&E indicated that based on a question from RIV last Friday (9/19) it was rerunning the calculations used to support the resolution of the DPO (see description in DPO case file pdf page 62 of 164 at ML14252A743 which discusses the scaling

factors used in the March 2014 PG&E analysis). PG&E indicated that it did not believe that the analysis was needed to demonstrate operability. Nevertheless, PG&E was rerunning the analysis with the data from the 2014 State of California report and should have the results for the Region to review by the end of this week.

The project plan has been updated to reflect the information above. The latest version of the project plan can be found at:

Vjew ADAMS P8 Properties ML14260Al02 Open ADAMS P8 Document !Project Piao for NBC Staff Review of PG&E's Report to the State of California Regarding Seismic Faults Near the Diablo Canyon Power Plant. )

Please let me know if you have any questions.

Thanks, Joe

From: Sebrosky. Joseph To: Stovall, Scott: MYQSOn, Qfford: w;mams, Megan: ~ HUlschman, Thomas: walker, Wayne:~

~ s1oaaL Batwant; Mar1<1ev, Michael; Jackson, Diane; Ptfrancesc;o. Nichofas: Whaley. Sheena:~

Lara.; ~ BumeJL Scott: OKeefe. Ne11: Farnhottz. Thomas; Kanatas Catherine: Roth<OGC\ Dav;d:

Mano!y. Kamal: Reynoso, John: HfH Brittain: Dudek Mk:haeJ: John Stamatakos Ostam@swrLoro}: StJ.!:.ewalt..

~ Buchanan. Theresa: weaver, Thomas; Karas, Rebecca: Graizer, Vladimir HIiand. Patrjck: Ross-Lee, MaryJane; Luootd. Iirootbv; WiJsoo George: Bowers. Anthony: Alexander. Ryan: Hay. M,chaeJ: Pruett. Troy:

Kock. Andrea: Young. Mrt:zi: Hams, Bnan

Subject:

RE: Info: status of dlablo operability review 9-22-14 Date: Monday, September 22, 2014 6:00:30 AM Attachments: PGE spectral comoarlsgn.ootx To all, The purpose of this email is to provide you with the latest status of the Diablo Canyon operability review. Based on discussions with the licensee on 9/18 and an internal meeting directly after that meeting, senior management was briefed oin 9/19.

The agenda for the 9/19 meeting can be found below. The outcome of the meeting was as follows:

• RIV took an action to get back to the licensee and inform them that the operability determination should include a discussion of the new hazards against the DOE as well as the Hosgri. (RIV subsequently informed the licensee of this on 9/19 so the licensee is aware of the issue)

• Headquarters will continue to evaluate the State of California report as part of the operability review inspection. If information needs are developed as part of the review they will be provided to RIV and RIV will work with the licensee to get the information needs addressed.

o For the week of 9/22 Wayne Walker and Ryan Alexander will be the RIV lead for the inspection activities (Tom Hipschman (SRI) is out of the office this week).

o NRO has scheduled an internal meeting today (9/22) with key technical staff to identify information needs. It is expected that the outcome of that meeting will be provided to Wayne and Ryan

• It was recognized that PG&E may have two public outreach activities in the near term. A public workshop in the beginning of October and a public SSHAC meeting at the end of October. The headquarters staff will continue to review the information in the State of California report and if a public SSHAC meeting is held NRC staff will attend. NRC attendance at the SSHAC meetings is consistent with past practice. It is unclear at this point if the inspection report on the operability determination will be issued before or after the public SSHAC meeting. If an immediate safety concern or operability issue is identified the NRC will take appropriate action regardless of the timing of the SSHAC, but there is some thought that the staff would benefit from the SSHAC discussions as part of its assessment of the information in the State of California report. Regardless the information in the State of California report will be reviewed as part of the March 12, 2015 50.54(f)

response.

Please let me know if you have any questions.

Thanks, Joe

>>>>>>>>>>agenda for 9/19 diablo senior management briefing>>>>>>>>>>>>>>>>>>>

Purpose:

internal meeting with SES managers to discuss process going forward for Diablo Canyon operability determination associated with new seismic information in the State of California report Outcome: Decision made on how to proceed Agenda:

I. Background - new information in report regarding the capabilities of several faults including the Hosgri-San Simeon, Shoreline, San Luis Bay and Los Osos (see table below)

a. Table below provides description of changes to various faults

b. Figure below is a plot of the new ground motion response spectrum for the various faults

c. PG&E operability determination based on comparison of new ground motion response spectrum to hosgri

d. Public released DPO and DPO appeal suggests in the 2012 time frame the licensee should have also compared the new hazards to the ODE

i. DPO decision documents the additional analysis that was done by the licensee

e. Other considerations

1. PG&E considering public outreach meeting in early October time frame iii. PG&E considering additional public SSHAC meeting at the end of October

1. Timing of letter back to licensee may need to consider the public SSHAC meeting II. Issue - what is the NRC's position on the calcs that the licensee should do to verify operability

a. Position that no additional calcs are needed

b. Position that calcs or comparisons are needed based on precedence set in DPO The rest of this string may be found as document C/41 in FOINPA-2015-0071 {ML 1518A428).

From: ~

To: sebrosky. Joseph: stovan Scott; Munson. Qifford: Williams. Megan: ~ HiQSChman. Thomas:~

~ Qest:ecle, Eric: s1naa1 sa1want: Markley, Michael; Jackson. Diane: D1francesco Nicholas:~

~ Vseldjng Lara: Burnell Scott: OKeefe Neil: Farnholtz Thomas; Kanatas Catherine: RothCQGC}.

Qa:tilt Mano1v. Kamal: Revao:;o, John: Hill Bnttain: Dudek Mmael: HO*OWEN-oaB02-120: John Stamatakos

/lstam@swri org}: Stirewalt, Gerry: Buchanan, Theresa: weaver. Thomas: Karas, Rebecca: Graizer. YJadlmlr:

Hiland. Patnck; Ross-Lee MaryJane: Lupold. Tjmothy: Wilson, George: HO*OWFN*08BQ6* 12p Cc: DE calendar Resource

Subject:

RE: Info: status of dlablo operal>illty review Date: Friday, September 19, 2014 7:19:59 AM lio all-Please note, this was prepared by myself (Jon) and Oiff. We have not really been able to do any more than visually compare these to the plots in the report for the purposes of checking. We will need to double check next week.

Jon From: Sebrosky, Joseph Sent: Friday, September 19, 2014 6:02 AM lio: Stovall, Scott; Munson, Clifford; Williams, Megan; Li, Yong; Hipschman, Thomas; Walker, Wayne; Oesterle, Eric; Singal, Balwant; Markley, Michael; Jackson, Diane; Difrancesco, Nicholas; Whaley, Sheena; Uselding, Lara; Ake, Jon; Burnell, Scott; OKeefe, Neil; Famholtz, Thomas; Kanatas, Catherine; Roth(OGC), David; Manoly, Kamal; Reynoso, John; Hill, Brittain; Dudek, Michael; HQ-OWFN-08B02-12p; John Stamatakos Ustam@swri.org); Stirewalt, Gerry; Buchanan, Theresa; Weaver, Thomas; Karas, Rebecca; Graizer, Vladimir; Hiland, Patrick; Ross-Lee, MaryJane; Lupold, Timothy; Wilson, George; HQ-OWFN-08B06-12p Cc: DE_Calendar Resource

Subject:

info: status of diablo operability review To all, The purpose of this email is to provide you with the status of the diablo operability review. Since our internal meeting yesterday two things have happened: 1) Jon Ake has provided plots comparing the 2014 State of California report information to the information in the 2011 shoreline fault report, and 2) a senior management meeting has been scheduled for 9/19 at 1:00 pm (eastern). The plots and the agenda for the senior management meeting are found below. The branch chiefs are meeting in the morning to discuss the issue. Currently the thinking is that the senior management meeting will need to have limited technical assistance. If this changes based on feedback from the 8:00 am branch meeting I will let you know.

As always please let me know if you have any questions or if you think I am missing something.

Thanks, Joe Plots Jon provided the following cautions associated with the plots.

Attached is a set of two plots comparing the PG&E 2011 and 2014 84th-percentile response spectra for the 4 major faults that control the hazard at DCPP. For the most part the results are lower for the 2014 results compared to the 2011 estimates.

It is important to remember that this assumes that all elements of the PG&E assessment are "correct" and we agree with them. We will need to spend some time over the next couple of weeks verifying the PG&E calculations were done correctly. The matter of if we agree with the assumptions may take a bit longer to sort out ( or at least reach interna.l agreement).

From: StoyatJ. SCott To: Grajzer. Vladimir: sebroskv. Joseph: Munsoo. Clifford: Williams. Mecan: .Li...Yllag_; Hjoschman. Thomas:~

~Oesterle.Enc: s,noal. BaJwant: Markley. Michael: Jackson. o,ane; Difrancesco Nicholas;~

~ Vsefdjna Lara: ~ Burnell Scott* QKeefe Neil: farnholtz Thomas: Kanatas Catherine; Roth(OGC}. Dayjd; Mano!y. Kamal : Reynoso. John; Hi!I. Bnttain; Dudek. Mjchael; HO*OWFN-08B02* l2p: ~

Stamatakos Ostam@swd org}* st;rewatt GeCIY: Buchanan. Theresa: weaver. Thomas; Karas Rebecca: J:illa.Ol1.

fatdt!s.: Ross-Lee MarvJane* Lupold Timothy: Wilson. George: HQ*QWFN-OBB06-120 Cc: PE Calendar Resource

Subject:

RE: Info: status or dlablo operability review Date: Friday, September 19, 2014 9:34:24 AM I thought I heard yesterday PG&E state that t he peak at 2.5 Hz is from site response. Based on t he Average Vs profiles this seems reasonable.

Scott Stovall From: Graizer, Vladimir Sent: Friday, September 19, 2014 8:41 AM To: Sebrosky, Joseph; Stovall, Scott; Munson, Oifford; Williams, Megan; Li, Yong; Hipschman, Thomas; Walker, Wayne; Oesterle, Eric; Singal, Balwant; Markley, Michael; Jackson, Diane; Difrancesco, Nicholas; Whaley, Sheena; Uselding, Lara; Ake, Jon; Burnell, Scott; OKeefe, Neil; Farnho!tz, Thomas; Kanatas, Catherine; Roth(OGC), David; Mano!y, Kamal; Reynoso, John; Hill, Brittain; Dudek, Michael; HQ*OWFN* 08B02* 12p; John Stamatakos (jstam@swri.org); Stirewalt, Gerry; Buchanan, Theresa; Weaver, Thomas; Karas, Rebecca; Hiland, Patrick; Ross-Lee, MaryJane; Lupold, Timothy; Wilson, George; HQ*OWFN*08B06*12p Cc: DE_Calendar Resource

Subject:

RE: info: status of diablo operability review What looks puzzling to me are the shapes of 2014 Hosgri and Shoreline spectra:

What is the origin of an "angle" at 2.5 Hz?

Do they attribute it to site response or a very strong hanging wall effect?

From: Sebrosky, Joseph Sent: Friday, September 19, 2014 6:03 AM To: Stovall, Scott; Munson, Clifford; Williams, Megan; Li, Yong; Hipschman, Thomas; Walker, Wayne; Oesterle, Eric; Singal, Balwant; Markley, M1ichael; Jackson, Diane; Difrancesco, Nicholas; Whaley, Sheena; Uselding, Lara; Ake, Jon; Burnell, Scott; OKeefe, Neil; Farnho!tz, Thomas; Kanatas, catherine; Roth(OGC), David; Manoly, Kamal; Reynoso, John; Hill, Brittain; Dudek, Michael; HQ-OWFN*08B02*12p; John Stamatakos (jstam@swn.org); Stirewalt, Gerry; Buchanan, Theresa; Weaver, Thomas; Karas, Rebecca; Graizer, Vladimir; Hiland, Patrick; Ross-Lee, MaryJane; Lupold, Timothy; Wilson, George; HQ*

OWFN* 08B06* 12p Cc: DE_calendar Resource

Subject:

info: status of diablo operability review To all, The purpose of this email is to provide you with the status of the diablo operability review. Since our internal meeting yesterday two things have happened: 1) Jon Ake has provided plots comparing the 2:01 4 State of California report information to the information in the 2011 shoreline fault report, and 2) a senior management meeting has been scheduled for 9/19 at 1:00 pm (eastern). The plots and the agenda for the senior management meeting are found below. The branch chiefs are meeting in the

morning to discuss the issue. Currently the thinking is that the senior management meeting will need to have limited technical assistance. If this changes based on feedback from the 8:00 am branch meeting I will let you know.

As always please let me know if you have any questions or if you think I am missing something .

Thanks, Joe Jon provided the following cautions associated with the plots.

Attached is a set of two plots comparing the PG&E 2011 and 2014 84th-percentile response spectra for the 4 major faults that control the hazard at DCPP. For the most part the results are lower for the 2014 results compared to the 2011 estimates.

It is important to remember that this assumes that all elements of the PG&E assessment are "correct" and we agree with them. We will need to spend some time over the next couple of weeks verifying the PG&E calculations were done correctly. The matter of if we agree with the assumptions may take a bit longer to sort out (or at least reach internal agreement).

<< File: PGE_spectral comparison.pptx >>

Senior Management Meeting Draft Agenda (subject to change)

Purpose:

internal meeting with SES managers to discuss process going forward for Diablo Canyon operability determination associated with new seismic information in the State of California report Outcome: Decision made on how to proceed Agenda:

I. Background - new information in report regarding the capabilities of several faults including the Hosgri-San Simeon, Shoreline, San Luis Bay and Los Osos (see table below)

a. Table below provides description of changes to various faults

b. Figure below is a plot of the new ground motion response spectrum for the various faults

c. PG&E operability determination based on comparison of new ground motion response spectrum to hosgri

d. Public released DPO and DPO appeal suggests in the 2012 time frame the licensee should have also compared the new hazards to the ODE

i. DPO decision documents the additional analysis that was done by the licensee II. Issue -what is the NRC's position on the calcs that the licensee should do to verify operability

a. Position that no additional calcs are needed

b. Position that calcs or comparisons are needed based on precedence set in DPO

i. Possibility of doing a comparison between 2014 ground motion plots vs 2011 plots for San Luis Bay, Los Osos, and Shoreline

1. If 2014 plots bounded by 2011 plots no additional calcs are needed because the ODE plots would be bounded

2. Hosgri/san simeon no 2011 plots licensee would have to do some calcs for this scenario Ill. Recommendation IV . Next steps V. Wrapup Fault 2011 Shoreline Report Updated Parameters Maximum Length (km) Minimum Dip (degrees) Mag. (90th fractlle) Maximum Le ngth (km) Minimum Dip (degrees)

Mag.*

Shoreline 23 90 6.5 45 90 6.7 Hosgri 110 80 7.1 171 75 7.3 Los Osos 36 45 6.8 36 55 6.7 San Luis Bay 16 50 6.3 16 50 6.4

<< OLE Object: Pict ure (Device Independent Bitmap)>>

---

Original Appointment-----

From: Sebrosky, Joseph Sent: Tuesday, September 16, 2014 9:37 AM To: Sebrosky, Joseph; Stovall, Scott; Munson, Oifford; Williams, Megan; Li, Yong; Hipschman, Thomas; Walker, Wayne; Oesterle, Eric; Singal, Balwant; Markley, Michael; Jackson, Diane; Difrancesco, Nicholas; Whaley, Sheena; Uselding, Lara; Ake, Jon; Burnell, Scott; OKeefe, Neil; Farnholtz, Thomas; Kanatas, catherine; Roth(OGC), David; Manoly, Kamal; Reynoso, John; Hill, Brittain; Dudek, Michael; HQ-OWFN-08B02-12p; John Stamatakos (jstam@swrj.org ); Stirewalt, Gerry; Buchanan, Theresa;

Weaver, Thomas; Karas, Rebecca; Graizer, Vladimir; Hiland, Patrick; Ross-Lee, MaryJ'ane; Lupold, nmothy; Wilson, George; HQ-0WFN-08B06-12p Cc: DE_calendar Resource

Subject:

internal meeting to discuss path forward based on information from phone call with PG&E When: Thursday, September 18, 2014 2:30 PM-4:00 PM (UTC-05:00) Eastern Time (US & canada).

Where: HQ-0WFN-08B06-12p Bridge: 888-677-0690 Passcode:! (bJ(6J I

Purpose:

Internal meeting to discuss path forward on inspection of PG&E operability determination based on information in State of California report Outcome: Determination made on how to proceed including information needs, and briefing of senior management as appropriate Agenda:

I. Discussion of results of insights gained from immediately preceding phone call with PG&E II . Discussion of information needs 111. Discussion of PG&E's positions on whether or not in-structure motions have been done or need to be done IV. Next steps V. Wrapup

PG&E Results-Comparison of Hosgri and Shoreline Fault Spectra:

84th-Percentile-2011 vs 2014, Power Block Elevation 2.5

-Shoreline 2014

- - Shoreline 2011 2 -- Hosgri 2014

- - Hosgri 2011

-HE 1.5 __ ~ LTSP b l)

V, 1

0.5 ~

0 0.1 1 10 100 Frequency (Hz)

PG&E Results-Comparison of Los Osos and San Luis Bay Fault Spectra:

84th-percentile, 2011 vs 2014 Power Block Elevation 2.5 I -san Luis Bay 2014

- - San Luis Bay 2011 2

l 1- - -

Los Osos 2-014 Los Osos 2011

_.,_...__ ____ --"'-*- ~ - -- - *-------- - ..... - - - --- - - -

-HE 1.5 1 ~.LtsP ---

Q.O V,

1 "I ,'X, .. , ,

/ /,'/ ~

0.5 0

0.1 1 10 100 Frequency {Hz)

From: Scott. Mictiael To: oesterle. Ertc Cc: f>edersen. Renee: Wilson. George: Markley. Michael: Broaddus. Douo Su bject: RE: New AskManagemeot Submission Date: Monday, November 10, 2014 5:48:54 PM Thanks Eric. I assume the infonnation in the Comm Plan you sent can be freely shared with staff.

Please confirm.

Mike

---

Original Message-----

From: Oesterle, Eric Sent: Monday, November 10, 2014 8:20 AM To: Scott, Michael Cc: Pedersen, Renee; Wilson, George; Marld'ey, Michael; Broaddus, Doug

Subject:

RE: New AskManagement Submission

Mike, We prepared a mini Comm-plan associated with the EDO Decision on the Appeal of the DPO (see attached) and the release of the DPO case file for public availability. Perhaps the attached will address the question. Like Mike Markley indicated, tlhere is no indication that we will be responding directly to the 9/19 article.

Eric R. Oesterle NRC Project Manager Diablo canyon Power Plant Cooper Nuclear Station NRR/D0RL/LPL4-1 301-415-1014

---

Original Message-----

From: Markley, Michael Sent: Monday, November 10, 2014 8:10 AM To: Scott, Michael; Broaddus, Doug Cc: Oesterle, Eric; Pedersen, Renee; Wilson, George

Subject:

RE: New AskManagement Submission

Mike, We had all kinds of stuff going at the time of the DPO Director's Decision and EDO Appeal. The DCPP PM, Eric Oesterle can provide you with the infonnation subject to our communications. plan, but OE owns the DPO process. Rene Pedersen would be the right person to discuss the DPO. I do not believe there is a Sharepoint link.

There were a lot of articles. Some making assertions about how the DPO was handled and timing. We have referred some to the OIG. In DCPP space, September 19 is a long time ago. We are responding to about 10 DCPP Congressional/concerned citizen items right now. I will have the PM, Eric Oesterle take a look, but my guess is we are not responding explicitly to the September 19 article.

Mike

---

Original Message-----

From: Scott, Michael Sent: Friday, November 07, 2014 5:42 PM To: Markley, Michael; Broaddus, Doug

Subject:

FW: New AskManagement Submission Gentlemen:

can whichever of you has cognizance of Diablo canyon please help me out? can you please ask the PM to send me a link to a Sharepoint site or wherever else that we have compiled information on the Diablo canyon seismic DPO and the Agency's review and response to it? The below question was submitted anonymously by someone on the Region I staff. I would like to answer it with a simple link to wherever the info can be found, if such a link exists.

Thanks in advance for your help.

Michael (Mike) Scott Deputy Director Division of Reactor Projects Region I (610) 337-5126

---

Original Message-----

From: rlaskmanagement@nrc.gov [mailto:rlaskroanagement@nrc,goy)

Sent: Friday, October 31, 2014 7:29 AM To: RlASKMANAGEMENT RESOURCE

Subject:

New AskManagement Submission On September 19, The Santa Barbara Independent ran an article, which was also put on the Rl website, about the former Diablo Canyon SRI who had a concern about how Diablo Canyon's new seismic information was handled and did not feel that is DPO about this concern was adequately addressed. Does the NRC plan to do anything additional to address his concern in light of the recent article? If so, please inform us of the resolution to this when it is concluded.

From: cm, Otag. Lynn To: Markley MldJaet

Subject:

FW: STARS OEDO Office NoClflcation (LTR* 14*0<l9S+ NRR)

O.e: lln.l'sday, September 25, 2014 1:57:53 PH FYI

• **--Original Message-----

From: Walker(NRR), Sandra Sent: Thursday, September 25, 2014 1:57 PM To: Olen, Qiao-Lynn

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Hi Lynn, The ticket has been dosed in STARS. Since it was just an appropriate action I was able to access STARS and state that staff will not be responding.

Thanks, Sandra

---

Original Message----*

From: Olen, Qiao-Lynn Sent: Thursday, September 25, 2014 7:58 AM To: Walker(NRR), Sandra

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Importance: High Good Morning Sandra, Would you be able to help me with this answer.

Thank you!

---

Original Message---**

From: Burkhardt, Janet Sent: Thursday, September 25, 2014 7:52 AM To: Chen, Qiao-Lynn; Cox, Linda

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Importance: High can either of you please respond to Mike? I have never heard of STARS and don't know how to advise him.

Jan

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • ~****************************************

---

Original Message-----

From: Markley, Michael sent: Thursday, September 25, 2014 7:46 AM To: Burkhardt, Janet Cc: Orf, Tracy

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Jan, Do I dose a STARS ticket In the same manner as we request extensions for due dates.

Mike

---

Original Message-----

From: Stuchell, Sheldon Sent: Wednesday, September 24, 2014 5:59 PM To: Dudek, Michael; Markley, Michael Cc: Mohseni, Aby; Banic, Merrilee; Mensah, Tanya; Khanna, Meena; Singal, Balwant; Oesterle, Eric; Pedersen, Renee

Subject:

FW: STARSOEDO Office Notification (LTR-14-0495-1 -NRR)

Mike & Mike, I'd like to make sure this Issue is dosed, and any ticket assigned to NRR Is dosed. Any correspondence coming to the NRC can be considered as a 2.206 petition, if It meets the requirements of our MD and is determined to be an actual petition. In this case, the submittal does not meet the requirements to be a 2.206 petition, and should be considered general correspondence.

The e-mail chain below can be confusing, and I must point out that no single individual submitted this correspondence. It was not Mr. Peck. Mr. Peck, one of our Sr. Resident Inspector's, did in fact have a DPO about Diablo, but that DPO has been dispositloned. The submitter in this case was "change.org."

Therefore, there Is no Individual we can respood to.

I highly recommend this be dosed with no further action. As noted In the bcket, staff is to respood "as appropriate." In this case, the appropriate response is no response to an organization.

If there are still questions as to how to dose tihe issue, it should be worked out between Mike and Mike. This is not a 2.206 petition and NRR/DPR 1s not involved.

Hope this helps, Sheldon

• • • • -Original Message-****

From: Banic, Merrilee Sent: Wednesday, September 24, 2014 1:36 PM To: Stuchell, Sheldon Cc: Mensah, Tanya

Subject:

RE: STARS OEDO Office Notification (LTR-14*0495* 1-NRR)

A little background:

If dnange.org is basing its petition on M. Peck's, a Sr Resident's, DPO, tihe NRC resolved his DPO:

htto*11r1 ore govtbeadhnestO,abtoSafe 9-ts-2014 pdf From: Stuchell, Sheldon Sent: Wednesday, September 24, 2014 12:34 PM To: Dudek, Michael; Mensah, Tanya; Banic, Merrilee; Markley, Michael; Kokajko, Lawrence; Khanna, Meena Cc: Singal, Balwant; Oesterle, Eric; Pedersen, Renee

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

All, The easiest solution to this, is for the DORL PM to respond by e-mail to tihe submitter (he is not a petitioner) and let him know that we have received his general correspondence and thank him for his interest in nudear safety. There Is no need to expound or explain any further than that.

We receive numerous submittals all year long, that require nothing more than an acknowledgement.

She'ldon From: Dudek, Michael Sent: Wednesday, September 24, 2014 12:25 PM To: Mensah, Tanya; Banic, Merrilee; Markley, Michael; Kokajko, Lawrence; Khanna, Meena Cc: Singal, Balwant; Oesterle, Eric; Pedersen, Renee; Stuchell, Sheldon

Subject:

RE: STARS OEDO Office Notification (LTR* l4-049S* l *NRR)

All: As a result of the past e-mails, it now appears that we (the staff) have an action to contact tihe petitioner (Mr. Peck) to have him formally submit the petition in hard-copy to tihe NRC so that we have an official record of his concerns.

Question: Does the staff want to take this action, or should I try to go back through the Chairman's Office for this request since that is where is action originated?

Please advise.

Michael I. Dudek Michael I. Dudek I OEOO Executive Technical Assistant I U.S. NRC I

• : Michael.Dudek@nrc.gov<ma!lto-Michaej Qudek@orc gov> I *: (301) 415-6500 I B8:.__ _(_bl_(6_l _ __.

From: Mensah, Tanya Sent: Wednesday, September 24, 2014 11:24 AM To: Banic, Merrilee; Markley, Michael; Kokajko, Lawrence; Khama, Meeoa Cc: Singal, Balwant; Oesterle, Eric; Pedersen, Renee; Dudek., Michael; Stuchell, Sheldon

Subject:

RE: STARS OEOO Office Notification (LTR-14*0495*1-NRR)

To expand on Lee's comment, in the past we've had several petitioners attempt to direct us to their personal websites or biogs to "download" 2.206 petitions and other supplemental mat.erials. In consultation w/ OGC years ago, tiheir position has always

been consistent with MD 8.11, that the petition be submitted in writing. In these cases, the PM Simply informed the petitioner of the process to submit a 2.206 petition, In writJng, if they want their concerns considered under that process.

Members of the public often change their website links/blOgs. Their URLs may not even exist in a year. So we need an official NRC record of the petitioner's concerns, which they have to submit in writing to the NRC. If the petitioner has videos or other electronic media to support their 2.206 petition, we advise them of the proper way to submit it. I think the DCD has guidance on the proper submission of electronic media to ensure that it is dodceted.

Tanya From: Banic, Merrilee Sent: Wednesday, September 24, 2014 8:32 AM To: Markley, Michael; Kokajko, Lawrence; Khanna, Meena Cc: Slngal, Balwant; Oesterle, Eric; Mensah, Tanya; Pedersen, Renee; Dudek, Michael; Stuchell, Sheldon

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Per our MD 8.11 "Section 2.206 requires that the petition be submitted in writing and provide the grounds for taking the proposed action ...."

From: Markley, Michael Sent: Wednesday, September 24, 2014 8:11 AM To: Kokajko, Lawrence; Khanna, Meena Cc: Slngal, Balwant; Oesterle, Eric; Mensah, Tanya; Banic, Merrilee; Pedersen, Renee; Dudek, Michael

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Lawrence and Tim, The assertion that this follows the process in 2.206 for submitting petitions to the EDO seems highly out of process. We should not have to download software to reVJew a submittal to the NRC. Likewise, we should not have to go through extreme measures to access the information via an external website. I am struggling to see how the link provides an actual petition. It merely asserts that Michael Peck's DPO should provide the baSis for a petition to shut down the plant. This is highly out of process.

From my view, we have nothing to process here. The petitioner should be referred to the regulations in 2.206 and follow the process. NRR/DPR may disagree, but I do not see a document that we have submitted In an official manner that warrants the asSignment of a petition manager. Let's talk. I do not see a baSis for entering this into the petition process.

Mike Markley From: Dudek, Michael Sent: Tuesday, September 23, 2014 2:43 PM To: Markley, Michael Cc: Singal, Balwant; Oesterle, Eric

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

I went onto my iPhone and found it on the web site.

[cid:image001.jpg@01CFD800.6EBS78A0)

Petitioning Nuclear Regulatory Commission Decommission the aging Oiablo canyon Nuclear Power Plant L

[ cid :image002.jpg@<HCFDSOO. 6EBS7BAOJ < httos* 1/www change org/organizations/uncommon folk>

2.

L Petition by uncommon Folk<bttps*//www change org/orgarnzatjons/uncommon fotk>

In fault-ridden San Louis Obispo County, stands ca!lfomia's last two operating nuclear reactors In the aging Diablo Canyon Power Plant (circa 1973). They are located proximally to the Los Osos, Hosgrt, San Andreas, and Shoreline Faults, along shores near Avila Beach.

According to a recent report by Miehael Blood (ABC 30 Action News); a senior federal nudear expert, Michael Peck, has urged regulators to shut down the aging power plant until they can determine whether or not the facility's twin reactors can withstand an earthquake of similar or larger size than the one that recently shook Napa. Blood reports:

Pede, who for five years was Oiablo canyon's lead on-site Inspector, says in a 42-page, confidential report that the Nuclear Regulatory Commission is not applying the safety rules it set out for the plant's operation.

In light of the unfolding disaster at the Fukushima Daichii power plant, we the undersigned are asking that Governor Jerry Brown support us in demanding that the Diablo canyon Plant be shut down until it can be properly earthquake tested and Michael Peck's charges of negligence be thoroughly investigated.

Or better yet, we ask that Jerry Brown work to shut down the Diablo canyon Plant permanently, as it Is located In such an

unsafe region.

We the undersigned ask that NRC Inspector General Hubert T. Bell, Chaiman Allison Macfarlane, and Govenor Jerry Brown listen to the experts and heed the warnings of recent history, so we are not collectively doomed to repeat such catastrophic failures.

For the sake of California and its citizens, young and old. please shut down the Diablo Canyon Nudear Power Plant!

Here is a short and enlightening PBS video that was made before several more major faultlines were found in that area ...making it even MORE Imperative that these professional opinions be heeded. Please take a few minutes to watch. There is a long history of lies and suppression of information surrounding the Diablo Canyon Nudear Plant, at the peril of our citizens andl their families->

http:/Jyjdeo.obs or0Mdeot2os66ss2os1 MORE PETITIONS TO SIGN. THIS MOVEMENT IS GAINING MOMENTUM, THANKS TO ALL OF YOU. Please sign them all and PASS IT ON! Together we can do it->

(1) http://actjon toe org/o/dja/actjon31common/oubfict'action KEY= 16333 (2) htto://oetitions.moveon.oro/sian/nrc-shut-down-d1abfo'source=s.1a,.tw&r by=7595393 (3) htto'//act credoactjon.com/slon/diablo canyon IMPORTANT TO THOSE LIVING IN NEAR DIABLO CANYON. RECENT STUDY INDICATES SIGNIFICANTLY HIGHER CANCER RATES IN RESIDENTS->

http*11ca1coastnews.com12014/03/high-cancer-rates-near-diablo-canyon-nudear-otaott http*//www hetencaldicottfoundatjon org/b!ogs/health-studies-expjode-the-mvth-of-the-'safe'-nuclear-power-plant.html< http://www.heleocaldicottfoundat;on org/bfoas{health *studres-exotooe*the*mvth-of*the-*sare* -oudear-oowec*

plant html>

htto*((wortdbuSioess ora/nuc1ear-oower-healtb*1moact-stuctvt More information->

http*//worldbusiness org/c;afe-energy-oroject/dose-d,ablo-ranyon-nudear-oower-plantt http* //wortdbusiness.org/nudear-reoulators-hear-from-anorv-oubljc-on-diablo-canyon-plantt http* //wwwsfaate comtnews/artjcle/Earthguake-concems-oromot-can-to-shut-nudear-57 J1Z17.oho http*//www cbsnews.com/newstcaUfo[Dla -earthauake-expert-uroes-nudear-01ant-closure-over* threat/

http*//www danynews com/genera1-news12014Q825/diabk>-canyon-nudear-ofant-should*be*dosed-for-guake-testing-exoert-Sil¥S To:

Nuclear Regulatory CommlSSion, Hubert T. Bell, Inspector General at the NRC Nudear Regulatory Commission, Allison Macfarlane, Chariman of the NRC Sen. Barbara Boxer, California Gov. Jerry Brown, California Decommission Aging Dlabfo Canyon Nudear Power Plant Sincerely,

[Your name)

Michael I. Dudek l OEDO Executive Technical Assistant I U.S. NRC

• Michael.Dudek@nrc.gov<majjto;Mjchael Dudek@orc.gov> I *: (301) 415-6500 I BB..___

I lb-J(-6)_ __,

From: Markley, Michael Sent: Tuesday, September 23, 2014 2:24 PM To: Dudek, Michael Cc: Singal, Balwant; Oesterle, Eric

Subject:

FW: STARS OEDO Office Notification (LTR*14-0495*l*NRR)

Mike,

can we go back to the Chairman's office to get a hard copy of the petition.? We are having no luck in accessing the document via the links.

Mike From: Singal, Balwant Sent: Tuesday, September 23, 2014 12:42 PM To: Mensah, Tanya Cc: Oesterle, Eric; Markley, Michael

Subject:

RE: STARS OEDO Office Notificati<>n (LTR-l 4-'0495* l -NRR)

Cathy was unable to help (could not open the file from the link in the file). She suggested contacting CSC. CSC was on my desk yesterday, but were also unable to open the file. They believe there is a problem with the link. Hence, as of now we do not have a resolution and do not have a copy of the petition.

From: Mensah, Tanya Sent: Tuesday, September 23, 2014 11:57 AM To: Markley, Michael; Banic, Merrilee Cc: Singal, Balwant

Subject:

RE: STARS OEOO Office Notification (LTR-14-0495-1-NRR)

Any resolution on this? I typically email Cathy Jaegars for the incoming when we have problems accessing it via ADAMS. Looks like Balwant already submitted an email to her.

Just following up.

Tanya From: Markley, Michael Sent: Monday, September 22, 2014 3:41 PM To: Banic, Merrilee; Mensah, Tanya Cc: Singal, Balwant

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Lee and Tanya, We have not seen the actual petition but the OEOO tasking seems at hand.

Mike From: Singal, Balwant Sent: Friday, September 19, 2014 2:26 PM To: Jaegers, cathy Cc: Markley, Michael

Subject:

RE: STARS OEDO Office Notification (LTR* l4* 049S* l *NRR)

Cathy, can we get access to the actual petition please?

From: Markley, Michael Sent: Friday, September 19, 2014 12:47 PM To: Singal, Balwant

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Sorry, Balwant, I am not seeing an actual petition in any of these files. Just a lot of duplicate letters , a Susquehanna Security*

related document, and an Army document. The links do not allow asccesssx to an actual petition and it is not in any of these ADAMS files.

From: Singal, Balwant Sent: Friday, September 19, 2014 12:33 PM To: Markley, Michael

Subject:

RE: STARS OEOO Office Notification (LTR-1H)49S* l*NRR)

Yes. I was able to open it. It has reference to the following two ML numbers and I was able to get to the documents by clicking the link:

ML14245A494 ML14245A495 (Package)

Contains ML14246A484, Mll4246A496, and ML14246A494).

Couple of documents are large (30-40 pages).

I can help on Monday if needed.

From: Markley, Michael Sent: Friday, September 19, 2014 12:11 PM To: Singal, Balwant; Oesterle, Eric Cc: RidsNrrMailCenter Resource; Jaegers, Cathy

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Balwant, Can you get to the petition? I tried to open the link but it appears to require downloading software that is not supported on NRC systems.

Mike From: Singal, Balwant Sent: Friday, September 19, 2014 10:20 AM To: Oesterle, Eric Cc: Markley, Michael

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

For your information please.

From: RldsNrrDort Resource Sent: Friday, September 19, 2014 10:11 AM To: Singal, Balwant

Subject:

FW: STARS OEOO Office Notification (LTR-14-0495-1-NRR)

From: RidsNrrMaiJCenter Resource Sent: Thursday, September 04, 2014 1:05 PM To: RidsNrrDorl Resource Cc: Cox, Linda

Subject:

FW: STARS OEOO Office Notification (LTR-14-0495-1-NRR)

The following appropriate action on Request Decommissioning of the Aging Diablo Canyon Nudear Power Plant has been assigned to DORL.

Please let me know if you plan to respand.

SECY would like this document released to the public in ADAMS. Please review and let me know if that is ok.

From: ADAMS p8_icm_service Sent: Wednesday, September 03, 2014 2:24 PM To: ICM_STARS_NRR; Dudek, Michael

Subject:

STARS OEDO Office Notification (LTR-14-0495-1-NRR)

A new OEDO Tlcket has been assigned to you by Jaegers, Cathy (cej) on 09/03/2014.

[htto*l[adamsmn ore gov*9Q801STARS/STARS pnaJ <https*lladarosicro ore gov/STARS>

Last User Comment has been added to a Tlcket by 09/03/2014 on 09/03/2014. The comment was -

09/03/2014 The Ticket information is below.

Ticket Info Activity Information case Number LTR- 14-0495-1-NRR Status

New Activity Type LTR EDO Due Date SECY Due Date Requested Due Date Assigned Offices NRR Routlng Coples to Region IV I OGC EDO Point of Contact Dudek, Michael (mid)

Other Parties Incoming ADAMS Accession Mll4245A494< https* //adamsxt ace go11/WorkplaceJ<TJgetconteol' objectStoreName=Majn%20Ubrarv&objectTyoe=dorument&)ISld=%7bCF392F21-1FBE-4027 -A2AB-4298S8S68P3Ao/o7d>

Date of Incoming 09/29/2014 Incoming ADAMS Package ML1424SA49S<https://adamsxt nrc,go11/WorkQlaceXI{oetcontent' obJectStoreName- Majno/o20Library&obJectType- dorument&YSld- %7b814EAS8Q* 3F37 -4SA1-9l02-4E3394A9DCP l %7d >

Frequency Incoming Information Originator Keating M Originator Organization Citizens Task E-mail Addressee Name Mac.fartane A M

Addressee Affiliation NRC/Chairman Incoming Received Date 09/02/2014 Subject Request Decommissioning of the Aging Diablo canyon Nuclear Power Plant Desaiption Process Information Special Instructions Type Appropriate Action Special Instructions For Appropriate Action. Office/Region to determine if a response is needed. If response is appropriate, please be sure to include your response to the ADAMS Package and process accordingly. Copies should be sent to RidsEdoMailCenter and RldsSecyMailCenter. Toe incoming dOOJment needs to be made publicly available in ADAMS per SECY for immediate release. If this should not be made publidy available, please let us know ASAP.

Near Term Commeflt Requested Action Type Appropriate Action Cross Reference Numbers Signature Level No Signature Required OIG Recommend OEDO Concurrence 0CM Concurrence OCA Concurrence

From: ~

To: Burkhardt >mx:t Cc: Mackley MiclJm:1

Subject:

RE: STARS OEDO omcr Notification (LTR-14"-049S-!-NRR)

Date: Thursday, September 25, 20H 8:29:00 AM When the doseout is sent to RidsNrrMailCenter Resource it gets dosed in STARS. NRR worlcs to that end-

Thanks,

---

Original Message-----

From: Burkhardt, Janet Sent: Thursday, September 25, 2014 7:52 AM To: Chen, Qlao-Lynn; Cox, Linda

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Importance: High Can1either of you please respond to Mike? I have never heard of STARS and don't know how to advise him.

Jan

---

Original Message-----

From: Markley, Michael Sent: Thursday, September 25, 2014 7:46 AM To: Burkhardt, Janet Cc: Orf, Tracy

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Jan, Do I close a STARS ticket In the same manner as we request extensions for due dates.

Mike

---

Original Message-----

From: Stuchell, Sheldon Sent: Wednesday, September 24, 2014 5:59 PM To: Dudek, Michael; Markley, Michael Cc: Mohseni, Aby; Banic, Merrilee; Mensah, Tanya; Khanna, Meena; Singal, Balwant; Oesterle, Eric; Pedersen, Renee

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1 -NRR)

Mike & Mike, I'd like to make sure this issue is dosed, and any ticket assigned to NRR is d osed. Any correspondence coming to the NRC can be considered as a 2.206 petition, if it meets the requirements of our MD and is determined to be an actual petition. In this case, the submittal does not meet the requirements to be a 2.206 petition, and should be considered general correspondence.

The e-mail chain below can be confusing, and I must point out that no single individual submitted this correspondence. It was not Mr. Peck. Mr. Peck, one of our Sr. Resident Inspector's, did 1n fact have a DPO about Diablo, but that DPO has been dlspositloned. The submitter in this case was "change.erg."

Therefore, there is no individual we can respond to.

I highly recommend this be dosed with no further act.ion. As noted in the ticket, staff is to respond

• as appropriate.* In this case, the appropriate response is no response to an organization.

If there are still questions as to how to dose the issue, it should be worked out between Mike and Mike. This is not a 2.206 petition and NRR/DPR is not involved.

Hope this helps, Sheldon

---

Original Message----

From: Banic, Merrilee Sent: Wednesday, September 24, 2014 1:36 PM To: Stuchell, Sheldon Cc: Mensah, Tanya The full version of this email may be found as document C/43 in FOIA/PA-2015-0071 (ML15181A428).

From: Stychen. SheJdon To: Dudek. Michael Cc: Markley. MJchaeJ

Subject:

RE: STARS OEOO Office Notification (LTR-14-0495-1-NRR)

Date: Thursday, September 25, 2014 1:52:40 PM Understand. The ticket was assigned to DORL, DPR will support as needed. The only point I have to make. is that the request does not meet 2.206 requirements. Therefore, DPR is not involved.

• • • • -Original Message*****

From: Dudek, Michael Sent: Thursday, September 25, 20 14 I: 17 PM To: Stuchell, Sheldon Cc: Markley, Michael

Subject:

RE: STARS OEDO Office Notification (L TR-14-0495-1-NRR)

Sheldon: The only way that you can close the ticket is to provide the justification to NRR"s Mailroom and have them work (through the OEDO STARS System) to close it out. Unfortunately, with the new system, I cannot facilitate closing out a ticket any longer.

Also, FYI, the justification should be in paragraph form and answer all of the who, what, and why for the Chairman's Office.

Thanks!

Michael I. Dudek Michael I. Dudek I OEDO Executive Technical Assistant U.S. NRC I: Michacl.Dudek@nrc.gov 11: (30 1) 415-6500 I BB: \bli6)

• • • • • Original Message--***

From: Stuchell, Sheldon Sent: Wednesday, September 24, 2014 5:59 PM To: Dudek, Michael; Markley, Michael Cc: Mohseni, Aby; Banic, Merrilee; Mensah, Tanya; Khanna, Meena; Singal, Balwant; Oesterle, Eric; Pedersen, Renee

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NIRR)

Mike & Mike, I'd like to make sure this issue is closed, and any ticket assigned to NRR is closed. Any correspondence coming to the NRC can be considered as a 2.206 petition, ifit meets the requirements of our MD and is determined to be an actual petition. In this case, the submittal does not meet the requirements to be a 2.206 petition, and should be considered general correspondence.

The e-mail chain below can be confusing, and l must point out that no single individual submitted this correspondence. It was not Mr. Peck. Mr. Peck, one of our Sr. Resident Inspector's, did in fact have a DPO about Diablo, but that DPO has been dispositioned. The submitter in this case was "change.org."

Therefore, there is no individual we can respond to.

I highly recommend this be closed with no further action. As noted in the ticket, staff is to respond "as appropriate." In this case, the appropriate response is no response to an organization.

If there are still questions as to how to close the issue, it should be worked out between Mike and Mike. This is not

a 2.206 petition and NRR/DPR is not involved.

Hope this helps, Sheldon

---

Original Message-----

From: Banic, Merrilee Sent: Wednesday, September 24, 20 14 I :36 PM To: Stuchell, Sheldon Cc: Mensah, Tanya

Subject:

RE: STARS OEDO Office Notification (LT R-14-0495- 1-NRR)

A little background:

lfchange.org is basing its petition on M. Peck's, a Sr Resident's, DPO, the NRC resolved his DPO:

http-//rJ nrc.i:ov/headjjnes/DjabloSafe.9-18-2014.pdf From: Stuchell, Sheldon Sent: Wednesday, September 24, 2014 12:34 PM To: Dudek, Michael; Mensah, Tanya; Banic, Merrilee; Markley, Michael; Kokajko, Lawrence; Khanna, Meena Cc: Singal, Balwant; Oesterle, Eric; Pedersen, Renee

Subject:

RE: STARS OEDO Office Notification (LTR- 14-0495-1-NRR)

All, The easiest solution to this, is for the DORL PM to respond by e-mail to the submitter (he is not a petitioner) and let him know that we have received his general correspondence and thank him for his interest in nuclear safety. There is no need to expound or explain any further than that.

We receive numerous submittals all year long, that require nothing more than an acknowledgement.

Sheldon From: Dudek, Michael Sent: Wednesday, September 24, 2014 12:25 PM To: Mensah, Tanya; Banic, Merrilee; Markley, Michael; Kokajko, Lawrence: Khanna, Meena Cc: Singal, Balwant; Oesterle, Eric; Pedersen, Renee; Stuchell, Sheldon

Subject:

RE: STARS OEDO Office Notification (LTR- 14-0495- 1-NRR)

All: As a result of the past e-mails. it now appears that we (the staff) have an action lo contact the petitioner (Mr.

Peck) to have him formally submit the petition in hard-copy to the N RC so that we have an official record of his concerns.

Question: Does the staff want to take this action, or should I try to go back through the Chairman's Office for this request since that is where is action originated?

Please advise.

Michael I. Dudek Michael I. Dudek I OEDO Executive Technical Assistant I U.S. NRC

• Michael.Dudek@nrc.gov<mailto*Mjchael Dudek@nrc i:ov> I *: (30 I) 4 15-6500 I BB:....  ! __ 1b_)(G_) _ ~

From: Mensah, Tanya

Sent: Wednesday, September 24, 201411:24 AM To: Banic, Merrilee; Markley, Michael; Kokajko, Lawrence; Khanna, Meena Cc: Singal, Balwant; Oesterle, Eric; Pedersen, Renee; Dudek, Michael; Stuchell, Sheldon

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

To expand on Lee's comment, in the past we've had several petitioners attempt to direct us to their personal websites or biogs to "download" 2.206 petitions and other supplemental materials. In consultation w/ OGC years ago, their position has always been consistent with MD 8.11 , that the petition be submitted in writing. In these cases, the PM simply infomied the petitioner of the process to submit a 2.206 petition, in writing, if they want their concerns considered under that process.

Members of the public often change their website links/biogs. Their URLs may not even exist in a year. So we need an official NRC record of the petitioner's concerns, which they have to submit in writing to the NRC. If the petitioner has videos or other electronic media to support their 2.206 petition, we advise them of the proper way to submit it. I think the DCD has gu idance on the proper submission of electronic media to ensure that it is docketed.

Tanya From: Banic, Merrilee Sent: Wednesday, September 24, 2014 8:32 AM To: Markley, Michael; Kokajko, Lawrence; Khanna, Meena Cc: Singal, Balwant; Oesterle, Eric; Mensah, Tanya; Pedersen, Renee; Dudek, Michael; Stuchell, Sheldon

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Per our MD 8.11 "Section 2.206 requires that the petition be submitted in writing and provide the grounds for taking the proposed action ...."

From: Markley, Michael Sent: Wednesday, September 24, 2014 8: 11 AM To: Kokajko, Lawrence; Khanna, Meena Cc: Singal, Balwant; Oesterle, Eric; Mensah, Tanya; Banic, Merrilee~ Pedersen, Renee; Dudek, Michael

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Lawrence and Tim, The assertion that this follows the process in 2.206 for submitting petitions to the EDO seems highly out of process.

We should not have to download software to review a submittal to the NRC. Likewise, we should not have to go through extreme measures to access the infomiation via an external website. I am struggling to see how the link provides an actual petition. It merely asserts that Michael Peck's DPO should provide the basis for a petition to shut down the plant. This is highly out of process.

From my view, we have nothing to process here. The petitioner should be referred to the regulations in 2.206 and follow the process. NRR/DPR may disagree, but I do not see a document that we have submitted in an official manner that warrants the assignment of a petition manager. Let's talk. I do not see a basis for entering this into the petition process.

Mike Markley From: Dudek. Michael Sent: Tuesday, September 23, 2014 2:43 PM To: Markley, Michael Cc: Singal, Balwant; Oesterle, Eric

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1 -NRR)

I went onto my iPhone and found it on the web site.

[cid:imageOO 1.jpg@O ICFD800.6 EB578AO)

Petitioning Nuclear Regulatory Commission Decommission the aging Diablo Canyon Nuclear Power Plant I.

[cid:image002.jpg@OICFD800.6EB578AO]<hups*//www chan1,1e.or~/ori:aoiza1jons/uncommon folk>

2.

I. Petition by Uncommon Folk<hn:ps:/iwww.chanee or1,1/or1:aoiza1jons/uncommon folk>

In fault-ridden San Louis Obispo County, stands Californ ia's last two operating nuclear reactors in the aging Diablo Canyon Power Plant (circa 1973). They are located proximally to the Los Osos, Hosgri, San Andreas, and Shoreline Faults, along shores near Avila Beach.

According to a recent report by Michael Blood (ABC 30 Action News); a senior federa l nuclear expert, Michael Peck, has urged regulators to shut down the aging power plant until they can determine whether or not the facility's twin reactors can withstand an earthquake ofsimilar or larger size than the one that recently shook Napa. Blood reports:

Peck, who for five years was Diablo Canyon's lead on-site inspector, says in a 42-page, confidential report that the Nuclear Regulatory Commission is not applying the safety rules it set out for the plant's operation.

In light of the unfolding disaster at the Fukushima Daichii power plant, we the undersigned are asking that Governor Jerry Brown support us in demanding that the Diablo Canyon Plant be shut down until it can be properly earthquake tested and Michael Peck's charges of negligence be thoroughly investigated.

Or better yet, we ask that Jerry Brown work to shut down the Diablo Canyon Plant permanently, as it is located in such an unsafe region.

We the undersigned ask that NRC Inspector General Hubert T. Bell, Chaiman Allison Macfarlane, and Govenor Jerry Brown listen to the experts and heed the warnings of recent history, so we are not collectively doomed to repeat such catastrophic failures.

For the sake of California and its citizens, young and old. please shut down the Diablo Canyon Nuclear Power Plant!

Here is a short and enlightening PBS video that was made before several more major faultlines were found in that area...making it even MORE imperative that these professional opinions be heeded. Please take a few minutes to watch. There is a long history of lies and suppression of information surrounding the Diablo Canyon Nuclear Plant, at the peril of our citizens and their families->

btlp-llvideo pbs org/vjdeo/20566'>5-,05/

MORE PETITIONS TO SIGN. THIS MOVEMENT IS GAIN ING MOMENTUM, THANKS TO ALL OF YOU.

Please sign them all and PASS IT ON! Together we can do it->

( I) http' //action foe oe1o:/p/d ia/actjon3kommon/publ icl?action K EY- 16, B (2) http*//petitious moveon.ori:lsii.:o(orc-shut-down-djablo?source-=s ico.tw&r by-7525393 (3) lrnp*//act credoaction,com/sj~ntdjablo canyon IM PORTANT TO THOSE LIVING IN NEAR DIABLO CANYON. RECENT STUDY INDICATES SIGNIFICANTLY HIGHER CANCER RATES IN RESIDENTS->

hup://calcoastnews com/">O 14/03/bii:b-cancer-rates-near-diablo-canyon-nuclear-plant/

http* //www.helencald jcottfoundat ion oriu)>lol:'s/heahh-stud ies-explode-the-mytb-o [-the-* safe' -nuclear-power-plant. htm I<bttp* //www he!encald jcottfoyndat ion.or"/bloi,:s/hcal 1h-stud jes-explode-the-myth-of-t he-* safe* -nuclcar-power-plan t html>

h11p://worldhusjness.ori.i(nuclear-power-healtb-impact-stydy/

More information->

tnw //world husi ness ori,:/safe-eneri,:y-pro ject/close-d iahlo-canyon-nuc !ear-power-plan LI http://worldbusioess.oril,l'nuclear-r:s:"ulators-hear-from-anery-public-on-diablo-canyon-plant/

http://www.sfi:ate com/news/article/Earthquake-concerns-prompt-caH-10-shut-nucleac-S7 I I 717,php http://www.chsnews com/news/ca Ii fornia-carthQ uake-expcrt-u ri,:cs-nuc!ear-plant-closure-oyer-1breat/

http" //www.dailynews.com/i,:encrat-ncws/20 I408" Sid iablo-ca nyon-nuc Iear-ptan1-should-be-closcd-for-Qw1ke-1cs1ini,:-cxpcrt-says To:

Nuclear Regulatory Commission, Hubert T. Bell, Inspector General at the NRC Nuclear Regulatory Commission, Allison Macfarlane, Chari man of the NRC Sen. Barbara Boxer, California Gov. Jerry Brown, California Decommission Aging Diablo Ca11yon Nuclear Power Plant Sincerely,

[Your name]

Michael I. Dudek I OEDO Executive Technical Assistant I U.S. NRC

• Michael.Dudek@nrc.gov<majho:Mjchael Dudek@nrqoy> I *: (30 I) 4 15-6500 I BB: . I.__-"'-""""---'

(b)(6)

From: Markley, Michael Sent: Tuesday, September 23. 2014 2:24 PM To: Dudek, Michael Cc: Singal, Balwant; Oesterle, Eric

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Mike, Can we go back to the Chairman's office to get a hard copy of the petition.? We are having no luck in accessing the document via the links.

Mike From: Singal, Balwant Sent: Tuesday, September 23, 20 14 12:42 PM To: Mensah, Tanya Cc: Oesterle, Eric; Markley, Michael

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Cathy was unable to help (could not open the file from the link in the file). She suggested contacting CSC. CSC

was on my desk yesterday, but were also unable lo open the file. They believe there is a problem with the link.

Hence, as of now we do not have a resolution and do not have a copy of the petition.

From: Mensah, Tanya Sent: Tuesday, September 23, 2014 I I :57 AM To: Markley, Michael; Banic, Merrilee Cc: Singal, Balwant

Subject:

RE: STARS OEDO Office Notification (L TR-14-0495-1-NRR)

Any resolution on this? I typicarny email Cathy Jaegars for the incoming when we have problems accessing it via ADAMS. Looks like Balwanl already submitted an email to her.

Just following up.

Tanya From: Markley, Michael Sent: Monday, September 22, 20 14 3 :41 PM To: Banic, Merrilee; Mensah, Tanya Cc: Singal, Balwant

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-N R.R)

Lee and Tanya, We have not seen the actual petition but the OEDO tasking seems at hand.

Mike From: Singal, Balwant Sent: Friday, September 19, 2014 2:26 PM To: Jaegers, Cathy Cc: Markley, Michael

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Cathy.

Can we get access to the actual petition please?

From: Markley, Michael Sent: Friday, September 19, 2014 12:47 PM To: Singal, Balwant

Subject:

RE: STARS OEDO Office Notification {LTR-14-0495-1-NRR)

Sorry, Balwant, I am not seeing an actual petition in any of these files. Just a lot of duplicate letters , a Susquehanna Security-related document, and an Army document. The links do not allow asccesssx to an actual petition and it is not in any of these ADAMS files.

From: Singal, Balwant Sent: Friday, September 19, 2014 12:33 PM To: Markley, Michael

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495- 1-NRR)

Yes. I was able to open it. It has reference to the following two ML numbers and I was able to get to the documents by clicking the link:

ML I4245A494

ML I4245A49S (Package)

Contains ML14246A484, MLl4246A496, and ML14246A494).

Couple of documents are large (30-40 pages).

I can help on Monday if needed.

From: Markley, Michael Sent: Friday, September 19, 20 14 12: 11 PM To: Singal, Balwant; Oesterle, Eric Cc: RidsNrrMailCenter Resource; Jaegers, Cathy

Subject:

RE: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

Balwant, Can you get to the petition? I tried to open the link but it appears to require downloading software that is not supported on NRC systems.

Mike From: Singal, Balwant Sent: Friday, September 19, 20 14 10:20 AM To: Oesterle, Eric Cc: Markley, Michael

Subject:

FW: STARS OEDO Office Notification (LTR- 14-0495- 1-NRR)

For your information please.

From: RidsNrrDorl Resource Sent: Friday, September 19, 2014 I 0: 11 AM To: Singal, Balwant

Subject:

FW: STARS OEDO Offi ce Notification (LTR- 14-0495- 1-NRR)

From: RidsNrrMailCenter Resource Sent: Thursday, September 04, 2014 I:05 PM To: RidsNrrDorl Resource Cc: Cox, Linda

Subject:

FW: STARS OEDO Office Notification (LTR-14-0495-1-NRR)

The following appropriate action on Request Decommissioning of the Aging Diablo Canyon Nuclear Power Plant has been assigned to DORL.

Please let me know if you plan to respond.

SECY would like this document released to the public in ADAMS. Please review and let me know if that is ok.

From: ADAMS p8_icm_service Sent: Wednesday, September 03, 2014 2:24 PM To: ICM_STARS_NRR; Dudek, Michael

Subject:

STARS OEDO Office Notification (LTR-14-0495-1-NRR)

A new OEDO Ticket has been assigned to you by Jaegers, Cathy (cej ) on 09/03/20 14.

[http*//adamsjcm .nrc.i;:ov *9080/STA RS/STA RS pn~J<https://adamsjcm nrc.i;:ov/STARS>

Last User Comment has been added to a Ticket by 09/03/2014 on 09/03/2014. The comment was -

09/03/20 14 The Ticket information is below.

Ticket In fo Activity In formation Case Number LTR-14-0495- 1-NRR Status New Activity T ype LT R EDO Due Date SECY Due Date Requested Due Date Assigned O ffices N RR Ro uting Copies to Region IV I OGC EDO Point o f Contact Dudek, Michael (mid)

Other Parties Incoming ADAMS Accession

ML I 4245A494<hnps://adamsx1 ore 11ov/Workp)aceXT/11e1Conteot9 objectStoreName=Maio%20Ljbracy&objectType- document&ystd- %7bCf392f2 1- IFOE-4027-A2AB-429858"68Q3A%7d>

Date of Incoming 09/29/2014 Incoming ADAMS Package ML I 4245A495<https://adamsxt.nrc 11ov/WorkpJaceXTl11etContent?

objectStoreName- Main%20Ljbrary&objectType=document&vs!d %7b814EA5B0-3f 17-:15A 1-2102-4El394A9DCDJ%7d>

Frequency Incoming Information Originator Keating M Originator Organization Citizens Task E-mail Addressee Name Macfarlane A M Addressee Affiliation NRC/Chaim1an Incoming Received Date 09/02/2014 Subject Request Decommissioning of the Aging Diablo Canyon Nuclear Power Plant Description

Process Information Special Instructions Type Appropriate Action Special Instructions For Appropriate Action. Office/Region to determine ifa response is needed. If response is appropriate, please be sure to include your response to the ADAMS Package and process accordingly. Copies should be sent to RidsEdoMailCenter and RidsSecyMailCentcr. The incoming document needs to be made publicly available in ADAM S per SECY for immediate release. If this should not be made publicly available, please let us know ASAP.

Near Tern, Comment Requested Action Type Appropriate Action Cross Reference Numbers Signature Level No Signature Required OIG Recommend OEDO Concurrence OCM Concurrence OC A Concurrence

From: Pedersen, Renee Sent: Tuesday, August 20, 2013 1:20 PM To: Wertz, Trent Cc: Sewell, Margaret; Solorio, Dave

Subject:

ACTION: Status of Establishing DPO Panel Attachments: QUESTION: DP0-2013-002, Memo Forwarding Differing Professional Opinion Involving Diablo Canyon Seismic Issues ; DPO Panel

Trent, Can you give me a status of where you are on establishing the DPO Panel? I know you mentioned that Eric was out.

I'll be out the rest of the week, and wanted to make sure I knew where things were so I could get back to the submitter and Neil O'Keefe and give them an update.

Thanks!

Renee

From: OKeefe, Neil Sent: Tuesday, August 20, 2013 10:37 AM To: Pedersen, Renee

Subject:

DPO Panel

Renee, For the Peck DPO, who is on the panel, and when do they plan to meet?

My travel schedule is very busy for the next month, but I really want to be able to support the panel.

Neil

From: Peck, Michael Sent: Tuesday, August 20, 2013 10:17 AM To: Pedersen, Renee

Subject:

QUESTION: DP0-2013-002, Memo Forwarding Differing Professional Opinion Involving Diablo Canyon Seismic Issues Ms. Pedersen.

Please provide an update on the status of DP0-2013-002. Has Mr. Leeds assigned a committee chair person?

Thank you.

Michael Peck 423-855-6515 From: Hasan, Nasreen Sent: Friday, August 02, 2013 4:01 PM To: Leeds, Eric Cc: Bergman, Thomas; Campbell, Andy; Campbell, Vivian; Fuller, Karla; Dorman, Dan; Uhle, Jennifer; Howell, Art; Evans, Michele; Markley, Michael; Wertz., Trent; Weber, Michael; Merzke, Daniel; Peck, Michael; Rutledge, Steven; OKeefe, Neil; Wittick, Brian; Sewell, Margaret; Pedersen, Renee; Solorio, Dave; Zimmerman, Roy; Johnson, Michael; Mitchell, Reggie

Subject:

DP0-2013-002, Memo Forwarding Differing Professional Opinion Involving Diablo Canyon Seismic Issues August 2, 2013 MEMORANDUM TO: Eric J. Leeds, Director Office of Nuclear Reactor Regulation FROM: Renee M. Pedersen, Sr. Differing Views Program Manager IRA/

Office of Enforcement Please see the link below.

View ADAMS P8 Properties ML13213A248 Open ADAMS P8 Package (DPO 2013 002, Differing Professional Opinion Involving Diablo Canyon Seismic Issues)

ADAMS Package: ML13213A248 Memo: ML13213A249 DPO Submittal: ML13214Al62 Milestones and Timeliness Goals: ML 132 l 3A259 Note: This document is limited to those on distribution only Tlumk yo11, Nasree11 Ha.w m Adm illistrative Assista11t

Office of Enforcement location I Mai/stop: 0-4A I SA Office #: (301)415-2741 Fax: (30/)415-3431 2

From: Pedersen, Renee Sent: Wednesday, August 28, 2013 9:10 AM To: Case, Michael; Wertz, Trent Cc: Sewell, Margaret; Solorio, Dave

Subject:

RE: Diablo Canyon DPO Attachments: Milestones and Timeliness Goals.docx Actually, the clock has already started. The timeliness goal for the DPO process is to have a DPO Decision issued 120 days from the date when the DPO was accepted , which is 11 /29/2013.

I've attached the Milestones and Timeliness Goals. Each milestone has a timeliness goal-a way of meeting the overall goal. The goal for establishing the DPO Panel is 14 days. In this case, we're past that , in part due to Eric's schedule. This is something to keep in mind if an extension is required. The goal for the DPO Panel is still 70 days-the DPO Panel shouldn't necessarily try and make up the time, nor should Eric when he writes the DPO Decision.

Trent, let me know if you need anything for the memo.

Thanks!

Renee From: Case, Michael Sent: Wednesday, August 28, 2013 8:55 AM To: Wertz, Trent Cc: Pedersen, Renee

Subject:

RE: Diablo canyon DPO Great. As long as the clock hasn't started ...

From: Wertz, Trent Sent: Wednesday, August 28, 2013 8:31 AM To: Case, Michael Cc: Pedersen, Renee

Subject:

RE: Diablo Canyon DPO Still working on the last member. Eric needs to talk to Scott Flanders.

From: case, Michael Sent: Wednesday, August 28, 2013 8:06 AM To: Wertz., Trent Cc: Pedersen, Renee

Subject:

Diablo Canyon DPO Hi Trent. Did we get the memo out yet on the panel or is it still working?

1

From: Tracy, Glenn Sent: Wednesday, August 28, 2013 12:05 PM To: Leeds, Eric Cc: Wertz, Trent; Dorman, Dan; Uhle, Jennifer; Pedersen, Renee; McCree, Victor; Wert, Leonard; Holahani, Gary; Sheron, Brian; West, Steven; Flanders, Scott; Schum, Constance; Tonacci, Mark; Chokshi, Nilesh

Subject:

"Ot10"'RESPONSE: DPO Panel Members euo Eric, I know Scott speaks with you regularly, but I wanted to get back to you regarding our support of your request for Cliff Munson on this panel. Please realize that we will try to minimize the impacts of this request and effort, relative to Cliff's other important ongoing work wrt Fukushima 2.1 and new reactors. There will obviously be some impact. Best always, Glenn From: Leeds, Eric Sent: Wednesday, August 21, 2013 10:55 AM To: Mccree, Victor; Wert, Leonard; Tracy, Glenn; Holahan, Gary; Sheron, Brian; West, Steven Cc: Wertz., Trent; Dorman, Dan; Uhle, Jennifer; Pedersen, Renee

Subject:

DPO Panel Members Folks -

We are putting together a DPO panel to handle seismic licensing issues at Diablo Canyon. The NRR ET is requesting your assistance and support for the following individuals:

Mike Case - as the lead SES. Mike brings licensing and all around deep thinking and common sense to the team.

Cliff Munson - Cliff would bring the technical muscle to the team as a seismic guru.

Rudy Bernhard - Rudy was one of three candidates identified by the DPO submitter.

Please let mefTrent Wertz know as soon as possible if you can support. If you can support, Trent will contact the identified individuals. Thanks for your consideration!

Eric J. Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulaotry Commission 301-415-1270 000

From: Pedersen, Renee Sent: Thursday, August 29, 2013 8:52 AM To: Leeds, Eric Cc: Sewell, Margaret; Wertz, Trent; Solorio, Dave

Subject:

RE: ACTION: Quest ion on DPO Panel Member Importance: High

Eric, It isn't written that you have to take them in the order provided, but employees typically list the nominees in the order that they would like them selected. As I said before, as long as you have a rationale for Rudy vs. the other nominees, we're O.K. I want to avoid any appearance that an employee wasn't selected because they are viewed as too outspoken, etc ..

Because panel selection is so critical to success. I took the liberty of running the selection of Mike Case and Cliff Munson by the submitter. (I didn 't say anything about the third member because I wanted to check in with you first. ) FYI , the submitter is very concerned with the selection of Cliff Munson. Please see the excerpt from his email:

I would like to alert you to a potential conflict with Mr. Munson as a DPO panel member. Mr. Munson is listed as a senior advisor with the Division of Site Safety and Environmental Analysis. Annie Kammerer is shown on the NRC web page as currently assigned to this division. Dr. Kammerer was largely responsible for the prevailing NRC position on the Diablo Canyon seismic issues and was the primary contributor to the NRC response to my non-concurrence. Dr. Kammerer went so far pressing her viewpoint to include making OIG allegations against me related to the Diablo Canyon seismic issues (I subsequently received an OIG clearance letter related to these allegations}.

Please consider Mr. Munson's organizational relationship with Dr. Kammerer during panel selection.

In addition, the submitter also noted ...

While seismic is in the title of the DPO, this DPO is really not about seismic technical issues. I've made the assumption that all seismic evaluations (included in the FSAR or presented in the NRC Research Information Letters) are correct. This DPO is about how the agency enforces design and licensing bases requirements and ve rifies operability for non-conforming and unanalyzed conditions. These issues could be applied to any NRC licensing basis requirements (flooding, ECCS acceptance criteria, containment accident response).

I hope this information helps. I want to emphasize that panel selection is your responsibility--it is not a negotiation with the submitter. That having been said, if the submitter doesn't think the panel is credible. we've failed before we've started.

Please let me know if you need any additional assistance from us.

Renee From: Leeds, Eric Sent: Wednesday, August 28, 2013 6:31 PM To: Pedersen, Renee Cc: Sewell, Margaret; Weru., Trent; Solorio, Dave

Subject:

Re: ACTION: Question on DPO Panel Member

I didn't know that I had to take them in the order provided. I thought that any of the three was acceptable to the submitter.

Where is it written differently? Is this a crisis? I picked Rudy because of a number of reasons that I found desirable - no prior involvement with the issue, he's an SRA, different region, etc. I need a team as pure as the driven snow on this issue

- I'm sure it will eventually receive media attention.

From: Pedersen, Renee To: Leeds, Eric Cc: Sewell, Margaret; Wertz., Trent; Solorio, Dave Sent: Wed Aug 28 12:39:34 2013

Subject:

ACTION: Question on DPO Panel Member

Eric, Sorry I didn't catch this sooner, but is there a reason you are including the submitter's 3 rd choice (Rudy Bernhard) versus his 1st (Gerond George) or 2nd (Larry Criscione) choice for the DPO Panel? Normally, we would expect the 1st choice, unless there were conflicts. As long as there is a rationale, we're in good shape. We wouldn't want someone to claim that an employee wasn't selected because he or she has a history of being outspoken, etc.,

Renee From: Leeds, Eric Sent: Wednesday, August 21, 2013 10:55 AM To: Mccree, Victor; Wert, Leonard; Tracy, Glenn; Holahan, Gary; Sheron, Brian; West, Steven Cc: Wertz., Trent; Dorman, Dan; Uhle, Jennifer; Pedersen, Renee

Subject:

DPO Panel Members Folks -

We are putting together a DPO panel to handle seismic licensing issues at Diablo Canyon. The NRR ET is requesting your assistance and support for the following individuals:

Mike Case - as the lead SES. Mike brings licensing and all around deep thinking and common sense to the team.

Cliff Munson - Cliff would bring the technical muscle to the team as a seismic guru.

Rudy Bernhard - Rudy was one of three candidates identified by the DPO submitter.

Please let meffrent Wertz know as soon as possible if you can support. If you can support, Trent will contact the identified individuals. Thanks for your consideration!

Eric J. Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulaotry Commission 301-415-1270 2

From: Leeds, Eric Sent: Thursday, August 29, 2013 12:31 PM To: Pedersen, Renee; Flanders, Scott Cc: Wertz, Trent; Sewell, Margaret; Solorio, Dave; Hilton, Nick; Case, Michael

Subject:

RE: -etf&RESPONSE: DPO Panel Members Good thoughts Renee ! Scott - please look through this email thread. I continue to make life hard for you and your staff - I apologize. Please see the concerns that Renee has raised and consider whether we should switch to Brett.

Thanks for your patience!

Eric From: Pedersen, Renee Sent: Thursday, August 29, 2013 10:33 AM To: Leeds, Eric Cc: Wertz, Trent; Sewell, Margaret; Solorio, Dave; Hilton, Nick

Subject:

RE: 000-RESPONSE: DPO Panel Members.

Importance: High

Eric, In light of the submitters concerns, I would recommend that you consider Brett Hill. In addition, because of the submitters view on the issues (how the agency enforces design and licensing bases requirements and verifies operability for non-conforming and unanalyzed conditions), you could even consider asking for another panel member from OE. Just a thought.

Renee From: Leeds, Eric Sent: Thursday, August 29, 2013 10:20 AM To: Pedersen, Renee Cc: Wert2., Trent

Subject:

FW: GUO-RESPONSE: DPO Panel Members Just saw this. Do I need to go back to Scott and tell him we need Brett Hill?

From: Flanders, Scott Sent: Thursday, August 29, 2013 10:07 AM To: Leeds, Eric; Tracy, Glenn Cc: Wertz, Trent; Dorman, Dan; Uhle, Jennifer; Pedersen, Renee; Mccree, Victor; Wert, Leonard; Holahan, Gary; Sheron, Brian; West, Steven; Schum, Constance; Tonacci, Mark; Chokshi, Nilesh

Subject:

RE: ffi:te RESPONSE: DPO Panel Members Eric, I think Cliff is the right person. As Glenn said having Cliff work on the DPO will impact our 2.1 work, but we will work to minimize the impact.

Scott l

From: Leeds, Eric Sent: Wednesday, August 28, 2013 6:26 PM To: Tracy, Glenn Cc: Wertz., Trent; Dorman, Dan; Uhle, Jennifer; Pedersen, Renee; Mccree, Victor; Wert, Leonard; Holahan, Gary; Sheron, Brian; West, Steven; Flanders, Scott; Schum, Constance; Tonacci, Mark; Chokshi, Nilesh

Subject:

Re:"'Ot:1&RESPONSE: DPO Panel Members Thanks, glenn. Scott and I discussed and I'm fine if he wants to propose another individual. He's weighing the pros and cons and will get back to me with a good person.

Scott always comes through!

Eric From: Tracy, Glenn To: Leeds, Eric Cc: Wertz., Trent; Dorman, Dan; Uhle, Jennifer; Pedersen, Renee; McCree, Victor; Wert, Leonard; Holahan, Gary; Sheron, Brian; West, Steven; Flanders, Scott; Schum, Constance; Tonacci, Mark; Chokshi, Nilesh Sent: Wed Aug 28 12:04:47 2013

Subject:

Otte RESPONSE: DPO Panel Members Eric, I know Scott speaks with you regularly, but I wanted to get back to you regarding our support of your request for Cliff Munson on this panel. Please realize that we will try to m inimize the impacts of this request and effort, relative to Cliffs other important ongoing work wrt Fukushima 2.1 and new reactors. There will obviously be some impact. Best always, Glenn From: Leeds, Eric Sent: Wednesday, August 21, 2013 10:55 AM To: Mccree, Victor; Wert, Leonard; Tracy, Glenn; Holahan, Gary; Sheron, Brian; West, Steven Cc: Wertz., Trent; Dorman, Dan; Uhle, Jennifer; Pedersen, Renee

Subject:

DPO Panel Members Folks -

We are putting together a DPO panel to handle seismic licensing issues at Diablo Canyon. The NRR ET is requesting your assistance and support for the following individuals:

M ike Case - as the lead SES. Mike brings licensing and all around deep thinking and common sense to the team.

Cliff Munson - Cliff would bring the technical muscle to the team as a seismic guru.

Rudy Bernhard - Rudy was one of three candidates identified by the DPO submitter.

Please let me/Trent Wertz know as soon as possible if you can support. If you can support, Trent will contact the identified individuals. Thanks for your consi:deration!

Eric J. Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulaotry Commission 301-415-1270 2

ouo 3

From: Craver, Patti Sent: Tuesday, September 03, 2013 3:02 PM To: Peck, Michael; Pedersen, Renee Cc: Wertz, Trent

Subject:

DP0-2013-002 Good Afternoon, Below is the electronic link for the memorandum appointing members to the Ad Hoc Review Panel for the Differing Professional Opinion (DPO) Involving Seismic Issues at Diablo Canyon.

A paper copy has been mailed to each of the panel members with the DPO and milestones and timeliness goals.

View ADAMS P8 Properties ML13242A305 Open ADAMS P8 Document (DP0-2013-002 - Ad Hoc Review Panel - Differing Professional Opinion Involving Seismic Issues at Diablo Canyon)

Should you have any questions, please contact Trent Wertz by phone at 415-1568.

Thanks!

Patti Craver Management Analyst Infrastructure Services Branch Program Management, Policy Development and Analysis Staff Office of Nuclear Reactor Regulation (301) 4 15-1513 patti. craver@nrc.gov

From: Leeds, Eric Sent: Friday, September 06, 2013 8:05 AM To: Bernhard, Rud olph; Case, Michael; Hill, Brittain Cc: Wertz, Trent; Schwarz, Sherry; Pedersen, Renee

Subject:

DPO Panel Gentlemen-Thank you all for being willing to serve on the Diablo Canyon seismic DPO Panel. Each of you were distinctly chosen for what you can bring to the team; your independence from the issue and your expertise, experience and past service to the agency.

I'd like to hold a brief, Yi hour meeting to provide the Panel my thoughts on the DPO process and my expectations for your challenge in conducting this review. Sherry Schwarz will arrange the meeting. Rudy, I understand that you will be unavailable for the next few weeks, so we will work based on your schedule and will try to use the VTC for the meeting. All you need to do to prepare for the meeting is to have read the DPO submittal.

Thank you again for your willingness to serve!

Eric J. Leeds Director, Office o f Nuclear Reactor Regulation U.S. Nuclear Regulaotry Commission 301-415-1270

From: Leeds, Eric Sent: Friday, September 06, 2013 9:44 AM To: Pedersen, Renee Cc: Sewell, Margaret; Schwarz, Sherry; Wertz, Trent

Subject:

RE: ACTION: Can I attend your DPO Panel meeting Sounds like a good idea, Renee. I'll kick off the meeting. Basically, all I want to tell them is how I value the DPO process, that its important, that they are doing an important service for the agency, etc. About how important the first step in the process is: make sure they document the DPO submitters issue such that they understand it and the submitter agrees that they've captured his issue (fyi - from my read, its not clear in the existing documentation). My expectation is that they need to dig deep into the technical , as well as regulatory aspects of the issue and that they need to avail themselves of the expert staff throughout the agency. Don't work in a vacuum . Then I turn the meeting over to you.

Motherhood and apple-pie. But I want them to know how much I care about the process and that the agency needs them to do a good job.

Whaddyathink?

From: Pedersen, Renee sent: Friday, September 06, 2013 8:51 AM To: Leeds, Eric Cc: Sewell, Margaret Subj ect: ACTION: can I attend your DPO Panel meeting

Eric, I think it's good for you to meet with the panel to discuss your expectations. Taking the time to meet with the panel demonstrates your support for the process. That being said, because independence is a keep attribute of the panel process, we need to be cautious that your engagement with the panel (now and in the future) doesn't get misunderstood as driving the outcome. (I know that you understand the importance of perception vs. reality in dealing with this process.)

I'd like to suggest that Marge and I attend the meeting.

In addition, I typically have a kickoff meeting with the panel to discuss the process and responsibilities, so perhaps I can piggyback off of your meeting? If Sherry sets up the meeting in your conference room with VTC, is it possible to ask for another Yi hour that Marge and I can meet with the panel?

Renee From: Leeds, Eric sent: Friday, September 06, 2013 8:05 AM To: Bernhard, Rudolph; case, Michael; Hill, Brittain Cc: Wertz., Trent; Schwarz, Sherry; Pedersen, Renee

Subject:

DPO Panel Gentlemen -

Thank you all for being willing to serve on the Diablo Canyon seismic DPO Panel. Each of you were distinctly chosen for what you can bring to the team; your independence from the issue and your expertise, experience and past service to the agency.

I'd like to hold a brief, Y2 hour meeting to provide the Panel my thoughts on the DPO process and my expectations for your challenge in conducting this review. Sherry Schwarz will arrange the meeting. Rudy, I understand that you will be unavailable for the next few weeks, so we will work based on your schedule and will try to use the VTC for the meeting. All you need to do to prepare for the meeting is to have read the DPO submittal.

Thank you again for your willingness to serve!

Eric J. Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulaotry Commission 301-415-1270 2

From: Case, Michael Sent: Monday, November 25, 2013 10:42 AM To: Leeds, Eric Cc: Sheron, Brian; West, Steven; Pedersen, Renee; Bernhard, Rudolph; Hill, Brittain; Sewell, Margaret; Wertz., Trent

Subject:

RE: Diablo Canyon DPO Update Attachments: Appendix A.docx The Statement of Concerns is attached (excuse whatever typos are there. Haven't polished yet).

From: Leeds, Eric Sent: Satmday, November 23, 2013 11:17 AM To: case, Michael Cc: Sheron, Brian; West, Steven; Pedersen, Renee; Bernhard, Rudolph; Hill, Brittain; Sewell, Margaret; Wertz., Trent

Subject:

Re: Diablo canyon DPO Update Thank so much, Mike! As I mentioned to the team, your work will be highly scritinized both internally and externally, so doing a thorough job is critical. If you can share the statement of concern that your team develped with agreement from the Cl , please send it to me.

I really appreciate the heads up!

Eric From: case, Michael To: Leeds, Eric Cc: Sheron, Brian; West, Steven; Pedersen, Renee; Bernhard, Rudolph; Hill, Brittain; Sewell, Margaret Sent: Fri Nov 22 16:04:19 2013

Subject:

Diablo canyon DPO Update Hi Eric. I just wanted to give you a quick update on the progress on the Oiablo Canyon DPO. After the distractions of furloughs, vacations and performance appraisals, I think we have a good head of steam now. We've completed the statement of concerns, and have been primarily in the information gathering phase. Although we still need to gather some more information {including potentially w ith the licensee), we have a solid outline so we're entering the initial writing phase now. I think there is reasonable alignment among the panel so the struggle is likely to be not what to say, but how to say it.

As you m ight expect, the professionalism of both my fellow panelist and the folks involved in the Oiablo Canyon issue has been outstanding . You're probably wondering about when we are planning to get done. My estimate would be mid-December at this point.

If I don't get to see you, have a great Thanksgiving!

Mike

Appendix A:

Statement of Technical Concerns, Derived from Diablo Canyon DP0-2013-002

1) The NRC has not enforced Diablo Canyon Technical Specification requirements that key plant safety equipment remain operable during reactor operation. New seismic information developed by Pacific Gas and Electric concluded that Technical Specification requ ired Structures, Systems and Components (SSCs) can be exposed to greater vibratory motion than was used to qualified this equipment for the faci lity safe shutdown earthquake (SSE) design basis. For Technical Specification required SSCs to be considered operable, the licensee is required to demonstrate a reasonable assurance that this plant equipment would still be capable of performing the safety functions in accordance with the plant design bases and safety analysis.

2) Pacific Gas and Electric's operability evaluation following development of the new seismic information was inadequate. Comparison of the new seismic information only against the Hosgri Event (HE) and Long Term Seismic Program (LTSP) ground motions was not adequate to demonstrate Technical Specification required SSCs were operable . Neither the HE nor the LTSP methods were approved to be used in SSE safety analysis . The HE and LTSP methods over-predicted SSC performance when compared to the SSE design basis methods. Even though the HE and LTSP include higher ground motions, neither of these methods were bounding for plant Technical Specification SSCs seismic qualification . Use of the HE and LTSP ground motions failed to demonstrate that that the requirements of the American Society of Mechanical Engineers' (ASME) Boiler and Pressure Vessel Code acceptance limits would be met at the higher ground motions. 10 CFR 50.50a required that ASME acceptance limits be met for plant safety Class 1 and 2 following an SSE. Demonstration that the ASME acceptance limits are met provides assurance that the integrity key plant systems, including the reactor coolant pressure boundary would be maintained following the higher seismic stress levels represented by the new seismic information .

3) The NRC has failed to enforce the 10 CFR 50.59 requirements that Pacific Gas and Electric obtain an amendment to the Diablo Canyon Operating License prior to incorporating the Shoreline scenario into the FSARU. A license amendment was required because the change resulted in more than a minimal increase in the likelihood of a malfunction of SSCs important to safety than previously evaluated in the FSARU. A license amendment was also required because this change represents a departure from the FSARU method of evaluation used to establish the seismic SSE design basis. The NRC conclusion that a "reasonable assurance of safety" existed was not an adequate basis to conclude an amendment to the Diablo Canyon Operating License was not required.

4) The NRC failed to adequately address the Los Osos and San Luis Bay faults . The new seismic information concluded that these faults were also capable of producing ground motions in excess of the current plant SSE design basis.

From: Pedersen, Renee Sent: . Wednesday, November 27, 2013 10:12 AM To: Wertz, Trent Cc: Sewell, Margaret; Solorio, Dave; Leeds, Eric

Subject:

RE: Diablo Canyon DPO Update Importance: High

Trent, The ticketing must have slipped through the cracks. In any event, just have Eric send an email (like in the past) to DPOPM.Resource@nrc.gov.

requesting an extension.

Include the current due date, the reason for the delay, and the proposed due date. I know that it took longer than expected to establish the panel. Maybe you can include something on that as well as furlough, scheduling issues, etc. Get input from Mike Case on when report will be complete and add 21 days. Although Mike says mid-December, is it realistic with holiday schedules?

Once we have your request, we'll forward iaw with DPO MD guidance.

Renee P.S. Please be sure to include Marge on your emails because she is attempting to cover day-to-day activities while I work on a special project.

From: Wertz., Trent Sent: Tuesday, November 26, 2013 8:24 AM To: Pedersen, Renee

Subject:

FW: Diablo Canyon DPO Update

Renee, I talked to Eric about this earlier this morning. Since we don't have a green ticket for the DPO, do we need to request an extension or should we just send a memo to the EDO stating that due to the following reasons the DPO that was originally scheduled to be completed in December will now be finished up in early Feb?

Seems like a better approach.

Let me know what you think.

Thanks, Trent From: Leeds, Eric Sent: Monday, November 25, 2013 4:31 PM To: Weru., Trent

Subject:

FW: Diablo Canyon DPO Update Need your help with this - let's discuss! Thanks

From : Sewell, Margaret Sent: Monday, November 25, 2013 4:20 PM To: Leeds, Eric Cc: Pedersen, Renee

Subject:

FW: Dlablo Canyon DPO Update Hi Eric, Renee is working on a project today and asked me to follow-up with you on this case. In light of Mike's update below, it's clear that an extension is going to be required. Mike is estimating that the panel report won't be complete until mid-December, which means that your decision should be issued around early January. With the holidays upon us, it may be more realistic to extend your decision to early February ....just a thought.

Attached is the original Milestones & Timeliness Goals for your information. Please send us your justification for an extension request along with a new date and we'll be sure to submit it to EDO as soon as possible. We'll look forward to hearing from you.

If you have any questions, just let Renee or me know.

Thanks, Eric.

Marge From : Case, Michael Sent: Monday, November 25, 2013 10:42 AM To: Leeds, Eric Cc: Sheron, Brian; West, Steven; Pedersen, Renee; Bernhard, Rudolph; Hill, Brittain; Sewell, Margaret; Wertz., Trent

Subject:

RE: Diablo Canyon DPO Update The Statement of Concerns is attached (excuse whatever typos are there. Haven't polished yet).

From: Leeds, Eric Sent: Saturday, November 23, 2013 11:17 AM To: Case, Michael Cc: Sheron, Brian; West, Steven; Pedersen, Renee; Bernhard, Rudolph; Hill, Brittain; Sewell, Margaret; Wertz., Trent

Subject:

Re: Diablo Canyon DPO Update Thank so much, Mike! As I mentioned to the team, your work will be highly scritinized both internally and externally, so doing a thorough job is critical. If you can share the statement of concern that your team develped with agreement from the Cl , please send it to me.

I really appreciate the heads up!

Eric From : Case, Michael To: Leeds, Eric Cc: Sheron, Brian; West, Steven; Pedersen, Renee; Bernhard, Rudolph; Hill, Brittain; Sewell, Margaret Sent: Fri Nov 22 16:04:19 2013

Subject:

Diablo Canyon DPO Update Hi Eric. I j ust wanted to give you a quick update on the progress on the Diablo Canyon DPO. After the distractions of furloughs, vacations and performance appraisals, I think we have a good head of steam now. We've completed the statement of concerns, and have been primarily in the information gathering 2

phase. Although we still need to gather some more information (including potentially with the licensee), we have a solid outline so we're entering the initial writing phase now. I think there is reasonable alignment among the panel so the struggle is likely to be not what to say, but how to say it.

As you might expect, the professionalism of both my fellow panelist and the folks involved in the Diablo Canyon issue has been outstanding. You're probably wondering about when we are planning to get done. My estimate would be mid-December at this point.

If I don't get to see you, have a great Thanksgiving !

Mike 3

From: Case, Michael Sent: Wednesday, November 27, 2013 11:36 AM To: Peck, Michael Cc: Hill, Brittain; Bernhard, Rudolph; Sewell, Margaret

Subject:

DPO Update Attachments: Appendix A.docx Note: Attachment may be found as part of document B/46 in FOIA/PA-2015-0071 (ML16181A428).

Hi Michael. Happy Thanksgiving. I just wanted to give you a quick update on where we are and what we've been up to. First, attached is the statement of concerns that we're using. We're basically using the markup you provided earlier (there may be typos; my AA had to rekey it in). Since you've been back from leave, we've been mostly talking with other folks related to the DPO so we've done Mike Markley, Neil O'Keefe and Jon Ake. Quite frankly, we're still pulling information related to Diablo. After all, it is about 45 years of history.

Schedule wise, we're not going to make the initial timeline that I think you got when the DPO was initiated. We actually have started to write, but mostly it's just getting background information into the document. As far as estimates on getting our report done, I'm shooting for mid-December. If that turned out to be a final draft, I would be shocked but we have a good chance at a "report with holes" if you are familiar with how SERs are sometimes built.

Britt said you might be in town teaching in December. I'm sure the panel would enjoy meeting with you in person (except for Rudy who is out in Region II). If you have questions about what's going on, feel free to call (although email might be better in some respects. If I have free time, I'll be off working on the DPO which is almost impossible for me to do in my office).

Mike

From: Leeds, Eric Sent: Wednesday, November 27, 2013 12:05 PM To: DPOPM Resource Cc: Sewell, Margaret; Pedersen, Renee; Wertz, Trent; Case, Michael

Subject:

DPO Extension Request To Whom It May Concern, In accordance with Management Directive 10.159, Handbook (D)(S)(b), DPOs are expected to be completed within 120 days and the 120-day time frame may only be extended with the approval of the EDO through the DPOPM for offices that report to the EDO.

The purpose of this email is to request an extension for DP0-2013-002.

In particular, please revise the current due date from November 29, 2013 to January 31 , 2014.

The schedule has been impacted by several issues including the unavailability of one of the panel members due to prior work and leave commitments, the furlough in October, and the complex nature of the issue.

The DPO process affords employees an opportunity to have their views expressed to and considered by high level managers. Ensuring that managers have sufficient time to fully consider the issues is critical to the success of the process. We have reviewed the extension request and think that it is reasonable and consistent with the goals of the DPO Program.

Thank you for your consideration of this request.

Eric J. Leed s Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 30 1-415* 1270

From: Sewell, Margaret Sent: Tuesday, December 03, 2013 9:15 AM To: Leeds, Eric Cc: Pedersen, Renee; Solorio, Dave; Wertz, Trent; Case, Michael; Hill, Brittain; Bernhard, Rudolph; Peck, Michael; Zimmerman, Roy

Subject:

FW: Extension Request for DP0-2013-002 Attachments: DPO Extension Request; Milestones and Timeliness Goals.docx Importance: High

Eric, Based on the approved subject extension, attached is the new, updated schedule for OP0-2013-002.

If you have any questions, please feel free to contact us.

Thank you.

Marge Marge Sewell Safety Culture Specialist Office of Enforcement/Concerns Resolution Branch 301-415-8045 margaret.sewell@nrc.gov From: Khanna, Meena Sent: Monday, December 02, 2013 9:19 PM To: Sewell, Margaret; Pedersen, Renee Cc: Wertz., Trent

Subject:

FW: Extension Request for DP0-2013-002 Importance: High Just an fyi . .. thanks!

From: Khanna, Meena Sent: Monday, December 02, 2013 4:28 PM To: ExtensionRequest, EDO Cc: Sanfilippo, Nathan

Subject:

FW: Extension Request for DP0-2013-002 Importance: High Denise, I approve NRR's extension request for DP0-2013-002 from Nov 29, 2013 to January 31 , 2014.

Thanks, Meena From: ExtensionRequest, EDO Sent: Monday, December 02, 2013 4:22 PM To: Khanna, Meena

Subject:

FW: Extension Request for DP0-2013-002 Importance: High Hi Meena, For your review and approval.

Thanks, Denise From: Sewell, Margaret Sent: Wednesday, November 27, 2013 1:05 PM To: Extensi'onRequest, EDO Cc: Khanna, Meena; Leeds, Eric; Pedersen, Renee; Solorio, Dave; Zimmerman, Roy; Peck, Michael; Case, Michael; Hill, Brittain; Bernhard, Rudolph; Wert:J., Trent

Subject:

Extension Request for DP0-2013-002 Importance: High In accordance with Management Directive 10.159, Handbook (0)(5)(b), DPOs are expected to be completed within 120 days and the 120-day time frame may only be extended with the approval of the EDO through the DPOPM for offices that report to the EDO.

The purpose of this email is to request an extension on behalf of Eric Leeds, Director, Office of Nuclear Reactor Regulation, for DP0-2013-002.

In particular, please revise the current due date from November 29, 2013 to January 31 , 2014.

I am attaching Eric Leeds' extension request. The schedule has been impacted by several scheduling issues including leave commitments, the Government Shutdown, and the complex nature of the issue.

The DPO process affords employees an opportunity to have their views expressed to and considered by high level managers. Ensuring that managers have sufficient time to fully consider the issue is critical to the success of the process. I have reviewed the extension request and think that it is reasonable and consistent with the goals of the DPO Program.

I am also including the current Milestones and Timeliness Goals for this case.

Please let me or Renee Pedersen know if you have any questions. Thank you for your consideration of this request and we look forward to hearing from you.

Marge Sewell Safety Culture Specialist Office of Enforcement/Concerns Resolution Branch 301-415-8045 Renee Pedersen Office of Enforcement/Concerns Resolution Branch Sr. Differing Views Program Manager 301-415-2742 2

From: Pedersen, Renee Sent: Friday, January 24, 2014 11:16 AM To: Leeds, Eric Cc: Wertz, Trent; Sewell, Margaret Subj ect: FW: Status of Diablo Canyon Seismic Issues - DP0-2013-002 Importance: High

Eric, Just a heads up on your OPO. BTW, the Chairman's office referred Diane Curran (Mother for Peace) to me to answer her question about the status of this DPO.

Renee From: Sewell, Margaret Sent: Friday, January 24, 2014 10:54 AM To: Case, Michael Cc: Pedersen, Renee; Solorio, Dave

Subject:

Status of Diablo Canyon Seismic Issues - DP0-2013-002 Importance: High Hi Mike, We noticed that the projected DPO decision is quickly approaching (1/31/ 14) and just wanted to touch base to see how the panel is progressing. Do you have an approximate date for finalizing the panel report yet? Can you let us know where you are at this point in the process?

While the DPO guidelines say that Eric will have 21 days to make his final decision after receiving the report, he may need more time to do a thorough review of the report and prepare his decision. Consequently, it seems that another extension will be needed. If you haven't already done so, you may want to reach out to Eric so that he can submit an extension request to us as quickly as possible.

Thanks, Mike, and we'll look forward to hearing from you soon.

Marge

From: Sewell, Margaret Se nt: Monday, January 27, 2014 1:34 PM To: Case, Michael Cc: Pedersen, Renee; Solorio, Dave; Hill, Brittain; Benney, Brian; Sheron, Brian; Bernhard, Rudolph; Giitter, Joseph; Leeds, Eric; Wertz, Trent

Subject:

RE: Status of Diablo Canyon Seismic Issues - DP0-2013-002 Hi Mike, Thanks very much for the status update. A few questions came to mind as I read your email.

Having Joe Gitter review the final report for a quality/readability check isn't a problem and can certainly add value ; however. it's not typically part of the process. Therefore, we want to make sure Michael Peck has been informed of this extra step as well as the additional time involved. Have you discussed it with him yet to make sure he's onboard with the plan?

Also, have you been keeping Michael informed in general of the progress the panel has made and your recommendation to Eric for an extension?

As we've discussed in the past, it's really important to make sure the submitter is aware of the panel's progress, especially any anticipated delays in the final outcome.

If you have any questions, please give Renee (X2742) or me a call. Thanks very much and we'll look forward to receiving the extension request from Eric.

Marge Marge Sewell Safety Culture Specialist Office of EnforcemenVConcerns Resolution Branch 301-415-8045 marqaret.sewell@nrc.gov From: case, Michael Sent: Monday, January 27, 2014 9:52 AM To: Wertz., Trent; Leeds, Eric Cc: Pedersen, Renee; Solorio, Dave; Sewell, Margaret; Hill, Brittain; Benney, Brian; Sheron, Brian; Bernhard, Rudolph; Giitter, Joseph

Subject:

RE: Status of Diablo canyon Seismic Issues - DP0-2013-002 Good morning gentlemen.

I wanted to give you a status update and unfortunately recommend that we seek another extension. As you may recall , back in December, we had a teleconference with the licensee and requested that they develop some information that would support our DPO analysis. That seems to be the long pole in the tent at this point. They are working on it but have had some challenges due to the holidays and an illness. We have a fully written document at this point except for Concern #2 which I expect relatively shortly. We have also coordinated with Joe Giitter who has kindly agreed to give the report a quality/readability check when we complete it. Summarizing, the major steps remaining are:

Receive licensee information Complete drafting of Concern #2 Factor licensee information into existing writeup Write conclusion and recommendation section QC review Issue I'll touch base with Brian B. on the licensee information but I would think it would take two weeks from the point that we get it to get to final draft. Joe will try to do his review in about a week.

Sorry for the delay. Among the panel, I think we all have a good grasp of the issue (and the submitter has been very helpful with that) and we seem to see the issues in the same way (although we emphasize different aspects).

From: Sewell, Margaret Sent: Friday, January 24, 2014 10:54 AM To: Case, Michael Cc: Peders.en, Renee; Solorio, Dave

Subject:

Status of Diablo Canyon Seismic Issues - DP0-2013-002 Importance: High Hi Mike, We noticed that the projected DPO decision is quickly approaching (1/31/14) and just wanted to touch base to see how the panel is progressing. Do you have an approximate date for finalizing the panel report yet? Can you let us know where you are at this point in the process?

While the DPO guidelines say that Eric will have 21 days to make his final decision after receiving the report, he may need more time to do a thorough review of the report and prepare his decision. Consequently, it seems that another extension will be needed. If you haven't already done so, you may want to reach out to Eric so that he can submit an extension request to us as quickly as possible.

Thanks, Mike, and we'll look forward to hearing from you soon.

Marge 2

From: ExtensionRequest, EDO Sent: Thursday, January 30, 2014 4:59 PM To: Sewell, Margaret; IExtensionRequest, EDO Cc: Brock, Kathryn; Leeds, Eric; Pedersen, Renee; Solorio, Dave; Zimmerman, Roy; Campbell, Andy; Peck, Michael; Case, Michael; Hill, Brittain; Bernhard, Rudolph; Wertz, Trent; Dorman, Dan; Uhle, Jennifer

Subject:

RE: Extension Request for DP0-2013-002 OEOO has reviewed and approved the subject extension. The new due date is 03/28/ 14.

Thanks, Denise From: Sewell, Margaret Sent: Wednesday, January 29, 2014 2:28 PM To: ExtensionRequest, EDO Cc: Brock, Kathryn; Leeds, Eric; Pedersen, Renee; Solorio, Dave; Zimmerman, Roy; campbell, Andy; Peck, Michael; case, Michael; Hill, Brittain; Bernhard, Rudolph; Wertz, Trent; Dorman, Dan; Uhle, Jennifer

Subject:

Extension Request for DP0-2013-002 In accordance with Management Directive 10.159, Handbook (D){S)(b), DPOs are expected to be completed within 120 days and the 120-day time frame may only be extended with the approval of the EDO through the DPOPM for offices that report to the EDO.

The purpose of this email is to request an extension on behalf of Eric Leeds, Director, Office of Nuclear Reactor Regulation, for OP0-2013-002.

In particular, please revise the current due date from January 31, 2014 to March 28, 2014.

I am attaching Eric Leeds' extension request. The schedule has been impacted by several issues including the development of information from the licensee (which has been delayed due to the holidays and an illness),

addition of a peer review of the information, and the complex nature of the issue.

The DPO process affords employees an opportunity to have their views expressed to and considered by high level managers. Ensuring that managers have sufficient time to fully consider the issue is critical to the success of the process. I have reviewed the extension request and think that it is reasonable and consistent with the goals of the DPO Program.

I am also i1ncluding the current Milestones and T imeliness Goals for this case.

Please let me or Renee Pedersen know if you have any questions. Thank you for your consideration of this request and we look forward to hearing from you.

Marge Sewell Safety Culture Specialist Office of EnforcemenVConcerns Resolution Branch 301-415-8045 marqaret. sewell@nrc.gov

From: Sewell, Margaret Sent: Friday, January 31, 2014 9:32 AM To: Leeds, Eric Cc: Brock, Kathryn; Pedersen, Renee; Solorio, Dave; Zimmerman, Roy; Campbell, Andy; Case, Michael; Peck, Michael; Hill, Brittain; Bernhard, Rudolph; Wertz, Trent

Subject:

Extension Request for DP0-2013-003 Attachments: RE: Extension Request for DP0-2013-002; Milestones and Timeliness Goals.docx

Eric, OEDO has approved the subject extension request (see attached email). Based on OEDO's approval, the new due date is 3/28/2014. Attached is the updated Milestones & Timeliness Goals for DP0-2013-002.

If you have any questions, please feel free to contact Renee or me.

Thank you1.

Marge

From: Sewell, Margaret Sent: Monday, February 10, 2014 4:23 PM To: Leeds, Eric Cc: Case, Michael; Wertz, Trent; Pedersen, Renee; Solorio, Dave

Subject:

FW: FOIA 2014-0134 has been rec'd about a DPO Attachme nts: 2014-0134-r.pdf; RE: FOIA 2014-0134 has been rec'd about a DPO Importance: High Note: FOIA-2014-0134 is publicly available in ADAMS as ML14035A435.

Hi Eric, We just wanted to give you a heads-up that Michael Peck has submitted the FOIA request below to publicly release his Diablo Canyon Seismic Issues DPO prior to the case closing (i.e., issuance of the management decision). I think you're aware that there has been previous external interest in this case and just wanted to make you aware.

Of course, we provided the attached email explaining that it is premature to publicly release the DPO at this time.

Thanks!

Marge (& Renee)

From: FOIAPAOE Resource Sent: Friday, February 07, 2014 9:01 PM To: Pedersen, Renee; Sewell, Margaret

Subject:

FOIA 2014-0134 has been rec'd about a DPO Importance: High Hi Renee and Marge, A FOIA has been rec'd from Michael Peck requesting that his DPO ADAMS Pkg ML13213A248 be made publicly available (see attached PDF of incoming FOIA).

To summarize:

On pg 2 of the incoming he says: "As the author of the DPO, I have expert understanding of the issues raised in the document.

External stockholders, including members of Congress, have expressed an interest in the issues raised in the DPO. Release of the DPO will provide clarity to the public understanding of issues affecting nuclear and seismic safety at Diablo Canyon.

This DPO raised immediate operability concerns related to important to safety plant equipment required by the facility Technical Specifications and the operating license. This DPO was submitted on July 18, 2013 but still remains unresolved by the agency. I request the DPO be released prior to final disposition by the DPO Panel due to the length of time these potential safety significant outstanding issues remained unresolved.*

I'm thinking that premature release of this would be contrary to the OPO Mgmt Dir. Pis let me know ASAP if we can make this public or how we can respond to this. {I'm working a late to make up some time. OE has rec'd sevl FOIAs in the past few days.)

From: Case, Michael Sent: Friday, February 28, 2014 12:58 PM To: Peck, Michael Cc: Bernhard, Rudolph; Hill, Brittain; Wertz, Trent; Sewell, Margaret

Subject:

Latest Update Hello Michael. I just wanted to give you a status update. PG&E finished up some additional information for us and Brett and I are flying out to take a look at it Tuesday of next week. The panel has pretty much drafted our report with some open items to write up what we found in this additional information. So we're not done but making some good progress.

Maybe we* can hook up Monday and touch base.

From: Sewell, Margaret Sent: Wednesday, March 19, 2014 10:29 AM To: Case, Michael Cc: Sheron, Brian; West, Steven; Hill, Brittain; Bernhard, Rudolph; Leeds, Eric; Giitter, Joseph; Wertz, Trent; Pedersen, Renee; Solorio, Dave

Subject:

RE: DPO Status Update Attachments: DPO Panel Report.doc; Milestones and Timeliness Goals.docx Hi Mike, Thanks for the update on the DPO. Just in case you need it, I'm attaching some DPO panel report instructions along with a template for your use. Just let me know if you need anything else.

In light of the activities that still need to be done by the panel, it seems likely that you will need another extension. The current Milestones & Timelineness goals (attached) indicate that Eric will issue his decision by next Fri., 3/28, which may not be realistic. If you decide to request an extension, please let me know as quickly as possible so that I can submit it to EDO.

!bX5)

Please let me know if you have any questions and/or if you'll need the extension.

Thanks !

Marge From: case, Michael Sent: Monday, March 10, 2014 2:01 PM To: Wertz, Trent; Sewell, Margaret; Giitter, Joseph; Leeds, Eric Cc: Sheron, Brian; West, Steven; Hill, Brittain; Bernhard, Rudolph

Subject:

DPO Status Update I just wanted to keep you all informed about DPO status. Britt and I made it to CA to review some information that PG&E developed for us (see attached status I gave the DPO submitter). I thought was we saw was very good evidence with respect to the issues in the DPO and very much worth the *wait". (Easy for me to say, but we do really appreciate the support you have given us to fully illuminate the issues). Britt deserves a great deal of credit because he was prime architect behind our thoughts.

Still have to formally write up what we saw.

Do a minimal amount of polishing Get Joe to give us a sanity check Get the report to Eric.

Thanks again for your support.

MEMORANDUM TO: Panel Chair Panel Member Panel Member FROM: (Name of Office Director or Regional Administrator)

SUBJECT:

AD HOC REVIEW PANEL - DIFFERING PROFESSIONAL OPINION ON (use subject description from tasking) (DP0-20YY-nnn)

In accordance with Management Directive (MD) 10.159, "The NRC Differing Professional Opinions Program," I am appointing you as members of a Differing Professional Opinion (DPO)

Ad Hoc Review Panel (DPO Panel) to review a DPO that was forwarded to me to disposition.

The DPO (Enclosure 1) raises concerns (subject).

I have designated (name) chairman of this DPO Panel and (name) as a DPO Panel member.

(Name) was proposed by the DPO submitter and serves as the third member of the DPO Panel.

[Optional: Because this issue addresses enforcement, (name) is serving as the fourth member.] In accordance with the guidance included in MD 10.159 and consistent with the DPO Program objectives, I task the DPO Panel to do the following:

D Review the DPO submittal to determine if sufficient information has been provided to undertake a detailed review of the issue.

o Meet with the submitter, as soon as practicable, to ensure that the DPO Panel understands the submitter's concerns and scope of the issues. (Normally within 7 days.)

D Promptly after the meeting, document the DPO Panel's understanding of the submitters concerns, provide the Statement of Concerns (SOC) to the submitter, and request that the submitter review and provide comments, if necessary. (Normally within 7 days.)

D Maintain the scope of the review to not exceed those issues as defined in the original written DPO and confirmed in the SOC.

D Consult with me as necessary to discuss schedule-related issues, the need for technical support (if necessary), or the need for administrative support for the DPO Panel's activities.

o Perform a detailed review of the issues and conduct any record reviews, interviews, and discussions you deem necessary for a complete, objective, independent, and impartial review. The DPO Panel should re-interview individuals as necessary to clarify information during the review. In particular, the DPO Panel should have periodic discussions with the submitter to provide the submitter the opportunity to further clarify the submitter's views and to facilitate the exchange of information.

Multiple Addressees 2 D Provide monthly status updates on your activities via email to Renee Pedersen, Differing Views Program Manager (DVPM) about the last day of the month. This information will be reflected in the Milestones and Timeliness Goals for this DPO. Please provide a copy of email status updates to the submitter and to me.

D Issue a DPO Panel report, including conclusions and recommendations to me regarding the disposition of the issues presented in the DPO. The report should be a collaborative product and include all DPO Panel member's concurrence. Follow the specific processing instructions for DPO documents.

D Consult me as soon as you believe that a schedule extension is necessary to disposition the DPO.

D Recommend whether the DPO submitter should be recognized if the submitter's actions result in significant contributions to the mission of the agency.

Disposition of this DPO should be considered an important and time sensitive activity. The timeliness goal included in the MD for issuing a DPO Decision is 120 calendar days from the day the DPO is accepted for review. The timeliness goal for issuing this DPO Decision is (date).

Process Milestones and Timeliness Goals for this DPO are included as Enclosure 2. The timeframes for completing process milestones are identified strictly as goals-a way of working towards reaching the DPO timeliness goal of 120 calendar days. The timeliness goal identified for your DPO task is 70 calendar days.

Although timeliness is an important DPO Program objective, the DPO Program also sets out to ensure that issues receive a thorough and independent review. The overall timeliness goal should be based on the significance and complexity of the issues and the priority of other agency work. Therefore, if you determine that your activity will result in the need for an extension beyond the overall 120-day timeliness goal, please send me an email with the reason for the extension request and a new completion date. I will subsequently forward this request to the DVPM who will forward it to the EDO for approval.

Please ensure that all DPO-related activities are charged to Activity Code ZG0007.

Because this process is not routine, the DVPM will be meeting and communicating with all parties during the process to ensure that everyone understands the process, goals, and responsibilities. The DVPM will be subsequently sending you information intended to aid you in implementing the DPO process.

An important aspect of our internal safety culture includes respect for differing views. As such, you should exercise discretion and treat this matter sensitively. Documents should be distributed on an as-needed basis. In an effort to preserve privacy, minimize the effect on the work unit, and keep the focus on the issues, you should simply refer to the employee as the DPO submitter. Avoid conversations that could be perceived as "hallway talk" on the issue. We need to do everything that we can in order to create an organizational climate that does not chill employees from raising dissenting views. It is appropriate for employees to discuss the details of the DPO with their co-workers as part of the evaluation; however, as with other predecisional

Multiple Addressees 3 processes, employees should not discuss details of the IDPO outside the agency.

As a final administrative note, please ensure that all correspondence associated with this case include the DPO number in the subject line, be profiled in accordance with ADAMS template OE-011 , be identified as non-public with limited viewer rights to those included on distribution of correspondence and declared an official agency record when the correspondence is issued.

Please email the ADAMS accession number for the record to DPOPM Resource@nrc gov and the record will be filed in the applicable DPO case file folder (DPO-YYYY-NNN) in the ADAMS Main Library. Following this process will ensure that a complete agency record is generated for the disposition of this DPO. If the submitter requests that the documents included in the DPO Case File be made public when the process is complete , you will be provided specific guidance to support a releasability review.

I appreciate your willingness to serve and your dedication to completing an independent and objective review of this DPO. Successful resolution of the issues is important for NRC and its stakeholders. If you have any questions, you may contact me, Renee Pedersen, DVPM, at (301) 415-2742, or Marge Sewell, Safety Culture Specialist at (301) 415-8045.

I look forward to receiving your independent review results and recommendations.

Enclosures:

1. DP0-20YY-nnn

2. Milestones and Timeliness Goals cc w/o

Enclosure:

Submitter DVPM

From: Wertz, Trent Sent: Tuesday, March 25, 2014 8:32 AM To: Case, Michael

Subject:

RE: DPO Status Understand. I'll suggest to Eric that he request an extension until April 18. He did mention that he wants to have a meeting with you to discuss the report, possibly even before you send it to him formally. Maybe the afternoon of 4/1 or 4/2 (those are the next free times he has on his calendar).

From: Case, Michael Sent: Tuesday, March 25, 2014 7:30 AM To: Wertz., Trent Cc: Hill, Brittain; Bernhard, Rudolph; Sewell, Margaret

Subject:

RE: DPO Status Hi Trent. Thanks for your patience. Let me update you on where I think we are. We are working on resolving some comments from Joe Giitter who did an informal review of our report as Eric had suggested. Best case, if we don't have any scheduling issues and alignment issues, I think we could have the report to Eric by Friday. Worst case, it would be a week from Friday.

I'm not sure wrt time how long Eric will need to take to review the report and finalize his decision. The report itself is about 20 pages so it's not huge. We would be available to walk him through it if that would be helpful. I think Margaret has some ballpark time frames from the MD on this part of the process. I think it's about 2 weeks but I could be wrong .

From: Wertz., Trent Sent: Monday, March 24, 2014 1:28 PM To: Case, Michael

Subject:

DPO Status

Mike, Given that the due date is this Friday, what would you project as a reasonable extension date? Perhaps a couple of weeks past the time you project Eric receiving the panel report?

Thoughts?

Thanks, Trent L. Wertz Technical Assistant Office of Nuclear Reactor Regulation 301-415-1568 trent.wertz@nrc.gov

From: Wertz, Trent Sent: Tuesday, March 25, 2014 8:41 AM To: Leeds, Eric

Subject:

DPO Extension Request

Eric, Here is a draft for the DPO extension request. You'll need to send it to DPOPM Resource and copy Marge Sewell, Renee Pedersen, Mike Case, and myself.

To Whom It May Concern, In accordance with Management Directive 10.159, Handbook (D)(S)(b), DPOs are expected to be com pleted within 120 days and the 120-day time frame may only be extended with the approval of the EDO through the DPOPM for offices that report to the EDO.

The purpose of this email is to request an extension for DP0-2013-002.

In particular, please revise the current due date from March 28, 2014 to April 18, 2014.

The schedule has been impacted by the complex nature of the issue and the need to gather information from the licensee.

The DPO process affords employees an opportunity to have their views expressed to and considered by high level managers. Ensuring that managers have sufficient time to fully consider the issues* is critical to the success of the process. We have reviewed the extension request and think that it is reasonable and consistent with the goals of the OPO Program.

Thank you for your consideration of this request.

Eric J. Leeds Direct or, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-1270

From: Sewell, Margaret Sent: Tuesday, March 25, 2014 9:23 AM To: Case, Michael Cc: Hill, Brittain; Bernlhard, Rudolph; Wertz, Trent; Pedersen, Renee; Solorio, Dave; Leeds, Eric

Subject:

RE: DPO Status Attachments: Milestones and Timeliness Goals.docx; Eric's DPO Extension request.txt

Mike, Thanks for the update and estimate on getting the report to Eric. The Milestones & T imeliness goals (see attached) allow for 21 days after receiving the report for Eric to issue his decision, which is scheduled for Fri.,

3/28. Obviously, this isn't going to happen based on your estimates for submitting the panel report to Eric.

So in your best case scenario, Eric would need to issue his decision on 4/18. In your worst case scenario, 4/25 would be the issue date. Either way, an extension is going to be needed. In order to allow for any scheduling issues, etc., I would recommend requesting an extension to 4/25 or maybe even the end of April just to make sure Eric has enough time to thoroughly evaluate the report before making his final decision.

Please ask Eric to submit his extension request as quickly as possible, so that we can submit to EDO for approval.

For your convenience. I'm attaching the Eric's last extension request submitted on 1/29.

Please call if you have any questions. Thanks, again, and we'll look forward to receiving the request!

Marge (& Renee)

Marge Sewell Safety Culture Specialist Office of EnforcemenUConcerns Resolution Branch 301 -415-8045 margaret.sewell@nrc.gov From: Case, Michael Sent: Tuesday, March 25, 2014 7:30 AM To: Wertz., Trent Cc: Hill, Brittain; Bernhard, Rudolph; Sewell, Margaret

Subject:

RE: DPO Status Hi Trent. Thanks for your patience. Let me update you on where I think we are. We are working on resolving some comments from Joe Giitter who did an informal review of our report as Eric had suggested. Best case, if we don't have any scheduling issues and alignment issues, I think we could have the report to Eric by Friday. Worst case, it would be a week from Fri day.

I'm not sure wrt time how long Eric will need to take to review the report and finalize his decision. The report itself is about 20 pages so it's not huge. We would be available to walk him through it if that would be helpful. I think Margaret has some ballpark time frames from the MD on this part of the process. I think it's about 2 weeks but I could be wrong .

The entire email string may be found as document 8/60 in FOIA/PA-2015-0071 (ML15181A427).

From: Leeds, Eric Sent: Tuesday, March 25, 2014 10:56 AM To: DPOPM Resource Cc: Sewell, Margaret; Ped erson, Cynthia; Case, M ichael; Wertz, Trent

Subject:

DPO Extension request To Whom It May Concern, In accordance with Management Directive 10.159, Handbook (D)(5)(b), DPOs are expected to be completed within 120 days and the 120-day time frame may only be extended with the approval of the EDO through the DPOPM for offices that report to the EDO.

The purpose of this email is to request an extension for DP0-2013-002.

In particular, please revise the current due date from March 28, 2014 to April 30, 2014.

The schedule has been impacted by the complex nature of the issue and the need to gather information from the licensee.

The DPO process affords employees an opportunity to have their views expressed to and considered by high level managers. Ensuring that managers have sufficient time to fully consider the issues is critical to the success of the process. We have reviewed the extension request and think that it is reasonable and consistent with the goals of the DPO Program.

Thank you for your consideration of this request.

Eric J. Leed s Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-1270

From: Sewell, Margaret Sent: Tuesday, March 25, 2014 4:24 PM To: ExtensionRequest, EDO Cc: Brock, Kathryn; Leeds, Eric; Pedersen, Renee; Solorio, Dave; Zimmerman, Roy; Case, Michael; Case, Michael; Hill, Brittain; Bernhard, Rudolph; Wertz, Trent

Subject:

Extension Request for DP0-2013-002 Attachments: DPO Extension request; Milestones and Timeliness Goals.docx In accordance with Management Directive 10.159, Handbook (0 )(5)(b), DPOs are expected to be completed within 120 days and the 120-day time frame may only be extended with the approval of the EDO through the DPOPM for offices that report to the EDO.

The purpose of this email is to request an extension on behalf of Eric Leeds, Director, Office of Nuclear Reactor Regulation, for DP0-2013-002.

In particular, please revise the current due date from March 28, 2014 to April 30, 2014.

I am attaching Eric Leeds' extension request. The schedule has been impacted by the complex nature of the issue and the need to gather information from the licensee.

The DPO process affords employees an opportunity to have their views expressed to and considered by high level managers. Ensuring that managers have sufficient time to fully consider the issue is critical to the success of the process. I have reviewed the extension request and think that it is reasonable and consistent with the goals of the DPO Program.

I am also including the current Milestones and Timeliness Goals for this case.

Please let me or Renee Pedersen know if you have any questions. Thank you for your consideration of this request and we look forward to hearing from you.

Marge Marge Sewell Safety Culture Specialist Office of EnforcemenVConcems Resolution Branch 301 -415-8045 margaret.sewell@nrc.gov

From: Case, Michael Sent: Wednesday, March 26, 2014 7:24 AM To: Hill, Brittain; Bernhard, Rudolph Cc: Wertz, Trent

Subject:

FW: DPO Status Hi guys. How's your availability on April 1 st or 2nd afternoon (Briit, I think you said you were out). Trent, I'm available both days. Probably April 1 st would be preferred.

From: Wertz, Trent Sent: Tuesday, March 25, 2014 8:32 AM To: case, Michael

Subject:

RE: DPO Status Understand. I'll suggest to Eric that he request an extension until April 18. He did mention that he wants to have a meeting with you to discuss the report, possibly even before you send it to him formally. Maybe the afternoon of 4/1 or 4/2 (those are the next free times he has on his calendar).

From: case, Michael Sent: Tuesday, March 25, 2014 7:30 AM To: Wertz., Trent Cc: Hill, Brittain; Bernhard, Rudolph; Sewell, Margaret subject: RE: DPO Status Hi Trent. Thanks for your patience. Let me update you on where I think we are. We are working on resolving some comments from Joe Giitter who did an informal review of our report as Eric had suggested. Best case, if we don't have any scheduling issues and alignment issues, I think we could have the report to Eric by Friday. Worst case, it would be a week from Friday.

I'm not sure wrt time how long Eric will need to take to review the report and finalize his decision. The report itself is about 20 pages so it's not huge. We would be available to walk him through it if that would be helpful. I think Margaret has some ballpark time frames from the MD on this part of the process. I think it's about 2 weeks but I could be wrong.

From: Wertz, Trent Sent: Monday, March 24, 2014 1:28 PM To: case, Michael

Subject:

DPO Status

Mike, Given that the due date is this Friday, what would you project as a reasonable extension date? Perhaps a couple of weeks past the time you project Eric receiving the panel report?

Thoughts?

Thanks, Trent L. Wertz Technical Assistant

From: Sewell, Margaret Sent: Friday, March 28, 2014 12:28 PM To: Leeds, Eric Cc: Case, Michael; Peck, Michael; Hill, Brittain; Bernhard, Rudolph; Wertz, Trent; Pedersen, Renee; Solorio, Dave; Zimmerman, Roy; Foster, Jack; Brock, Kathryn

Subject:

Approved Extension Request - DP0-2013-003 Attachments: RE: Extension Request for DP0-2013-002; Milestones and Timeliness Goals.docx

Eric, OEDO has approved the subject extension request {see attached email). Based on OEDO's approval, the new due date is 4/30/20 14. Attached is the updated Milestones & Timeliness Goals for DP0-2013-002.

If you have any questions, please feel free to contact Renee or me.

Thanks!

Marge Marge Sewell Safety Culture Specialist Office of EnforcemenUConcerns Resolution Branch 301-415-8045 marqaret.sewell@nrc.gov

From: Case, Michael Sent: Tuesday, April 01, 2014 7:21 AM To: Peck, Michael Cc: Hill, Brittain; Bernhard, Rudolph; Wertz, Trent; Sewell, Margaret

Subject:

DPO Status Update Hi Michael. I'm doing a rotation in the next couple of days down at IP so things are a bit crazy. I j ust wanted to keep you up to speed on status. We very close to being done on our piece of the process. Eric has asked us for a status briefing of where we are and we are scheduled to do that today. Unless there are some surprises from that meeting, we would expect to sign out the panel report shortly thereafter.

When we send it to Eric, we also send copies to you (and a few other folks). That will give you an opportunity to review it and then maybe we can schedule some time with you and the panel to field some questions. Eric has about 3 weeks before he issues his decision (I think they are targeting the end of April)

From: Pedersen, Renee Sent: Tuesday, April 08, 2014 11:45 AM To: Leeds, Eric Cc: Wertz, Trent; Sewell, Margaret; Solorio, Dave

Subject:

RE: I've received the draft Diablo Canyon DPO report - EOM Attachments: DPO Decision.doc

Eric, For your convenience, here is a template for the decision.

Renee From: Leeds, Eric Sent: Tuesday, April 08, 2014 10:55 AM To: case, Michael Cc: Wertz., Trent; Pedersen, Renee

Subject:

I've received the draft Diabio canyon DPO report - EOM Eric J. Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-1270

DPO Decision Template/Instructions MEMORANDUM TO: DPO Submitter FROM: OD or RA

SUBJECT:

DIFFERING PROFESSIONAL OPINION DECISION INVOLVING (ISSUE)

(DPO-YYYY-NNN)

GENERAL INSTRUCTIONS:

The DPO Decision should be a factual discussion focused on the DPO and the decision (including the rationale for the decision). It should not include personnel performance type issues. If these issues are necessary to be addressed, they should be addressed separately. Although the DPO Decision is being issued to the individual employee, the submitter may request that the DPO case file be made public. Therefore, the DPO Decision has the ability to affect and/ or influence the entire staff and the NRC's public image.

The format of the DPO Decision is meant to be flexible to accommodate each unique DPO. For example, some DPOs include multiple issues. The DPO Panel's report may include conclusions and recommendations that do not align with each DPO concern. The format of the DPO Decision may be influenced by whether the OD or RA agrees or disagrees with all the conclusions, or whether the OD or RA agrees with some conclusions and disagrees with others.

Regardless of specific formatting, the DPO Decision should address the following elements:

Introduction/purpose: identify (1) issue and date of DPO submittal; (2) date DPO Panel was established; (3) date(s) (or statement) that DPO Panel met with submitter to establish a concise statement of the submitter's concern(s); (4) date (or statement) that submitter approved statement of concern(s).

Statement of how the decision was made, e.g., after reviewing the DPO Panel's report, meeting with the DPO Panel, meeting with the submitter, meeting with the staff, reviewing the submitter's

comments on the DPO Panel's report.

list of Concern(s)

DPO Panel conclusion(s)

OPO Panel recommendation(s)

Decision Rationale Closing statement thanking the submitter for raising the concern(s).

Notification that a summary of the DPO will be included in the Weekly Information Report to advise interested employees of the outcome when the case is closed.

Notification that the submitter will be included on correspondence involving the development/listing of followup actions and implementation schedules.

cc: DPOPM Backup DPOPM Director, OE DPO Panel members ADAMS DOCUMENT PROCESSING INSTRUCTIONS:

Use DPO ADAMS template OE-011 Name of record=DPO Decision Document type= Differing Professional Opinion Case File Case/reference number=DPO-YYYY-NNN Keyword=OE-011 Make the record non-public

limit viewers to those NRC employees on distribution and provide owner rights to "DPO Staff' Declare the document as an OAR Send email to DPOPM.Resource@nrc.gov with the ML# so that we can file the record in the ADAMS DPO Case Files folder for the specific DPO

From: Wertz, Trent Sent: Tuesday, April 29, 2014 12:35 PM To: Leeds, Eric

Subject:

DPO Extension req uest

Eric, Suggested wording for the DPO extension request. Please edit and send to DPOPM Resource and copy Marge Sewell, Mike Case, and myself.

To Whom It May Concern, In accordance with Management Directive 10.159, Handbook (D)(5)(b), DPOs are expected to be completed within 120 days and the 120-day time frame may only be extended with the approval of the EDO through the DPOPM for offices that report to the EDO.

The purpose of this email is to request an extension for DP0-2013-002.

In particular, please revise the current due date from April 30, 2014 to May 30, 2014.

The schedule has been impacted by the complex nature of the issue, the need to gather information from the licensee. and competing schedule commitments.

The DPO process affords employees an opportunity to have their views expressed to and considered by high level managers. Ensuring that managers have sufficient time to fully consider the issues is critical to the success of the process. We have reviewed the extension request and think that it is reasonable and consistent with the goals of the DPO Program.

Thank you for your consideration of this request.

Eric J. Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-1270

From: Sewell, Margaret Sent: Tuesday, April 29, 2014 5:30 PM To: ExtensionRequest, EDO Cc: Brock, Kathryn; Leeds, Eric; Pedersen, Renee; Solorio, Dave; Zimmerman, Roy; Campbell, Andy; Case, Michael; Peck. Michael; Hill, Brittain; Bernhard, Rudolph; Wertz, Trent

Subject:

DP0-2013-002 - Extension Request Attachments: DPO extension request.; Milestones and Timeliness Goals.docx In accordance with Management Directive 10.159, Handbook (D)(5)(b), DPOs are expected to be completed within 120 days and the 120-day time frame may only be extended with the approval of the EDO through the DPOPM for offices that report to the EDO.

The purpose of this email is to request an extension on behalf of Eric Leeds, Director, Office of Nuclear Reactor Regulation, for DP0-201 3-002.

In particular, please revise the current due date from April 30, 2014 to May 30, 2014.

I am attaching Eric Leeds' extension request. The schedule has been impacted by the complex nature of the issue, the need to gather information from the licensee, and competing schedule commitments.

The DPO process affords employees an opportunity to have their views expressed to and considered by high level managers. Ensuring that managers have sufficient time to fully consider the issue is critical to the success of the process. I have reviewed the extension request and think that it is reasonable and consistent with the goals of the DPO Program.

I am also including the current Milestones and Timeliness Goals for this case.

Please let us know if you have any questions. Thank you for your consideration of th1is request and we look forward to hearing from you.

Marge Sewell Safety Culture Specialist 301 -415-8045 margaret.sewell@nrc.gov Renee Pedersen Sr. Differing Views Program Manager 301-415-2742 Renee.pedersen@nrc.gov Marge Sewell Safety Culture Specialist Office of Enforcement/Concerns Resolution Branch 301-415-8045 margaret.sewell@nrc.gov

From: Sewell, Margaret Sent: Friday, May 09, 2014 4:21 PM To: Leeds, Eric Cc: Case, Michael; Peck, Michael; Hill, Brittain; Bernhard, Rudolph; Wertz, Trent; Pedersen, Renee; Solorio, Dave; Zimmerman, Roy; Foster, Jack; Weil, Jenny

Subject:

Approved Extension Request - DP0-2013-002 Attachments: STARS OEDO Office Notification (OED0-14-00211-NRR); Milestones and Timeliness Goals.docx

Eric, OEDO has approved the subject extension request (see attached email). Based on OEDO's approval, the new due date is May 30, 2014. Attached is the updated Milestones & Timeliness Goals for DP0-2013-002.

If you have any questions, please feel free to contact Renee or me.

Thanks!

Marge Marge Sewell Safety Culture Specialist Office of Enforcement/Concerns Resolution Branch 301-415-8045 margaret.sewell@nrc.gov

DPO Milestones and Timeliness Goals DP0-2013-002: Diablo Canyon Seismic Issues Assigned to: Eric Leeds, NRR DPO Panel: Michael Case, Panel Chair; Britt Hill, Panel Member; Rudolph Bernhard, Panel Member Timeliness Actual DPO Milestone Goals* Date Individual submits DPO (NRC Form 680) None 7/19/2013 DPOPM receives, screens, and accepts DPO 8 days 7/31/2013 DPOPM forwards DPO to office manager 7 days 8/2/2013 Office manager establishes DPO Panel 14 days 9/3/2013 DPO Panel conducts review and issues report 70 days

- meets with submitter (=7 days)

- establishes Statement of Concern (=7 days)

- confirms schedule with. office manager (=7 days)

- completes review (= 49 days after start of review)

- writes report (=21 days after completion of review)

Office manager issues DPO Decision 21 days 5/29/2014 DPO TIMELINESS GOAL 120 days 302 days (time from acceptance of DPO to DPO Decision) 11/29/2013 1/31/201 4 (1) 3/28/2014 (2) 4/30/2014 (3) 5/30/2014 (4)

• The timeframes for completing process milestones are identified strictly as goals-a way of working towards reaching the Differing Professional Opinions (DPO) timeliness goal of 120 calendar days.

Office managers should e-mail requests for extension beyond the 120-day timeframe to DPOPM.Resource@nrc.gov and the DPOPM will forward the request to the EDO with a recommendation.

(1) New Schedule approved by EDO 12/3/2013. Extension due to several scheduling issues including leave commitments, the Government Shutdown, and the complex nature of the issue.

(2) New Schedule approved by EDO 1/30/2014 . Extension due to development of Information from the licensee (which has been delayed due to the holidays and an illness), addition of a peer review of the information, and the complex nature of the issue.

(3) New Schedule approved by EDO 3/28/2014. Extension due to complex nature of issue and need for Panel to gather Information from the licensee.

(4) New schedule approved by EDO 5/9/2014. The schedule has been impacted by the complex nature of the issue, the need to gather information from the licensee, and competing schedule commitments.

Timeliness Actual DPO Appeal Milestone Goals* Date Individual submits DPO Appeal (NRC Form 690) NLT 21 days 6/23/2014 ofDPO Decision DPOPM screens, accepts, and requests statement of views 4 days 6/24/2014 from OD or RA OD or RA provides statement of views to DPOPM 14 days 6/27/2014 DPOPM provides DPO appeal package to EDO 2 days 7/7/2014 EDO issues DPO Appeal Decision 30-60 days 9/9/2014 DPO APPEAL TIMELINESS GOAL 50-80 days 77 days (time from acceptance of appeal to DPO Appeal Decision)

• The timeframes for completing process milestones are identified strictly as goals-a way of working towards reaching the DPO appeal timeliness goal of 80 calendar days.

From: Sewell, Margaret Sent: Tuesday, May 13, 2014 2:54 PM To: Wertz, Trent

Subject:

DP0-2013-002 Submittal & Panel Report

Trent, Got your voicemail. Here's the ADAMS link to the documents you're looking for as well as a screen shot. So, it looks like everything is there and you have viewer rights. Just let me know if you have any other questions.

p.s. thanks so much for attending the OCWE Champion mtg. this morning. It was good to finally meet you in person!

https://adamsxt.nrc.qov/WorkplaceXT/Browse. jsf FA, I dil View Favo*ittt Tools Help r,.,v,,1""' , i.. 1Hom.

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From: Cho, Esther Sent: Tuesday, May 20, 2014 10:49 AM To: Wertz, Trent

Subject:

RE: DPO Memo Good Morning, I have added the document in ADAMS and provided OE, Renee Pedersen, and yourself "owner" rights to the document.

The Accession No. is as follows:

• ML14140A225 - Differing Profession Opinion Involving Seismic Issues at Diablo Canyon (DP0-2013-002)

I also left a hard copy for you on your chair. Please let me know if there is anything else I can assist you with.

Thank you' Sincerely, Esther Cho From: Wertz, Trent Sent: Tuesday, May 20, 2014 9:38 AM To: Cho, Esther

Subject:

DPO Memo Attached.

Trent L. Wertz Technical Assistant Office of Nuclear Reactor Regulation 301-415-1568 trent.wertz@nrc.gov

From: Pedersen, Renee Sent: Thursday, May 22, 2014 9:12 AM To: Leeds. Eric Cc: Wertz, Trent; Sewell, Margaret; Solorio, Dave; Zimmerman, Roy

Subject:

Diablo Canyon DPO Importance: High

Eric, I just wanted to pass this on to you. This reinforces my recommendation to you to consider a communication plan, which would bring OPA in. In addition, we* will pass the DPO Decision on to senior management and the Commission to keep them informed because we delay the WI R until the process is complete (which could take time if the submitter appeals). (Lesson learned from previous DPO).

Trent, On an administrative note, include Dave Skeen on distribution for the DPO Decision. Declare as non-public and limit view rights to those on distribution, including "DPO Staff as a viewer and email the ADAMS ML to OPOPM.Resource@nrc.gov.

Please let us know if you have any questions or if there is something that we can do to support you.

We 're here to help!

Renee & Marge P.S. Starting next week, I will be out for 2 weeks (I know--unbelievable), so if you need assistance, please contact Marge or Dave Solorio.

From: Pedersen, Renee Sent: Thursday, May 22, 2014 8:54 AM To: McIntyre, David Cc: Sewell, Margaret; Solorio, Dave

Subject:

RE: DPO Process

Dave, Two wrongs don't make a right. We are still in a predecisional process and should not release or discuss documents until the process is complete and records are reviewed iaw for procedures for discretionary release.

When Eric Leeds issues the DPO Decision on Diablo Canyon, we will notify the submitter of his right to appeal the decision and will remind him our policy on not releasing predecisional information to the public.

Renee From: McIntyre, David Sent: Thursday, May 22, 2014 8:40 AM To: Pedersen, Renee Cc: Sewell, Margaret

Subject:

RE: OPO Process

Thanks , Renee. If the submitter leaks it to the press (he has already been in touch with an AP reporter in California}, are we then free to discuss it?

From: Pedersen, Renee Sent: Wednesday, May 21, 2014 5:11 PM To: McIntyre, David Cc: Sewell, Margaret

Subject:

RE: DPO Process The DPO Decision is part of the DPO Case file which does not go public (if the submitter wants and it has been screened by management) until the process 1s complete. The DPO process is complete if the employee does not appeal the decision o; after the EDO issues a decision on the appeal.

This is why we wait until the process is complete before we put a summary in the WIR.

Renee From: McIntyre, David Sent: Wednesday, May 21, 2014 3:48 PM To: Pedersen, Renee

Subject:

DPO Process Hi Renee - when a DPO decision is signed by an office director, how does it become public? Five days later in ADAMS?

Thanks, Dave 2

From: Cho, Esther Sent: Thursday, May 22, 2014 10:17 AM To: DPOPM Resource Cc: Wertz, Trent; Pedersen, Renee

Subject:

Diablo Canyon DPO Good Morning, On behalf of the NRR Front Office, I have made adjustments to the distribution and viewer permissions of the Diablo Canyon DPO as requested.

The ADAMS Accession No. is as follows:

• ML14140A225 - Differing Profession Opinion Involving Seismic Issues at Diablo Canyon (DP0-2013-002)

Please let me know if there is anything else I can assist you with. Thank you. Have a great day!

Sincerely, Esther Cho Contract Administrative Assistant U.S. Nuclear Regulatory Commission NRR/DPR/MSD, Location: 0-13H18 Main: 301-415-2239 Direct: 301-415-061 8 Esther.Cho@nrc.gov

From: Leeds, Eric Sent: Thursday, May 22, 2014 11:23 AM To: Dapas, Marc; Reynolds, Steven Cc: Dricks, Victor; Burnell, Scott; McIntyre, David; Johnson, Michael; Dorman, Dan; Uhle, Jennifer; Evans, Michele; Lund, Louise; Flanders, Scott; Cook, Christopher; Wertz, Trent; Kennedy, Kriss; Schwarz, Sherry; Case, Michael

Subject:

FW: Heads up!!!! Belay my last on Diablo Canyon Folks-Marc and I discussed the issue this morning and I need to reflect on what I heard before I issue my decision.

still plan to issue the decision this month - certainly by the end of next week. I appreciate everyone's attention on this matter and your interest in being prepared to discuss the issue in a public forum once the DPO submitter grants release of the information. I will let everyone know if anything changes with regard to my proposed key messages.

Sorry for any confusion.

Eric From: Leeds, Eric Sent: Wednesday, May 21, 2014 1:26 PM To: Dapas, Marc; Reynolds, Steven Cc: Dricks, Victor; Burnell, Scott; McIntyre, David; Johnson, Michael; Dorman, Dan; Uhle, Jennifer; Evans, Michele; Lund, Louise; Flanders, Scott; Cook, Christopher; Wertz., Trent; Kennedy, Kriss; Schwarz, Sherry

Subject:

Heads up!!!! Diablo Canyon DPO on seismic RIV-Heads up. I'm planning on signing out my decision on the DPO involving seismic issues at Diablo Canyon by COB tomorrow, Thursday May 22. We will sendl everyone on concurrence for this email a copy of the final letter. Obviously, we expect stakeholder interest in the issue, so I am providing you some high level key messages for external (and internal) stakeholders.

Key messages:

• The DPO Panel, a group of three independent staff members who have NOT worked on the seismic issues at Diablo Canyon previously (and one of which had been recommended by the DPO submitter),

concluded that there is not a significant or immediate safety concern regarding the seismic design of the Diablo Canyon Nuclear Power Plant (DCNPP). The Director of the Office of Nuclear Reactor Regulation has concluded that this is not a safety significant issue as independ ent groups have verified that the most recent seismic information is bounded by the existing analysis for DCNPP.

• The NRC is currently re-evaluating the seismic hazards at all the nuclear power plants in the US, as part of its response to the accident at the Fukushima Dai-ichi nuclear power plant. The Diablo Canyon plant is required to provide its response to the re-evaluation in March 2015.

• In order to clarify the regulatory process in this area, the NRC is committed to revise its formal regulatory guidance for evaluating new information on natural hazards, including new seismic information, as part of its response to the Fukushima accident.

Let me know if you have any questions.

Eric J. Leeds Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-1270 2

From: Sewell, Margaret Sent: Tuesday, May 27, 2014 2:01 PM To: Wertz, Trent

Subject:

DP0- 2013-002

• M L13268A466

Trent, Got you message. Try the subject M L# for the actual DPO submital. Here's a screen shot to show you where it is too. Call if you have any more questions.

Package Name: DPO 2013 002. Differing Professional Opinion Involving Diablo Canyon Seismic Issues Accession Number: ML13213A248 Package Properties

. --* t View Profile Open , Checkout

• Name¢ Accession Officia' Number¢ Record?

DP0-2013-002, Memo Forwarding Differing Professional Opinion lrwoMng Diablo Canyon ML13213A249 Yes Seismic Issues (OE00-14-00211)

DP0-2013.002, Milestones and Timeliness Goals ML13213A259 Yes (OE00-14-00211)

OP0-201~2. Olablo Canyon Seismic Issues, DPO Submittal (OE00-14-00211) Yes There are 3 Documents in this Package I<

~ Local in Marge Sewell Safety Cul1ture Specialist

Office of EnforcemenVConcerns Resolution Branch 301-415-8045 margaret.sewell@nrc.gov 2

From: Leeds, Eric Sent: Wednesday, May 28, 2014 3:31 PM To: Wertz, Trent Cc: Dapas, Marc; Johnson, Michael

Subject:

Diablo Canyon DPO Trent -

I've reflected on my conversation with Marc Dapas as well as the email I received from Michael Peck today. I stand firm on my decision with regard to Mr. Peck's DPO that we discussed last week. Please issue the DPO letter as we, have previously discussed and that I signed. Thanks! See you in the office when I return from Paris!

Eric

From: Leeds, Eric Sent: Thursday, May 29, 2014 12:43 AM To: Dapas, Marc Cc: Johnson, Michael; Uhle, Jennifer; Wertz, Trent

Subject:

Re: Follow up from our meeting with the Mothers for Peace last Tuesday afternoon Thanks Marc. I think you've done all you can. I'm sure my decision will elicit feedback. I've chosen to focus on the safety aspect of the issue and will be rather short and direct in stark contrast to the DPO submittal, as well as the work done by the DPO panel. At the least, it should be understandable to all.

Eric From: Dapas, Marc Sent: Wednesday, May 28, 2014 09:10 PM To: Leeds, Eric Cc: Johnson, Michael; Krsek, Robert

Subject:

FW: Follow up from our meeting with the Mothers for Peace last Tuesday afternoon In follow up to our discussion last week Eric, I am forwarding this to you so that you are aware of my communication with Jane Swanson of the Mothers for Peace on the subject matter. Thanks.

From: Dapas, Marc Se . 4 8:08 PM To: (b)(GJ Su6 e : o ow up rom our meeting with the Mothers for Peace last Tuesday afternoon Jane, I much appreciate the opportunity we had to meet with you and the other members of your Mothers' Board last week. I thought the discussion was mutually beneficial in terms of providing me with a perspective on the various issues/concerns you and your fellow board members have with respect to operation of the Diablo Canyon plant and affording us the chance to answer your questions.

Since the Differing Professional Opinion (DPO) filed by Mr. Peck was the subject of some of our discussion, I wanted to follow up with you on the current status of the DPO process. Eric Leeds, who is the Director of our Office of Nuclear Reactor Regulation, will be signing out the DPO decision tomorrow. The DPO panel, which is comprised of three independent staff members who have not previously worked on the* seismic issues at Diablo Canyon (and one of which had been recommended by the DPO submitter), forwarded to Mr. Leeds the results of the panel's review of the DPO. Mr. Leeds has reviewed the panel's recommendation and supporting basis and is ready to make his decision on the DPO. Once Mr. Leeds issues his DPO decision, we will notify the DPO submitter (in this case, Mr. Peck) of his right to appeal the decision to our Executive Director for Operations (Mark Satorius) and will remind him of our policy not to release pre-decisional information. The DPO decisio n is considered pre-decisional if the DPO submitter decides to appeal the decision to the EDO since in that circumstance , the EDO has to review the case and make a final agency determination regarding the appeal. If Mr. Peck decides not to appeal the DPO decision, the DPO process is complete, and therefore ,

if Mr. Peck asked us to make his DPO public, we would honor his request. Should Mr. Peck appeal the DPO decision, once the EDO has rendered a decision on the appeal, the DPO process would be complete and we would make the DPO public upon Mr. Peck's request for us to do so.

I hope you find this responsive to my commitment to keep you informed of where we are in the process with respect to Mr. Peck's DPO submittal. Thanks and please let me know if you have any questions.

From: Cho, Esther Sent: Thursday, May 29, 2014 4:08 PM To: Skeen, David; Pedersen, Renee; Zimmerman, Roy; Case, Michael; Bernhard, Rudolph; Dapas, Marc; Johnson, Michael; Satorius, Mark; Hill, Brittain Cc: Wertz, Trent

Subject:

Differing Professional Opinion Involving Seismic Issues at Diablo Canyon (DP0-2013-002)

Attachments: DPO Panel Report.pdf; Ml14140A225.pdf Good Afternoon, Please follow the link below fo r the electronic distribution of:

DATE: May 29, 2014 TO: Michael S. Peck FROM: Eric J. Leeds

SUBJECT:

Differing Professional Opinion Involving Seismic Issues at Diablo Canyon (DP0-2013-002)

This has been sent to the submitter. This has not been released to the public. Thank you.

Sincerely, Esther Cho Contract Administrative Assistant U.S. Nuclear Regulatory Commission NRR/DPR/MSD, Location: 0-13H18 Main: 301-415-2239 Direct: 301-415-0618 Esther.Cho@nrc.gov

From: Burnell, Scott Sent: Wednesday, September 03, 2014 9:14 AM To: Mcintyre, David; Brenner, Elio t; Harrington, Holly

Subject:

Re: Chairman brief on Diablo I can call in, of course, but if we prefer in-person then it's obviously Dave.

Sent from an NRC Blackberry Scott Burnell I (b)(6)

---

Original Message - -

From: McIntyre, David Sent: Wednesday, September 03, 2014 09:01 AM To: Burnell, Scott; Brenner, Eliot; Harrington, Holly

Subject:

RE : Chairman brief on Diablo Per the morning meeting, this meeting has now been moved to THURSDAY at 11 am.

---

Original Message---

From: Burnell, Scott Sent: Wednesday, September 03, 2014 6:16 AM To: Brenner, Eliot; Harrington, Holly; McIntyre, David

Subject:

RE : Chairman brief on Diablo I've dealt with the Diablo seismic issues for years. Both Dave and I are working on the foreign ownership paper, for whatever that's worth.

From: Brenner, Eliot Sent: Wednesday, September 03, 2014 12:16 AM To: Harrington, Holly; McIntyre, David; Burnell, Scott

Subject:

Re: Chairman brief on Diablo I think dave because this is a long runing operating issue.

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From: Harrington, Holly Sent: Tuesday, September 02, 2014 10:01 PM To: Brenner, Eliot; McIntyre, David; Burnell, Scott

Subject:

FW: Chairman brief on Diablo Ok, the one we're invited to is this Friday from 3 to 3:45. Who is best to represent OPA?

Holly Harrington Senior Level Advisor Office of Public Affairs U.S. Nuclear Regulatory Commission 301 .415.8203 8

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Original Message----

From: Burnell, Scott Sent: Tuesday, September 02, 2014 3:20 PM To: Harrington, Holly; McIntyre, David; Uselding, Lara; Brenner, Eliot

Subject:

RE : Chairman brief on Diablo Understood.

From: Harrington, Holly Sent: Tuesday, September 02, 2014 3:17 PM To: Burnell, Scott; McIntyre, David; Uselding, Lara; Brenner, Eliot

Subject:

RE : Chairman brief on Diablo Thursday's meeting is the one we're not invited to. The one we are is yet unscheduled Holly Harrington Senior Level Advisor Office of Public Affairs U.S. Nuclear Regulatory Commission 301 .415.8203

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Original Message-- -

From: Burnell, Scott Sent: Tuesday, September 02, 2014 3:09 PM To: McIntyre, David; Harrington, Holly; Uselding, Lara; Brenner, Eliot

Subject:

RE: Chairman brief on Diablo I can certainly call in to the separate meeting if it's Thursday -- both Dave and I have kept an eye on the foreign ownership issue.

From: McIntyre, David Sent: Tuesday, September 02, 2014 3:03 PM To: Harringt,on, Holly; Uselding, Lara; Brenner, Eliot Cc: Burnell, Scott

Subject:

RE : Chairman brief on Diablo Sounds like a fun day.

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Original Message----

From: Harrington, Holly Sent: Tuesday, September 02, 2014 2:54 PM To: Uselding, Lara; Brenner, Eliot Cc: McIntyre, David; Burnell, Scott

Subject:

RE: Chairman brief on Diablo From Jen: It's my understanding that Thursday's meeting is going to deal with the technical issues associated with the Shoreline fault and an update of what's going on with the DPO, and that Phil has requested a separate meeting (as yet unscheduled) to address messaging on Diablo and the foreign ownership issue - to which he's asked that OPA, OCA, and assorted others be invited.

Holly Harrington 9

Senior Level Advisor Office of Public Affairs U.S. Nuclear Regulatory Commission 301.415.8203

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Original Message-----

From: Uselding, Lara Sent: Tuesday, September 02, 2014 2:07 PM To: Brenner, Eliot; Harrington, Holly

Subject:

Chairman brief on Diablo Hello: I left a voicemail for Scott as I heard from a RIV staffer that the Chairman wants a brief on all things Diablo this Thursday. Do you know about this and if so, will someone from HQ OPA sit in on that?

Lara

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Original Message-----

From: Burnell, Scott Sent: Tuesday, September 02, 2014 1:03 PM To: Uselding, Lara

Subject:

I'm out today and tomorrow Sorry, should have updated my voicemail. Haven't heard anything about a chairman brief. Check w/Holly?

Sent from an NRC Blackberry Scott Burnell I (b){6) 10

From: Burnell, Scott Sent: Wednesday, September 10, 2014 8:34 AM To: Brenner, Eliot; Mcintyre, David; Harrington, Holly; Uselding, Lara; Dricks, Victor Cc: Oesterle, Eric

Subject:

DPO comm plan I'm told by reliable sources that NRR is updating the plan to account for the EOO decision and we'll see it this morning.

Sent from an NRC Blackberry Scott Burnell (b)(6) 1

From: Burnell, Scott Sent: Wednesday, September 10, 2014 9:45 AM To: McIntyre, David; Uselding, Lara; Brenner, Eliot; Harrington, Holly

Subject:

Re: Diablo DPO IS public in ADAMS Yes, I agree.

Sent from an NRC Blackberry Scott Burnell I (b)(6) I From: McIntyre, David sent: Wednesday, September 10, 2014 09:42 AM To: Burnell, Scott; Uselding, Lara; Brenner, Eliot; Harrington, Holly

Subject:

RE: Diablo DPO IS public in ADAMS But it IS public as of yesterday. They just won't be able to find it via our nrc.gov website until later today.

From: Burnell, Scott Sent: Wednesday, September 10, 2014 9:42 AM To: McIntyre, David; Uselding, Lara; Brenner, Eliot; Harrington, Holly

Subject:

Re: Diablo DPO IS public in ADAMS I would imagine someone's given ADAMS staff a nudge to immediately replicate it t o the public site.

Sent from an NRC Blackberry Scott Burnell (b)(6)

From: McIntyre, David Sent: Wednesday, September 10, 2014 09:39 AM To: Uselding, Lara; Brenner, Eliot; Harrington, Hoity; Burnell, Scott SUbject: Diablo DPO IS public in ADAMS Lara, et al - The DPO is public in Adams at ML14252A743. It was dated yesterday (9/9) and date to be released is yesterday (9/9). It does not yet come up in web-based Adams, which has a 1-day delay; however, anyone who has direct adams access can already find it. (eg., Platts, I imagine) 3

From: Burnell, Scott Sent: Wednesday, September 10, 2014 11:39 AM To: Uselding, Lara; Sebrosky, Joseph

Subject:

RE: Scott/Joe ; review of blog prior to sending to Eliot Attachments: SEP2014blogAB1632_srb.docx Here are my edits.

From: Uselding, Lara Sent: Wednesday, September 10, 2014 11:03 AM To: Burnell, Scott; Sebrosky, Joseph

Subject:

Scott/Joe; review of blog prior to sending to Eliot Importance: High 6

Diablo Canyon In the News Today PG&E issued a report to the state as required by California Assembh Bill 163'> and has also shared a copy with the NRC. In 2006, the bill required the California Energy Commission to assess the vulnerability of the state's nuclear power plants to seismic hazards and plant aging among other things. As part of the assessment, PG&E perfonned state-of-the-art seismic studies on and offshore the area near the plant.

The methodology used for the state report is different than was used to assess the Shoreline fault after it was discovered in 2008. New seismic information in the state-required report indicates that the Shoreline fault is both longer than previously thought and able to produce a stronger earthquake. Along with the report, PG&E provided Region IV with an operability evaluation after entering the new infonnation in their corrective action program to assess its impact on plant operations.

NRC Resident Inspectors and Region IV staff have looked at the lieensee*sPC:i&Fs assessment and so far the information indicates reasonable as~urance of public health and sak t, after n seismic e,*entthere is no new inforrnalit)A 11:lal *,'i01:1ld lead !Re l!l,Rc 10 eonelude that conliHHed safe 013eralion of Diablo Can~on is eAallenged. This is beeause\\'hilc the new seismic information gathered by PG&E adds detail about the Shoreline fault's len!!th and strcn!.!th.tffltl the compal1\ *stf evaluation reaffinns that the Shoreline fault is a lesser inelut..led fot:1ll still hot:1nded h) not as powerful as the I losgri earthquake Diablo Can\'on must\\ ithstand.

14owewr, jlust as was donethe RC wit At1'le reviewed &f..the Shoreline fault infonnation in 2009 anJ 20 12 ~ , the agcncv-NR:b will do a more thoroughlv review &f..the new infonnation through our inspection process. The l .(}00-page seismic report is 1,000 pages aFtd contains new technical infonnation that will be reviewed by staff to independently verify the calculations.

Prevlo1:1Sl) NRC pro*,ided its assessn1e11I ef the Shoreline litull sei:,mic hazard in the Re~1e1m.h 1*

111 tt:mfHtli on Letter ( RI L) 12 01 ..Conlirma10ry Analysis of £eisH1ie Hazard at \Re Diab lo Can) on Po,H'F Ph.ml from the £hore line Fault Zonl'... In the Rll .. NRC staff delerrnined thal the

ma!<imum groui~J moli oAexpee1ed al Diablo from a seismie e,.'elll aloAg the ShoreliAe fault

'<'< ould ee bounded by e:<f)eeled grotiAEi tfletioA fo r seismie eYents along. 1he Hosgri fault. E..-en though 1he shoreline fault is eapuale of produeing o eigger earth41,1t1lce than previou:ily eHlcula1e<l.

i1 i!.i mill bounded by 11:le I losgri for v,hi d~ the tJlanl is able 10 f;ulel) shu1cl1mn uml protect the publ ic nml the e,wironrfH:!IH.

+tttS-PG&E wil l also use this new seismic information will also be used to respond toin providing an overall seismic hnzard rc-anah"sis to the NRC's request for e*,*ery U.8. nuclear po wer plant lo re anal) ze lhei r eartht1ualce ha2:ards follov, ing Japan* s as part of the agencv* s 1

response to the 20 11 Fukushima nuclear accident. PG&E's response re-anal vsis is due to the NRC in March 2015.

From: Burnell, Scott Sent: Wednesday, September 10, 2014 11:50 AM To: Brenner, Eliot; Harrington, Holly; Mcintyre, David; Dricks, Victor

Subject:

FW: DPO Case file now public FYI From: Pedersen, Renee Sent: Wednesday, September 10, 2014 11:47 AM To: Burnell, Scott; Oesterle, Eric; Buchanan, Theresa; Uselding, Lara; Walker, Wayne; Hipschman, Thomas; Hill, Brittain; Sebrosky, Joseph; Pruett, Troy; Williams, Megan Cc: Markley, Michael

Subject:

RE: DPO case file now public It's there now.

7

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From: Pedersen, Renee Sent: Wednesday, September 10, 2014 11:38 AM To: Burnell, Scott; Oesterle, Eric; Buchanan, Theresa; Uselding, Lara; Walker, Wayne; Hipschman, Thomas; Hill, Brittain; Sebrosky, Joseph; Pruett, Troy; Williams, Megan Cc: Markley, Michael

Subject:

RE: DPO Case file now public Scott, Thanks for bringing this to my attention. We're looking into it and will send out clarification.

From: Burnell, Scott Sent: Wednesday, September 10, 2014 11:13 AM To: Pedersen., Renee; Oesterle, Eric; Buchanan, Theresa; Uselding, Lara; Walker, Wayne; Hipschman, Thomas; Hill, Brittain; Sebrosky, Joseph; Pruett, Troy; Williams, Megan Cc: Markley, Michael

Subject:

RE: DPO Case file now public Still not visible in the public website ADAMS.

From: Pedersen, Renee Sent: Wednesday, September 10, 2014 11:11 AM To: Oesterle, Eric; Buchanan, Theresa; Uselding, Lara; Burnell, Scott; Walker, Wayne; Hipschman, Thomas; Hill, Brittain; Sebrosky, Joseph; Pruett, Troy; Williams, Megan Cc: Markley, Michael

Subject:

FYI: DPO Case file now public FYI. the OPO Case File is now public.

From: Oesterle, Eric Sent: Wednesday, September 10, 2014 9:55 AM To: Buchanan, Theresa; Uselding, Lara; Burnell, Scott; Walker, Wayne; Hipschman, Thomas; Hill, Brittain; Sebrosky, Joseph; Pedersen, Renee; Pruett, Troy; Williams, Megan Cc: Markley, Michael

Subject:

draft DPO comm Plan Importance: High Everyone, Good morning. Attached please find a draft of the DPO Comm plan that was discussed at the 8:30 call this AM.

This is provided to you for comment. Please note that it reflects real-time action on the OPO Appeal and incorporates comments from the discussion this morning on the AB-1632 Seismic Report. Much of the Q&A comes from the "living-DCPP Comm Plan" that is being maintained by RIV (the highlighted questions are troublesome to NRR/DORL but we understand that RIV prefers to maintain these). I have included a question at the end about whether new information in the AB-1632 report could impact the DPO conclusions. Also note that the Comm Plan does not contain a timeline as we are already real-time. Please let me know if you have any questions or com ments.

EYio'R. O~ul,e; Acting Branch Chief NRR/DORL/LPL4-1 301-415*1014 9

From: Burnell, Scott Sent: Wednesday, September 10, 2014 4:52 PM To: Uselding, Lara; OPA Resource; Dricks, Victor

Subject:

Re: Diablo Canyon nuclear plant decision?

Thanks.

Sent from an NRC Blackberry Scott Burnell I (b){6)

From: Useldi119, Lara Sent: Wednesday, September 10, 2014 04:51 PM To: Burnell, Scott; OPA Resource; Dricks, Victor

Subject:

RE: Diablo canyon nuclear plant decision?

Yes. I took care of this From: Burnell, Scott Sent: Wednesday, September 10, 2014 3:17 PM To: OPA Resource; Uselding, Lara; Dricks, Victor

Subject:

RE: Diablo canyon nuclear plant decision?

Lara's handling these requests.

From: OPA Resource Sent: Wednesday, September 10, 2014 4:16 PM To: Burnell, Scott

Subject:

FW: Diablo canyon nuclear plant decision?

Scott, Can you please help with the below email.

Thanks, Office of Public Affairs U.S. Nuclear Regulatory Commission (301) 415-8200 opa.resource@nrc. gov From: Raab, Lauren [1]

Sent: Wednesday, September 10, 2014 4:03 PM To: OPA Resource

Subject:

Diablo canyon nuclear plant decision?

13

Can you confirm reports that an NRC official has rejected a call to shut down Diablo Canyon, California's last remaining nuclear power plant, until it can be determined whether the facility can stand up to an earthquake off the Central Coast?

I'd appreciate any details and/or documents you can provide.

In case it helps you route the question to the right person, the Associated Press is saying this:

A top Nuclear Regulatory Commission official has rejected a federal expert's recommendation to shut down California's last operating nuclear power plant until it can determine whether its reactors can withstand powerful shaking from nearby earthquake faults.

In a decision released Wednesday, operations executive Mark Satorius said there is no immediate or significant safety concern at the Diablo Canyon plant.

Thank you very much.

Lauren Raab Los Angeles Times Work: 12131237-6090 Cell{ (bl(6)

Twitter: @raablauren 14