DCL-10-104, Response to NRC Letter Dated July 20, 2010, Request for Additional Information (Set 13) for License Renewal Application

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Response to NRC Letter Dated July 20, 2010, Request for Additional Information (Set 13) for License Renewal Application
ML102310036
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 08/17/2010
From: Becker J
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-10-104, OL-DPR-80, OL-DPR-82
Download: ML102310036 (30)
v • d • e


Text

Pacific Gas and Electric Company' James R.Becker Diablo Canyon Power Plant Site Vice President Mail Code 104/5/601 P.0. Box 56 Avila Beach, CA 93424 August 17, 2010 805.545.3462 PG&E Letter DCL-1 0-104 Internal: 691.3462 Fax: 805.545.6445 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20852 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Response to NRC Letter dated July 20, 2010, Request for Additional Information (Set 13) for the Diablo Canyon License Renewal Application

Dear Commissioners and Staff:

By letter dated November 23, 2009, Pacific Gas and Electric Company (PG&E) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for the renewal of Facility Operating Licenses DPR-80 and DPR-82, for Diablo Canyon Power Plant (DCPP) Units 1 and 2, respectively. The application included the license renewal application (LRA), and Applicant's Environmental Report -

Operating License Renewal Stage.

By letter dated July 20, 2010, the NRC staff requested additional information needed to continue their review of the DCPP LRA.

PG&E's response to the request for additional information is included in Enclosure 1. LRA Amendment 11, resulting from the responses, is included in Enclosure 2 showing the changed pages with line-in/line-out annotations.

PG&E makes no regulatory commitments (as defined in NEI 99-04) in this letter.

If you have any questions regarding this response, please contact Mr. Terence L. Grebel, License Renewal Project Manager, at (805) 545-4160.

I declare under penalty of perjury that the foregoing is true and correct.

Executed onA us , -10.

SincA11 James R. Becker A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Caltaway

  • Comanche Peak
  • Diabto Canyon
  • Palo Verde
  • San Onofre
  • Wolf Creek

Document Control Desk PG&E Letter DCL-10-104 August 17, 2010 Page 2 pns/50330133 Enclosure cc: Diablo Distribution cc/enc: Elmo E. Collins, NRC Region IV Regional Administrator Nathanial Ferrer, NRC Project Manager, License Renewal Kimberly J. Green, NRC Project Manager, License Renewal Michael S. Peck, NRC Senior Resident Inspector Alan B. Wang, NRC Project Manager, Office of Nuclear Reactor Regulation A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Catlaway

  • Comanche Peak
  • Diabto Canyon o Palo Verde o San Onofre o South Texas Project o Wolf Creek

Enclosure 1 PG&E Letter DCL-10-104 Sheet 1 of 22 PG&E Response to NRC Letter dated July 20, 2010, Request for Additional Information (Set 13) for the Diablo Canyon License Renewal Application RAI 2.3-07 10 CFR 54.4(a) provides criteria for determining whether systems or components are in scope for license renewal. The staff confirms inclusion of all components subject to an aging management review (AMR) by reviewing the components within the license renewal boundary. In Section 2.1.2.2 of the Diablo Canyon Power Plant (DCPP)license renewal application (LRA), the applicant indicates that nonsafety-related systems and components that contain fluid or steam and are located inside structures that contain safety-related systems, structures and components (SSCs) are included in scope for, potentialspatial interactionunder criterion 10 CFR 54.4(a)(2).

During the scoping and screening review process, several nonsafety-related piping components were found on the DCPPlicense renewal boundarydrawings in areas containing safety-related components but were not included within the scope of license renewal. Excluding these components contradicts the applicanfs approach stated in LRA Section 2.1.2.2. In addition, based on the guidance in NEI 95-10, these components should be within the scope of license renewal because of spatial interaction of the fluid that could prevent the performance of a safety function by a safety-related SSC.

The applicantstated during the scoping audit presentations that for (a)(2) spatial interaction, they used a building approachexcept as identified in procedure TR-6DC; hence, all fluid filled components in the auxiliarybuilding should be in scope under 10 CFR 54.4(a)(2). However, the applicant has additionalareasin the auxiliary building where they did not include fluid-filled components. Specific examples are identified in the table below:

License Renewal Application Piping Component/ Issue (LRA) Section / Drawing Number 2.3.3.3 - Saltwater and Chlorination System The applicant shows strainersand piping LR-DCPP-17-106717-07 components in piping (at locations 77-A and -

C and 77a-C and-D), which denotes that the components are not in scope of license renewal, connected to the auxiliarysaltwater,

Enclosure 1 PG&E Letter DCL-10-104 ISheet 2 of 22 (ASW) pump vaults. These fluid-filled lines are located inside the intake structure and may have the potentialfor spatial interaction with the nearby safety-related ASW piping.,

4 At locations 79-8 and 79a-D. there are portions of the ASW system piping highlighted in scope for license renewal under 10 CFR 54.4(a)(1) at the intake structure when the ASW piping transits outside of the LR-DCPP-17-106717-07 ASW pump vault rooms priorto entering the LR-DCPP-17-106717-7A "yard:" However, there are surroundingfluid-filled piping at the intake structure not highlighted in scope for license renewal that could interact with the safety-related ASW piping.

On the ASW piping in the yard at locations 81-8 and 92-E. there is (a)(1) piping and LR-DCPP-17-106717-08 components on the vacuum relief portion.

LR-DCPP-17-106717-09 The LRA drawings show fluid-filled piping, in the vicinity of the (a)(1) piping, not within scope of license renewal.

2.3.3.6 - NuclearSteam Supply Sampling System The applicant depicts a makeup water system line tied into the high radiationsample panel at location 50-D and is in scope for license renewal under 10 CFR 54.4(a)(2) for spatial' LR-DCPP-11-106711-05 interaction. There is a branch line off this makeup water system line that is not in scope for license renewal with no spatialinteraction termination identified. -

Enclosure 1 PG&E Letter DCL-10-104 Sheet 3 of 22 At locations 25-C and 27 -C. there are sections of piping highlightedin scope of license renewal under 10 CFR 54.4(a)(1) inside the sampling room. However. there are LR-DCPP-11-106711-02 multiple fluid-filled piping and components in the surroundingarea that are not highlighted for possible spatialinteraction with these safety-related portions of the system.

The staff requests the applicant to address the following:

1. Identify exclusion areasand justify the methodology for excluding piping and components with the potential to adversely impact the requiredfunctions of safety-related SSCs due to spatialinteraction.
2. Justify the exclusion of the components identified above from the scope of license renewal per 10 CFR 54.4.

PG&E Response to RAI 2.3-07 2.3.3.3 - Saltwater and Chlorination System The nonsafety-related lines in the intake structure that could impact safety-related lines were previously identified and were added to the scope of license renewal in Amendment 1 to the license renewal /application (LRA) submitted by letter dated June 18, 2010. The lines identified in the request for additional information (RAI) for Boundary Drawings LR-DCPP-1 7-106717-07 and LR-DCPP-1 7-106717-7A were addressed in the amendment.

The lines identified on Boundary Drawings LR-DCPP-17-106717-08 and LR-DCPP-17-106717-09 in the RAI are separated by a concrete wall. Final Safety Analysis Report, Figure 9.2-3, shows the lines are separated by the wall and therefore there is no spatial interaction by nonsafety-related systems, structures, and components (SSCs) on safety-related SSCs.

2.3.3.6 - Nuclear Steam Supply Sampling System The end point for spatial interaction was not shown on Boundary Drawing LR-DCPP-1 1-106711-05. The drawing has been revised to show the spatial

Enclosure 1 PG&E Letter DCL-10-104 Sheet 4 of 22 interaction end point. Similar changes have been made to Boundary Drawings LR-DCPP-1 1-106711-06, LR-DCPP-1 1-107711-05, and LR-DCPP-1 1-107711-06.

Nonsafety-related SSCs shown on Boundary Drawing LR-DCPP-1 1-106711-02 that have the potential to impact safety-related components have been added to the scope of license renewal. The boundary drawing has been revised to include these components.

In addressing these questions, revisions and other clarifications have been made to the nuclear steam supply sampling system boundary drawings. DCPP revised its aging evaluation to address these changes and LRA Tables 2.3.3-6 and 3.3.2-6 have been revised to reflect the changes to the scope of license renewal. See Enclosure 2 for revised LRA Tables 2.3.3-6 and 3.3.2-6.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 5 of 22 RAI 2.3-08 10 CFR 54.4{a) provides criteria for determining whether systems or components are in scope for license renewal. The staff confirms inclusion of all components subject to AMR by reviewing the components within the license renewal boundary.

During the scoping and screening review process, the continuationfrom one drawing to anothercould not be established. Drawing numbers and/or locations could not be located where identified, the continuation drawing was not provided, or piping expected to be in scope based on one drawing led to a different conclusion on a connecting drawing. Consequently, the staff is unable to complete its scoping and screening review for the particularsystems. Specific examples are identified in the table below:

License Renewal Application ContinuationLocation / Issue (LRA)Section / Drawing Number 2.3.3.5 - Makeup Water System The applicant indicates the line going into the firewater tank at location 166-D is in scope of LR-DCPP-16-106716-16 license renewal under 10 CFR 54.4{a)(2) for attachedpiping. However, on the continuation drawing (location 68-E), the line going into the firewater tank is not highlighted.

The applicantdepicts nonsafety-relatedpiping components to the auto resin sample system (at location 189-D) as in scope for license renewal LR-DCPP-16-106716-18 under 10 CFR 54.4(a)(2) for spatial interaction.

No spatialinteraction termination was identified priorto the continuation flag and the continuation drawing was not provided.

At location 198-A on the interface to the charging LR-DCPP-16-106716-19 pump 2-3 seal.cooling tank, the continuation drawing identified (LR-DCPP-08-107708-05)did not show the continuation.

At location 219-D, there are several continuations shown as arrows to/from otherareas, e.g., control LR-DCPP-16-106716-21 room, main domestic/drinking water, hot recirculationand hot water. There are no spatial interaction terminations identified priorto the continuationarrows, and the continuation drawing

Enclosure 1 PG&E Letter DCL-1 0-104 Sheet 6 of 22 was not identified.

At location 217-C, a continuation of domestic water into "batteryrooms' is shown that was terminated with a spatialinteraction flag. There LR-DCPP-16-106716-21 was no continuation drawing identified. The staff is concerned with possible interactionresulting from a failure of this water piping in the "battery rooms."

2.3.3.14 - Diesel Generator System The applicantdepicts the diesel engine lube oil reservoir 1-1 as not being in scope for license renewal. 'However, the diesel engine lube oil LR-DCPP-21-106721-06 reservoir for the subsequent LRA drawings for the diesel generatorsystem is shown highlighted in scope for license renewal under 10 CFR 54.4(a)(1).

2.3.3.16 - Gaseous Radwaste System The applicant depicts piping in scope for license LR-DCPP-24-106724-02 renewal under 10 CFR 54.4(a)(2) going to the LR-DCPP-24-106724-03 nitrogen system (at location 29-A). However, the continuationdrawing was not provided.

2.3.3.17 - Liquid Radwaste System The drawing depicts several lines in scope of license renewal running from Laundry Distillate Tanks 0-1 and 0-2 to the auxiliary building sump.

LR-DCPP-19-106719-12 However, on the continuationdrawing (LR-DCPP-19-106719-06), the color of these lines changes from red [(a)(2)] to green [(a)(1) or (a)(3)]. The basis for this transition is not clear.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 7 of 22 2.3.4.1 - Turbine Steam Supply System At locations 161-A, 161-B, 162-A, 162-B, 163-A, and 163-B), connections are shown to the service LR-DCPP-04-106704-16 air LR-DCPP-04-107704-16 system with only LR-DCPP-04-107704-16 component identification numbers and no connecting lines.

'The staff requests that the applicantprovidesufficient information for the continuation issues identified above to permit the staff to review all portions of the systems within the license renewal boundary.

PG&E Response to RAI 2.3-08 2.3.3.5 - Makeup Water System The continuation from Boundary Drawing LR-DCPP-16-106716-16 to Boundary Drawing LR-DCPP-18-106718-06 should have been highlighted. Boundary Drawing LR-DCPP-18-106718-06 has been revised to include the highlighted piping at coordinate 68-E as in-scope for spatial interaction.

The piping on Boundary Drawing LR-DCPP-16-106716-18 coordinate 189-D continues to Boundary Drawing LR-DCPP-78-106719-15 coordinate 158-D. The continuation is shown on the drawing and as within the scope of license renewal. No changes to the boundary drawings are required.

LR-DCPP-16-106716-19 The configuration shown on Boundary Drawing LR-DCPP-16-106716-19 has been modified to cut and cap the piping in question. Boundary Drawing LR-DCPP-16-106716-19 has been revised to show the piping to the right of Valve 2-790 cut and capped. The valve, cap, and piping remain within the scope of license renewal. No license renewal application (LRA) changes are required.

LR-DCPP-16-106716-21 Boundary Drawing LR-DCPP-16-106716-21 was revised as part of the LRA, Amendment 1, submitted by letter dated June 18, 2010. The drawing currently shows the additional spatial interaction details at Coordinates 217-C and 219-D.

Enclosure 1 PG&E Letter DCL-1 0-104 Sheet 8 of 22 2.3.3.14 - Diesel Generator System The diesel generator lube oil reservoir shown on LR-DCPP-21-106721-06 is the diesel engine crankcase and is an integral part of the diesel engine complex assembly, which is an active component per NEI 95-10. Therefore, the component labeled "Diesel Engine Lube Oil Reservoir 1-1" is shown correctly on the drawings as not highlighted.

The lube oil reservoirs for the five other diesel engines have been revised to remove the green highlighting on the following Boundary Drawings:

LR-DCPP-21-106721-11 LR-DCPP-21-106721-16 LR-DCPP-21-107721-06 LR-DCPP-21-107721-11 LR-DCPP-21-107721-16 There were no changes made to the LRA.

2.3.3.16 - Gaseous Radwaste System The nitrogen system is not within the scope of license renewal and was highlighted incorrectly on Boundary Drawings LR-DCPP-24-106724-02 and LR-DCPP-24-106724-03. These boundary drawings have been revised to remove the highlighting of the line segment depicted on these drawings. There were no changes made to the LRA.

2.3.3.17 - Liquid Radwaste System The lines in question are correctly shown in green on LR-DCPP-19-106719-12, because they have a fire protection function. The drain lines from the laundry distillate tanks that go to the auxiliary building sump are depicted separately on Boundary Drawing LR-DCPP-1 9-106719-02. These lines only have a leakage barrier function and are highlighted red.

The drain lines from the laundry distillate tanks that go to the auxiliary building sump are not depicted separately from other drain piping on Boundary Drawing LR-DCPP-19-106719-06. These lines are shown grouped, by'name only, with a number of other drain lines that feed/join together to become a single drain line going to the auxiliary building sump. These floor drains in the auxiliary building were assigned an a(3) fire protection function. Thus when the tank drain lines combine with the floor drain lines to become a single drain line, that single drain line takes on the a(3) fire protection function and is highlighted green.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 9 of 22 2.3.4.1 - Turbine Steam Supply System Portions of the connecting lines to the service air system on Boundary Drawings LR-DCPP-04-106704-16 and LR-DCPP-04-107704-16 did not show due to a coding error in the drawing master which caused the software to print the lines as white instead of black. The error has been corrected. The portions of service air piping that were not visible are not within the scope of license renewal.

Enclosure 1 PG&E Letter DCL-1 0-104 Sheet 10 of 22 RAI 2.3-09 10 CFR 54.4(a) provides criteriafor determining whether systems or components are in scope for license renewal.

During the scoping and screening review process, several components were found highlighted on DCPPlicense renewal boundary drawings as being in scope for license renewal, but were not found on the associatedtables for mechanical systems in the "Scopingand Screening Results-Mechanical System" 'section of the DCPPLRA.

Specific examples are identified in the table below:

License Renewal Application Table Location / Issue (LRA)

Section / Drawing Number 2.3.3.5 - Makeup Water System The makeup water transferpump expansionjoints were found highlighted (atlocation 165-B) as being in scope for license renewal, but the component type "expansionjoin" was not found LR-DCPP-16-106716-16 on the associatedtable for the makeup water system. Similar pump and heat exchanger expansionjoints are specifically identified on the associatedtable for the ASW system in the DCPP LRA.

2.3.3.14 - Diesel Generator System The applicant depicts the after cooler and turbochargeras within scope of license renewal LR-DCPP-21-106721-07 under 10 CFR 54.4(a)(1) for purposes of LR-DCPP-21-106721-06 maintainingthe system pressure boundary LR-DCPP-21-106721-11 intended function on license renewal boundary LR-DCPP-21-106721-16 drawing LR-DCPP-21106721-07for emergency LR-DCPP-21-107721-06 diesel generator(EDG) 1-1 (and identical LR-DCPP-21-107721-11 drawings for the remaining 5 EDGs). The LR-DCPP-21-107721-16 turbochargersand after coolers are not listed on the associatedAMR table for the diesel generator system.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 11 of 22 2.3.3.15 - Lube Oil System The lube oil system CCW pump motor lubricators (oilers) were found highlighted as being in scope for license renewal under 10 CFR 54.4( a)( 1) for purposes of LR-DCPP-20-106720-12 maintaining the system pressure boundary intended LR-DCPP-20-107720-12 function. However, the lubricators were not found on the associated table for the lube oil. Similar lubricators are specifically identified on the associated table for the diesel generator system in the DCPP LRA.

The staff requests that the applicant explain its methodology for establishingwhat components are specifically identified on the system specific AMR Table. The staff also requests for the applicant to justify the exclusion of the listed components with a specific intended function from AMR.

PG&E Response to RAI 2.3-09 2.3.3.5 - Makeup Water System The expansion joints are short-lived because they are inspected annually and are replaced on a 10-year frequency. Therefore they are not within the scope of license renewal.

2.3.3.14 - Diesel Generator System The turbochargers are assigned the component type of "turbine," and the aftercoolers have been assigned the component type of "heat exchanger (DG Intercooler)." The components account for all applicable internal and external environments. These component types appear correctly in License Renewal Application (LRA)

Tables 2.3.3-14 and 3.3.2-14.

2.3.3.15 - Lube Oil System The lube oil system component cooling water pump motor lubricators (oilers) found on Boundary Drawings LR-DCPP-20-106720-12 and LR-DCPP-20-107720-12 do not have specific component identification numbers in the Diablo Canyon Power Plant' equipment database. While performing screening for this system, a generic piping component was created to account for these specific oiler components, with a glass material of construction. Other steel piping components were also created to account for the steel portion of these oilers. Therefore, these piping components accounting for the oilers are listed in LRA Tables 2.3.3-15 and 3.3.2-15. There were no changes made to the LRA.

Enclosure 1 PG&E Letter DCL-1 0-104 Sheet 12 of 22 RAI 2.3.3,3-01 The applicantshows piping components, which are not highlighted as in scope for license renewal, connected directly to safety-related piping where the ASW system dischargesinto the ocean (at location 89-B on LR-DCPP-17-106717-08and location 99-E on LR-DCPP-17-10671709). The staff is concerned that degraded piping along the dischargepath could impact the discharge function of the ASW. The staff requests that the applicantjustify why the portion of the dischargepath between the safety-relatedportions of the ASW at the above drawing locations is excluded from scope of license renewal.

PG&E Response to RAI 2.3.3.3-01 The black line connecting the auxiliary saltwater system (ASW) to the ocean represents the discharge structure, which is in-scope. The ASW piping is buried from the turbine building to the point where it discharges directly into the top of the discharge structure.

The discharge structure provides a release path for the auxiliary discharge lines, steam generator blowdown tanks, and the turbine building sump. The structure is divided into two chambers (one for each unit) that are open to the ocean under all conditions. The nonsafety-related piping at locations 89-B and 99-E do not directly connect to the ASW system; this nonsafety-related piping also discharges into the discharge structure.

There is no potential to impact the discharge function of the ASW.

The discharge structure provides structural support, shelter, and protection for nonsafety-related systems, structures, and components whose failure could prevent performance of a safety-related function. The discharge structure is within the scope of license renewal based on the criteria of the 10 CFR 54.4(a)(2).

Enclosure 1 PG&E Letter DCL-1 0-104 Sheet 13 of 22 RAI 2.3.3.5-01 The applicant depicts the firewater tank inside the safety-relatedprimary water transfer storage tank, on license renewal boundary drawing LR-DCPP-16-106716-16.On license renewal boundary drawing LR-DCPP-18-106718-06 for the fire protection system, the applicant indicates in the LR note that the firewater tank is used for fire protection and included in scope for license renewal under 10 CFR 54.4(a)(3). In DCPP FinalSafety Analysis Report (FSAR) Chapter3, Section 3.8, "Design of Design Class I Structures," the applicant indicates that the firewatertank is a Class I structure. DCPP LRA Section 2.1.2.1, 'Title 10 CFR 54.4(a)(1 )-Safety Related:' states that components that are classified as Design Class I are considered safety-related and treated as (a)(1) for the purpose of license renewal. The staff finds that the firewater tank should be included in scope as an (a)(1) component, and the attachedpiping, which is not highlighted,should be included in scope for license renewal under 10 CFR 54.4 (a)(2).

The staff requests the following from the applicant:

" Review other Design Class I components to ensure they were properly included in scope of license renewal under 10 CFR 54.4(a)(1) and their associatedpiping under 10 CFR 54.4(a)(2).

PG&E Response to RAI 2.3.3.5-01 The inner firewater tank is in-scope for (a)(3) as shown on License Renewal Boundary Drawing LR-DCPP-1 8-106718-06, Revision 0. The outer primary water transfer tank is in-scope for (a)(1) as shown on license renewal Boundary Drawing LR-DCPP-16-106716-16, Revision 1. The lines and valves that are attached to the primary water transfer tank are nonsafety-related but have been included within the scope to an end-point or to a connection to other safety-related or nonsafety-related pipe that is also in scope. The lines and valves are highlighted green on License Renewal Boundary Drawings LR-DCPP-18-106718-06, Revision 0, and LR-DCPP-16-106716-16, Revision 1, for (a)(3) to protect the tank water source for fire protection.

License renewal Boundary Drawing LR-DCPP-18-106718-06 has been revised to indicate that the lines and valves that are attached to the inner firewater tank are nonsafety-related but have been included within the scope to an end-point or to a connection to other safety-related or non-safety related pipe that is also in scope.

License Renewal Boundary Drawing LR-DCPP-1 6-106716, sheets 16 and 17, have been revised to remove the license renewal note, "The pipe sizes are much smaller than the tank, and consequently impose no structural impact. The tank penetrations are not associated with venting."

Enclosure 1 PG&E Letter DCL-10-104 Sheet 14 of 22 RAI 2.3.3.5-02 On license renewal boundary drawings LR-DCPP-16-106716-16and LR-DCPP 106716-17, the applicant shows the condensate storage tanks (CST), depicted as 1-1 and 2-1, having attached lines highlighted in scope for 10 CFR 54.4(a)(2). These lines are connected to the safety-related tank without a closed isolation valve. The staff is concerned that the following failures involving these lines have the potential to result in an inadvertent drain-down of the CST if the lines connect to the CST below the reserved safety-related capacity level:

  • A failure of surroundingnonsafety-relatedcomponents could cause a failure of 10 CFR 54.4 (a)(2) lines, leading to a drain down of CST.
  • A failure of the downstream connections that are not in scope could cause a drain down of the CST.

The staff requests that the applicantprovides the following details:

  • Verify that the connected lines are above the reserve'capacity level so that a failure involving these lines will not affect the safety-related inventory.
  • Verify that a satisfactoryscoping evaluation of the attachedpiping and any surrounding components up to a closed isolation valve was performed around the CST.
  • Clarify that an approved station emergency procedure exists to isolate these lines to prevent loss of the safety-related inventory.

The staff also requests that the applicantjustify the exclusion of the downstream piping not in scope of license renewal (e.g., components at location 168-C downstream on line to the demineralizers, connection to main condenserat LR-DCPP-02-106702-02location 21E, and connection to package boiler at LR-DCPP-06-106706-03 location 30-C).

Similarly, since the applicantscoped the safety-relatedprimary storage transfertank under 10 CFR 54.4(a)(1), the staff requests that the applicantperform a similar evaluation of 10 CFR 54.4 (a)(2) lines directly attached to the tank.

PG&E Response to, RAI 2.3.3.5-02 The condensate storage tank (CST) is a safety-related Design Class I tank designed to store sufficient demineralized water to satisfy the requirements of both the secondary-cycle makeup and the auxiliary feed water system (AFWS) requirements. The usable reserved inventory in the CST is 224,860 gallons. Technical Specification (TS) 3.7.6 requires that a useable volume of 200,000 gallons for Unit 1 and 166,000 gallons for Unit 2 be maintained in the CST for use by the AFWS.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 15 of 22 To meet the TS minimum water inventory, design changes were completed during the Unit 2 fourteenth refueling outage (2R14) and the Unit 1 fifteenth refueling outage (1 R1 5) for both units to maintain the minimum TS volume in the tank. To achieve this, internal plenums around any nonseismically qualified tank connections in the usable volume region were installed. These internal plenums are installed on CST Nozzles N2, N1 1, and N14 (reference Line Valves 676, 704, and 675 respectively) up to an elevation of approximately 141 ft. 11 in. A tank subcomponent has been added to LRA Tables 2.3.3-5 and 3.3.2-5 for the stainless steel plenums. See revised LRA Tables 2.3.3-5 and 3.3.2-5 in Enclosure 2.

Valves 1/2-681 in the piping connected to Nozzle N3 at elevation 135 ft. 8 in. are normally closed as they are connected to abandoned portion of the system. In Unit 1, the line is cut and capped immediately downstream of the closed valve and the section connected to the CST has been evaluated per the seismic induced system interaction (SISI) criteria to withstand a seismic event without failure. The Unit 2 line is still connected to the abandoned'section with Valve 2-681 closed. The piping configuration is similar to Unit 1 and has been evaluated to meet the SISI criteria similar to Unit 1.

This line up to Valves 1/2-681 is in scope of license renewal application ,boundary.

Based on the above, an emergency operating procedure is not required to isolate these lines to prevent inadvertent loss of safety-related inventory from the CST.

r

Enclosure 1 PG&E Letter DCL-10-104 Sheet 16 of 22 RAI 2.3.3.5-03 License renewal boundary drawing LR-DCPP-16-1,06716-11shows two pipe sections exiting the east and west reservoirs(0-18 and 0-1A) at location 112-C. During the DCPPscoping and screening methodology audit, the applicant clarified that the reservoirs were in scope of license renewal under 10 CFR 54.4(a) (3) for fire protection.

However, the applicantalso stated that piping from 10 CFR 54.4 (a)(3) components was conservatively scoped to the nearestisolation valve. The piping in question was not highlighted as in scope for license renewal. The staff requests that the applicant justify the exclusion of these piping from being in scope of license renewal under 10 CFR 54.4(a)(3).

PG&E Response to RAI 2.3.3.5-03 By letter dated June 18, 2010, PG&E submitted License Renewal Application Amendment 1, in response to RAI 2.3-5, which revised the scoping boundary for the sections of pipe in question and Boundary Drawing LR-DCPP-1 6-106716-11, Revision 1, now shows this piping highlighted. The east and west reservoirs are not highlighted since these are considered structural components and not mechanical components. The boundary drawing accurately depicts isolation capabilities of the fire protection branch piping for the piping that supports the fire system yard loop at Coordinate 113-A. All branches are isolated except the branch that goes through Valve 0-882 (114-C). This entire branch is in-scope to supply fire water to the areas indicated on the drawing.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 17 of 22 RAI 2.3.3.5-04 The applicantstates in the DCPPLRA that the NEI 95-10 guidance was used to perform the scoping boundaries for the systems in scope for license renewal according to 10 CFR 54. NEI 95-10 states that for nonsafety-related SSCs directly connected to safety-related SSCs, the non-safety piping and supports up to and including the first appropriateanchorbeyond the safety and non-safety interfaces are within the scope of license renewal.However, the staff identified the following instances in. the makeup water system boundary drawings in which the appropriateanchors were not identified:

  • On LRA drawing LR-DCPP-16-106716-03,the applicant depicts (at location 30-B) piping not highlighted in scope for license renewal directly attached to nonsafety-relatedpiping that leads into the CST, transfertank, and raw water open reservoir.No seismic anchoris identified along the piping in scope for license renewal to the piping not highlighted in scope.
  • On LRA drawing LR-DCPP-16-106716-16,the applicant shows attached nonsafetyrelatedpiping components from the demineralizeroutlet (at location 168-B) to the CST and the transfertank in scope of license renewal under 10 CFR 54.4(a)(2). No seismic anchoris identified at the interface with the demineralizeroutlet or on the continuation drawing.
  • On LRA drawing LR-DCPP-16-106716-16,the applicantshows attached nonsafetyrelatedpiping components from the firewatertank exiting the auxiliary building (at location 184-A). The piping located outside the building is not highlighted in scope for license renewal, nor does it have a seismic anchor identified along the piping.

" On LRA drawing LR-DCPP-16-106716-17,the applicantshows attached nonsafetyrelatedpiping components from the unit 2 evaporatordistiller(at location 178-C) to the safety-related unit 2 condensate storage tank 2-1 in scope of license renewal under 10 CFR 54.4(a)(2). No seismic support is identified at the interface with the unit 2 evaporatordistiller or on the continuationdrawing.

Similar omissions exist at the interface to the main condenser and the package boiler feed pump suction from the safety-related unit 2 condensate storage tank 2-1.

The staff requests that the applicantjustify its methodology for establishingseismic boundaries on directly attached nonsafety-relatedpiping to safety-relatedpiping for the makeup water system, and justify the exclusion of the abovementioned piping up to an appropriateanchor. The staff also requests that the applicant review the makeup water system piping to ensure all 10 CFR 54.4 (a)(2) piping was scoped properly to an appropriateanchor.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 18 of 22 PG&E Response to RAI 2.3.3.5-04 The lines and valves in question that are attached to safety-related vessels are nonsafety-related but have been included within the scope to an end-point or to a connection to other safety-related or nonsafety-related pipe that is also in scope.

Where the nonsafety-related piping is in scope, it is in scope for 10 CFR 54.4(a)(2) for spatial interaction.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 19 of 22 RAI 2.3.3.5-05 On license renewal boundary drawing LR-DCPP-16-106716-18,the applicant depicts piping for the makeup water system to the spent fuel pool and CCW surge tank as within scope of license renewal under 10 CFR 54.4(a)(1) for purposes of maintaining the system pressure boundary intended function. The piping transitionto nonsafety-related piping, at drawing locations 187-E and 184-A, is depicted as within scope of license renewal under 10 CFR 54.4(a)(2). The piping, shown at location 184-A on the LRA drawing, leads to the condenserpolish demineralizersand flush water, and this piping is not highlighted as in scope for license renewal. Since this flow path is indicated as normally open, the staff is concerned that failure of this piping could impact the pressure boundary of the makeup water system.

The staff requests that the applicantjustify its exclusion of this piping to the condenser polish demineralizers from scope of license renewal, including any proceduralmitigation methods.

PG&E Response to RAI 2.3.3.5-05 Makeup to the component cooling water (CCW) surge tank is normally provided by the nonseismic Category I demineralized water makeup system. A seismic Category I source of makeup water is available from the condensate storage tank via seismic Category I piping and the makeup water transfer pumps. After a safe shutdown earthquake, the operator would take local manual action to close Valve MU-1 -1567 and transfer makeup supply to the CCW surge tank from the normal nonseismic Category I demineralized water makeup system to the seismic Category I condensate storage and transfer system. The procedure for the manual action to align the condensate storage tank for makeup is OP F-2:VII, "Alternate MakeupWater Sources to the CCW System."

The procedure aligns the code-break valves in the closed position and establishes a flowpath using seismic class piping. This procedure would be used in the response to a low level alarm in the head tank, low CCW header pressure and high radiation alarms in the CCW system. Final Safety Analysis Report, Section 9.2.2.3.3 and Table 9.2-7, and Supplement to Supplier Evaluation Report 16 discusses that norkmal makeup to the CCW system is nonseismic and that manual action is required to provide a Class I source of water to the CCW surge tank.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 20 of 22 RAI 2.3.3,6-01 On license renewal boundary drawings LR-DCPP-11-106711-04and LR-DCPP 107711-03, the applicant includes the sample coolerrack heat exchangers supplied by the CCW system as within scope of license renewal under 10 CFR 54.4(a)(1) for purposes of maintainingthe system pressure boundary intended function. However, there are piping components directly attached to the heat exchangers that are not highlighted, indicatingthat they are not included in the scope for license renewal. In accordance with guidelines specified in NEI 95-10, the applicant should include attached piping to 10 CFR 54.4 (a)(1) components up to the appropriateendpoint after the safety and nonsafety-relatedinterface.

The staff requests that the applicantjustify its exclusion of the non-highlighted piping components that are directly attached to the heat exchangers from license renewal and verify no spatial interactionexist from the lines to the abandoned equipment.

PG&E Response to RAI 2.3.3.6-01 2

Boundary Drawings LR-DCPP-106711-04 and LR-DCPP-1 1-107711-03 have been revised to show the heat exchangers as being within the scope of license renewal for the 10 CFR 54.4(a)(2) function of structural integrity.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 21 of 22 RAI 2.3.3.7-01 On license renewal boundary drawing LR-DCPP-25-106725-26 (at locations 260-A and 261-D), two solenoid valves (SVs) (SV-526A and SV-526B; SV-516A and SV-516B) and their associatedtubing are not highlighted,indicating that the valves and tubing are not included in the scope for the license renewal. Backup airsupply tanks are attached to those portions of the system to provide pressurized airin the event normal air is lost.

The staff is concerned that if the pressure boundary of these components fail, then the pressure boundary intended function of the safety-relatedpiping could be compromised. Therefore, the pressure boundary of these SVs and associatedtubing should have been properly considered in the scoping process.

The staff requests that the applicantjustify its exclusion of the solenoid valves and the tubing between both sets of solenoid valves from scope of license renewal. The staff requests that the applicant review the compressed airsystem to assure a proper endpoint was establishedto protect the safety-relatedpressure boundary.

PG&E Response to RAI 2.3.3.7-01 Three-way Solenoid Valve SV-526E provides the pressure boundary between the safety-related backup air supply tanks and the normal instrument air system. The two positions of Solenoid Valve SV-526E direct flow to Valve 1-PCV-20 from either the normal instrument air system (including Solenoid Valves SV-526A and SV-526B) or from the backup air tanks. When Solenoid Valve SV-526E.is positioned to one of the air sources, the other air source is isolated. Therefore, when Solenoid Valve SV-526E is positioned to direct flow from the backup air tanks, it acts as a pressure boundary so that a loss of air pressure in the normal instrument air system will not affect operation of Valve 1-PCV-19. The backup air systems are seismically designed and qualified with seismic anchors as indicated on the License Renewal Boundary Drawing LR-DCPP-25-106725-26.

The designs for Solenoid Valves SV-516A, SV-516B, SV-516E, and Valve 1-PCV-19 are the same as described above.

Enclosure 1 PG&E Letter DCL-10-104 Sheet 22 of 22 RAI 2.3.3.18-02 On license renewal boundary drawings LR-DCPP-23A-106723-03 and LR-DCPP-23A-10772303, the applicant depicts piping in scope for license renewal under 10 CFR 54.4(a)(2) going to and from the containment airsample supply and return, respectively at locations 37-0 and 37-C. Continuing onto license renewal boundary drawings LR-1 1-106711-06 (at locations 60-B and 66-B) and LR-1 1-1 07711-05 (at locations 50-B and 56-B), the piping directly attached to the 10 CFR 54.4(a)(2) piping is not highlighted as in scope for license renewal beyond the spatialinteractionflags. Additionally, the applicant did not identify an appropriateanchor on the attached nonsafety-related piping.

The staff requests that the applicantjustify its exclusion of the above mentioned piping to an appropriateanchor. The staff requests the applicantreview the attachedpiping to containment isolation valves to assure a properendpoint was established, to include seismic concerns in accordance with guidelines provided in NEI 95-10.

PG&E Response to RAI 2.3.3.18-02 T-he containment air sample panel serves as a terminal component for the lines from Boundary Drawings LR-DCPP-23A-106723-03 and LR-DCPP-23A-107723-03 that continue onto Boundary Drawings LR-DCPP-1 1-106711-06 and LR-DCPP-11-107711-05 respectively. Boundary Drawings LR-DCPP-11-106711-06 and LR-DCPP-1 1-1"07711-05 have been revised to show the panel as a terminal component.

There were no changes made to the' license renewal application.

PG&E Letter DCL-10-104 Page 1 of 6 LRA Amendment 11 LRA Section RAI Section 3.3.2.1.5 2.335-02 Table 2.3.3-5 2.3.3.5-02 Table 2.3.3-6 2.3-07 Table 3.3.2-5 2.3.3.5-02 Table 3.3.2-6 2.3-07

PG&E Letter DCL-10-104 Page 2 of 6 3.3.2.1.5 Makeup Water System Materials The materials of construction for the makeup water system component types are:

  • Elastomer Aging Effects Requiring Management The following makeup water system aging effects require management:
  • Hardening and loss of strength Section 3.2 PG&E Letter DCL-10-104 SCOPING AND SCREENING RESULTS Page 3 of 6 MECHANICAL SYSTEMS Table 2.3.3-5 Makeup Water System Component Type Intended Function Seal Pressure Boundary Tank (Internal Plenum) Pressure Boundary Section 3.2 PG&E Letter DCL-1 0-104 SCOPING AND SCREENING RESULTS Page 4 of 6 MECHANICAL SYSTEMS Table 2.3.3-6 Nuclear Steam Supply Sampling System Component Type Intended Function Heat Exchanger (Post LOCA Sample) Leakage Boundary (spatial)

StrLuetual Intdgrity (attalhod)

Regulators Leakage Boundary (spatial)

Section 3.3 PG&E Letter DCL-10-104 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 5 of 6 Table 3.3.2-5 Auxiliary Systems - Summary of Aging Management Evaluation - Makeup Water System Component Intended Material Environment Aging Effect Aging Management NUREG- Table I Item Notes Type Function Requiring Program 1801 Vol.

Management 2 Item Closure Bolting PB Stainless Demineralized Loss of preload Bolting Integrity (B2.1.7) None None H, 1 Steel Water (Ext)

Closure Bolting PB Stainless Demineralized Loss of material Water Chemistry VIII.E-29 3.4.1.16 C Steel Water (Ext) (B2.1.2) and One-Time Inspection (B2.1.16)

Seal PB Elastomer Demineralized Hardening and Inspection of Internal None None G Water (Ext) loss of strength Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)

Tank (Internal PB Stainless Demineralized Loss of material Water Chemistry VIII.E-29 3.4.1.16 C Plenum) Steel Water (Ext) (B2.1.2) and One-Time Inspection (B2.1.16)

Tank (Internal PB Stainless Demineralized Loss of material Water Chemistry VIII.E-29 3.4.1.16 C Plenum) Steel Water (Int) (B2.1.2) and One-Time Inspection (B2.1.16)

Section 3.3 PG&E Letter DCL-1 0-104 AGING MANAGEMENT OF AUXILIARY SYSTEMS Paae 6 of 6 Table 3.3.2-6 Auxiliary Systems - Summary of Aging Management Evaluation- Nuclear Steam Supply Sampling System Aging Effect Aging Management NUREG- Table I Item Notes Requiring Program 1801 Vol.

Management 2 Item rneat Loss of material Closed-Cycle Cooling VII.C2-10 3.3.1.50 D Exchanger Steel Cooling Water Water System (B2.l1.10)

(Post LOCA (Ext)

Sample)

Heat LBS,-SIA Stainless Closed Cycle Loss of material Closed-Cycle Cooling VII.C2-10 3.3.1.50 D Exchanger Steel Cooling Water (Int) Water System (B2.1.10)

(Post LOCA Sample)

Heat LBS,-,SIA Stainless Plant Indoor Air None None VII.J-15 3.3.1.94 A Exchanger Steel (Ext)

(Post LOCA Sample)

Heat LBS,-SIA Stainless Treated Borated Loss of material Water Chemistry VII.E1-17 3.3.1.91 E, 3 Exchanger Steel Water (Int) (B2.1.2) and One-Time (Post LOCA Inspection (B2.1.16)

Sample)

Regulators LBS Stainless Borated Water None None VII.J-16 3.3.1.99 A Steel Leakage (Ext)

Regulators LBS Stainless Treated Borated Loss of material Water Chemistry VII.El-17 3.3.1.91 E, 3 Steel Water (Int) (B2.1.2) and One-Time Inspection (B2.1.16)

Valve PBLBS Carbon Steel Closed Cycle Loss of material Closed-Cycle Cooling VII.C2-14 3.3.1.47 B Cooling Water (Int) Water System (B2.1.10)

Valve PBLBS Carbon Steel Plant Indoor Air Loss of material External Surfaces VII.I-8 3.3.1.58 B (Ext) Monitoring Program (B2.1.20)

Valve PBLBS Stainless Closed Cycle Loss of material Closed-Cycle Cooling VII.C2-10 3.3.1.50 B Steel Cooling Water (Int) Water System (B2.1.10)

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