DCL-10-162, Response to NRC Draft Request for Additional Information (Draft Set 34), Dated November 10, 2010, for the License Renewal Application

Response to NRC Draft Request for Additional Information (Draft Set 34), Dated November 10, 2010, for the License Renewal Application

ML103480589
Person / Time
Site:	Diablo Canyon
Issue date:	12/13/2010
From:	Becker J Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
DCL-10-162, OL-DPR-80, OL-DPR-82
Download: ML103480589 (6)

Text

Pacific Gas and Electric Company James R. Becker Diablo Canyon Power Plant Site Vice President Mail Code 104/ 5/ 601

p. O. Box 56 Avila Beach, CA 93424 805.545.3462 December 13,2010 Internal: 691.3462 Fax: 805.545.6445 PG&E Letter DCL-1 0-162 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 Draft Request for Additional Information (Draft Set 34), dated November 10,2010, for the Diablo Canyon License Renewal Application

Dear Commissioners and Staff:

By letter dated November 23, 2009 (Reference 1), 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 draft request for additional information dated November 10, 2010, the NRC staff requested additional information needed to continue their review of the DCPP LRA.

On November 18, 2010 a telephone conference between the NRC and representatives of PG&E was held to obtain clarification on PG&E's response to the request for additional information (RAI) submitted to the NRC in PG&E Letter DCL-10-126, dated September 30, 2010, regarding the Structures Monitoring Aging Management Program.

PG&E's supplemental information to the RAI response for which the staff requested information is provided in Enclosure 1. PG&E revises a commitment in amended LRA Table A4-1, License Renewal Commitments, shown in Enclosure 2. LRA Amendment 32 is included in Enclosure 2 showing the changed pages with line-in/line-out annotations.

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

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

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

Document Control Desk PG&E Letter DCL-10-162 December 13,2010 Page 2 I declare under penalty of perjury that the forego ing is true and correct.

Executed on December 13,2010.

Site Vice President TLG/50365158 Enclosures cc: Diablo Distribution cc/enc: Elmo E. Collins, NRC Region IV Regional Administrator Nathanial B. Ferrer, NRC Project Manager, License Renewal Kimberly J. Green, NRC Project Manager, License Renewal Michael S. Peck, NRC Senior Resident Inspector Alan B. Wang, NRR Project Manager A member of the STARS * (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

Enclosure 1 PG&E Letter DCL-10-162 Page 1 of 2 Diablo Canyon Nuclear Power Plant, Units 1 and 2 (DCPP)

License Renewal Application (LRA)

Draft Request for Additional Information (RAI) Set 34 Aging Management Programs D-RAI B2.1.32-1 (follow-up)

Background:

By letter dated September 30, 2010, the applicant responded to follow-up RAI B2.1.32-1 regarding the Structures Monitoring Program acceptance criteria. In the response, the applicant stated that prior to the period of extended operation, the acceptance criteria for concrete structural elements for safety-related structures will be revised to incorporate the quantitative evaluation criteria provided in ACI 349.3R.

Issue:

The qualitative acceptance criteria should apply to all concrete elements within the scope of the Structures Monitoring Program; however, the applicants response only addresses safety-related structures. In addition, the response makes no mention of conducting a baseline inspection with qualitative acceptance criteria. In order to properly monitor and trend structural degradation during the period of extended operation, a baseline inspection in accordance with ACI 349.3R acceptance criteria, must be completed prior to the period of extended operation.

Request:

1) Update the acceptance criteria for all in-scope concrete elements or justify why it is not needed.

2) Provide plans and a schedule to conduct a baseline inspection in accordance with the ACI 349.3R acceptance criteria prior to the period of extended operation, or justify why a baseline inspection is not needed.

PG&E Response to D-RAI B2.1.32-1 (follow-up)

1) By Pacific Gas and Electric Company (PG&E) Letter DCL-10-126, dated September 30, 2010, PG&E responded to follow-up RAI B2.1.32-1 regarding the Structures Monitoring Program acceptance criteria. In the response, PG&E stated that prior to the period of extended operation, the acceptance criteria for concrete structural elements for safety-related structures will be revised to incorporate the quantitative evaluation criteria provided in American Concrete Institute (ACI ) 349.3R.

In response to RAI B2.1.32-1 (follow-up), prior to the period of extended operation, the acceptance criteria for concrete structural elements provided in the implementing procedures for the Structures Monitoring Program for both safety and non-safety related structures, will be revised to incorporate the quantitative

Enclosure 1 PG&E Letter DCL-10-162 Page 2 of 2 evaluation criteria provided in ACI 349.3R, Evaluation of Existing Nuclear Safety Related Concrete Structures, Chapter 5, Evaluation Criteria. See amended LRA Table A4-1 in Enclosure 2.

2) PG&E will conduct a baseline inspection of all safety and non-safety related structures concrete elements (in the scope of the Structures Monitoring Program) in accordance to ACI 349.3R acceptance criteria prior to entering the period of extended operation. See amended LRA Table A4-1 in Enclosure 2.

PG&E Letter DCL-10-162 Page 1 of 2 LRA Amendment 32 LRA Section RAI Table A4-1 D-RAI B2.1.32-1 (follow-up)

Appendix A PG&E Letter DCL-10-162 Final Safety Analysis Report Supplement Page 2 of 2 Table A4-1 License Renewal Commitments Item # Commitment LRA Implementation Section Schedule 43 Prior to the period of extended operation, the acceptance criteria for concrete B2.1.32 Prior to the period structural elements provided in the implementing procedures for the Structures of extended Monitoring Program for both safety and non-safety related structures, will be operation revised to incorporate the quantitative evaluation criteria provided in ACI 349.3R, Evaluation of Existing Nuclear Safety Related Concrete Structures, Chapter 5, Evaluation Criteria.

55 PG&E will conduct a baseline inspection of all safety and non-safety related B2.1.32 Prior to the period structures concrete elements (in the scope of the Structures Monitoring Program) of extended in accordance to ACI 349.3R acceptance criteria prior to entering the period of operation extended operation.