Emergency Plan License Basis

CMCG assisted Pacific Gas & Electric (PG&E) Diablo Canyon Power Plant (DCPP) Strategic Projects and Emergency Preparedness departments to establish a baseline comparison between the regulatory requirements in the NRC SER approved DCPP Emergency Plan (E-Plan) and the currently implemented/used E-Plan.

The purpose of the comparison was to identify changes of intent, evaluate those changes with regards to compliance and reduction in effectiveness against today’s standards. The comparison will also identify any gaps in the historical change evaluations.

In addition, a library of historical changes made since the original NRC approval of the E-Plan and their evaluations has been collected and organized to provide tools to assist in future 10 CFR 50.54(q) evaluations performed using the methodology of Regulatory Guide 1.219.

Emergency Planning

CMCG is currently assisting the PG&E Diablo Canyon Power Plant (DCPP) with implementation of tasks to incorporate the new NRC Emergency Preparedness Rulemaking into the DCPP Emergency Preparedness Program. CMCG assured the implementation actions reflected the latest industry guidance to provide a cohesive foundation for the implementation of the DCPP emergency program. Specifically, CMCG is working with the DCPP project team to implement the tasks identified in the DCPP-specific Emergency Preparedness Rulemaking Project Plan for implementation of the new NRC emergency preparedness regulations. In addition, CMCG also provided assistance to Constellation Energy fleet with implementing the new rulemaking into their existing programs.

Gap Assessment

CMCG supported PG&E Diablo Canyon Power Plant (DCPP), SCE San Onofre Nuclear Generating Station (SONGS), South Texas Project (STP), and other USA/STARS member utilities Emergency Preparedness Department – as well as various non-member utilities – in reviewing and analyzing the new NRC Emergency Preparedness Rulemaking impact on the their Emergency Preparedness Programs. Specifically, CMCG worked with the utilities project teams to review the existing sites’ emergency preparedness programs and processes to determine differences as they relate to the eleven new rulemaking areas and additional guidance documents related to the new rule. The CMCG team then proceeded with determining the impact of each of these vulnerabilities and developed recommended actions to bring the EP programs into compliance with the new rule.

NEI 12-01 Staffing Study

CMCG is supporting the PG&E Diablo Canyon Power Plant (DCPP), South Texas Project (STP), FirstEnergy Operating Company (FENOC) fleet, and Southern California Edison (SCE) response to the NRC’s Requested Actions and Requested Information associated with Recommendation 9.3 for Emergency Preparedness (EP) programs.

Emergency Plan and Procedure Development

Emergency Response Planning involves the identification of numerous activities that must be taken to prevent, prepare for, respond to and recover from a potential hazard. CMCG has extensive experience in managing and developing emergency response programs for nuclear facilities both on-site and off-site. Our consultants have hands-on experience and are knowledgeable in developing programs under high regulatory visibility, as well as ensuring that programs continually meet the standards. Our staff is experienced in working with local, state, federal and utility officials in developing integrated emergency plans and procedures.

CMCG consultants have assisted in the program improvements for the San Onofre Nuclear Generating Station, Constellation Energy Group as well as other major utilities such as the Entergy Northeast, Dominion, Exelon, Duke Energy and others.