In this session you will be introduced to the principles of disaster planning and you will be introduced to the district disaster planning matrix. Why would we plan? Think about why we plan. We plan for health emergencies to get better prepared to respond to the disaster and to save lives. To know the resources needed and activities anticipated. Resources are limited and have to be used in the best possible way. Good plan should be operation that is simple to use. Written to include operational level detail on each and everything that is to be done. And are camped by standard operating procedures and checklists. Good plans are consensus based. That is written by a group. And they are developed by consensus among stakeholders. Good plans are capability based. That is based upon what we are actually capable of doing. Or should prescribe activities that lead to building capabilities. Good plan should be objective based. That is they should include measurable objectives. Good plan should be compliant. That is they should be in line with national guidelines and policies. And in addition regional guidelines and frameworks. Consensus based planning. The best plans are written by those who will actually implement the plan. They are viewed as contracts that result from the negotiation of various stakeholders. The process requires a very well organized facilitation process in order to save time and result in the product. Objectives, good management planning objectives should be smart. That is specific, measurable, attainable, realistic and time bound. Or time based. Or time referred. Good planning objectives answer five questions. What tasks do we perform during the disaster? Who will perform the tasks? How will we perform the tasks? When will we perform the tasks? Where will we perform the tasks? Plans may be made according to time. That is short time plans, intermediate time plans and long time plans. But plans may also be made according to the degree of detail. Either strategic plans or operational plans. Strategic plans are broad and general. Mainline form of protocols. They prescribe what actions are to be performed broadly. Plans on the other hand are detailed and focused and describe how actions will be performed. Who will perform them? When will they be performed with respect to the disaster? And where will these actions be performed? Strategic plans do identify the main strategy, provide overview of response and identify collaborations. They do not engage operational level health workers and stakeholders. They describe detailed actions. And they often do not provide references in form of checklists, phones and templates. This is an example of a matrix for operational planning. As you can see, it shows the strategic objective. The operational objectives within that strategy. The actions, the checklists if necessary. The responsible parties, the timing with respect to the disaster and the location with respect to the disaster. The planning cycle involves planning in which we describe the tasks. Training in which we land the tasks through meetings, consensus, building, sessions, negotiations. Exercise in which we perform the tasks and test them with respect to scenarios. Analysis in which we review performance of these tasks with respect to the exercises or disasters that have occurred. And then we plan again or improve the plan. In planning collaborate with others, prepare the plan, highlight standards and indicators, assign tasks and make relevant checklists if possible to guide the implementers on what we mean by a given operation. Train response teams, ensure that tasks are land, conduct exercises and drills and assess performance of exercises. Implement the plan, implement the pre-disaster activities, implement response activities in case of a disaster, implement the post-disaster activities after the disaster. Analysis, monitor and evaluate the plan, check on actual performance, assess what worked and what did not work, improve the plan. This is called plan maintenance. Problem issues in current disaster plans include the fact that the plans are cumbersome to use, checklists that fail or are not relevant to the disasters, focus on tasks rather than management, the naming possible hazard scenario so we try to plan for every possible hazard that is likely to hit our district and then lack of clear objectives and measures of effectiveness. How do we know that we have responded appropriately? Challenges of emergency management planning for public health emergencies. Planning must be written by consensus among all stakeholders that is planners, responders and managers. Planning should not be an ending in itself and should not be more important than the plan. It should be a way for everyone to learn the plan so that it is implemented. You shall now be introduced to the district disaster planning matrix. The SOAR matrix is used in planning for disasters. It stands for strategic objectives, operation objectives and activities. Districts are already used to planning using matrices. The strategic objectives in the matrix have already been prepared for you based on the sphere standards. The operation objectives have already been prepared for you based on the sphere standards. These were prepared by the regional disaster management training team and discussed and analyzed. These prepared strategic objectives and operation objectives are contained in a matrix that we shall issue to you and it is available on this resource. It is called the SOAR library standing for strategic operation objectives and activities. Under each operation objectives we expect several activities. Your task is to select the appropriate activities that suit each operation objective. Revised objectives if needed so as to suit your local context and situation. Some of them can be matched, some of them can be split, some of them can be rewarded. This is the planning matrix that you will use in planning for disasters for your district or agency. This shows strategic objectives, operation objectives, activities, responsible parties, timing and location and an estimate of the budget. Being operational plans they provide this level of details so that we can know who will exactly do what in a disaster situation. The SOAR library is in form of planning capabilities. You will plan based on capability areas. These are based on the sphere standards. The capabilities include response management that is minimum standards common to all disasters. The second capability is water in case of a disaster situation that needs water. Shelter in case of a disaster that needs shelter. Food in case of a disaster that needs food what will you do? Health services in case of a disaster that requires emergency health services or that results in a disruption of existing services what will you do? So you fit in activities that show what you will do for each of these areas in case they are needed in a disaster situation. When you make a plan based on these capabilities, the five capabilities mentioned, this is called capability based planning. When taken together the sum total of capabilities is what is described as capacity. These planning capabilities have been used as the basis for developing your strategic objectives and the operational objectives. They are contained in an electronic planning template called the SOAR library. In this extension activity, try and refer to the sphere manual and match the strategic and operational objectives to the response areas that are prescribed in the sphere manual. You will see that they are matched. However, they have been revised and enhanced to include issues that were left out and to make them relevant to the eastern Africa region. Half a brief exercise to check on this. Start with the capability on general response management and browse. Thereafter, look at water and sanitation and see how the strategic and operational objectives are matched to the major strategic and operational areas prescribed in the sphere standards.


Operator, if you would please queue up the questions from folks on the telephone and if you would please start with members of government organizations, government officials. As soon as you have the first one queued up we'd appreciate putting that person on and folks who are asking questions or comments. If you'd please identify yourself and your organization before you make your comment or question we would appreciate that. Thank you at this time if you'd like to ask a question please press star then one. Please lower your short to unmute your phone and record your first and last name clearly when prompted. If you are a government official please identify yourself as such. Again if you'd like to ask a question please press star one. If you decided at any point you would like to withdraw your question you may press star two. Again if you'd like to ask a question please press star one and identify yourself as a government official. Our first question comes from Daniel Mills from California Energy Commission. Your line is open. Hi thanks for including us in this conference I appreciate it. My question is with regard to PG&A's request for enforcement discretion and they discussed the significance of the violation and mentioned that there's a very low mobile transient population. I'm just curious to what extent the NRC is looking at the estimated number of endangered citizens and the probability of an event. Emergency preparedness is a defense in depth measure you know we look at the plants are designed to ensure that there is not an event that would result in a significant radiological release notwithstanding emergency preparedness function is there to provide that defense in depth so we don't look at it in the context of the probability of whether there would be an accident at the plant that would require evacuation we have if you will deterministic requirements whereby the licensee has to meet our emergency planning standards and meet the requirements and the regulations specific to the emergency preparedness function so it's not a matter of whether there are you know 10 boats that would be on the ocean or whether we're talking about the densely populated area the licensee has to develop protective action recommendations that are a function of the direction of the radiological plume and the projected dose assessments and then communicate those recommendations to the county so that the county can make an informed protective action decision. Thank you it's very helpful. Thank you our next question comes from Ron Oswald, Sam Louise Ophispo and County OES. Your line is open. Thank you and actually I failed to identify myself as a government agency and so I just have some additional input on the conversation should I make that an hour or should I get back in queue representing a government entity? Please go ahead. Okay thank you. I just wanted to mention and for clarification for those that don't know, Sam Lois Ophispo County is the lead off-site response organization for Diablo Canyon and we do work closely with Diablo Canyon and in this case with the US Coast Guard and I wanted to fill in a couple of things that that I heard and one in particular regarding five miles versus 10 miles and I wanted to note that with on our procedures our standard operating guidance that we use for Diablo Canyon emergency response is one of our guidelines is establishing an article safety zone and to do so you know we pass the information through for the Coast Guard and the request that we make is our pre-determined that you know check the box if you will is five five nautical mile safety zone ten nautical mile safety zone other and then it goes on to you know note the downwind sectors and and other things and tied in with that is for those that aren't aware I wouldn't understand in this case the most on the line are aware that as the lead off-site response organization we make the protective action decision in that case we being the County of San Luis Obispo and so as noted throughout whether or not we got a protective action recommendation based on the on the situation you know we could make and we have in exercises and would make in an event if necessary a pad a protective action decision on our own without any input from the utility if need be and we actually practice that and we study up for that and in fact to keep us aware of what's going on and how things work we have the FEMA FEMA's radiological protection course that it's actually the radiological accident assessment course then the past we've sent people down to Georgia for and citizens in one or two people down to Georgia the course is being hosted here this week so we have our folks some of our off-site folks and the FEMA course about 25 people our pollution control district Cal OES is in there there's a state emergency management agency California Department of Public Health FEMA NRC and even a person from Delaware and this is ongoing you know so we look on our own independently of what's going on off-site what happened to the plant what other actions might we might we need to take other than the powers and so we coordinate also with all the off-site response organizations the other organizations including the Coast Guard so we maintain and edit and keep in this case the Coast Guard SOP as well as we do with the Sheriff's Department and schools and all that it's their SOP but we edit it so we have one centralized point so we want to make sure that what's in a Coast Guard SOP is consistent what's in the rest of our SOPs and so on so I just wanted to add those points that the NRC has already pointed out at no time was the public health and safety that threatened out in the ocean well thank you mr. Oswald this is marked upon I just was going to underscore what I think was your overarching conclusion that the public health and safety was not at risk as by virtue of the process in role that the county would exercise as you described so thank you thank you thank you our next question comes from Richard Gunstrom from FEMA your line is now open yeah good afternoon everyone this really maybe not be a question but it's kind of a comment you know we've evaluated the off-site response organizations for a long time there's an elusive islam in the EOF in the county EOC it's in the same building unified dose assessment center in both the utility the county in the state they all participate in developing protective action recommendations and then they provide their recommendations to their decision makers turning into a decision and you know you say that you know that unified those assessment center and they participate in that protective action recommendation including the part about making protection recommendations for kind of a mitigating factor that you need to consider well thank you for your comment I think that is consistent with the description provided by the licensee and that there is that collaboration and discussion that occurs as part of the exercises which underscores the licensees view that protective action recommendation may very well have been generated I think the salient point from the NRC perspective is that we expect the emergency preparedness implementing procedures to specifically call out that process step to ensure that that does in fact occur certainly do appreciate though the perspective that you provided based on your own interactions in the licensees EOF and a joint if you will county EOC thank you thank you that was our last government question our next question comes from Ray Lutz from citizens oversight your line is now open okay thank you very much I hope you can hear me I'm with citizens oversight and our primary mission is civic engagement I have a few comments and questions first of all slide six in the in the package that you provided to the public was was blank it had the headers and footers but there was no figure on it we I think that this meeting the fact that it's not being held within the public education area despite the fact that success in dealing with the emergency scenarios relies upon actions by the public is pretty astounding you're holding this meeting over in in Texas that doesn't allow the public to engage very effectively with your process I did make a written complaint to the NRC on this point and there was no changes made to the location and I would assert that in the future the NRC in order to to actually you know fulfill your obligations to engage with the public in this in public engagement education area you need to hold your meetings either in that area or very close to it another thing I submit that you should not close your meeting prior to hearing from the public the public interaction is a very important part of your meeting and you should not blow it off as not part of the meeting you already closed the business portion of your meeting without even hearing from the public shame on you now no changes I didn't notice any comments about lessons from Fukushima in this emergency action plan the thing that concerns me here is that it took almost 10 years to detect the violation from 2005 despite saying that there the public was not put at risk the fact is that your root cause analysis identified the fact that you may changes to your plan that were then in missing from the written version of the plan and you didn't didn't figure that out for 10 years the question that everybody needs to ask what other parts of your plan are missing that you're not catching and that we may not see for another 10 years what is it about your procedure in making such changes is broken and that root cause analysis of going back to find out what you did back in 2005 why did this happen that you could make a change and nobody's caught it is it because you don't have a review committee is it because you just have a few people making changes willy-nilly and that 10 years later you might find out it's very concerning to the public that at least from my view that you can you can miss this for 10 years and I am astounded that the NRC can sit here without even finishing your meeting and say that the public was not put at risk because they can't find their own mistakes of course the public is being put at risk by this process that you have in place where you can make a mistake and not catch it for 10 years that's the problem I'm not talking about the mistake of whether boaters are out there or not I'm talking about the mistake of taking this out of your plan and not catching it that's the mistake how many other things have been taken out of the plan and not caught that's the problem and that could be putting people at risk because I'll tell you what you don't know what those things are and it's very clear from the discussion that I heard today that the NRC itself is not adequately reviewing these plans you're relying upon PG&E the operator of the plant to make their own plans and to evaluate their their their emergency plans of themselves and then come to you if they find a problem and say please give me a fine or by the way give me discretion don't give me a fine or anything I found something and I'm going to give it to you but make sure that I don't get anything passed a green when in reality you guys the NRC who are sitting here happily reviewing the fact that they're not even able to catch something for 10 years you're not reviewing their plans either that is amazing to me the root cause now has the root cause been corrected the root cause that I'm talking about is the missing of this back in 2005 not the fact that that that that maybe the boats were going to be told to get out of the area that's not the concern concern is that that was eliminated from the plan and not caught for 10 years now this voluntary self-assessment is nice but it didn't detect it for a very long time and the NRC is relying upon this group to do self-assessments versus check it yourself how can we rely upon the operator to always come forward and self-assess themselves and catch everything this is a big this is a big issue the same issue that happened in Santa November with the steam generators they self-assessed and said we don't need to do a 50 59 review we don't need to submit that to the NRC fine we don't do it then we're stuck with a 3.3 billion dollar bill over here and the inspector general report on the whole process was that you guys at the NRC were not doing an adequate job of reviewing the 50 59 and here again we're seeing something where you're relying upon the operator of this plant to do their own self-internal reviews and say that everything is fine and you sit there during the meeting and say there's no problem with what they did ridiculous you shouldn't be making that conclusion when you haven't even gotten to the root cause of what happened here now extending I hear this we're extending significant resources to make sure everything is handled well maybe but I haven't heard what changes you're making to your process so that you're not going to miss stuff anymore I haven't heard what the NRC is doing so that they can catch the evacuation six miles out into the ocean how come that's not 10 miles the I was reading here from the GRO the general accounting office in GAL 13-243 it says now that they want a 50 mile ingestion exposure pathway emergency planning zone where is your 50 mile ingestion exposure pathway emergency planning zone have you taken that into account this is what the general accounting office is expecting now according to this guidance the principal health risk in this zone is exposure from ingesting contaminated water or food stuff such as milk fresh festivals or fish and this pathway health risks would come from longer-term problems associated with contaminated food and water I didn't hear any talk about a 50 mile ingestion exposure pathway I didn't hear any talk in this discussion about the changes from Fukushima and what's going to happen due to the fact that when they analyzed the Ablo Canyon nuclear power plant with a similar failure that occurred at Fukushima which by the way they all said we have defense and death and nothing will happen that in this analysis done at Stanford they determined that the nuclear radiation would actually come all the way down the coast due to the due to the weather conditions all the way to San Diego so the 10 mile area isn't enough and the fact that the general accounting office is saying 50 miles is necessary that that's not in your plan I am very concerned that these plans are not being reviewed and that the NRC is just passing the book down to the operator of the plant and say you guys analyze your own plan and tell us if it's bad and then they say everything's fine and you repeat that in the meeting everything's fine Mr. Lutz this is Mark DePaul I'd like an opportunity to comment on a number of the areas that you provided a comment I do appreciate your comments I'm pretty much done just so I'm finished my list of things so yeah but I would like to remain your respond after you're done go ahead okay I would like to give others an opportunity to ask questions and certainly as there's time when it would come back to any further questions that you have but first thing thank you for pointing out that slide 6 did not the content for whatever reason was not included in what we provided on the website we'll correct that and make sure a full set of slides is provided and we'll verify that the content is visible I made the decision not to change the location of the venue based on discussion with our program office the office of enforcement and the reason for that is because this is a pre-decisional conference here a conference for us to discuss with the licensee and understand their perspective on the apparent violation no decision has been made that is different than other public meetings that we would conduct where we're communicating the results of regulatory decisions here once we conclude our deliberations and determine what is the appropriate enforcement action we are certainly can talk about that for example in the context of the public meeting that we would have in the vicinity of the plant to discuss our overall assessment of licensee performance and that would include any findings that are greater than green or any apparent violations but that would be at a point in time where we certainly have rendered a regulatory conclusion the other reason why I decided not to shift the venue here was the recognition that that to be consistent with how we have historically treated all regulatory conferences and that's that the licensee comes to our house if you will to discuss with us their perspective on the particular apparent violation or preliminarily greater than green findings and that's consistent with how we have treated regulatory conferences across all four regions including regions with that have sites that have the same high degree of external stakeholder involvement and so that was the principal reason for why we decided not to or I decided not to change the venue we did look at web streaming which is something that I would like to pursue in the future and we face some technical difficulties with the ability to implement web streaming and we're looking at what we can do to provide the web streaming capability with future meetings I appreciate your comments about lessons from Fukushima I will offer that we the NRC have looked very seriously at lessons from the Fukushima accident and we have required a number of things of licensees and issued orders in terms of mitigating strategies there are actions that licensees need to take in the context of emergency preparedness and we will hold licensees accountable as we review the responses to those requirements that we issued following our task force review of the Fukushima lessons learned I agree with your characterization that this was an issue that remained unidentified for a significant period of time I think we very clearly heard the licensee explain their extent of cause and extent of condition reviews and that is certainly it is important that the licensee understands why did they not identify this in an earlier time frame and what are the organizational learnings and and quite frankly by the same token we did not identify that via our inspection process it's a sampling inspection process but the entire regulatory framework is based upon the precedent here that the licensee is responsible for ensuring the safety and security of the facilities and our inspection program is a sampling program to verify that the licensee is doing that and yes they're going to be instances where licensees miss things it's important once those issues are identified that we assess the safety significance of that issue determine what is the appropriate regulatory action to preclude recurrence and a good performing licensee would do the same thing within their organization in terms of lessons learned you did make some comments regarding the emergency plan and you know the degree of review that we conduct when a facility is licensed we do look at the emergency plan and we render an overarching conclusion on whether we agree with that our regulations are structured to allow a licensee to make changes to their emergency plan they evaluate that and determine whether there is a reduction in effectiveness associated with that and then we do on a sampling basis look at those 5054Q evaluations to determine whether the licensee made the appropriate conclusion and that's exactly why we're here today having this discussion because here is an instance where the licensee did not conduct that 5054Q review appropriately and I acknowledge your comments about santa no free and the inspector general review and the context of the 5059 there are some learnings for us we have a comprehensive lessons learned review that we're conducting to look at whether our guidance to inspectors needs to be enhanced regarding a review of licensee 5059s but again i want to come back to the principal responsibility does rest with the licensee and it is through that sampling inspection program that we feel that we conduct enough inspection to validate that the licensee is in fact executing that responsibility in the manner that it should be i'm not sure i understood your thoughts about the 50 mile ingestion pathway there is a 50 mile ingestion pathway that the licensee is responsible to address and there are exercises that are conducted that address the ingestion pathway so i'm not aware of the of the licensee not having that in place i'm quite confident they do because there is a requirement to that effect so those are some of my thoughts regarding the comments and questions that you raise and and i do appreciate your engagement and your sharing your perspective if i could ask the operator to cue up any other questions that others would have and mr let's i certainly welcome coming back to any additional comments you have once we've heard from some other folks thank you absolutely our next question comes from lin walter private citizen your line is open thank you and i just want to offer i appreciate the previous comments but i'm sitting here in my home in avila and i i like the fact that i can participate in this meeting and listen to what's being said actually i think i hear things better in the teleconference and in a you know a noisy room noisier room i also like the fact that i didn't have to drive that i didn't have to find a parking place and i didn't have to yeah i had the ability to sit in a comfortable chair so i just wanted to put a counter opinion um on the record about i think the teleconference worked really well i appreciate being able to participate in this way and i did cue up on my computer just for information that i did get slide six i got the math and it was pretty clear on my computer so i'm not sure that the problem is at your end maybe it's just a difference in technology anyway um my question is that uh i heard a lot of comments from the nrc and questions from the nrc to pg me about the important benchmarking and at one point i heard the nrc mentioned about their experience in region one as an obvious you know well you know obviously over water is is um an important part of your circle on your map but you know i i'd wonder if the nrc is asking itself the same question of itself um internal benchmarking um and uh that's in fact that the the regulations that have increasingly got more clear more clarity red guide 1.129 the recent et rulemaking it it seems to underscore to me that the state that we were in in the early 80s and 2005 is a different state of clarity than we are right now because we have Fukushima lessons so we are getting clearer and we are getting more aware um so but there's a complicit a complicit nature that the nrc has and as i haven't heard the nrc um admit to their own feelings of internal benchmarking here which i clearly see and that's that's my question yeah thank you for the question i i do think that benchmarking is very important and and you know i i'm the one that made the comment regarding the experience in region one where there are facilities this is marked upon there are facilities that are located along the coast and do have protective action recommendation process for areas over the ocean and and i do think the licensee acknowledged that or did it you know indicate that they identified this deficiency as a result of the benchmarking that was conducted but getting to your point about internal benchmarking it is an important process and i wanted to mention that there is a uh a review that we are subject to two years ago it's called an international regulatory review service mission where the international atomic energy agency sends a team consisting of experts from regulatory organizations that in various countries and they look very critically at the nrc's regulatory structure and how we implement our programs and processes and then provide recommendations and observations and then we address those and we did receive a a comprehensive review and there were some recommendations that were provided that resulted in us revisiting and making changes to some of our processes and then of course we we do have the office of the inspector general and and that office clearly you know conducts audits and evaluations of nrc programs and processes and over the years has provided a number of recommendations and observations and findings and has resulted in clear action by the nrc to improve its programs and processes and then of course we do have self assessments that we conduct similar to the industry that has self assessments but we do try and look at critically in those areas and specific to the regions we have the program offices at headquarters that conduct evaluations of the regions to determine how we are implementing the programs and processes that are defined by those headquarters offices so i do think there is a fair amount of introspection and evaluation regarding how we're doing as well as external reviews and some of those external reviews can include government accountability office reviews gao reviews and we have received a number of recommendations and collectively all of those point to there are opportunities for us to improve how we execute the regulatory mission but i'm not aware of any overarching review that reached a conclusion that we are not fulfilling our statutory mandate to ensure protection of public health and safety by virtue of our inspection and licensing programs but certainly our opportunities to enhance those processes to make them as efficient and effective as they can be but i do appreciate your question and thank you thank you thank you one moment for our next question our next question comes from Dan Hirsch from the University of California your line is now open thanks very much i have two questions if i may it was said early in the meeting today and also in the press release that the nrc issued about this meeting that this issue that arose had no immediate safety significance because quote at no time was the public going to be allowed to stay in an area that had the potential for radioactivity if an event had occurred and the basis for that is the citation to the fact that the county had its procedure and the u.s. coast guard had it but i am confused by the radius of these procedures in the actual inspection report the finding was that pgne had eliminated procedures for guidance or requirements for developing and communicating protective action requirements for areas of the pacific that lie within the 10 mile emergency planning zone it goes on to say that this was a degradation rather than a complete loss of protection because the county quote has procedures which include a default action to recommend that the u.s. coast guard evacuate waterborne vessels within five nautical miles if the licensee notifies the county of a general emergency and that the u.s. coast guard has additional guidance recommending a two nautical mile safety zone for an alert or site area emergency so the issue seemed to be this zone between five nautical miles and 10 regular miles which represents actually the majority of the ocean area and the inspection report goes on to say the required planning standard function was degraded because the licensee's procedures did not direct the licensee to issue appropriate protective action recommendations to cover affected areas over the ocean within five to ten miles of the site the planning standard function was degraded rather than lost because default procedural actions of local governments would have resulted in effective protection protective actions for areas within five miles of the site so this is my first question i have one other but i wonder if that could be explained to us it appears as though protections within five nautical miles were still in place and therefore no immediate safety concern regarding the area within five nautical miles but as i read your inspection report it sounds as though there may have been situations in which boats and obviously the people on those boats and ships between five and ten miles might not have in fact been removed from the area if i heard the official from the county correctly it sounds as though their procedure is that they have a default which is what your inspection report says of five nautical miles but do have other boxes that they can check ten miles or other but it would appear that the loss of PG&E procedure for making recommendations to the county would have degraded the county's ability to choose a box other than the default and your own inspection report seems to make clear that the zone from five to ten miles was an area in which that protection was degraded so perhaps someone could answer that and then i do have one other question if i may yeah thanks mr hers this is mark pop we could answer that and then we would we'll give you the opportunity to ask your second question i'm going to ask mark here who is the branch chief that signed out the actual inspection report to speak to the areas that you just described in your question thank you yeah this is mark here and i'll just attempt to address that question in a couple of ways the first is uh there the ten mile requirement is is the requirement so when we when we look at the emergency plan we ask ourselves does it meet the requirement to provide for protective action recommendations instructions for protective action recommendations for the entire 360 degrees all the way out to ten miles so when we looked at this we said this is a non-compliance because their procedure removed the instructions to cover out to ten miles for over the ocean so so the non-compliance was identified then the question we began to ask was what is the significance of this non-compliance what was the safety impact of this non-compliance and that's when we get into the question of what other layers of protection and what other elements of this can we can we look at to just to decide what is the significance so when we're asking ourselves was it a degraded planning standard or was it a lost planning standard or was there what was the impact on the planning standard we're asking ourselves what is the significance of the non-compliance we've already established they don't meet the requirement out to ten miles so when we're looking at the significance some of the things that we look at i talked about earlier we look at what was the licensee's capability they had a demonstrated capability through drills and exercises over all of the years that they've been operation we observe those regularly they've demonstrated the ability to assess radiological conditions 360 degrees they've demonstrated the ability to assess a release to assess wind direction to assess those consequences so whether the wind direction was pointed over the ocean or over the land they had the capability to make that assessment the second aspect is they had the capability to engage and notify the off-site agencies so they had demonstrated that because all of their drills and exercises again demonstrated their capability to interact effectively with the the the local government agencies in in this case the the county the county had a relationship with the coast guard the utility had a relationship with the coast guard as well so they had those demonstrated abilities to interact and communicate uh irrespective of the fact that they lost one of their defense and depth elements because they didn't have the over the ocean area proceduralized they still had all these other capabilities that they could have relied on and then third we noted that there were default actions already in place which effectively protected the public by default out to five nautical miles because of the actions that the coast guard and the county had in place regardless of whether the licensee had been able to make a protective action recommendation or not so in recognition of those factors and in addition what mr. Gunstrom pointed out in his comment earlier that the emergency facilities are co-located so that there's significant interaction between the county folks who are involved in dose assessment and the utility folks that are involved in dose assessment that it's reasonable to conclude that the right decision for the public would have been made all the way out to 10 miles and beyond if the site conditions had warranted it still nonetheless we document the apparent violation because the licensee's procedures that's a layer of defense and depth that we require the procedures did not have the instructions appropriate to cover those areas i hope that clarified and answered the question of what's the difference between the five and the 10 miles well it troubles me frankly i mean i think you have a logical disconnect in the inspection report and in this decision to then determine that quote unquote at no time was the public going to be allowed to stay in an area that had the potential for radioactivity if an event had occurred and the significance of their failure is that there was a zone from five to ten nautical miles for which there wasn't coverage and maybe we would have gotten lucky and in the midst of the emergency someone would have figured out there was a problem and gotten the right recommendation in but that's not how we want to do things i mean you all remember the extraordinary real-life confusion that occurred at the time of three mile island so you want those procedures in place so a very clear recommendation can be made to the county so it doesn't check the box five miles but checks the 10 mile box i just would suggest that your press release and the inspection report are not entirely consistent and clear on this matter and there was an area that was potentially uncovered by this change my second question has to do with your conclusion that there are no cross cutting issues here i was troubled in the listening to your conversation i want to applaud those whoever it was from the nrc who managed to get this matter acknowledged but this was not the only such incident in which a 50-54 problem had arisen regarding changes to the emergency plan and that pgne has now knowledge that they have confusion in their licensing basis regarding the emergency plan and are about to or have commenced the licensing basis verification project similar to what they have done for other aspects of the licensing basis and i wonder if you at nrc could just summarize for a moment that larger lbvp and the discoveries that have occurred through it regarding other changes to the facility over the last decades that were not done to the actual licensing basis and they're now having to go back and revisit and reanalyze particularly you know on the seismic side because it would seem to me those would be very troubling to an inspector to a regulator that there had been so many years of changes made without meeting the actual licensing basis and that those discoveries are occurring belatedly and they're having to go back retroactively to do new analyses and it would seem to me that there is a larger cross cutting issue here of a unclear licensing basis in many many regards and numerous changes that have been made to the facility over the years that did not take into account the actual current licensing basis Mr. Hirsch this is marked upon i am aware that the licensee is engaged in a licensing basis verification project that is separate and apart from the ep functional area as with any one of these licensing basis verification project efforts you know we are aware by virtue of our inspection activities and our on-site resident presence of any significant findings that are coming out of those projects and we would assess the significance of those in the same context that we're doing here today with the licensee identified deficiency here associated with the change to the emergency plan implementing procedure so you know i'm struggling to understand the basis for saying that there are significant deficiencies that exist in the licensing basis here that you indicated it's not apparent to me. I'll give that out for a moment my understanding is to give two examples that the steam generator replacements and the vessel head replacements were done to the wrong seismic basis that they had to go back they discovered they hadn't done it to the appropriate seismic basis and tried to reevaluate to determine whether or not even though they hadn't designed it for the appropriate seismic challenge they were still okay and that's true not just for those two significant features but for many other changes that have occurred over the decades we think to me that that would suggest an underlying problem rather than individual problems that's what we're talking about in terms of cross-cutting an underlying problem of not having kept a very clear licensing basis and having made many changes to the facility without doing 50-54 or 50-59 analyses and after the fact with some embarrassment having to go back and try to say well if we had done the analysis at the time it would still have been okay. It just seems to me you have a generic underlying potential problem here. Thanks for that. Thanks for that additional context. The one example you're referring to obviously deals with the licensee replacing the steam generator and reactor vessel head and not accounting for the ground accelerations it would be evident from the rosary event coupled with loss of coolant accident loads to determine whether that exceeded the ASME code allowables the licensee did evaluate the double design earthquake plus loss of coolant accident loads as I know you are aware however they did not address rosary plus loss of coolant accident or local licensee did identify that and I think it was May 2011 as a result of their licensing basis verification project and then did a conduct an evaluation of that as found condition and determined that the steam generator in this example had sufficient margin such that there was not a concern with the ability of that particular component to withstand those forces. We looked at the operability of determination which is the licensee's evaluation of that and determined we did not have a safety concern. The licensee has subsequently conducted another 50-59 evaluation for that configuration and we are evaluating that at this point in time but I do think that is an example of something that did come out of a licensing basis verification project but your point I do appreciate is that it is important that we as a regulator step back and look at that if there's an example there are there other examples that would cause us to question to what degree is the licensee rigorously implementing the 50-59 process we do have an inspection that looks at that and we make draw conclusions based on the particular 50-59 evaluations that we look at as a sampling and then if there are problems we expand the scope to be able to reach an informed assessment regarding the veracity of that program and how it's implemented but it's not lost on me that we do need to look at it in a cross-cutting manner and I would offer that our inspection program does do that. I don't want to belabor it so just one last point I think the point I'm trying to make is not that once they went back and looked they lucked out and their analysis and whether this is an accurate analysis or not let's put that aside they now claim that okay if we had done it for the HOSV we still would have been okay saying there's a fundamental concern about a facility that could operate for so long and be making major changes to the facility based on the wrong licensing basis in this case the wrong seismic load and therefore to say that this particular incident that we've just had of the change to the emergency plan is an isolated matter not connected to others when they have apparently two others on the emergency plan side and my understanding is many many on the structural side the steam generators and vessel head there might be just two troubling examples so it's not the specific fact whether or not the steam generator is or is not okay or the vessel head is or is not okay it's a fundamental matter that you could go that many years making that many changes to the using the wrong licensing basis yeah thanks for that thank you i appreciate the comments i think we need to be careful when you make broad statements like many many i think the facts well let me ask one favor then on that it would be very helpful for the nrc and the licensee to release publicly the full details of the lbvp what they've looked at what was found i think if you feel that they really have been only a couple of examples of that would be clear from that public transparency if there have been many people should know that as well so let me just make that as a request or recommendation that they have that full lbvp the documents regarding it what led to it what they've analyzed what they found that should all be made public i appreciate your request and that's really a decision for the licensee i'll offer that we do look at the issues that do that are identified by virtue of the lbvp and determine via our own independent review and assessment that agree to which we think those are significant and those reviews are documented in our inspection reports so that that's how you can obtain some insights regarding what the licensee is identifying and what our independent assessment is of the safety significance of those findings of course that is based on licensee communicating to us the results of their lbvp and quite frankly the licensee has a responsibility to communicate to the regulator significant findings deriving from that where there is a safety question or where there is a degraded margin etc so i'd leave you with that i do appreciate your comments question what you have what nrc has to be made public but more than that my understanding is that when you review things generally pgne holds on to what you're reviewing and therefore it's not made publicly available but if they had given it to you if you ask for it then it needs to be made publicly available i think that would be a very useful thing for your region to do this should not be done behind a curtain i think there really needs to be some ability for the public to scrutinize so anyway thank you very much well thank you for your comment and i think your last statement refers to if we are in possession of documents and we have a freedom of information act request we make those documents available but the licensee can communicate why those documents are considered proprietary and there's a process we go through to determine whether that is the appropriate characterization i do appreciate your comments though mr herce thank you and and let me ask the operator to provide or connect us with any other individuals that have questions thank you our next question comes from ace hoffman from nuke free north county your line is open hi thank you very much for taking my call just a couple of short things um there's no discussion here the licensee is in is supposed to be taking the initiative on a lot of different steps and the nrc backs off and says we have a sampling program but who decides that the 10 mile limit is the right limit isn't the time that we reconsider that okay so that's too big for this little project maybe but if we did that 130 sound systems or whatever the number was explode very very rapidly which relates to whether or not you know because as you go out on a on a circle that the number goes up by you know the square um so fishermen in the five to ten mile region what about the 10 to 12 mile region of the 12 to 15 how many fishermen are there and is there any chance we're talking about sacrificing uh that somebody might get hurt in which case this is really a very serious thing and i think i'm what i'm hearing is that it's not significant because there are so many uh more the population is so much greater elsewhere uh in the on the land areas so there's very few fishermen comparatively but there's still people there they are people so um let's get to the sampling program you described the nrc's job as a sampling program and i wonder if with a 10-year wait it's effective i would think that to be effective there have to be surprise visits and occasionally these have to be microscopic visits that not only make the utility think that you might look at anything or everything but also that they have no idea when it's coming and it gives a check on whether or not your sampling programs are actually effective and you can't do that without an enormous i mean everybody would hear about it they're the nrc is doing that this is the month that they came and did that uh sand and no free but what did it have happened so those are all of my comments and thank you again very much for the opportunity well thank you mr. Hoffman and i do appreciate your acknowledging the opportunity we're providing here to engage members of the public that's an important part of being open and transparent in our processes uh just comment on the emergency planning zone or e pz size there have as you i'm sure you're aware there have been extensive engagement with the nrc about the need to revisit the size of the e pz there've been a number of studies that have been published that would that would indicate that the current 10-mile emergency planning zone is sufficient to ensure that the protective action decisions that would be implemented would result in uh protections for the public again the premise with emergency planning is that's the last defense in depth measure there that the design of the facilities and how those facilities are operated or such that you would not uh it would be extremely unlikely that you would see a radiological release release of a magnitude that would require uh protective action decisions such as sheltering in place or evacuation uh we have as an agency indicated very clearly that if there is new information that indicates the size of the e pz is not adequate we will revisit that most recently being a fukushima accident and and we've acknowledged if there are studies or that would indicate that uh uh the current e pz size is inappropriate we will look at that new information and uh and make decisions accordingly the sampling let me move on to our inspection program yes it is a sampling program and and that that clearly we do not have the resources to do a hundred percent uh inspection of all activities uh you know we we conduct a sampling inspection and then we draw conclusions based on the results of those inspection activities you know our our our focus is trust but verify with independent verification through our inspection program and and and when we do miss something we look at why and does the inspection guidance need to be enhanced as the scope of the inspection need to be expanded and there are a number of instances throughout our regulatory history here where we have made changes to our inspection program uh uh regarding unannounced inspections i personally am not convinced that an unannounced inspection will provide you any more information you know if we're looking at a particular program uh the fact that we announced that we are planning to look at that i don't think results in any different uh uh insights than if we were to communicate we're conducting an unannounced inspection um and there are a very selected number of areas where we do have unannounced inspections uh and an example of that can be radiographers or materials licensees where we have determined that the unannounced inspection is appropriate uh but i do appreciate your comments and uh thank you thank you thank you our next question comes from don lightning from citizens oversight your line is open hi uh thanks for taking my call a couple uh two or three uh items i'd like to bring up first of all the slides are very hard to to look at on on the computer so i think a really easy thing to do would be provide a a web link for each slide and therefore when people are looking at the slide they could also open up a window with a pdf or something of that slide and be able to zoom in or do whatever they want that would make it much easier to actually see what's going on uh secondly um i'm concerned with the tsunami problems that california may may face we all know that uh you know they're one in a thousand or one in a ten thousand year event but as fuji shima proved three meltdowns occurred you know within a week so what we have to deal with in california and other places in the u.s is if nature goes crazy and we have gigantic tsunamis coupled with gigantic earthquakes then what is the plan if uh you know the shit hits the fan i'm not trying to be cute but i think that's a at metaphor when things that people never predicted in size and mass just crush um our facilities are located near the ocean and uh well i got two other things i'll go over them real quick one on the surprise inspections i think it should be appropriate for the nrc when they do these inspections to have the inspectors be from outside whichever nrc region normally uh inspects that plan we saw with santa nofri that there was there was a cozy relationship between region four and the people that worked at the plan and that definitely worked against us when we got our replacement steam project and the other thing i think that needs to be said is that the licensees and the nrc needs to publish how much nuclear waste they're stored at each facility both in pools and in dry gas because as those numbers get bigger and bigger then i think there should be different levels of scrutiny and different um sort of conferences of protection because it becomes an ever bigger potential problem so thank you for taking my question well i certainly appreciate your comments um let me attempt to address the the three comments you provided regarding the tsunami hazard we clearly uh as a result of the fukushima lessons learned the near term task force that delivered a number of recommendations to the commission and then follow on review by the nrc staff there are specific actions or requirements that we have put in place for the industry to address potential hazards from tsunamis or earthquakes there's flooding reanalysis that we're requiring seismic reanalysis that we are requiring mitigating strategies to ensure that utility can address a prolonged loss of offsite power coupled with a significant external event such as an earthquake or a tsunami so i do think we clearly have as a result of the fukushima lessons learned a number of our various requirements and actions that we have put in place to ensure that the facilities can address those potential hazards i can't speak to the specific example you gave regarding a cozy relationship between the nrc inspectors at san anofri you made reference to the steam project quote unquote i do think that the inspection staff that we have at the sites are very professional in objective and do conduct their inspection function in an appropriate manner there we do have measures in place to ensure that those inspectors at the sites maintain their objectivity with supervisory visits opportunities for those inspectors to go to other sites and benchmark practices but and we have a requirement in place for any member of the resident staff they have to mandatory rotation at the end of seven years and that's part of the overarching measure we put in place to ensure objectivity you are correct about waste does continue to accumulate edda facility whether it be fuel spent fuel stored in the spent fuel excuse me the spent fuel uh spent fuel pool excuse me or a dry cast storage i i am a strong proponent for the administration and congress with a reaching closure on what will be the permanent solution for high-level waste whether it be a geological repository or some other means but that is a matter of you know of administration policy as supported by congress but in the meantime until such a solution is identified and put into place our role is to ensure the fuel that is stored on site here in the interim is done so in a safe manner and i would offer dry cast storage and wet storage our safe means of storing that fuel until we decide what we will do as a national strategy there with our policy and decision makers that we have elected to our government okay one real quick following question if i may about the fuel storage dry cast it's been shown that the high burn up fuel which many reactors are using now has not been proven safe in dry cast storage for any real length of time and the nrc i know is doing testing and working on that but for people to buy dry cast storage with the expectation that it's going to last 50 or 100 years and perhaps is a huge and i think the nrc needs to do a lot more about not only speeding up the testing on high burn up fuel and how long you last in dry cast but also any kind of major approval until they get that testing done because otherwise they're guessing and that's not a good thing to do well thank you for that i i am highly confident that our office of spent fuel storage and transportation or office of nuclear material safety and safeguards is looking very carefully and thoroughly at the capability for dry cast storage designed from the various vendors whether they can that can support storage of high density or high burn up fuel for a period of time we would not license particular design without the assurance that the storage of that fuel would be done safely and as you've indicated there is testing associated with that and i certainly would expect us to have a clear understanding of the testing results before we would go forward with any licensing decision but i do know the storage of high burn up fuel is something that we are looking at and evaluating and ensuring that before we would authorize any storage of fuel at a facility in uh meaning high burn up fuel in a cast that those casts can accommodate that fuel in a safe manner well just to let you know they're they're starting the approval process at san anofre for high burn up fuel so they each commissioned it and they're looking at some some cast that have not proven they can understand it so you might uh check that out when you have some spare time no thank you for that and i just would offer again we are not going to license use of that cast without uh complete confidence that the fuel the licensee intends to store in that cast can be done safely this is mark here appreciate that and uh would you be interested in sharing your email address in case we'd like to send you uh specifically some comments that's fine now we'll provide you an email address here uh at the conclusion of our public question and answer period so you can forward any comments that you have thank you this is uh mark here with the nrc and i'd like to add a couple of comments before we move to the next caller there were a couple of callers have now commented on their desire for uh nrc to exercise more surprise inspections and i would just add that we do have resident inspectors on site at every facility who have unfettered access to the entire facility at any time day or night seven days a week and they do conduct surprise inspections they show up unannounced at all kinds of activities that are going on a facility looking in on race activities and so to that degree we we do conduct regular uh surprise inspections and i also like to add a response to the previous caller mr hoffman made a quick comment that uh would like to address and he made the comment that he got the impression that our significance determination was related to how many people might potentially be exposed and indicated that we might be sacrificing uh the safety of some people because there were a low population zone only a few boaters and that sort of thing and i would just like to respond to that directly and say that the rc uh does not base its significance determination on the number of people who are exposed our significance determination has to do with the compliance and the safety significance of the non-compliance as as i described and so that that is not impacted by the number of people who might be impacted by the non-compliance and and i would add that some comments were made earlier in the conference to the effect that major drills and exercises tend to focus on the more risk significant higher population zones and i would add that that typically has to do with getting the maximum amount of exercise value because of the number of organizations that are involved in the exercise there are fewer organizations involved in low population areas than there are in in large population areas so the focus of exercises that are evaluated typically are addressing getting the maximum value training value for all the organizations that could be impacted that's not a statement of of whether high population or low population zones are significant the nrc's significance determination is not affected by the number of people that are impacted i just wanted to add those two comments we're ready for the next caller thank you we do have one additional question after i introduced this person our next question comes from ray lutz from citizen oversight your line is open okay yeah i just uh wanted to uh get closure on a couple things i did i was able to download the pdf and by using you know a direct access to that versus going through the browser it did show up i wanted to mention that my request for a local and in-person meeting did not mean that i didn't expect also that it be used a teleconference would not be available in that case i believe that teleconference should still be available as well as a webcast even if you hold the meeting within a convenient area for the public access and i'd like to underline the point that the public there's other things that happen at these meetings that the public makes use of other than the the official business portion of the meeting there's a lot of interaction with different members of the public that are coordinating their activities of the various maybe unofficial responses that groups that are planning to make plans in the event of emergency all those things happen and on an unofficial level and so i don't think that you can discount the value of an in-person meeting for something like emergency planning regardless of whether this is customary for the nrc there was a comment made by the nrc official saying well it's not what we do it's not our customs we just don't do it that way and so therefore we're going to continue not doing it that way i beg to differ this needs to change you guys need to have these meetings in the area the emergency planning meetings regardless of what kind it is whether you're doing a so-called regulatory type of meeting like you are right here or something that's that's uh you know intended to be specifically outreach to the public those things should be in that area and so that that tradition that you have of holding this meeting in texas should change now finally i had one more thing i mentioned that there was the question about the 50 mile ingestion exposure pathway emergency planning zone that is an emergency planning zone and i believe that it should be included on these various maps that you have here it's not i don't see an ingestion emergency planning zone included you asserted in your response to me that it is part of your plan but then why isn't it on the map so i i would like to request that you include that on the map um so that people can see that that's part of the plan if it is um since i can now see the map okay thank you very much for letting me follow up on those things thank you mr let's uh this is mark bomb i'm not sure i'm aware of what you're referring to when you say the map uh is this i'm looking at page six page six of your handouts you have an emergency entitled emergency planning zone there's a map with the various levels whether it be six mile ten mile state extended but there is no ingestion pathways zone shown yeah thank you understand what i'm speaking about i do now thank you and i'd highlight that that was a slide that was provided by the licensee as part of their presentation today uh so they did not obviously include an indication of the 50 mile gestion pathway epz it would offer that that would be a 50 mile radius there from the location of diablo canyon but but that was not a product that we provided but i do now understand your point thank you i couldn't agree more with you regarding your comment that if we are engaging in public outreach we need to do that in the vicinity of the plant that absolutely and i do appreciate your views on uh uh why this meeting should have been conducted in the vicinity of uh of diablo canyon you know it does underscore mr let's uh your clear interest in activities at the site in our regulatory uh role here and uh you do want an opportunity to engage us in that regard and i do appreciate the importance of the emergency preparedness function we are going to provide members of the public located at the plant with an opportunity to engage us we do have some planned public meetings i i would like uh wane walker here who is the branch chief with oversight responsibility of the in the inspection program at the oblo can and to just comment on the public meetings that we have planned coming up uh yeah mr let's we're planning uh it'll probably be in the april time frame this year we would be out there and our current plans are to have some type of like a workshop which should allow the public to ask a really a number of questions regarding um even some of the issues that have come up today about the licensing basis verification project about the recent seismic studies that have been um conducted by the licensee and our ongoing and some of the reviews that we've done recently and then of course i'm sure you're aware of the 5054 f response that's due in march of this year we'll also be able to discuss some of that that will be provided at that time and and also we'll try and our current planning anyway as we probably have our in the cycle meeting at that time also which would be our assessment of the licensee's performance for this last year so those are a couple opportunities that should be coming up here in april and we're in the planning stages for that so just to let you make you aware of that okay just really quick are you guys coordinating with the independent safety uh committee that's in place at san anofre on these issues i guess um coordination i would say i don't know if you call it coordination we're aware of the meetings and we have attended some of the meetings chris smith an inspector here in the uh region has gone to several of those meetings and also tom hipschman who's the senior resident inspector at uh dabba canyon he's he's been actively in communication with the issues that come up at those meetings well i mean are they reviewing i mean this is something that they're they're supposed to be independent safety this is a safety issue and they're supposed to be giving independent review are they being provided the opportunity to provide independent review of this issue that you're talking about today this is state organization yeah yeah i'm not aware that they're reviewing this issue that we're talking about yeah thanks uh the licensee mr allen has indicated he can uh will comment but i thought that independent organization uh is a state uh entity as i understand it yeah the dabba canyon independent safety commission uh was chartered by the state of california uh has composed of three members of a very excellent background uh they they uh have a typically a monthly visit to the station i think a quarterly public meeting typically in in abba there for the public uh they're completely independent they look at whatever they want to they do have a a bit of a program laid out so they get a chance to on some period is to go through and look at you know most of the major topic areas they also review our everything in our corrective action program so they can they can choose issues such as this one to take a look at and typically ask us to provide presentations yeah thank you for that mr allen i would offer to that this group is on our distribution list for our inspection reports and and should be aware of the results of our inspection activities and as mr walker said uh you know um they would be aware that we are conducting a public meeting in the vicinity and are welcome to come and attend and ask any questions that they may have uh but we don't coordinate quote unquote if you will uh our evaluations of the as an example the emergency preparedness function with any uh a review that they might conduct since they are an independent state uh sponsored uh entity well if you're ever shorthanded and you don't have enough manpower to review stuff maybe you you might consider coordinating versus just blowing them up okay thank you very much for my for my questions thank you our next question comes from donna gilmore and this is our last question miss gilmore your line is open okay thank you please say where you're calling with uh stand over safety i'm in california uh can you hear me okay uh yes we can okay great um in january um i notice you mentioned about the the cast safety so that makes me think you may have a different emergency plan for that um in january 2014 every uh inspected uh a couple of diablo canyon canisters were not really unexpected they just checked for some surface particles found my magnesium chloride found the temperature on the canisters low enough uh that there is the potential for uh chlorine stress corrosion cracking at the canisters at diablo canyon now uh given that surprising information does that potentially trigger any kind of change in your emergency planning procedures and you know because you know since you've got other issues with their plan is this one that may need to be looked at we're not aware of uh any uh degradation to the dry cast storage canisters there uh and if there were a degradation that is certainly a matter that i would expect the licensee to communicate to that but let me ask uh mr allen if he has any comments uh regarding that just just two comments uh the uh the every study is really looking at long term degradation that's not short term near term there is no current degradation our operators do inspect that on rounds daily and have criteria to inspect and look for you know goods uh robust canisters and that's it um this is donna gillmore again uh i'm sorry go ahead and finish i didn't mean to interrupt you no i think uh mr allen it concluded his comments please go ahead mr allen all right well maybe then mr allen is not aware although there is no technology to inspect the half inch thick stainless steel canisters it does not exist in and the nrc uh spenfield management division is planning to give um tg&e and others five years to try and come up with a way to inspect even the surface for corrosion and and for cracks so the the problem is the canister must stay inside the concrete overpack cast so the so it's challenging to inspect it there are no current tools that will work in that environment so i'm a little concerned that you have this optimism when the reality is those employees couldn't check that even if they wanted to well i'm i'm not aware of the specific inspection challenges that you've indicated what i can do is uh have our office of spent fuel storage and transportation reach out to you directly to answer any questions that you may have i i just apologize that i don't have i don't have a question for them i already had the answers i've i've participated in in their technical meetings in july and august i communicate with mark lumbard and his staff so i think it's more a matter of maybe it would be good for people involved in emergency planning and definitely people at pg&e people to be aware of this if you want i can educate you on the on these issues but here you know i already have the information um i have the department of energy so i have every presentations i have a department of energy making presentations about their finding the findings on the canisters um and you know and my head you want to just take a look at the off august fifth the meeting minutes of that technical presentation you will see it's right in there that they're giving them five years to try and come up with a way to inspect the exterior of these canisters so i'm you know i don't think i'm the one that needs educating here and very concerned that that is anybody in this room i can't see you obviously is there anybody in this room that is aware of this issue well i'll offer you certainly if you've been engaging uh mark lumbard that's the right person here uh but i think uh yes but in terms of emergency response and i noticed that humble bay in december uh was approved to eliminate all off-site emergency planning because everything is in dry cast now with the assumption that nothing is going to go wrong um if you if the if your group is the one that's approving those things i'm concerned that maybe you're not aware of these um of these these relatively new findings about this and what and who who is the right person to talk about that part uh this is bob kaylor your group emergencies yes this is bob kaylor from nrc headquarters with emergency preparedness oversight um with regard to the dry cast storage and emergency preparedness the dry cast storage uh casks themselves there are emergency action levels in which classifications would be made upon their failure regardless of whatever the trigger would be for the uh for the release of any radio activity would come out of the dry cast with regard to humble bay um uh even though as as you had stated the off-site preparedness radiological emergency preparedness was no longer a requirement there's still on-site emergency preparedness requirements for those dry cast in which there would be classifications made upon their failure so emergency preparedness does indeed address issues associated with um dry cask and their um any events that would uh that would happen with them is there some kind of a document about that that i can read that's available that you're using to make your decisions on that would do deal with the cancers well it would be within um the classification system specific to the site there is generic classification schemes that you can uh you can find and their nuclear energy institute documents one in particular would be a 99.01 revision six 99-01 revision six would include emergency action levels for ISFICI as we call them the dry cast storage facilities what what i think i hear you're saying miss gilmore is that uh there are you would offer a degradation mechanism that has been documented by epri that uh we uh don't have a means right now of inspecting to determine whether that degradation is in fact occurring and i certainly uh do defer to you and your discussions with mr lumbard about that i'm i'm not aware of of that particular issue i can just offer that if the program office uh that is involved in reviewing dry cast storage designs identifies a degradation mechanism that could result in some type of release from the canister that would be communicated clearly to the regional offices and we would be conducting appropriate inspection and the licensee would be required to address that what mr caler said is right now the emergency action scheme is based on some presumed uh you know uh what would be the radiological footprint that would occur if there was known degradation of a cask and then those emergency action levels are a function of the degree of uh uh radiological impact that would result uh to ensure that actions are taken to protect members of the public uh well i'm i'm i'm i'm really shocked at the the level of disconnect between the different groups here maybe maybe there's some way we could you know have a meeting with uh with the emergency planning folks and the um the the the dry cast folks who spent two management folks and and some of the public and and kind of all get on the same page with us and utility companies of course because um i mean if this information isn't isn't coming out how could your emergency plans possibly deal with this so i see a major disconnect that that needs to be addressed with something that we can maybe uh um have a follow-up on on this issue well i don't you know what's happened at humble bay is uh because of the level of confidence that the emergency planners have that nothing's going to go wrong with those canisters and they're also located you know right at the beach um with uh you know you know same kind of you know pacific ocean faults there um and those canisters are even much cooler so they're more likely to have crack initiation because the humidity and and yet um yeah you've removed they don't do they even have to notify the local and state officials i noticed that you remove the requirement for how many minutes they have to notify the the local and state community is that was taken out is that do they have to notify them at all i don't know the the answer to that specific question but i can tell you in the case of santa no free in the case of humble bay in the case of any other decommissioning reactor that if there is a desire to change the emergency plan that is reviewed and approved by the nrc via the exemption process so when the fuel has been transferred to dry casks we look at you know what is the probability that there could be are the potential for there to be an accident at the cast that would result in some radiological release and then the emergency plan needs to be appropriate to ensure the protective actions that are provided in that circumstance i think what you've communicated is that there is a technical issue that is being evaluated regarding the potential degradation of the casks and what i was communicating is there has not been anything that has been communicated to us from mr lumbard's group that would say that the casks have this potential degradation mechanism that would result in some radiological release that previously hasn't been analyzed such that the emergency plan is deficient there has not been any communication regarding that and it sounds like the program office of nuclear material safety and safeguards where mr lumbard works they are an ongoing evaluation of that issue but there certainly hasn't been any safety concern communicated that would translate to the need for a different emergency plan so in terms of the humble bay um who i mean who's like the person at the nrc that that would be like the top person that deals with that issue so if they're if based on new information you needed to re-evaluate that who's the decision maker on that issue at the nrc well there's not there is an office that has responsibility for the spent fuel storage and transportation program that's the office of that very title emergency but i'm asking for the emergency plan in the one that approved um humble bay from not having to notify anybody outside the plant if something goes wrong that's the same that's the same office with input from the office of nuclear securing an incident response but it would be nmss is the office that would would evaluate the adequacy of the decommission excuse me the emergency plan associated with what a decommission facility so that so that's mark lumbard then he is a senior manager yes he is a senior manager i believe he is the director of that particular group yes oh okay all right so you go to him for that assessment then or or or he's a his group is the one that basically gave hold on both the exception i'm a little confused licensees submit an exemption request to the nrc and there is a program office that would have responsibility in that area which is the office of nuclear material safety and safeguards that would review that exemption request to determine whether there is any safety concern with nrc approval of that so there is a program office at headquarters that would be responsible for that the office director is kathy haney and the mark lumbard is a direct report to kathy haney who has specific responsibility for spent fuel storage okay all right so i'll have to leave back to mark it sounds like yes and it sounds like is that called a single point of failure i'm sorry i'm making a bad joke there did you have any other questions or comments uh yes if one of those canisters at diablo now now that that i'm aware that the odds are higher um at diablo we don't know about the others because they haven't been checked for faults or anything um what i'm more concerned what is the plan of that that canister was to crack dr sing the president of holtec said those canisters can't be repaired and he owns the you know he's the president of the company and he said that if there was a crack a through wall crack and that happens container it would release millions of curie of a radio radiation into the environment so my question is what is a pg and he's plan if that were to happen well i think you've cited some particular conclusion that has been drawn by an individual here uh you know without uh understanding uh the specific basis for that conclusion we're not in a position to render any value judgment regarding the veracity of that conclusion uh okay that's that's fine but but if there is a crack in the canister what is the emergency plan what is pg and he's plan to deal with the failed canister that's cracked all the way through that they would have to have some kind of plan right they do have an emergency plan that would address a situation and what would that and what would that be for a crack canister this is bob caler again um the emergency preparedness and even with regard to the drycast storage itself uh does not uh go to the to the point of determining what the impetus is for the release of radioactivity it deals with the with the outcomes such that we have done studies to to determine what that radioactive footprint would be and we have determined that that emergency action level i was talking about which would uh render a classification no higher than an alert would not release radioactivity that would have any impact upon public health and safety outside of the uh plant site itself so but the emergency preparedness plan would respond to that classification level as well as some offsite agencies uh with with with regard to the alert classification regardless of the initiating event uh what caused that cask to fail and that's what i was trying to say before we don't we don't go to what's the cause of the cracking of the cask or the release the radioactivity from the cask but what could be the plausible radioactive footprint from it and it would be a classification level of no higher than alert so the emergency plan does address is that is that in some kind of document that's available that we could have what it it's just it is it is part of the emergency preparedness plan for response to the classification level of an alert so anything that you would see i mean in terms in terms of determining that classification level for the the pgne canisters where is that documented that would be specific to the plant site and it would be up to the plant site to provide it or not but you guys don't look at that but the generic but the generic classification uh scheme that it would be based upon is the document i had previously stated which was that nuclear energy institute nei 99-01 revision six which is available on our public website okay okay yeah miss gilmore you may thank you you made a comment that we don't look at that yes we do look at that we look at the emergency plan associated with any decommissioned facility or any operating facility i do appreciate the extensive dialogue we've had with you it was my understanding from the operator that that was the last question i i did want to make sure that mr hoffman he had asked for an email for further communications and mr hoffman are you still on mr hoffman if you like your line to be open press star one well we'll attempt to reach out to mr hoffman and get him the email address so that he could forward any comments operator do we have any other questions from members of the public i do see um a question coming through just a moment here oh we have a couple actually um ace hoffman i'll go ahead and open up your line your line is open sir yeah thank you yes i only wanted to say that i think that was Ray Lutz that asked for the email address i'm sorry mr hoffman my apology sir no problem okay and we do have a couple more questions did you want to take those yeah we'll take questions here for about another 12 minutes here we had advertised the original length of this regulatory conference including the question and answer period from one to four central and we're now approaching 5 30 and i certainly want to be responsive to questions for members of the public but we'll take questions for another 12 minutes okay our next question comes from don lightning from citizens oversight your line is open hi thank you i was the one that asked for the email address not ray lutz but we both work we both support citizens oversight so i'd be happy to hear the email address and i was really excited to hear that donna gilmore got on the phone because she is an expert in cat storage although she doesn't work for the nrc and you folks would be well advised to try to interact with her because she knows what she's talking about thank you thank you let me give you the email address it's a o is an oscar p is in paul a is an apple 4 dot resource at nrc dot gov very much i got it operated the week sorry do we have another question yes it comes from patricia borschman your line is open thank you thank you i really appreciate this opportunity and i appreciate uh the priest the telephone conference call and opportunity for public participation so far it's been i'm it's been impressive so um i'm i'm happy to participate i'm i live in southern california i live in san diego county i wanted to just bring up the point that um there's activities underway that are being expedited by uh and accelerated uh by southern california edison who's the licensee at seven oh three so they are um undertaking a decommissioning plan they've already processed and prepared their ps dar their radiative fuel management plan et cetera and they'll update cost estimate uh citizens in southern california are very concerned about public safety because um many analysts independent analysts believe that the type of cast design that they're proposing here is only an interim uh cast design and and an inferior compared to other cast designs uh that provide more durability longer lifetimes and more protective features um the public is interested in um asking the nrc to take a position to represent us and in in the manner that would give us greater assurance of public public safety ongoing public safety so um in the nipa in the federal environmental quality act there's requirements that um certain levels of mitigation be provided in uh in this case i think it would be appropriate for nrc to uh formally endorse a level of protection is the best the best available control technology for cast designs i think that typically um agencies have different level choices and edison i think is choosing a cheaper uh less expensive uh alternative and i understand their interest um and you know doing this as quickly as possible and i understand there's a lot of uh differing opinions you know so some people wanted to go faster some some uh communities want it to slow down better um i'm interested in having it slow down because i think this is going to be a huge investment that is just they're just going to have to buy it twice um and i'm since we're aware that there's better cast designs available with features that can allow storage stored waste to be transferred um from wet wet storage to dry storage there's a lot of um technical components and complexities here um anyway the current plan that edison is expediting and uh it's just going too fast and they're going to be uh getting approval real quickly and i think that someone in our scene needs to uh gear up and become more involved at this point before before it's finalized well i want to thank you for your comments uh in death you know i know this was a regulatory conference uh in connection with the oblo canyon and protective action recommendations over the ocean and i think we've done our best to address a broad spectrum of questions that are not just specific to that aspect and i certainly would like to comment on your question specific to santa nofri and i know that the licensee is looking at what is the particular cask vendor that they choose to use i think they've even announced that we look at that and have to license that for approval there i don't know if that is a cask design that we have already reviewed and approved but the licensee will not be able to use any cask design that has not been reviewed and approved in a safety context by the nrc that's a requirement so there are there are different cask vendors that um um you know and the cost of the cask may be clearly different depending on the vendor that you choose but any vendor that is chosen by the licensee has to use a cask that has been reviewed and approved by the nrc i understand um it's a timing issue the nrc's level of review is um that level of site specific level of review won't apply until after until the permits for decommissioning at santa nofri has already approved what we're saying is we need that site specific level of review at the front end we don't need it at the back end you know so this prolonged storage issue at santa nofri i know last august um nuclear regulatory commission authorized prolonged indefinitely prolonged onsite storage waste in dry cask storage and transfer fuel there's pending issues here that are just enormous and uh they haven't been fully resolved and i think edison is painting a picture that's overly optimistic about the levels of uh their their capabilities so their their extent of experience um there's there's just so many uncertainties been uh involved here and so many important choices and edison has brought this to the public after it's already been cooked you know like 75 done and so the public has not been involved at the front end so that's what is partially what people are concerned about you know they've already told you know what type of container they've already made those choices and those should have been part of the public participation process i think no i i i appreciate your comment there uh i do know of the community engagement panel that uh southern california edison has uh initiated and their various individuals that are are representing local stakeholder interests on that engagement panel but what i would offer here because i can't speak to the specific site review that you're commenting on i just don't have the expertise here uh in the room to address that question and so i was going to offer if uh and i can repeat it if you could send your question or comment to this email address i'll make sure that we get the right folks from our program office back in touch with you to address your concerns with the site specific review because because i'm not aware of what you're referring to and i apologize for that thank you so much do you need the email address or did you get that when i commented regarding um i can get it from any of the colleagues i can get it from donnie gilmore so you'll need to repeat it i'll give it okay well thank you um operator do we have any uh other questions from members of the public i am showing no other questions okay well i want to thank those members of the public and government officials that are still on the phone that uh participated and uh provided your questions uh thank you i i do think that that exchange was done in a very professional manner and i know that we people have different views and perspectives and i uh respect those views and appreciate the manner in which those were offered and the questions and comments that were provided by the individuals that participated so uh thank you and operator with that uh we're concluding the question and answer period thank you thank you for your participation in today's conference you may now disconnect at this time have a wonderful day