DCL-14-056, 2013 Annual Commitment Change Summary Report

2013 Annual Commitment Change Summary Report

ML14174A928
Person / Time
Site:	Diablo Canyon
Issue date:	06/23/2014
From:	Allen B Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-14-056, NEI 99-04
Download: ML14174A928 (4)

Text

Pacific Gas and Electric Company Barry S. Allen Diablo Canyon Power Plant Site Vice President Mail Code 104/6 P. 0. Box 56 June 23, 2014 Avila Beach, CA 93424 805.545.4888 Internal: 691.4888 PG&E Letter DCL-14-056 Fax: 805.545.6445 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 2013 Annual Commitment Change Summary Report

Dear Commissioners and Staff:

In accordance with Nuclear Energy Institute (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 the Regulatory Commitment Changes R~port 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, 2013, through

• December 31, 2013. The summary for each change identifies the source document(s), describes the original and revised commitments, and justifies the change.

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 Mr. Joe Loya at (805) 545-4486.

Sincerely,

,~~ S . #t--

sarry S. Allen A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• Wolf Creek

Document Control Desk PG&E Letter DCL-14-056 June 23, 2014 Page 2 J8L3/64093879 Enclosure cc/enc: Peter J. Bamford, NRR Project Manager Marc L. Dapas, NRC Region IV Administrator Thomas R. Hipschman, NRC Senior Resident Inspector A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• Wolf Creek

PG&E Letter DCL-14-056 Enclosure

SUMMARY

OF REGULATORY COMMITMENT CHANGES JANUARY 1, 2013, THROUGH DECEMBER 31, 2013 CONTENTS Item Commitment Subject 1.0 Safety System Outage Modification Inspections (SSOMI)

Assessment of Design Activities

PG&E Letter DCL-14-056 Enclosure 1.0 Safety System Outage Modification Inspections Assessment of Design Activities Source Document(s)

PG&E Letter DCL-89-1 00 Original Commitment

1. Guidance will be provided to initiate the process, Safety System Outage Modification Inspection (SSOMI)

Assessment of design activities, at least 30 days prior to scheduled plant outage start dates. Quality Support (QS) Work Instruction QS-20, which provides this guidance, was revised on April 13, 1989.

2. Quality Assurance (QA) will establish formal SSOMI follow-up assessments to assure potential problems or generic problems are fully evaluated subsequent to the conduct of a SSOMI. QS Work Instruction QS-22 establishing this requirement was issued December 6, 1988.

3. Potential Safety System Functional Audit and Review (SSFAR) problems are required to be investigated for cause determination, generic implications, and corrective actions in accordance with Quality Assurance Procedure (QAP) 18.C.

4. The SSOMI team leader will not be assigned specific design changes for assessment to assure that such design changes get the full attention of a team member (in order to increase the team leader's ability to observe installation activities). This will also assure that the team leader may fully devote his attention to the overall SSOM I process and potential problem areas. QS Work Instruction QS-20 was revised to reflect this change on April 13, 1989.

Revised Commitment The SSFAR and SSOMI will be scheduled and conducted in accordance with the Nuclear Power Generation Internal Auditing procedure. This procedure provides guidance for scheduling, planning, performing, and reporting. This includes: (1) determining audit schedule, frequency, scope, team composition; (2) handling of problems identified during the audit; and (3) corrective action follow up. Staffing for these audits will be determined as appropriate and as outlined in the procedure. Additionally, the audit scope determines the team and team functions. The SSOMI and SSFAR audits may focus entirely on design. Oversight of station activities is a line function and may be reviewed by Quality Verification.

Justification for Change The commitment was part of a response to a 1989 NRC Inspection Report, which identified three areas of generic weakness regarding understanding of the plant design bases, engineering/plant interface, and engineering work. The letter forwarding the inspection report also requested that PG&E provide a written response addressing NRC observations characterizing PG&E's SSFAR and SSOMI.

Nuclear Power Generation Internal Auditing Procedure, OM4.1D13, provides guidance for all internal auditing and implements this commitment. It also provides guidance for SSOMis and SSFARs. Additionally, the Internal Auditing procedure contains guidance on start dates, scheduling, corrective actions, and corrective action follow up.