DCL-15-028, Fourth 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)

Fourth 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)

ML15054A642
Person / Time
Site:	Diablo Canyon
Issue date:	02/23/2015
From:	Allen B Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-15-028, EA-12-051
Download: ML15054A642 (8)

Text

Pacific Gas and Electric Company Barry S. Allen Diablo Canyon Power Plant Vice President, Nuclear Services Mail Code 104/6 P. 0. Box 56 Avila Beach, CA 93424 February 23, 2015 805.545.4888 Internal: 691.4888 Fax: 805.545 . 6445 PG&E Letter DCL-15-028 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 Fourth 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. 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

3. NRC Letter, "Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051 ,"dated March 26, 2014

Dear Commissioners and Staff:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 to Pacific Gas and Electric Company (PG&E) directing PG&E to have a reliable indication of the water level in Diablo Canyon Power Plant's spent fuel pools (SFP).

Specific requirements are outlined in Reference 1, Attachment 2.

Pursuant to Reference 1,Section IV, Condition C, PG&E submitted its overall integrated plan (OIP) for reliable SFP instrumentation in Reference 2.

Pursuant to Reference 1,Section IV, Condition C.2, the enclosure to this letter provides PG&E's fourth six-month status report of its OIP. The enclosure also acknowledges the NRC's transition to an audit methodology for resolution of open or confirmatory items as described by Reference 3.

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

• Diablo Canyon

• Palo Verde

• Wolf Creek

Document Control Desk PG&E Letter DCL-15-028 February 23, 2015 Page 2 PG&E makes no new 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 February 23, 2015.

Sincerely,

~~Att--

Barry Allen Vice President, Nuclear Services c5c3/SAPN 50465912-12 Enclosure cc: Diablo Distribution cc:/enc: Marc L. Dapas, NRC Region IV Administrator Dan H. Dorman, NRC/NRR Director Thomas R. Hipschman, NRC, Senior Resident Inspector Siva P. Lingam, NRR Project Manager A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

Enclosure PG&E Letter DCL-15-028 Pacific Gas and Electric Company's Fourth Six-Month Status Report for the Implementation of Order EA-12-051

Enclosure PG&E Letter DCL-15-028 Page 1 of 4 Pacific Gas and Electric Company's Fourth Six-Month Status Report for the Implementation of Order EA-12-051 1 Introduction Pacific Gas and Electric Company (PG&E) developed an overall integrated plan (OIP)

(Reference 1 [Refer to Section 9 of this enclosure for a list of references.]), to achieve compliance with the requirements described in NRC Order EA-12-051 (Reference 2), . This enclosure provides the fourth 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. This enclosure also provides an update to the status of responses to requests for additional information (RAis) provided in Reference 3 and PG&E's responses to Reference 4.

2 Milestone Accomplishments No milestones have been completed since the submittal of the third six-month status report, and are current as of January 31, 2015.

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.

The target completion dates for developing the Unit 1 and Unit 2 design and equipment receipt have been updated to reflect the current schedule. The revised milestone completion dates do not impact the order implementation date.

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 Complete Update 3 8/2014 Complete Update 4 2/2015 Complete Update 5 8/2015 Not started Update 6 2/2016 Not started Update 7 8/2016 Not started

Enclosure PG&E Letter DCL-15-028 Page 2 of 4 Original Target Target Activity Completion Milestone Completion Status Date Date Changes July 3, 2013, Request for Additional Information Submit 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 3/31/15 Develop Unit 2 design 3/31/14 Started 3/31/15 Receipt of Unit 1 spent fuel pool 12/31/14 Not Started 6/30/15 (SFP) instruments Receipt of Unit 2 SFP instruments 12/31/14 Not Started 6/30/15 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

• None 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 7 Open Items and Responses to Requests for Additional Information PG&E submitted PG&E Letter DCL-13-073 (Reference 3) in response to an NRC RAI (Reference 6). In its response, PG&E committed to provide a status update of the information necessary to complete its response to the RAis.

Enclosure PG&E Letter DCL-15-028 Page 2 of 4 .

Original Target Target Activity Completion Milestone Completion Status Date Date Changes July 3, 2013, Request for Additional Information Submit 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 3/31/15 Develop Unit 2 design 3/31/14 Started 3/31/15 Receipt of Unit 1 spent fuel pool 12/31/14 Not Started 6/30/15 (SFP) instruments Receipt of Unit 2 SFP instruments 12/31/14 Not Started 6/30/15 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 None 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 7 Open Items and Responses to Requests for Additional Information PG&E submitted PG&E Letter DCL-13-073 (Reference 3) in response to an NRC RAI (Reference 6). In its response, PG&E committed to provide a status upd_ate of the information necessary to complete its response to the RAis.

Enclosure PG&E Letter DCL-15-028 Page 3 of 4 The NRC's Interim Staff Evaluation (ISE) (Reference 4) requested PG&E to provide responses to RAis in the six-month status updates as they become available, but no later than April 30, 2015.

Finally, an NRC Letter (Reference 9) announced the NRC's transition to an audit based review process of utility responses to Order EA-12-051. In addition to announcing the transition to an audit based review process, the audit plan also notified each licensee participating in the audit not to formally submit their RAI responses on the docket but instead, put their responses and any other supporting information on their ePortals by the date identified in their ISE to support the Staff's review process. PG&E will provide a status of the remaining Open Items and responses to RAis, described in Reference 8, as they become available, but no later than April 30, 2015.

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

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 Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)," dated July 18, 2013

4. NRC Letter, "Diablo Canyon Power Plant, Unit Nos. 1 and 2- Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation (TAC Nos. MF0963 and MF0964)," dated November 25, 2013

5. PG&E Letter 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)," dated August 22, 2013

Enclosure PG&E Letter DCL-15-028 Page 4 of 4

6. NRC Letter, "Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Request for Additional Information Regarding Overall Integrated Plan for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) (TAC Nos. MF0963 and MF0964)," dated July 3, 2013

7. PG&E Letter DCL-13-007, "Pacific Gas and Electric Company's Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013

8. PG&E Letter DCL-14-015, "Pacific Gas and Electric Company's Second 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)," dated February 26, 2014

9. NRC Letter, "Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051 ,"dated March 26, 2014

10. PG&E Letter DCL-14-077, "Pacific Gas and Electric Company's Third 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)," dated August 21, 2014