DCL-15-031, Proposed Commitment for Response to NRC Request for Additional Information Regarding Submittal Date of the Integrated Analysis, National Fire Protection Association Standard 805

Proposed Commitment for Response to NRC Request for Additional Information Regarding Submittal Date of the Integrated Analysis, National Fire Protection Association Standard 805

ML15056A774
Person / Time
Site:	Diablo Canyon
Issue date:	02/25/2015
From:	Allen B Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-15-031
Download: ML15056A774 (3)

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 25, 2015 805.545.4888 Internal: 691.4888 Fax: 805.545.6445 PG&E Letter DCL-15-031 U.S. Nuclear Regulatory Commission 10 CFR 50.90 ATTN: Document Control Desk Washington, D.C. 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Proposed Commitment for Response to NRC Request for Additional Information Regarding Submittal Date of the Integrated Analysis. National Fire Protection Association Standard 805

References:

1. PG&E Letter DCL-13-065, "License Amendment Request 13-03, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," dated June 26, 2013

2. PWROG-14001-P, Revision 0-B, "PRA Model for the Generation Ill Westinghouse Shutdown Seal," dated May 2014

3. WCAP-171 00-P-A, Revision 1, "PRA Model for the Westinghouse Shut Down Seal," dated August 2011

4. W_CAP-17100, Supplement 1, Revision 0, "PRA Model for the Westinghouse Shut Down Seal - Supplemental Information for All Domestic Reactor Coolant Pump Models," dated December 2012

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted a license amendment request (LAR) to adopt National Fire Protection Association (NFPA)

Standard 805.

On January 29, 2015, PG&E held a conference call with the NRC Fire Protection and Probabilistic Risk Assessment (PRA) Branch Chiefs, NRC NFPA 805 technical personnel, and the NRC Project Manager for Diablo Canyon Power Plant (DCPP).

The call discussed the schedule for the Safety Evaluation and License Amendment (SElLA) for DCPP.

The WCAP from Westinghouse (References 3 and 4) for reactor coolant pump (RCP) seals that were accepted by the NRC several years ago can no longer be applied for RCP seal credit to the fire PRA (FPRA). The Generation I seals failed to A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Call~way

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' & Page 2 meet their requirements after being tested once a full cycle run was completed in a nuclear plant. The Generation II seals also failed testing by Westinghouse after operations in a different nuclear plant. Westinghouse then submitted a Topical (Reference 2) on the Generation Ill seals to the NRC for acceptance. The NRC accepted the topical for use to meet qualitative analysis towards Fukushima commitments in the industry. As of this date, the NRC has not accepted the Topical for quantitative use in FPRA.

During the LAR acceptance process, the NRC requested PG&E remove the RCP seal credit from the PRA analysis to determine if the PRA would still fall within Regulatory Guide (RG) 1.174 requirements. DCPP's PRA did not meet the RG requirements with the RCP seal credit removed. PG&E is presently responding to requests for additional information (RAis), with the exception of PRA RAI 3 which is the integrated analysis.

PG&E is proposing a regulatory commitment to revise the submittal date of PRA RAI 3. By delaying submittal of PRA RAI 3, and the schedule for SElLA, it will provide time for PG&E to ensure:

• Generation Ill Seal testing data conforms to the Westinghouse Topical report

• NRC accepts the Westinghouse Topical for quantitative use in FPRA Following the above, PG&E would integrate the data into DCPP's final integrated PRA analysis and respond to PRA RAI 3 for NRC use in development of the SE/LA.

PG&E is proposing the following regulatory commitment:

PG&E will provide the response to PRA RAI 3 eight weeks following verification that seal testing data conforms to the Westinghouse Topical report and the NRC acceptance of the Westinghouse Topical report for quantitative use in FPRA. Concurrent with the PRA RAI 3 submittal, PG&E will submit a frozen FPRA, updated LAR tables, and a transition report. The transition report will include a revised schedule for an implementation period of 12 months from receipt of the SE/LA.

This approach is consistent with the goal of not having multiple additional rounds of RAis related to the integrated analysis, as well as revisions that would require significant review resources from both PG&E and the NRC.

Pursuant to 10 CFR 50.91, PG&E is sending a copy of this supplement to the California Department of Public Health.

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

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Document Control Desk PG&E Letter DCL-15-031 February 25, 2015 Page 3 PG&E is not revising the schedule for any plant modifications described in Reference 1. The date for complete transition to NFPA 805 will not be impacted by the proposed regulatory commitment.

If you have any questions or require additional information, please contact Philippe Soenen at 805-545-6984.

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

Executed on February 25, 2015.

Sincerely, u57sA/L-Barry S. Allen Vice President, Nuclear Services mjrm/4557/5063171 0 cc: Marc L. Dapas, NRC Region IV Thomas R. Hipschman, NRC Senior Resident Inspector Siva P. Lingam, NRR Project Manager Gonzalo L. Perez, Branch Chief, California Dept of Public Health Diablo Distribution A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

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