DCL-13-080, Pacific Gas and Electric Company'S First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

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Pacific Gas and Electric Company'S First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
ML13235A103
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 08/22/2013
From: Allen B
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-13-080, EA-12-051
Download: ML13235A103 (8)
v • d • e


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 August22,2013 Internal: 691.4888 Fax: 805.545.6445 PG&E Letter DCL-13-080 U.S. Nuclear Regulatory Commission 10 CFR 50.4 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 Pacific Gas and Electric Company's First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)

References:

1. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012
2. NRC Interim Staff Guidance JLD-ISG-2012-03, "Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation," Revision 0, dated August 29, 2012
3. PG&E Letter DCL-12-028, "Pacific Gas and Electric Company's Answer to March 12, 2012, Commission Order Modifying License with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 )," dated March 28, 2012
4. PG&E Letter DCL-13-011, "Pacific Gas and Electric Company'sOverall Integrated Plan in Response to March 12,2012, Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 )," dated February 27, 2013
5. PG&E Letter DCL-13-073, "Response to Request for Additional Information Regarding Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify License with Regard to Reliable Spent Fuel pool Implementation (Order Number EA-12-051 )," dated July 18, 2013.

Dear Commissioners and Staff:

On March 12, 2012, the Nuclear Regulatory Commission issued Reference 1 to Pacific Gas and Electric Company (PG&E). Reference 1 directs PG&E to have a reliable indication of the water level in associated spent fuel pools (SFPs). Specific requirements are outlined in Reference 1, Attachment 2.

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

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

Document Control Desk PG&E Letter DCL-13-080 August22,2013 Page 2 Reference 1 required submission of an initial status report 60 days following issuance of Reference 2 and an overall integrated plan pursuant to Section IV, Condition C. Reference 3 provided PG&E's consent to Reference 1. Reference 4 provided PG&E's overall integrated plan. Reference 5 provided PG&E's response to a request for additional information regarding the overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. The enclosure to this letter provides PG&E's first six-month status report pursuant to Section IV, Condition C.2 of Reference 1.

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

This letter includes no revisions to existing regulatory commitments.

If you have any questions, or require additional information, please contact Mr. Patrick Nugent at (805) 781-9786.

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

Executed on August 22, 2013.

Sincerely, Ba~7.n 5. AIL-Site Vice President crl b/SAP N 50465912-12 Enclosure cc: Diablo Distribution cc:/enc: Eric E. Bowman, NRC/NRR/DPR/PGCB Thomas R. Hipschman, NRC Senior Resident Inspector Jessica A. Kratchman, NRC/NRR/JLD/PMB Eric J. Leeds, NRC/NRR Director Eileen M. Mckenna, NRC/NRO/DSRAlBPTS Jennivine K. Rankin, NRC/NRR Project Manager Steven A. Reynolds, Acting NRC Region IV A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

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

PG&E Letter DCL-13-080 Enclosure Page 1 of 6 Pacific Gas and Electric Company's First Six-Month Status Report for the Implementation of Order 2 ..051 1 Introduction Pacific Gas and Electric Company (PG&E) developed an overall integrated plan (alP)

(Reference 1 [Refer to Section 9 of this enclosure for a list of references.]), which includes a description of how compliance with the requirements described in Reference 2, Attachment 2 will be achieved. This enclosure provides an update of milestone accomplishments since submittal of Reference 1, including any changes to the compliance method, schedule, or need for relief and the basis, if any.

2 Milestone Accomplishments The following milestones have been completed since the development of the 01 P (Reference 1) and are current as of July 31,2013:

On July 18, 2013, PG&E responded to a Nuclear Regulatory Commission (NRC) request for additional information (RAI) regarding the alP for reliable spent fuel pool (SFP) instrumentation (Reference 3).

In addition, commencement of Unit 1 and Unit 2 engineering and design has been completed.

3 Milestone Schedule Status The following table provides an update to the milestone schedule. It provides the activity status of each item, and whether the expected completion date has changed.

The dates are subject to change as design and implementation details are developed.

There were no changes to the original target completion dates.

Original Target Target Activity Completion Milestone Completion Status Date Date Changes Submit 60-day progress report 10/2012 Complete Submit overall integrated plan 2/2013 Complete Submit six-month updates Update 1 8/2013 Complete Update 2 2/2014 Not started Update 3 8/2014 Not started Update 4 2/2015 Not started Update 5 8/2015 Not started

PG&E Letter DCL-13-080 Enclosure Page 2 of 6 Original Target Target Activity Completion Milestone Completion Status Date Date Changes Update 6 2/2016 Not started Update 7 8/2016 Not started Request for Additional Information Submit RAI response 7/22/2013 Complete Commence Unit 1 engineering and 3/31/13 Complete design Commence Unit 2 engineering and 3/31/13 Complete design Develop Unit 1 design 3/31/14 Started Develop Unit 2 design 3/31/14 Started Receipt of Unit 1 SFP instruments 12/31/14 Not Started Receipt of Unit 2 SFP instruments 12/31/14 Not Started Complete Unit 1 SFP instrumentation procedures and 10/29/15 Not Started training Complete Unit 2 SFP instrumentation procedures and 5/31/16 Not Started training Unit 1 SFP instruments operational 10/29/15 Not Started

. Unit 1 SFP instruments operational 5/31/16 Not Started 4 Changes to Compliance Method The following identifies a change to Reference 1 and the reason for the change. The change meets applicable NEI 12-02 compliance methods.

Change 1 - Key SFP Water Levels Corrected SFP Level 1 from 133 feet to 134 feet 5 inches, which is consistent with PG&E's response to an NRC RAI pertaining to reliable SFP instrumentation (Reference 3). .

5 Need for Relief and Basis for the Relief PG&E expects to comply with the implementation date in the Order. No relief is being requested at this time.

6 Open Items from Overall Integrated Plan None

PG&E Letter DCL-13-080 Enclosure Page 3 of 6 7 Open Items from the Request for Additional Information PG&E submitted a response to an RAI regarding the reliable SFP instrumentation OIP (Reference 3). In its response, PG&E committed to provide a status update of the information necessary to complete its response to the RAls.

The following provides a summary and status of the RAI open items.

The specific locations of the probes will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

(1) Final dimensions of the pedestal and bracket will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

(2) Final dimensions of the bracket will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

(1) An estimate of the expected instrument channel accuracy under normal and beyond-design-basis conditions will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

(2) The calibration procedure, and the methodology and basis for establishing both the criteria indicating the need for recalibration, and the acceptance criterion to be used with the procedure, will be established during the design verification phase. The methodology for defining these criteria will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

PG&E Letter DCL-13-080 Enclosure Page 4 of 6 (1) Details of the capabilities and provisions of the level instrumentation for periodic calibration and testing will be established during the detailed design phase. A description of these features and the way they will support in-situ testing will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

(2) A description of how the instrument channel design provides for routine in-situ testing and calibration will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

(3) Details of functional checks and instrument channel calibrations will be determined during the detailed design phase. A description of how functional checks and calibration tests will be performed, and the frequency at which they will be conducted, will be provided in the six-month update following completion of detailed design. An explanation of how these surveillances will be incorporated into the plant surveillance program will be included.

Status: Detailed design has been completed.

(4) The preventative maintenance tasks required to be performed during normal operation, and the planned surveillance intervals will be determined during the detailed design phase. A description of these tasks and intervals will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

RAI-10

A list of the operating (both normal and abnormal response) procedures, calibration/test procedures, maintenance procedures, and inspection procedures will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

PG&E Letter DCL-13-080 Enclosure Page 5 of 6

RAI-11

(1) PG&E will provide a description of the maintenance and testing program, and a description of the plans for ensuring that necessary channel checks, functional tests, periodic calibration, and maintenance will be conducted for the level measurement system and its supporting equipment. The descriptions will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

(2) PG&E will implement measures to minimize the possibility of either the primary or backup channel being out of service for an extended period. Sufficient spares, components, and materials will be maintained to be able to repair or replace defective components in a short time. Descriptions of these measures will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

(3) PG&E will follow the NEI 12-02 guidance with regard to time during which one or more channels may be out of service, including compensatory actions. A description of the compensatory actions will be provided in the six-month update following completion of detailed design.

Status: Detailed design has not been completed.

8 Potential Safety Evaluation Report Impacts There are no potential impacts to the Draft Safety Evaluation Report identified at this time.

9 References The following references support the updates to the OIP described in this document.

1. PG&E Letter DCL-13-011, "Pacific Gas and Electric Company's Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051 ),"

dated February 27, 2013

2. NRC Order Number EA-12-051, "Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation," dated March 12, 2012

PG&E Letter DCL-13-080 Enclosure Page 6 of 6

3. PG&E Letter DCL-13-073, "Response to Request for Additional Information Regarding Overall Integrated Plan in Response to March 12, 2012, Commission Order to Modify License with Regard to Reliable Spent Fuel pool Implementation (Order Number EA-12-051 )," dated July 18, 2013
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