DCL-12-117, 2011 Annual Commitment Change Summary Report

2011 Annual Commitment Change Summary Report

ML12326A472
Person / Time
Site:	Diablo Canyon
Issue date:	11/20/2012
From:	Allen B Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
DCL-12-117
Download: ML12326A472 (12)

Text

Pacific Gas and Electric Company Barry S. Allen Diablo Canyon Power Plant Site Vice President Mail Code 104/6 P. O. Box 56 Avila Beach, CA 93424 805. 545. 4888 November 20,2012 Internal: 691. 4888 Fax: 805.545.6445 PG&E Letter DCL-12-117 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 2011 Annual Commitment Change Summary Report

Dear Commissioners and Staff:

In accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes," Revision 0, endorsed by the U. S. Nuclear Regulatory Commission (NRC) in SECY-00-0045, "Acceptance Of NEI 99-04, 'Guidelines for Managing NRC Commitments', " Pacific Gas and Electric Company (PG&E) is submitting the enclosed summary of regulatory commitment changes report for Diablo Canyon Power Plant, Units 1 and 2. The report provides a summary of the regulatory commitment changes that were considered by NEI 99-04 to require notification and occurred during the period January 1, 2011, through December 31,2011. The summary for each change identifies the source document(s), describes the original and revised commitments, and justifies the change. In cases where the Original Commitment and the Revised Commitment are both listed, the relevant changes are marked in bold text.

PG&E processed the regulatory commitment changes described in the report in accordance with the NEI guideline, and determined that they did not require prior NRC approval. The report does not include commitment changes that are contained in 10 CFR 50.59 evaluation summary reports, or in other submittals previously transmitted to the NRC.

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

If you have any questions or require additional information, please contact Steven Zawalick at (805) 545-4040.

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-12-117 November 20, 2012 Page 2 sszl64018345 Enclosure cc/enc: Elmo E. Collins, NRC Region IV Laura H. Micewski, Acting NRC Senior Resident Inspector Joseph M. Sebrosky, NRR Senior 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

PG&E Letter DCL-12-117 Enclosure

SUMMARY

OF REGULATORY COMMITMENT CHANGES JANUARY 1,2011, THROUGH DECEMBER 31,2011 CONTENTS Item Commitment Subject 1.0 CVCS Resin Tagout Process 2.0 Respirator Checkout 3.0 PORV Discharge Temperature Calibration 4.0 Accumulator Nozzle Inspections 5.0 Backdraft Damper Maintenance and Testing Commitments 6.0 Elimination of Life Safety Wardens 7.0 Silica Sampling In the Spent Fuel Pool 8.0 RCS Leak Test

PG&E Letter DCL-12-117 Enclosure 1.0 Chemical and Volume Control System (CVCS) Resin Tagout Process Source Document(s)

DCL-93-214 NCR N0001751 AR A0309856 Original Commitment CVCS demineralizers instruction Operating Procedure (OP) B-1A:XIII has been revised and re-titled to include instructions for all CVCS demineralizers. The changes include a new requirement to place an administrative tagout on any demineralizer that is in standby service. By procedure, an administrative tagout will specify conditions, such as boron concentration, that existed when demineralizer bed was last in service.

The changes also include requirements for when a demineralizer must be rinsed or flushed and instructions for pre-service flushing for each type of demineralizer prior to placement into service.

Revise applicable operating procedures to provide precautions on potential dilutions from CVCS charging paths.

Revised Commitment CVCS demineralizers instruction OP B-1 A:XIII has been revised and re-titled to include instructions for all CVCS demineralizers. The changes include a new requirement to place an administrative tagout on any demineralizer that is in standby service.

By procedure, an administrative tagout will specify conditions, such as boron concentration, that existed when demineralizer bed was last in service.

If the resin is depleted, a shift foreman (SFM) configuration control clearance should be used. For the cation demineralizer, a SFM configuration control clearance is required if it will not be placed in service within the next 7 days, such as a scheduled outage or curtailment.

The changes also include requirements for when a demineralizer must be rinsed or flushed and instructions for pre-service flushing for each type of demineralizer prior to placenient into service.

Revise applicable operating procedures to clarify operation of eves demineralizers during refueling outages.

Revise applicable operating procedures to provide precautions on potential dilutions from CVCS charging paths.

Justification for Change These changes clarified the expectations for tagout for depleted resins to prevent detrimental reactivity impacts. The requirements for the cation demineralizer isolation provide some flexibility for daily chemistry use while providing restrictions consistent with plant procedure OP B-1A:XIII, again to prevent a boron concentration differential from impacting the plant.

PG&E Letter DCL-12-117 Enclosure 2.0 Respirator Checkout Source Documents ARA0466264 DCL-98-176 Original Commitment Manual checkout for respirators In lieu of this action (a computer controlled respirator issue system), Pacific Gas and Electric (PG&E) has issued a foreman's expectation for issuing respiratory protection equipment that will require a manual check out method for respirators. This will verify that individuals receive the same size respirator that was used for fit testing. A valid respirator fit card will be required for respirator issuance. In the past, the respirator cards were used as a backup to the computer but will now be the primary means for issuing correct respirators.

PG&E may implement the computer program modification at a later time which will allow the computer to be used as the primary means for issuing respirators; however, in the interim, the actions taken will provide assurance that the correct respirators are issued.

Although not specifically stated in DCL-98-176 the requirement to manually verify the respirator size against the respirator fit card will be proceduralized per agreement with the RP director.

Revised Commitment This commitment was retired.

Justification for Change The commitment was created as an interim measure when a weakness was identified in earlier software that could allow issuance of an improperly sized respirator.

Since January of 2010, PG&E has used the Sentinel software program for issuing respirators. This software has controls that preclude this weakness from being an issue. If a respirator must be issued manually, detailed checks for qualification, name, 10, keycard number, respirator type, proper size, etc. are performed.

PG&E Letter DCL-12-117 Enclosure 3.0 Power-Operated Relief Valve (PORV) Discharge Temperature Calibration Source Documents DCL-89-144 LER 1-86-024-00 NCR NOOO 1279 Original Commitment Inclusion of Surveillance Requirements Surveillance Test Procedure (STP) 1-83C, "Calibration of Pressurizer PORV Temperature Channel 463," was added to the recurring task scheduler (RTS), and Abnormal Procedure (AP) C-3S1, "Surveillance Testing and Inspection," Attachments 6.3 and 6.4 of the master markup was modified to include the surveillance requirement. (STP 1-83C from RTS)

Revised Commitment This commitment was retired.

Justification for Change This commitment was created in 1993 when we discovered that we had neglected to create a required surveillance test.

These calibration requirements have been recognized and institutionalized consistent with our equipment control guideline (ECG) program and our ECG 7.8 requires this calibration every 24 months. Since the requirement for calibration is driven by the ECGs, the commitment is secondary, redundant, and, therefore, unnecessary.

PG&E Letter DCL-12-117 Enclosure 4.0 Accumulator Nozzle Inspections Source Documents AR A0241388-E27 DCL-93-266 LER 2-87-023-02 NCR DC2-91-TN-N075 Original Commitment EXAMINE ACCUMULATOR NOZZLES FOR CRACKS MONTHLY Revise the operations monthly inspection procedure to examine all accessible accumulator nozzles and underskirt piping for evidence of boric acid crystals that could indicate through wall cracks.

Revised Commitment This commitment was retired.

Justification for Change A plant evaluation has concluded that routine inservice inspections (ISis) are sufficient as the affected population has decreased through replacement, an efficient early detection technique is being used, the degradation mechanism is clearly defined, and inspections are performed more frequently than required.

PG&E Letter DCL-12-117 Enclosure 5.0 Backdraft Damper Maintenance and Testing Commitments Source Documents DCL-92-068 DCL-92-134 DCL-92-161 LER 1-91-019-00 LER 1-91-019-01 NCR N0001627 Original Commitment These two commitments (T34927 and T34928) established requirements for backdraft surveillance testing and maintenance.

Revised Commitment Both commitments were deleted.

Justification for Change A design change used mechanical anti-reverse rotation hardware and eliminated the backdraft dampers.

PG&E letter DCl-12-117 Enclosure 6.0 Elimination of Life Safety Wardens Source Documents DCl-OS-OS8 A0633773 Original Commitment Diablo Canyon Power Plant (DCPP) has a medical staff, including Life Safety Wardens and fire fighters who are Emergency Medical Technician (EMT) qualified. In addition, we have a medical facility, medical supplies, and an ambulance. A Memorandum of Understanding with local medical providers was made to address transportation issues for mass casualties.

Revised Commitment DCPP has a medical staff and firefighters who are Emergency Medical Technician (EMT) qualified. In addition, we have a medical facility, medical supplies, and an ambulance. A Memorandum of Understanding with local medical providers was made to address transportation issues for mass casualties.

Justification for Change Equivalent capabilities for onsite mass casualty response are available. We have memoradums of understanding with local providers of medical service, including ambulance capability. Individuals of our onsite fire and operations staff have either EMT or first aid and CPR qualifications.

PG&E Letter DCL-12-117 Enclosure 7.0 Silica Sampling In the Spent Fuel Pool Source Document DCL-96-215 Original Commitment SILICA SAMPLING IN SPENT FUEL POOL

1) Monthly silica samples will continue to be taken as part of the spent fuel pool silica trending program.

In addition,

2) A pool silica sample will be taken within one week prior to placing new fuel into the spent fuel pool for each refueling outage to ensure that there have been no sudden changes in the silica release rate.

Revised Commitment SILICA SAMPLING IN SPENT FUEL POOL

1) Take monthly silica samples as part of the spent fuel pool silica trending program.

Justification for Change This commitment was made to monitor for Boraflex degradation. License Amendment 154/154 removed the requirement for Boraflex in the spent fuel pool storage racks and allowed the use of credit for soluble boron in the spent fuel pool criticality analysis. Since DCPP no longer takes credit for the Boraflex, we no longer need to monitor for degradation. The monthly sample is continued for purposes of general silica monitoring.

PG&E Letter DCL-12-117 Enclosure 8.0 Reactor Coolant System (RCS) Leak Test Source Document(s)

DCL-88-143 DCL-03-008 GEN 88-05 Original Commitment Identification of leaks in the reactor coolant pressure boundary (RCPB): Boric Acid Generic Letter 88-05

1. Following each refueling outage, STP R-8A, "Reactor Coolant System Leakage Test," is performed to assure the leak integrity of the RCPB. This test includes a 4-hour "soak time" at normal operating pressure. An examination of all joints opened and closed since the last such test (minimum requirements) is performed using the ASME code require lSI examination technique discussed in procedure lSI VT 2-1, "Visual Examination During Section XI System Pressure Test." While removal of insulation is not required under STP R-8A, detailed instructions are contained in lSI VT 2-1 which should provide for discovery of any boric acid leaks with insulation in place. The acceptance criteria for STP R-8A include a statement that borated water shall not touch carbon steel fasteners and that the proximity of borated water to other components which may be damaged through corrosion or solidification of the boric acid should be evaluated.

2. STP R-8A provides for an inspection of the RCPB following each refueling outage to identify leaks. The principal locations identified in response to item 1 {detailed review of RCPB components to identify principal locations for small leaks and carbon steel pressure boundary components which may be susceptible to degradation due to leakage} above (have been) incorporated into STP R-8A, as appropriate.

3. STP R-8A is performed on a refueling outage frequency for those components that have been opened and closed since the last test. lSI procedure VT 2-1 is required by STP R-8A to document the results of the required visual RCS examination. lSI procedure VT 2-1 requires that an evaluation for wall thickness and/or continued serviceability be performed as corrective action when corrosion of carbon steel components on the RCPB are discovered which indicates abnormal reactor coolant leakage. The administrative procedure being developed will include this requirement and will also require that necessary information for an engineering evaluation be promptly gathered before removal of evidence of abnormal leakage, such as boric acid crystal buildup.

Revised Commitment Identification of leaks in the RCPB: Boric Acid Generic Letter 88-05

1. Following each refueling outage, STP R-8A, "Reactor Coolant System Leakage Test" is performed to assure the leak integrity of the RCPB. This test is performed at normal operating pressure and encompasses the entire ASME class 1 pressure boundary. The test is accomplished using the ASME code required lSI examination technique discussed in procedure lSI VT 2-1, "Visual Examination During Section XI System Pressure Test." While removal of insulation is not required under STP R-8A, detailed instructions are contained in lSI VT 2-1 which should provide for discovery of any boric acid leaks with insulation in place. The acceptance criteria for STP R-8A include a statement that borated water shall not touch carbon steel fasteners and that the proximity of borated water to other components which may be damaged through corrosion or solidification of the boric acid should be evaluated.

PG&E Letter DCL-12-117 Enclosure

2. STP R-BA provides for an inspection of the RCPS following each refueling outage to identify leaks. The principal locations identified in response to item 1 {detailed review of RCPS components to identify principal locations for small leaks and carbon steel pressure boundary components which may be susceptible to degradation due to leakage} above (have been) incorporated into STP R-BA, as appropriate.

3. STP R-8A is performed on a refueling outage frequency and encompasses the entire ASME class 1 pressure boundary. lSI procedure VT 2-1 is required by STP R-BA to document the results of the required visual RCS examination. lSI procedure VT 2-1 requires that an evaluation for wall thickness and/or continued serviceability be performed as corrective action when corrosion of carbon steel components on the RCPS are discovered which indicates abnormal reactor coolant leakage. The administrative procedure being developed will include this requirement and will also require that necessary information for an engineering evaluation be promptly gathered before removal of evidence of abnormal leakage, such as boric acid crystal buildup.

Justification for Change DCPP is committed to ASME Section XI Code, 2001 Edition with Addenda through 2003 for the third lSI interval. There is currently no Code requirement for the four hour full pressure hold time prior to walkdown of the Class 1 pressure boundary - Ref. Subsection IWA-5213(a): "For Class 1 components (lWS-2500-1, Examination Category S-P), no holding time is require after attain test pressure ... "

The "4-hour soak time at normal operating pressure" was previously used to satisfy the Code required hold time for hydrostatic testing of insulated repairs and replacement (R&R) per Code Case N-416 at normal operating pressure. This process allowed for concurrent inspection of R&R items in conjunction with the Class 1 system leakage test. Additionally, the four hour "soak time" satisfied a requirement associated with installation of control rod drive mechanism canopy seal weld clamps. These devices were used to repair small leaks in the canopy seal welds of the original reactor heads. This issue does not apply to the currently installed replacement heads.

Going forward, STP R-BA will specify that the Class 1 system leakage test may commence upon reaching normal operating pressure. VT-2 examinations of insulated repairs and replacement will be scheduled at the end of the system leakage test after the Code required four hour hold at full pressure has been satisfied for those components requiring the test specified by IWA-4540.