The current provisions for emergency planning for the Diablo Canyon Power Plant (DCPP) include, but are not limited to, on-site security personnel and facilities, on and off-site monitoring equipment, the County Emergency Operations Center, and an early warning siren system. The DCDEP recognizes that the decommissioning of the DCPP will create the need for changing the existing emergency plans for the DCPP and the community. As the risks related to the radioactive material changes, the Emergency Response Plan also changes. Throughout the decommissioning process, plant security controls remain in place. All the key security features including intrusion detection, response, assessment of alarms and when necessary, off-site assistance, remain in effect. The “security footprint” changes as the spent fuel is moved from the reactor to the spent fuel pool to dry cask storage as the primary purpose of the security is to protect the fuel. In addition, although the NRC involvement may change throughout decommissioning, as described below, the Federal Emergency Management Agency (FEMA) continues to require coordination between local, state and federal agencies relative to emergency planning.
The decommissioning process with the NRC requires two certifications from DCPP. The first is a letter to the NRC stating that operations have permanently ceased. The second is a letter stating that the reactor has been permanently defueled. The plant is officially in decommissioning with these two certifications. The next key item that is submitted to the NRC is the post-shutdown decommissioning activities report (PSDAR). The PSDAR must be submitted prior to the plant shutting down or within two years after its shutdown. The PSDAR contains a description of, and a high level schedule for, the planned decommissioning activities and allows the NRC to outline the needed resources to inspect during decommissioning. The PSDAR is noticed in the federal register and public comments are requested. A meeting in the vicinity of the site is held in order to receive public comments. The comments are considered by the NRC in their review of the PSDAR. Decommissioning cannot begin until the PSDAR is approved by the NRC. There are also local land use permitting approvals and CPUC requirements that must occur before decommissioning can begin.
The PSDAR also looks at the needed changes for emergency response. The NRC employs a graded approach to emergency planning (see Figure 5 – NRC Decommissioning Emergency Planning Levels). Level one occurs when the plant permanently ceases operations and all the fuel has been moved to the spent fuel pool. During level two, the spent fuel is being moved to the dry cask storage from the pool. The third level occurs when all the fuel is in dry storage and under its own emergency plan. The fourth level is reached when there is no need for emergency planning because the plant is gone and the fuel is gone.
The post-shutdown emergency plan (PSEP) begins after the two certifications have been docketed by the NRC. The PSEP is a transition period and covers approximately 16 months, which is about the time it takes for the spent fuel in the pools to cool or radioactively decay to a point where it is no longer generating enough heat to cause a zirconium fire, which could lead to off-site release of radioactive material that would reach the Environmental Protection Agency’s (EPA) protective action guidelines. During the PSEP, information is provided annually to the public regarding DCPP’s future status and required emergency drills still occur.
Approximately 3 to 5 years later, the permanently defueled emergency plan (PDEP) is in effect. It will allow the DCPP to combine the technical support center, the operation support center and the emergency operations facility into one on-site organization. Drills occur every two years and an off-site radiological emergency response plan is no longer required.
Once all spent fuel has been moved to the dry cask storage, emergency planning consists of the Independent Spent Fuel Storage Installation (ISFSI) Only Emergency Plan (IOEP). At this point, the dry cask storage has its own stand-alone emergency plan and the rest of DCPP is subject to a “hazards only” plan that contains emergency planning for fire protection, personal injury and contaminated personal injury.
Once the fuel is removed from the site, there’s no longer any NRC involvement and no emergency planning is required by the NRC.
Vision, Goals and Recommendations
Through these vision statements, goals and recommendations, it is the intent of the DCDEP to make emergency preparedness a primary consideration throughout the decommissioning process and to assure that the outstanding existing emergency planning readiness continues to be active and fully funded until there is no longer a potential threat to citizens and visitors.
- The highest levels of protection of the plant, the workers, and the public should be maintained both before plant closure and during decommissioning (including spent waste removal and management)
- The community should continue to be informed regarding emergency planning and the safety of the plant throughout the decommissioning process
- The future use of the Diablo Canyon Lands and any repurposed or retained facilities should ensure the continued safety of employees, residents and visitors, including emergency and evacuation planning and be consistent with reasonable and safe levels of traffic through neighboring communities, including Avila Beach and Los Osos
- The NRC should ensure the full oversight of the decommissioning process, with the primary concern being the safety of the DCPP, workers, residents of neighboring communities and visitors to the area
- PG&E should assure the retention of qualified, experienced personnel to maintain emergency preparedness
- The CPUC and PG&E should ensure that adequate funding is available to plan, execute, oversee, and communicate a rigorous safety and emergency planning program during the full decommissioning process, until the plant site is fully cleared of all waste, facilities, and other structures that are not suitable for repurposing
- The CPUC and PG&E should ensure that adequate funding is available to fully fund and/or reimburse the County of San Luis Obispo and other relevant agencies for all emergency planning and safety activities associated with the decommissioning of the DCPP
Emergency and Communications Plan
- The completion of a broad-based, fully integrated safety and emergency plan for the complete decommissioning process should be coordinated by PG&E and the CPUC and should include the County of San Luis Obispo, neighboring communities, and relevant regulatory decommissioning agencies
- The workers, residents of neighboring communities and visitors should be kept continually apprised of issues concerning safety of the DCPP and environment through a strong, extensive and broad based communications program provided through PG&E
- The future use of the Diablo Canyon Lands and any repurposed or retained facilities should include disaster planning for emergencies, including evacuation
Demolished Materials (contaminated and non-contaminated)
- The transfer of contaminated and non-contaminated demolition waste materials should be completed with the highest levels of safety for workers, residents and visitors
- The transport of demolition waste materials should be overseen by CPUC and completed by PG&E using best practices and best technologies, so as to reduce the impact to local communities in terms of traffic, noise, dust, and other factors
- The exploration of alternative means of transport of demolition waste materials, such as by sea, should be explored and used to the extent the methods are determined to be safe, cost effective and support the safety of nearby residents and visitors
- Recommend that the CPUC and PG&E ensure that adequate funding is available to plan, execute, oversee, and communicate a rigorous safety and emergency planning program until such time as the plant site is fully cleared of all waste, facilities, and other structures that are not suitable for repurposing
- Recommend to the CPUC that PG&E, the County of San Luis Obispo, neighboring communities, and relevant regulatory decommissioning agencies receive adequate funding to enable a coordinated, broad-based, fully integrated safety and emergency plan for the complete decommissioning process
- Recommend that the CPUC and PG&E ensure that adequate funding is available to fully fund and/or reimburse the County of San Luis Obispo for all emergency planning and safety activities associated with the decommissioning of the DCPP
- Recommend that the CPUC and PG&E ensure that adequate funding is available for continued protection and security of the dry cask storage system until such time as it is removed from the site
- Recommend that the CPUC ensure that funding is available to provide 24-hour real time monitoring of radiation levels at each dry cask as long as spent waste remains on site
- Recommend to the CPUC that PG&E be provided the funding to at a minimum maintain the early warning siren system until all spent fuel is moved into a robust dry cask storage system and potentially until the spent fuel is removed from the site
Emergency and Communications Plan
- Recommend that a broad-based, fully integrated safety and emergency plan for the entire decommissioning process be completed by PG&E which includes coordination with the CPUC, the County of San Luis Obispo, neighboring communities, and relevant regulatory decommissioning agencies
- Recommend that a robust communications program be provided by PG&E, including the preparation and completion of the PSDAR and the PSEP, to keep the workers, residents of neighboring communities and visitors continually apprised of issues concerning safety of the DCPP and environment
- Recommend that CPUC and PG&E prepare emergency plans that include disaster planning, potential evacuation procedures and emergency measures for the future use of the Diablo Canyon Lands and any repurposed or retained facilities
Demolished Materials (contaminated and non-contaminated)
- Recommend that the CPUC require that PG&E evaluate the safety and cost effectiveness of various demolition waste material transport alternatives, including by road, rail and sea
- Recommend that the CPUC and other regulatory agencies ensure that transportation of demolition waste material by road/truck be completed consistent with the safety and well-being of neighboring communities, taking into consideration dates and times to avoid peak traffic and to reduce the burden of noise and dust
- Recommend that emergency plans be prepared to address potential issues arising from vehicle accidents during the transport of demolition waste material