DCL-19-056, Response to NRC Request for Additional Information (Supplemental) Regarding License Amendment Request 18-01, Request to Revise Emergency Plan Response Organization Staffing and Augmentation.

Response to NRC Request for Additional Information (Supplemental) Regarding License Amendment Request 18-01, Request to Revise Emergency Plan Response Organization Staffing and Augmentation.

ML19184A599
Person / Time
Site:	Diablo Canyon
Issue date:	07/03/2019
From:	Gerfen P Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-19-056
Download: ML19184A599 (11)

Text

Pacific Gas .and Electric Company" Paula Gerten Diablo Canyon Power Plant Site Vice President Mail code 104/5/5 02 P.O. Box 56 Avila Beach, CA 93424 805.545.4596 Internal: 691.4596 Fax: 805.545.4234 July 3, 2019 PG&E Letter DCL-19-056 U.S. Nuclear Regulatory Commission 10 CFR 50.90 ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2

. Response to NRC Request for Additional Information {Supplemental) Regarding "License Amendment Request 18-01, Request to Revise Emergency Plan Response Organization Staffing and Augmentation"

References:

1. PG&E Letter DCL-18-064, "License Amendment Request 18-01, Request to Revise Emergency Plan Response Organization Staffing and Augmentation," dated September 12, 2018

[ML18255A368]

2. PG&E Letter DCL-19-039, "Response to NRC Request for Additional Information Regarding 'License Amendment Request 18-01, Request to Revise Emergency Plan Response Organization Staffing and Augmentation,"' dated May 2, 2019

[ML19122A494]

3. E-mail from NRC Senior Project Manager Balwant K. Singal, "Request for Additional Information (Supplemental) - License Amendment Request (LAR) to Revise Emergency Plan Response Organization Staffing and Augmentation (EPID L-2018-LLA-0248)," dated May 28, 2019 [ML19149A601]

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted a license amendment request to revise the Emergency Plan for Diablo Canyon Power Plant Units 1 and 2 to extend staff augmentation times for Emergency Response Organization functions. In Reference 2, PG&E submitted a response to the NRC Staff's request for additional information (RAI). In Reference 3, the NRC Staff provided a supplemental RAI. The Enclosure to this letter provides PG&E's response to the supplemental RAI.

A member of the STARS Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

Document Control Desk PG&E Letter DCL-19-056 July 3, 2019 Page 2 This letter includes a new regulatory commitment (as defined by NEI 99-04),

which is identified in Attachment 2 of the Enclosure.

If you have any questions or require additional information, please contact Mr. Hossein Hamzehee, Regulatory Services Manager, at (805) 545-4720.

I state under penalty of perjury that the foregoing is true and correct.

Executed on July 3, 2019.

Si72 Paula:!:~

Site Vice President rntt/4231 /50993706-07 Enclosure cc: Diablo Distribution cc/enc: Scott A. Morris, NRG Region IV Administrator Christopher W. Newport, NRG Senior Resident Inspector Gonzalo L. Perez, Branch Chief, California Department of Public Health Balwant K. Singal, NRG Senior Project Manager A member of the STARS Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

Enclosure PG&E Letter DCL-19-056 PG&E Response to NRC Request for Additional Information (Supplemental)

Regarding "License Amendment Request 18-01, Request to Revise Emergency Plan Response Organization Staffing and Augmentation"

References:

1. PG&E Letter DCL-18-064, "License Amendment Request 18-01, Request to Revise Emergency Plan Response Organization Staffing and Augmentation," dated September 12, 2018 [ML18255A368]

2. PG&E Letter DCL-19-039, "Response to NRC Request for Additional Information Regarding 'License Amendment Request 18-01, Request to Revise Emergency Plan Response Organization Staffing and Augmentation,"' dated May 2, 2019 [ML19122A494]

3. E-mail from NRC Senior Project Manager Balwant K. Singal, "Request for Additional Information (Supplemental) - License Amendment Request (LAR) to Revise Emergency Plan Response Organization Staffing and Augmentation (EPID L-2018-LLA-0248)," dated May 28, 2019 [ML19149A601]

NOTE-1: The background information that preceded each supplemental request for additional information (RAI) is not included in this Enclosure. Please see Reference 3 for the background information.

NOTE-2: Throughout the following responses, Maintenance Coordinator is used to represent both Electrical and Mechanical Maintenance Coordinator positions.

Supplemental RA/ 6.a. 1 Please provide a justification that supports replacing the electrical and mechanical engineers with maintenance coordinators. In addition to the qualification of the maintenance foremen to perform this function, this justification should address the capabilities of the maintenance foremen to concurrently perform the engineering function, maintenance/Operations Support Center (OSC) supervision, and maintenance technician functions.

PG&E Response to Supplemental RAI 6.a.1 Per Pacific Gas and Electric Company (PG&E) procedure MA 1.ID26, "Troubleshooting" (currently Revision 5), the tasks assigned to Mechanical and Electrical Engineering positions include the provision of technical expertise and investigation techniques to support Operations and Maintenance. PG&E is revising the proposed change to maintain the 60-minute augmented response time for the Mechanical and Electrical Engineering positions to provide technical expertise for the performance of troubleshooting activities, and to perform lead maintenance oversight functions for activities in the field as applicable.

1

Enclosure PG&E Letter DCL-19-056 As a result of this change, Maintenance Coordinators will be responsible for performance of initial maintenance tasks in the field and reporting results to the individual designated to perform the lead maintenance oversight function.

Table 5-1 and Figure 5-2 have been revised to reflect this change and are included in Attachment 1 to this Enclosure. The specific changes are marked with yellow highlighting on the pages in Attachment 1.

Supplemental RA/ 6.a.2 Please provide a justification that supports extending the time for providing engineering support, which is intended to support emergency core cooling system (EGGS) restoration, from 60 to 90 minutes. This support typically includes such items as formal troubleshooting and supporting alternate methods of establishing EGGS.

PG&E Response to Supplemental RAI 6.a.2 With the retention of the 60-minute augmented response times for the Mechanical and Electrical Engineering positions, the request for justification to support extending the response times to 90 minutes is no longer applicable. The following response is provided for completeness.

As stated in the response to Supplemental RAI 6.a.1, PG&E is revising the proposed change to maintain the 60-minute augmented response time for the Mechanical and Electrical Engineering positions to provide technical expertise for the performance of troubleshooting activities and to perform lead maintenance oversight functions for activities in the field as applicable.

Supplemental RAJ 6.b. 1 Please explain what tasks, other than core damage assessment and dose assessment, are performed by the electrical and mechanical engineers.

PG&E Response to Supplemental RAI 6.b.1 Per PG&E Procedure EP EF-1, "Activation and Operation of the Technical Support Center" (currently Revision 57), Electrical and Mechanical Engineering positions do not have any tasks assigned that are associated with performance of core damage assessment (CDA) and dose assessment.

The Mechanical Engineering position provides technical troubleshooting support and is responsible for tracking and trending plant conditions via the Emergency Response Facility Data System (ERFDS). The Electrical Engineering position provides technical troubleshooting support and is responsible for tracking and trending plant power and bus outage impacts. In addition, the Electrical or Mechanical Engineering positions may 2

Enclosure PG&E Letter DCL-19-056 perform lead maintenance oversight functions, which typically include establishing communications with the control room, providing technical expertise, prioritizing activities, and calling out additional maintenance technicians.

Supplemental RA/ 6.b.2 If the WCSFMISTA is expected to perform the electrical and mechanical engineer functions in addition to their current response functions, please provide a justification that the WCSFMISTA is qualified and capable of performing the electrical and mechanical engineering functions in addition to the WCSF/STA duties.

PG&E Response to Supplemental RAI 6.b.2 With the retention of the 60-minute augmented response time for the Mechanical and Electrical Engineering positions, the requested justification is no longer applicable. The following response is provided for completeness.

The Work Control Shift Foreman (WCSFM)/Shift Technical Advisor (STA) is not expected to perform electrical and mechanical engineering functions in addition to their current response functions. As stated in the response to Supplemental RAI 6.a.1, PG&E is revising the proposed change to maintain the 60-minute augmented response time for the Mechanical and Electrical Engineering positions.

Supplemental RA/ 7.alb. 1 Please provide a justification that the maintenance coordinators are qualified and proficient to independently perform maintenance technician tasks. Note: the original RA/ 7.a specifically asked how a maintenance foreman could do both the supervisor and technician tasks. The RA/ response appears to only addresses making sure the maintenance coordinators are qualified as maintenance foremen.

PG&E Response to Supplemental RAI 7.a/b.1 To clarify the information provided in PG&E's response to RAl-7a in Reference 2, Maintenance Foremen are required to comply with ANSI/ANS 3.1-1978, "Selection and Training of Nuclear Power Plant Personnel." The ANSI qualification requires that foremen have a minimum of four years' experience in the craft or discipline they supervise. This requirement ensures the foremen have the requisite knowledge and experience to perform maintenance technician tasks in response to emergencies. To ensure that these activities may be performed under potentially adverse conditions, PG&E commits to the addition of respirator and self-contained breathing apparatus (SCBA) qualifications for Maintenance Foremen qualified as Emergency Response Organization (ERO) Mechanical and Electrical Maintenance Coordinators (see ) .

3

Enclosure PG&E Letter DCL-19-056 As noted in the response to Supplemental RAI 6.a.1 above, the 60-minute response time for the Mechanical and Electrical Engineering positions will be maintained to perform lead maintenance oversight functions for activities in the field as applicable. As a result, the Maintenance Coordinators will not be required to perform both supervisor and technician tasks simultaneously. If not performing technician tasks in the field, the maintenance coordinators may perform lead maintenance oversight functions.

Supplemental RA/ 7.alb.2 Please provide a justification for not having maintenance technicians provide for minimum staff augmentation unless called in to an Alert or greater emergency classification level.

Note: Revised NUREG-0654/FEMA-REP-1 Table B-1: "Emergency Response Organization Staffing and Augmentation Plan," includes a mechanical and an electrical technician at 60 minutes (which will be performed by the maintenance foremen) and an electrical and mechanical supervisor at 90 minutes. Although NUREG-0654 provides for additional personnel to perform the maintenance and electrical supervision functions, PG&E does not provide any additional to support this function.

Additionally, the current DCPP Emergency Plan show 1 on-shift person in operations performing the mechanical maintenance function with 2 additional on-shift personnel performing the electrical and l&C maintenance functions.

PG&E Response to Supplemental RAI 7 .a/b.2 The augmentation of Maintenance Coordinators at 60-minutes meets the Revised Table B-1 guidance for performance of initial maintenance activities. As noted in Section 3.2.5, "Repair and Corrective Actions Major Task," in the submittal dated September 12, 2018 (Reference 1), credit for engineered safety features (ESFs) was provided as the basis for removal of the requirement for staffing of maintenance personnel and as the basis for the acceptability of performance of maintenance tasks by operations personnel on-shift. The proposed DCPP Emergency Plan maintains the callout of maintenance technicians based on the type and extent of the emergency. This call-out process is initiated for emergency declarations of Alert or higher classifications.

Supplemental RA/ 7.alb.3 Please explain how the maintenance foreman will be able to supervise OSC activities when they may be performing maintenance technician activities in the field.

4

Enclosure PG&E Letter DCL-19-056 PG&E Response to Supplemental RAI 7 .a/b.3 As stated in the response to Supplemental RAI 6.a.1, PG&E is revising the proposed change to maintain the 60-minute augmented response time for the Mechanical and Electrical Engineering positions to provide technical expertise for the performance of troubleshooting activities, and to perform lead maintenance oversight functions for activities in the field as applicable. As a result, the Maintenance Coordinators will not be required to perform supervisory activities while performing technician activities in the field.

Supplemental RA/ 7.alb.4 Please provide a justification that supports the proposed minimum staffing for the Plant System Engineering, Repair, and Corrective Actions functional area. Note: considering that an on-shift staffing analysis does not assess the tasks performed by the emergency response augmenting organization, this justification should include that the proposed staffing has been demonstrated during emergency preparedness drills or exercises PG&E Response to Supplemental RAI 7 .a/b.4 With the retention of the 60-minute augmented response time for the Mechanical and Electrical Engineering positions, the requested justification is no longer appli_

cable. The following response is provided for completeness.

PG&E is revising the proposed minimum staffing as stated in the response to Supplemental RAI 6.a.1. PG&E will maintain the 60-minute augmented response times for the Mechanical and Electrical Engineering positions to provide technical expertise for the performance of troubleshooting activities and to perform lead maintenance oversight functions for activities in the field as applicable.

5

Enclosure Attachment 1 PG&E Letter DCL-19-056 DCPP Emergency Plan Replacement Pages (markup)

(Two pages are attached. Changes from previous versions are indicated in yellow highlighting.)

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 43 of 56 Organizational Control of Emergencies 5.--1-85.19 TABLE i-4-A5-1 , DCPP ON-SHIFT AND AUGMENTED ERO MINIMUM STAFFING Functional Area Major Tasks Emergency Positions Shift 60 90 Staffina Minutes Minutes

1. Plant Operations and Assessment of Unit Shift Supervisor (SRO) 2 ---- ----

Operational Aspects Control Room Staff Operations Advisor (CR/TSC) ---- 1 ---

Control Room Operator (RO) 4 --- ----

Non-Licensed Operator (NO) 5 - -- ----

2. Emergency Direction and Control Shift Manager 1 --- ---

Classification Site Emergency Coordinator (TSC) ------ --- 1 Emergency Director (EOF) ----- ---- 1

3. Notification & Communication Licensee, Local/State Shift Phone Talker (SRO/RO/NO) 1 -*--- ---

Federal Shift Phone Talker (SRO/RO) 1 - -- ----

Agency/ENS Communicator (TSC) --- ---- 1 Communications Advisor (TSC) --- - -*- 1 Communications Coordinator (EOF) --- --- 1 Offsite Communicator (EOF) --- --- 1

4. Radiological Assessment WC Shift Foreman (SRO) 1" ---- ---

Rad Data Processor (TSC) ---- ---- 1 Dose Assessment Radiological Manager (EOF) ---*-- --- 1 Dose Assessor (EOF) --- ---- 1 FMT Leader (RP Technic ians) --- ---- 2 Offsite Surveys FMT Driver --- ---- 2 On-Site(out-of-plant) Team Leader (RP Tec hnician) ---- 1 ----

Surveys Team Driver ---- 1 ----

In-plant Surveys RP Technician 2 2 2

5. Plant System Engineering, Repair, and WC Shift Foreman (SRO)/ STA 1 ---- ----

Corrective Actions Reactor Engineer (TSC) --- -- 1 Technical Support Electrical Engineer (TSC j ---- I !I Repair and Corrective Mechanical Engineer Mech. Maintenance Coordinator Elec. Maintenance Coordinator (TSq (OSC)

(OSC) n 1

1 Actions l&C Maintenance Coord inator (OSC) --- ---- 1 OSC Director (OSC) --- --- 1 Site RP Coordinator (OSC) ---- 1 ---

6. In-Plant PAs Radiation Protection RP Technician 2* 1 1

7. Firefig hting -- Fire Department 5 Local Local Support Support

8. p t Aid and Rescue Ops - Industrial Fire Officers 2* Local Local Support Support

9. Site Access Contro l and Accountability Security & Accountability Security Personnel Per Security Local Local Plan Support Support TOTAL: 22 ~ 'ii

• May be performed by someone fi lling another position having functional qualifications E-Plan Section 5 Mark Up 061319 Rev X.XX

E-Plan Section 5 - Diablo Canyon Power Plant Emergency Plan Page 49 of 56 Organizational Control of Emergencies

~ 5.21 FIGURE 5-2, TSC ORGANIZATION Emergency Director (EOF)

Site Emergency Coordinator I osc I TSC Director I (See OSC Chart)

I I I I I I

rl Maintenance Engineering Radiological Ops Advisor Advisor Communications I Security Advisor I Advisor I I I Advisor Advisor I OPS I PPC I Communicator -

Radiological Control CR Data Processor Room :Mecihanical Engineer

.J Agency/ENS Communicator Electrical Engineer*

Reactor Engineer E-Plan Section 5 Mark Up 061319 Rev X.XX

Enclosure Attachment 2 PG&E Letter DCL-19-056 Regulatory Commitment:

1. PG&E commits to the addition of respirator and self-contained breathing apparatus (SCBA) qualifications for Maintenance Foremen qualified as Emergency Response Organization (ERO) Mechanical and Electrical Maintenance Coordinators.