DCL-11-002, Response to Telephone Conference Call Held on December 9, 2010, Between the NRC and Pacific Gas and Electric Company Concerning Responses to Requests for Additional Information Related to License Renewal Application

Response to Telephone Conference Call Held on December 9, 2010, Between the NRC and Pacific Gas and Electric Company Concerning Responses to Requests for Additional Information Related to License Renewal Application

ML110240237
Person / Time
Site:	Diablo Canyon
Issue date:	01/21/2011
From:	Becker J Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-11-002
Download: ML110240237 (7)

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 Internal: 691.3462 January 21, 2011 Fax: 805.545.6445 PG&E Letter DCL-11-002 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 1 and 2 Response to Telephone Conference Call Held on December 9, 2010, Between the U.S. Nuclear Regulatory Commission and Pacific Gas and Electric Company Concerning Responses to Requests for Additional Information Related to the Diablo Canyon Nuclear Power Plant, Units 1 and 2, 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 Units 1 and 2, respectively. The application included the license renewal application, and Applicant's Environmental Report - Operating License Renewal Stage. .

On December 9, 2010, a telephone conference call between the NRC and representatives of PG&E was held to obtain clarification on PG&E's response to a request for additional information (RAI) submitted to the NRC in PG&E Lettet DCL-1 0-148, dated November 24, 2010, regarding RAI B2.1.18-2 (Follow-up).

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, provided in Enclosure 2. LRA Amendment 36 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 ~anyon

• Palo Verde

• San Onofre

• South Texas Project

• Wolf Creek

Document Control Desk PG&E Letter DCL-11-002 January 21, 2011 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 21, 2011.

Sin~erely, Site Vice President TLG/50367233 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, NRC Licensing 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-11-002 Page 1 of 2 PG&E Supplements to Telephone Conference Call Held on December 9, 2010, Concerning a Response to Request for Additional Information (RAI)

Submitted to the NRC in a Letter Dated November 24, 2010, Regarding RAI B2.1.18-2 (Follow-up)

RAI B2.1.18-2 (Follow-up)

In a telephone conference call held on December 9, 2010, the NRC requested additional information regarding buried makeup water piping and components discussed in PG&E Letter DCL-10-148. Clarification was requested as to how copper components would be managed. In addition, the NRC requested clarification on the type of ultrasonic testing that will be conducted on excavated piping.

PG&E agreed to supplement the response to RAI B2.1.18-2 (Follow-up).

PG&E Supplement to RAI B2.1.18-2 (Follow-up)

PG&E Letter DCL-10-148, dated October 3, 2010, describes a short segment of in-scope, non-cathodically protected carbon steel piping contained inside a valve pit in contact with soil. Upon further review of the in-scope, makeup water piping, it was determined that the piping associated with valves MU-0-884, MU-0-883 and their associated traps are not required to be in scope for license renewal. This piping and its valves were originally in scope to perform a pressure boundary function to maintain the fluid level of the raw water storage reservoirs (RWSRs). The RWSRs provide water for fire protection of safety-related systems and long-term cooling.

The flow path of piping in line with MU-0-881 does not provide either license renewal function. The in-scope piping now ends at valve MU-0-881; shown on license renewal boundary drawing LR-DCPP-16-106716-11, coordinate C-113.

The RWSRs are equipped with low-level alarms that would notify Operations that an action is required. If the pressure boundary were to be compromised in the out-of-scope portion of makeup water piping, valve MU-0-881 could be closed to maintain the RWSR capacity. PG&E will enhance the operating procedures to provide direction to evaluate and close valve MU-0-881 as appropriate in case of a pressure boundary failure further along the flow path or in the event the RWSRs are in use for long-term cooling. See LRA Table A4-1 in Enclosure 2.

As indicated in PG&E letter DCL-10-097, dated August 2, 2010, the in-scope copper valves MU-0-267, MU-0-268, and MU-0-273 will be managed by the GALL Aging Management Program (AMP), XI.M34, Buried Piping and Tanks Inspection. PG&E has amended commitment No. 52, in LRA Table A4-1, to provide additional information regarding the inspection frequency of these valves. See amended LRA Table A4-1.

Enclosure 1 PG&E Letter DCL-11-002 Page 2 of 2 PG&E has also commitment No. 52, in LRA Table A4-1, to add clarification on the type of ultrasonic testing that will be conducted on excavated piping. See amended LRA Table A4-1 in Enclosure 2.

PG&E Letter DCL-11-002 Page 1 of 3 LRA Amendment 36 LRA Section Table A4-1 Appendix A PG&E Letter DCL-11-002 Final Safety Analysis Report Supplement Page 2 of 3 Table A4-1License Renewal Commitments Item # Commitment LRA Implementation Section Schedule 52 The Buried Piping and Tanks Inspection Program will be revised to include the following inspections that will be conducted during each 10-year period beginning 10 years prior to the entry in the period of extended operation. Examinations of buried piping and tanks will consist of visual inspections as well as non-destructive examination (e.g. ultrasonic examination capable of measuring wall thickness) to perform an overall assessment of the condition of buried piping and tanks.

Each inspection will examine either the entire length of a run of pipe or a minimum of 10 feet. If the number of inspections times the minimum inspection length (10 feet) exceeds 10 percent of the length of the piping under consideration, only 10 percent will need to be inspected. If the total length of the in-scope pipe constructed of a given material Prior to the period of B2.1.18 times the percentage to be inspected is less than 10 feet, either 10 feet extended operation or the total length of pipe present, whichever is less will be inspected.

Inspections of Buried Piping Based on Material and Environment Combinations Fire mains will be subject to a periodic flow test in accordance with NFPA 25 section 7.3 at a frequency of at least one test in each one year period. These flow tests will be performed in lieu of excavating buried portions of Fire Water pipe for visual inspections.

For cathodically-protected metallic piping, at least one excavation and visual inspection of steel piping will be conducted. Cathodically-protected steel piping within the scope of license renewal exists in the Appendix A PG&E Letter DCL-11-002 Final Safety Analysis Report Supplement Page 3 of 3 Table A4-1License Renewal Commitments Item # Commitment LRA Implementation Section Schedule Auxiliary Salt Water (ASW) system intake lines.

For non cathodically-protected buried metallic piping, at least four excavations and visual inspections of steel piping will be conducted.

At least one excavation and visual inspection of buried copper valves will be conducted. Non Cathodically-protected steel piping within the scope of license renewal exists in the ASW system discharge lines and Makeup Water system. Buried copper valves exist within the Makeup Water system.

For non metallic piping, at least one excavation and visual inspection each of polyvinyl chloride (PVC) and Asbestos Cement Pipe (ACP) will be conducted. PVC piping within the scope of license renewal exists in the Fire Water system. Asbestos cement piping within the scope of license renewal exists in the Fire Water system and Make-up Water system.

63 PG&E will enhance the operating procedures to provide direction to B2.1.18 Prior to the period of evaluate and close valve MU-0-881 as appropriate. extended operation