DCL-18-056, Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update

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Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update
ML18206A647
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 07/25/2018
From: Ginn M
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
DCL-18-056, DIL-18-009
Download: ML18206A647 (10)
v • d • e


Text

Pacific Gas and Ele*ctric Company~

Michael A. Ginn Diablo Canyon Power Plant Manager P.O. Box 56 Emergency Planning Avila Beach, CA 93424 805.545.3446 Internal: 691.3446 Fax: 805.545.6265 July 25, 2018 PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 U.S. Nuclear Regulatory Commission 10 CFR 50.54, 10 CFR 72.32 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 Docket No. 72-26, Materials License No. SNM-2511 Diablo Canyon Independent Spent Fuel Storage Installation Emergency Plan Implementing Procedure Update

Dear Commissioners and Staff:

In accordance with 10 CFR 50.54(q)(5) and the requirements of 10 CFR 72.32, Pacific Gas and Electric Company (PG&E) is providing a summary of the analysis of changes to Emergency Plan (E-Plan) Implementing Procedure OM1 0.ID1, "Maintaining Emergency Preparedness."

The associated enclosures are listed below:

  • Enclosure 2 - Summary of the Analysis of Changes to Emergency Plan Implementing Procedure OM1 O.ID1, Revision 18, "Maintaining Emergency Preparedness" PG&E evaluated the changes for a reduction in effectiveness, as defined in 10 CFR 50.54(q), and concluded that the changes do pot reduce the effectiveness of the E-Plan. The E-Plan continues to meet the requirements in Appendix E of 10 CFR 50 and the planning standards of 10 CFR 50.47(b). Therefore, prior NRC approval of the associated changes was not required.

A member of the STARS Alliance Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

Document Control Desk PG&E Letter DCL-18-056 July 25, 2018 PG&E Letter DIL-18-009 Page2 This update does not contain any privacy and proprietary information in accordance with NRC Generic Letter 81-27, "Privacy and Proprietary Material in Emergency Plans."

PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this letter.

If there are questions regarding this update, please contact me at (805) 545-3446.

Sincerely,

_A/\~~ b-Michael A. Ginn Emergency Planning Manager armb/4 743/50986332 Enclosures cc/enc: William C. Allen, NMSS Project Manager Kriss M. Kennedy, NRC Region IV Administrator Christopher W. Newport, NRC Senior Resident Inspector Balwant K. Singal, NRC Senior Project Manager Senior Emergency Preparedness Inspector (RGN-IV/DR)

A member of the STARS Alliance Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

Enclosure 1 PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Revision Numbers for Emergency Plan Implementing Procedures

Enclosure 1 PG&E Letter DC L-18-056 PG&E Letter DIL-18-009 DIABLO CANYON POWER PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURES Proc. No. Rev. Title OM10.1D1 18* Maintaining Emergency Preparedness OM10.DC1 9 Emergency Preparedness Drills and Exercises EP G-1 44 Emergency Classification and Emergency Plan Activation EP G-2 50 Interim Emergency Response Organization EP G-3 59 Emergency Notification of Off-Site Agencies EP G-4 30 Assembly and Accountability EP G-5 14 Evacuation of Non-Essential Site Personnel EP OR-3 10 Emergency Recovery EP RB-1 8 Personnel Dosimetry EP RB-2 8 Emergency Exposure Guides EP RB-3 7 Stable Iodine Thyroid Blocking EP RB-4 5 Access to and Establishment of Controlled Areas Under Emergency Conditions EP RB-5 8 Alternate Personnel Decontamination Facilities EP RB-8 29 Instructions for Field Monitoring Teams EP RB-10 20 Protective Action Recommendations EP RB-12 12 Plant Vent Iodine and Particulate Sampling During Accident Conditions EP RB-14 10 Core Damage Assessment Procedure EP RB-14A 2 Initial Detection of Fuel Cladding Damage EP RB-15 15 Post Accident Sampling System EP RB-16 15 Operating Instructions for the EARS Computer Program EP RB-17 0 Operation Instructions for QuickDose EP R-2 35 Release of Airborne Radioactive Materials Initial Assessment EP R-3 9 Release of Radioactive Liquids EP R-7 18 Off-Site Transportation Accidents EP EF-1 54 Activation and Operation of the Technical Support Center EP EF-2 40 Activation and Operation of the Operational Support Center EP EF-3 45 Activation and Operation of the Emergency Operations Facility EP EF-4 21 Activation of the Off-Site Emergency Laboratory EP EF-9 12 Backup Emergency Response Facilities EPEF-10 17 Activation and Operation of the Joint Information Center EP EF-11 2 Alternate Emergency Response Facilities/ Incident Command Post (ICP)

  • Revised Document Page 1 of 1

Enclosure 2 PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 Summary of the Analysis of Changes to Emergency Plan Implementing Procedure OM1 0.ID1, Revision 18, "Maintaining Emergency Preparedness"

Enclosure 2 PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 Summary of the Analysis of Changes to Emergency Plan lmQlementing Procedure OM10.ID1 2 Revision 18 Change Original Content Content Change Reason for Change 1 N/A - added new content 5.2.3.c. Added new content.

Radiological emergency response training This change adds in a new step to close a gap for is provided to those who may be called on training of personnel who may be called upon to to assist in an emergency _Too 747 assist in an emergency at Diablo Canyon Power Plant (DCPP).

The addition of this step does not create any new training requirements or expand the pool of potential people requiring training. This change does not result in the need to revise any part of the DCPP E-Plan or any other E-Plan procedure.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

2 N/A - added new content 5.2.3.d. Added new content.

Specialized training and periodic retraining This change adds in a new step to close a gap for in the categories in part NUREG-0654 part specialized training of personnel who may be O.4.a - O.4.j. is provided.T36234 called upon to assist in an emergency at DCPP.

The addition of this step does not create any new training requirements or expand the pool of potential people requiring training. This change does not result in the need to revise any part of the DCPP E-Plan or any other E-Plan procedure.

This change does not affect how the current E-Plan meets any planning standard functions, 1 of 5

Enclosure 2 PG&E Letter DCL-18-056 PG&E Letter DI L-18-009 Summary of the Analysis of Changes to Emergency Plan lm12lementing Procedure OM10.ID1 2 Revision 18 Change Original Content Content Change Reason for Change elements, or site-specific commitments. No additional evaluation required.

3 N/A - added new content 5.3.2.a. Added new content.

During drills, if appropriate, on-the-spot This change adds in a new step to close a gap for correction of incorrect performance is made correcting performance issues during drills.

and demonstration of the proper performance offered by the instructor_T36233 The addition of this step does not create any new drill and exercise program requirements. This change does not result in the need to revise any part of the DCPP E-Plan or any other E-Plan procedure.

This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

4 5.9 5.9 Modified existing content.

Annual Review of SuQQOrt Annual Review of SUQQOrt Agreements This change does not affect how the current Agreements r 35206 E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

5 N/A - added new content 5.9.1 Added new content.

Letters of Agreement for services are This change adds in a new step for listing maintained with the organizations listed agencies DCPP maintains agreements with.

below: T36206

  • Cambria Community Healthcare District The addition of this step does not create any new
  • CALFIRE / San Luis Obispo County letter of agreement requirements. This change Fire Dept. does not result in the need to revise any part of 2 of 5

Enclosure 2 PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 Summary of the Analysis of Changes to Emergency Plan lm~lementing Procedure OM10.ID1 1 Revision 18 Change Original Content Content Change Reason for Change

Patrol

  • DOE Oak Ridge Operations Office The content for this new step is copied from
  • French Hospital Medical Center E-Plan section 5.12.2.
  • INPO Nuclear Power Plant Agreement This change does not affect how the current
  • Marian Regional Medical Center E-Plan meets any planning standard functions,
  • PG&E Company Helicopter Operations elements, or site-specific commitments. No Department additional evaluation required.
  • San Luis Ambulance Service, Inc .

All emergency preparedness All emergency preparedness support Added steps 5.9.2.a. - 5.9.2.b.6 to provide support agreements shall be agreements shall be reviewed improved instructions on how the annual reviews reviewed annually. annually_T362* 6 of the letters of agreement are performed. Items from 5.9.2.b.1 - 5.9.2.b.6 were taken from E-Plan

a. Document the review of a. Perform review per AWP EP-007, section 8.6.

each agreement with a letter to "Updating Letters of Agreement."

file. The addition of this content to step 5.9.2 does not

b. Ensure each agreement includes: create any new letter of agreement requirements .
b. Update or renew all This change does not result in the need to revise agreements expiring prior to 1. A description of responsibility including any part of the DCPP E-Plan or any other E-Plan the next year's scheduled during hostile actions. procedure.

review.

2. When the support or service will be This change does not affect how the current
c. Update the Emergency Plan provided. E-Plan meets any planning standard functions, during the next revision to elements, or site-specific commitments. No reflect the current contracts or 3. How the support or service will be additional evaluation required.

agreements. initiated.

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Enclosure 2 PG&E Letter DCL-18-056 PG&E Letter DI L-18-009 Summary of the Analysis of Changes to Emergency Plan lm~lementing Procedure OM10.1D1 1 Revision 18 Change Original Content Content Change Reason for Change

4. Prior recognition by both parties that a prompt, effective response will be initiated.
5. The degree of emergency preparedness that response organization must continuously maintain in order to be capable of carrying out the obligation when the mobilization request occurs.
6. The identification of points of contact and telephone numbers for requesting assistance and verifying requests.
c. Document the review of each agreement with a letter to file.
d. Update or renew all agreements expiring prior to the next year's scheduled review.
e. Update the Emergency Plan during the next revision to reflect the current contracts or agreements.

7 Attachment 7: Page 1 of 3 Attachment 7: Page 1 of 3 Modified existing content.

Full Scale Drills Full Scope Drills Changed "full scale" to "full scope" to align OM1 0.ID1 with the drill and exercise procedure nomenclature in E-Plan section 8.3.1 and OM10.DC1.

The terms are synonymous and as such this is a title change only.

4 of 5

Enclosure 2 PG&E Letter DCL-18-056 PG&E Letter DIL-18-009 Summary of the Analysis of Changes to Emergency Plan lm~lementing Procedure OM10.1D1 1 Revision 18 Change Original Content Content Change Reason for Change This change does not affect how the current E-Plan meets any planning standard functions, elements, or site-specific commitments. No additional evaluation required.

5 of 5

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