DCL-02-114, Commitment Change Summary Report, January - December 2001
| ML022820335 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/24/2002 |
| From: | Oatley D Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| DCL-02-114 | |
| Download: ML022820335 (11) | |
Text
El Pacific Gas and Electric Company David H. Oatley Diablo Canyon Power Plant Vice President P0 Box 56 Diablo Canyon Operations Avila Beach. CA 93424 8055454350 Fax 8055454234 September 24, 2002 PG&E Letter DCL-02-114 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units I and 2 Commitment Change Summary Report Dear Commissioners and Staff; In accordance with the Nuclear Energy Institute's (NEI) "Guideline for Managing NRC Commitments," Revision 2, endorsed by the NRC in SECY-95-300, PG&E is submitting the enclosed Commitment Change Summary Report for Diablo Canyon Power Plant, Units I and 2. The report provides a summary of the regulatory commitment changes that occurred during the period January 1, 2001, through December 31, 2001. The summary for each change includes identification of the source document(s), a description of the original and revised commitments, and a justification for the change.
The regulatory commitment changes described in the report were processed in accordance with the NEI guideline and were determined to not require prior NRC approval.
Sincerely, David H. Oatley cc: Ellis W. Merschoff David L. Proulx Girija S. Shukla Diablo Distribution Enclosure PC)~DI
Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
REPORT JANUARY 1, 2001, THROUGH DECEMBER 31, 2001 Table of Contents
- 1. Voltage Based ARC - Leakage Monitoring Measures 2
- 2. ProceduralUpgrade Program 2
- 3. Diesel GeneratorFailureReports 3
- 4. APM Review of DCPPNCRs 4
- 5. SFP Pump Testing Following PartReplacement 4
- 7. Review Status of Open NCRs @ PSRCINSOC 6
- 8. ContainmentLeak Testing - PressureMeasurements 6
- 9. Change Screen DP Limit for Unit 2 7
- 10. QualityProblem Status Report 7 1
Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
REPORT JANUARY 1, 2001, THROUGH DECEMBER 31, 2001
- 1. Voltage Based ARC - Leakage Monitoring Measures Source Document(s): PG&E Letter DCL 97-034 dated 2/26/97 Original Commitment (T35988)
Line 3: "PWR Primary to Secondary Leak guidelines," May 1995 Line 7: "Procedure OP 0-4, "dented Steam Generators." OP 0-4 is in compliance with the action Level 2 plant shutdown limits in the EPRI guidelines (i.e., leakage greater than or equal to 150 gpd or leak rate increasing at greater than 60 gpd per hour)."
Revised Commitment Line 3: "PWR Primary to Secondary Leak Guidelines," Revision 2, April 2000.
Line 6: After "Determination," add "and STP I-11B, Routine Daily checks Required by Licenses" Line 7: Revise to: Procedure OP 0-4, "Primary to Secondary Steam Generator Tube Leak Detection." OP 0-4 is in compliance with the Action Levels in the EPRI guidelines."
Justification for Change Numeric values for plant shutdown limits in OP 0-4 for primary to secondary leakage are removed, and referenced to recently updated industry guidance in current EPRI report.
- 2. Procedural Upgrade Program Source Document(s): PG&E Letter DCL 87-136 dated 6/15/87 Original Commitment (T31394)
A significant procedural upgrade program is underway at the present time to enhance operations, maintenance, and test procedures in accordance with INPO guidelines which include human factor considerations. This is a long-term activity, but should enhance clear procedural communications. This procedural upgrade program includes the following:
(a) Administrative Procedure E-4, "Procedures" was revised to include the significant elements of the INPO writing style guidelines.
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Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
, REPORT JANUARY 1, 2001, THROUGH DECEMBER 31, 2001 (b) Writing guides have been or are being developed for the following classes of procedures: operating emergency, surveillance test, maintenance, chemistry and radiation protection.
Revised Commitment Add the following note to commitment T31394: Note 3: Paragraph (B) above references Emergency Procedures which apply to Emergency Operating and Abnormal Operating Procedures and does not apply to Emergency Planning Procedures.
Justification for Change The context of DCL 87-136 is related to issues stemming from, "Several recent events have been identified as examples of informal or secondhand communication affecting the quality of work or operations."
"A significant procedural upgrade program is underway at the present time to enhance operations, maintenance, and test procedures in accordance with INPO human factor guidelines." While Emergency Planning procedures (those required by 10CFRS0 App E) were not intended to be part of these corrective actions, Emergency Planning procedures do meet the format and content requirements of procedure ADI.ID1. These procedures also meet content requirements as applicable from ANSI N18.7, Section 5.3.9.3, ANSI/ANS 3.8.3 Section 4.1, NUREG 0654, 10CFR50.47(b) and 10CFR50 Appendix E.
- 3. Diesel Generator Failure Reports Source Document(s): OL1 & OL2 2.C(2); R.G. 1.108; T.S. 4.8.1.1.4 Original Commitment (T00504)
Report all Emergency Diesel Generator Failures, Valid or non-Valid, in a "Special Report" to the NRC.
Revised Commitment Delete.
Justification for Change The improved TS deleted Special Reporting requirements for EDG failures. The maintenance rule reporting requirement satisfies this function.
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Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
REPORT JANUARY 1, 2001, THROUGH DECEMBER 31, 2001
- 4. APM Review of DCPP NCRs Source Document(s): PG&E Letter DCL 89-004 dated 1/6/89 Original Commitment (T32883)
Any NCR pertaining to DCPP be reviewed and signed by an Assistant Plant Manager prior to convening a TRG.
Revised Commitment Any NCR pertaining to DCPP be reviewed and signed by a Director prior to convening a TRG.
Justification for Change There are no longer Assistant Plant Manager positions at DCPP. The equivalent to the old Assistant Plant Manager position is the Director.
- 5. SFP Pump Testing Following Part Replacement Source Document(s): PG&E Letter DCL 87-290 dated 12/2/87, IEB 83-05 Original Commitment (T34793)
In PG&E Letter No. DCL 87-290, the following statement is provided regarding a question about the inservice test requirements for the subject pump: "The two spent fuel pit pumps are tested quarterly under Diablo Canyon Surveillance Test Procedure P-11 C, "Surveillance Test Procedure Spent Fuel Pool Pump Two and Heat Exchanger Performance Verification," to check bearing vibration, pump differential pressure, and bearinghousing temperature. There are no ASME Section Xl Inservice Test Requirements for these two pumps. These pumps are not required to shut down the reactor to safe shutdown, maintain safe shutdown or mitigate the consequences of an accident.
Revised Commitment It is desired to remove the test requirement for bearing housing temperature (see bolded italics in the "original commitment description" section above). This temperature data is currently taken annually using STP P-SFP-12 and STP P-SFP-22, both of which have superceded STP P-11 C mentioned above.
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Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
REPORT JANUARY 1, 2001, THROUGH DECEMBER 31, 2001 Justification for Change The bearing housing temperatures have been checked and recorded annually for SFPPs 1-2 and 2-2, as required in STP P-SFP-12 and STP P-SFP-22, since 1987. SFPPs 1-2 and 2-2 both have a long history of satisfactory operation and other than establishing a "benchline operating temperature" for the bearing housings on these Hayward Tyler pumps early on, this annually collected temperature data is no longer used or needed. Since operation of these pumps began, no bearing housing temperature excursions, which might indicate a problem with the pump, have been observed. Furthermore, monitoring and trending other pump operational data, such as bearing vibration levels, pump head, and data from the PM program provides adequate indication of actual pump health and performance. Operator inspections performed during rounds and regularly conducted System Engineer walkdowns provide additional assurance that any changes in the performance of these pumps will not go undetected.
- 6. Precautions to Maintenance Testing on ABVS Dampers Source Document(s): PG&E Letter DCL 89-004 dated 1/6/89 Original Commitment (T32884)
Review potential NCRs at the Plant Manager's morning meeting for assignment of responsibility for NCRs based on consideration of the department with the most responsibility for the potential corrective actions.
Revised Commitment Responsible DCPP Director to review potential NCR for assignment of responsibility based on consideration of the group with the most responsibility for the potential corrective actions.
Justification for Change The Department Director along with the responsible group Manager can adequately determine assignment of the NCR.
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Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
REPORT JANUARY 1, 2001, THROUGH DECEMBER 31, 2001
- 7. Review Status of Open NCRs @ PSRC/NSOC Source Document(s): PG&E Letter DCL 89-004 dated 1/6/89 Original Commitment (T32881)
Review status of open NCRs at a monthly Plant Staff Review Committee (PSRC) meeting to increase the awareness of DCPP and Nuclear Engineering and Construction Services (NECS) management of significant plant problems.
Revised Commitment Review status of open NCRs on a monthly basis in a VP/Directors meeting to increase the awareness of significant plant problems to DCPP management.
Justification for Change To utilize the time of the DCPP VP and Directors in a daily meeting once a month, rather than PSRC time which may include personnel who are not directly affected. This satisfies the intent of the commitment because the same Director's attend the VP/Directors meeting as the PSRC. In addition, the NECS department no longer exists.
- 8. Containment Leak Testing - Pressure Measurements Source Document(s): STP M-7 Original Commitment (T08163)
Suitable facilities shall be provided for representative sampling of the containment air for determination of the vapor pressure. Instrumentation for this purpose shall comply with ASTM E 337-62, published by the American Society for Testing and Material, Philadelphia, Pennsylvania.
Revised Commitment Suitable facilities shall be provided for representative sampling of the containment air for determination of the vapor pressure. Instrumentation for this purpose shall comply with ANSI/ANS 56.8-1994, published by the American Nuclear Society, 555 North Kensington Avenue, La Grange Park, Illinois, 60525, USA.
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Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
REPORT JANUARY 1,2001, THROUGH DECEMBER 31, 2001 Justification for Change ANS 56.8-1994 specifies instrument accuracy requirements for containment integrated leakage rate testing. The original reference to ASTM E337-62 was not specific to type A tests (ILRT) nor did it specify instrument accuracy requirements.
- 9. Change Screen DP Limit for Unit 2 Source Document(s): LER 2-95-002-00 Original Commitment (35412)
Abnormal Operating Procedure AP-7, "Degraded Condenser" was revised to:
A. Require Circ water pump (CWP) shutdown if screen DP exceeds 50 inches to minimize the potential damage to the CWP screens.
Previously, shutdown of the CWP was required after the screens had stopped running.
Revised Commitment A. Require circ water pump (CWP) shutdown if screen DP exceeds 50 inches (UW) or 70 inches (U2) to minimize the potential damage to the CWP screens. Previously, shutdown of the CWP was required after the screens had stopped running.
Justification for Change Engineering evaluation supports a higher limit for screen differential pressure based on design changes made after the original commitment was made. These changes significantly strengthened the structure and drive mechanism of the Unit 2 traveling screens.
- 10. Quality Problem Status Report Source Document(s): PG&E Letter DCL 89-006 dated 1/6/89 Original Commitment (T32757)
The quality problem status reports will have the following characteristics monthly distribution:
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Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
REPORT JANUARY 1, 2001, THROUGH DECEMBER 31, 2001
" Statistics on the number of NCRs, AFRs, and other department specific quality problem reports issued, closed, and open for each department.
"* An aging analysis of the open NCRs, AFRs, and other department specific quality problem reports for each department.
"* Identification for each department of the NCRs, AFRs, and other department specific quality problem reports that are repetitive, whose closures are late, or whose closures are deemed otherwise "critical."
Revised Commitment Revision to second bullet as follows:
- Age of the open NCRs, AFRs, and other department specific quality problem reports for each department.
Justification for Change The reporting of the quality problem age to plant management accomplishes the intent of an analysis.
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Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
REPORT JANUARY 1, 2001, THROUGH DECEMBER 31, 2001 Table of Acronyms Acronym Definition AART Action Request Review Team AE Action Evaluation AFR AP Abnormal Procedure AR Action Request ASWS Auxiliary Saltwater System CCW Component Cooling Water CCWS Component Cooling Water System CWP Circulating Water Pump DCL Diablo Canyon Letter DCPP Diablo Canyon Power Plant EDG Emergency Diesel Generator EOP Emergency Operating Procedure EP Emergency Procedure EPRI Electric Power Research Institute ESF Engineered Safety Feature FHB Fuel Handling Building FHS Fuel Handling Supervisor GM General Manager ILRT Integrated Leak Rate Test INPO Institute of Nuclear Power Operations ITS Improved Technical Specifications JCO Justification for Continued Operation LA License Amendment LER License Event Report LOCA Loss-of-Coolant Accident NCR Nonconformance Report NEI Nuclear Energy Institute NPG Nuclear Power Generation NR Narrow Range NSOC Nuclear Safety Oversight Committee OP Operating Procedure PORV Power Operated Relief Valve PSRC Plant Staff Review Committee QPAR Quality Problem Assessment Report R*P Radiation Control Procedure RCS Reactor Coolant System RHR Residual Heat Removal RM Radiation Monitor 9
Enclosure PG&E Letter DCL-02-114 COMMITMENT CHANGE
SUMMARY
REPORT JANUARY 1, 2001, THROUGH DECEMBER 31, 2001 Acronym I Definition RP Radiation Protection RTP Rated Thermal Power Rx Reactor SFP Spent Fuel Pool SI Safety Injection SRO Senior Reactor Operator SSC Structures, Systems, and Components STP Surveillance Test Procedure SVP Senior Vice-President TOL Thermal Overload TS Technical Specifications 10