DCL-04-131, Response to Request for Additional Information Regarding License Amendment Request 04-05, Revision to Technical Specification Requirements for Handling Irradiated Fuel in the Primary Containment.

Response to Request for Additional Information Regarding License Amendment Request 04-05, Revision to Technical Specification Requirements for Handling Irradiated Fuel in the Primary Containment.

ML053130269
Person / Time
Site:	Diablo Canyon
Issue date:	10/31/2005
From:	Oatley D Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-04-131, DCL-05-124, LAR 04-005, OL-DPR-80, OL-DPR-82
Download: ML053130269 (5)

Text

Pacific Gas and Electric Company' David H. Oatley Diablo Canyon Power Plant Vice President and General Manager P.0. Box 56 Avila Beach, CA 93424 805.545.4350 October 31, 2005 Fax: 805.545.4884 PG&E Letter DCL-05-124 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Response to Request for Additional Information Regardinq License Amendment Request 04-05, "Revision to Technical Specification (TS) Requirements for Handling Irradiated Fuel in the Primary Containment and the Fuel Handling Building and Selected Specifications Associated with Performing Core Alterations"

Dear Commissioners and Staff:

Pacific Gas and Electric (PG&E) Letter DCL-04-131, dated October 29, 2004, submitted License Amendment Request (LAR) 04-05, "Revision to Technical Specification (TS) Requirements for Handling Irradiated Fuel in the Primary Containment and the Fuel Handling Building and Selected Specifications Associated with Performing Core Alterations," to revise the TS requirements for handling of irradiated fuel in the containment and fuel handling building, and certain specifications related to performing core alterations. The proposed changes to the TS are consistent with the NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications Change Traveler TSTF-51, Revision 2, "Revise containment requirements during handling irradiated fuel and core alterations." provides additional information required by the NRC staff to complete its review of LAR 04-05. It relates to the capability to filter and monitor any radioactive releases in the event of a fueling handling accident to reduce doses even further beyond that provided by natural decay. This information has been discussed with the staff.

The information provided in this submittal does not affect the results of the technical evaluation or the no significant hazards consideration determination previously transmitted in PG&E Letter DCL-04-131.

A Callaway member of the STARS (Strategic Teaming and Resource Sharing) Alliance

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek A-(LI

Document Control Desk PG&E Letter DCL-05-124 October 31, 2005 Page 2 If you have any questions or require additional information, please contact Stan Ketelsen at (805) 545-4720.

SIy, David H. Oatley Vice President and General Manager whyl/4279 Enclosure cc: Edgar Bailey, DHS Bruce S. Mallett, Region IV Terry W. Jackson, Senior Resident Inspector Diablo Distribution cc/enc: Girija S. Shukla, NRR A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

PG&E Letter DCL-05-124 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

) Docket No. 50-275 In the Matter of ) Facility Operating License PACIFIC GAS AND ELECTRIC COMPANY) No. DPR-80

)

Diablo Canyon Power Plant ) Docket No. 50-323 Units 1 and 2 ) Facility Operating License

) No. DPR-82 AFFIDAVIT David H. Oatley, of lawful age, first being duly sworn upon oath states that he is Vice President and General Manager of Pacific Gas and Electric Company; that he has executed this response to the NRC request for additional information regarding License Amendment Request 04-05 on behalf of said company with full power and authority to do so; that he is familiar with the content thereof; and that the facts stated therein are true and correct to the best of his knowledge, information, and belief.

David H. Oatley Vice President and General Manager Subscribed and sworn to before me this 31 't day of October, 2005, by David H. Oatley, personally known to me or proved to me on the basis of satisfactory evidence to be the person who appeared before me.

Notary Public Commission # 1425568 County of San Luis Obispo inu OtLpubCounty State of California MV C01=m ExpkmM 18. 204

Enclosure 1 PG&E Letter DCL-05-124 Response to Request for Additional Information Regarding License Amendment Request 04-05, "Revision to Technical Specification (TS) Requirements for Handling Irradiated Fuel in the Primary Containment and the Fuel Handling Building and Selected Specifications Associated with Performing Core Alterations" The changes in License Amendment Request (LAR) 04-05 revise, in part, the electrical and instrumentation Technical Specifications (TS) to be consistent with changes previously approved in License Amendments 163/165. Those amendments revised the applicability of the fuel handling building (FHB) ventilation system TS to apply to only the movement of recently irradiated fuel.

The maintenance rule, 10 CFR 50.65(a)(4), requires that the plant risk be assessed and managed during movement of fuel or other activities in the FHB while the unit is shut down. This would include assessing the capability to filter and monitor any radioactivity releases in the event of a fuel handling accident (FHA) to reduce doses even further beyond that provided by natural decay. Diablo Canyon Power Plant Administrative Procedure AD8.DC55, uOutage Safety Scheduling," defines the process for planning and scheduling outage activities to minimize shutdown risk and optimize defense-in-depth (the availability of plant safety systems and electrical sources). This procedure addresses requirements for Class 1E electrical power and FHB ventilation. In addition, AD8.DC55 references both 10 CFR 50.65(a)(4), "The Maintenance Rule," and NUMARC 93-01, "Shutdown Maintenance Guidelines," as the guiding documents.

Other plant procedures also require that radiation monitoring capability, in addition to the permanently installed radiation monitors, be provided for fuel movement in the spent fuel pool, i.e., additional functional radiation monitor(s). The OP B-8 series of plant operating procedures for fuel handling employ various methods of monitoring for excessive radioactivity in the area which could be the result of a FHA or hot particles emerging from the water. The procedures listed below require portable radiation monitors be available for use with a continuous air monitor located in the FHB and applicable sections of these procedures are referenced as follows:

DCPP Operating Procedure OP B-8D, "Core Alterations Checklist" .1, "Core Unloading Prerequisites Checklist," Step 5 - Portable radiation monitor(s) are available for use on the manipulator crane and spent fuel bridge crane, and a continuous area monitor is located in containment (1 40 ft el..) and the FHB. .2, "Core Loading Prerequisites Checklist," Step 13 - Portable radiation monitor(s) are available for use on the manipulator crane and spent fuel bridge crane, and a continuous area monitor is located in containment (140 ft el.) and the. F1iB.

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Enclosure 1 PG&E Letter DCL-05-124 DCPP Operating Procedure OP B-8H, uSpent Fuel Pool Work Instructions" Prerequisite Step 4.12 - The Spent Fuel Pool and New Fuel Storage Vault Radiation Monitors (RM-58/ 59) are OPERABLE per TS 3.3.8 (being revised by LAR 04-05) and a Gaseous Activity Monitor is in service per RCP D-200 Radiation Control Procedure.

(Note: RM-58 and RM-59 are the permanently installed radiation monitors in the FHB.)

DCPP Abnormal Operating Procedure OP AP-21 "Irradiated Fuel Damage" In this procedure, instructions are provided for actions to be taken by the crew in the event of a high radiation detection alarm from either the permanently installed radiation monitors or the portable radiation monitors during fuel movement.

While the portable radiation monitors do not have any automated functions, they are more sensitive in alerting the crew to worsening radiological conditions, and provide an alert earlier than the permanently installed RM-58/59 radiation monitors. The portable radiation monitors allow the crew to take corrective or mitigating actions before any automated action is initiated by the permanently installed RM-58/59 radiation monitors.

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