DCL-25-046, Diablo Canyon Power Plant License Renewal Application, Amendment 5
| ML25114A242 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/24/2025 |
| From: | Zawalick M Pacific Gas & Electric Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| DCL-25-046 | |
| Download: ML25114A242 (1) | |
Text
Maureen R. Zawalick Vice President Business and Technical Services Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 805.545.4242 Maureen.Zawalick@pge.com A member of the STARS Alliance Callaway x Diablo Canyon x Palo Verde x Wolf Creek PG&E Letter DCL-25-046 ATTN: Document Control Desk 10 CFR 54 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Supplement 3: Diablo Canyon Power Plant License Renewal Application, Amendment 5 References:
- 1. PG&E Letter DCL-23-118, License Renewal Application, dated November 7, 2023 (ML23311A154)
- 2. PG&E Letter DCL-24-092, Supplement and Annual Update: Diablo Canyon Power Plant License Renewal Application, Amendment 1, dated October 14, 2024 (ML24289A118)
- 3. PG&E Letter DCL-25-001, Response to Request for Additional Information by the Office of Nuclear Reactor Regulation Diablo Canyon Safety Review Pacific Gas and Electric Company Diablo Canyon Units 1 and 2 (Set 2),
dated January 2, 2025 (ML25002A050)
- 4. PG&E Letter DCL-25-022, Response to Request for Additional Information by the Office of Nuclear Reactor Regulation Diablo Canyon LRA Safety Review Pacific Gas and Electric Company Diablo Canyon Units 1 and 2 (Set 3), dated February 25, 2025 (ML25056A500)
- 5. PG&E Letter DCL-25-023, Supplement and Annual Update: Diablo Canyon Power Plant License Renewal Application, Amendment 4, dated March 6, 2025 (ML25069A508)
Dear Commissioners and Staff:
In Reference 1, Pacific Gas and Electric Company (PG&E) submitted an operating license renewal application (LRA) for Diablo Canyon Power Plant (DCPP) Units 1 and 2 to extend the current Facility Operating Licenses an additional 20 years beyond their current expiration dates. In References 2, 3, 4, and 5, PG&E amended the LRA. To support NRC's review of the LRA, PG&E is providing a voluntary supplement to the LRA included in the Enclosure. The supplement includes an editorial revision to align the title for an Aging Management Program (AMP) in LRA Appendix B and to add an exception related to the inspections implemented as part of the DCPP Fuel Oil Chemistry AMP. PG&E currently plans on either performing the inspections described in Attachment 1 of the Enclosure or evaluating the portable diesel electric generators as complex assemblies and removing the fuel oil tanks from the scope of license renewal by December 31, 2025.
Pacific Gas anti Elecmr: Company*
Document Control Desk PG&E Letter DCL-25-046 Page 2 A member of the STARS Alliance Callaway x Diablo Canyon x Palo Verde x Wolf Creek The Attachments in the Enclosure include a description of the changes along with the affected section(s) and page number(s) of the docketed full LRA (Reference 1) where the changes apply. For clarity, revisions to the LRA are provided with deleted text by red strikethroughs and inserted text by blue underline. Bolded LRA text indicates portions that were previously amended by References 2, 3, 4, or 5.
PG&E makes no new or revised regulatory commitments (as defined by NEI 99-04) in this submittal.
If you have any questions or require additional information, please contact Mr. Philippe Soenen at (805) 459-3701.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on ____________________.
Sincerely, Maureen R. Zawalick Vice President, Business and Technical Services Enclosure cc:
Diablo Distribution cc/enc:
Anthony Chu, Chief, California Department of Public Health Kim Conway, NRC Environmental Project Manager Lauren Gibson, NRC License Renewal Branch Chief Brian Harris, NRC Senior Project Manager Mahdi O. Hayes, NRC Senior Resident Inspector Delphine Hou, California Department of Water Resources Samson S. Lee, NRR Senior Project Manager John D. Monninger, NRC Region IV Deputy Administrator April 24, 2025 1
Enclosure PG&E Letter DCL-25-046 Diablo Canyon Power Plant, Units 1 and 2 License Renewal Application, Amendment 5, Change Description and Revisions
Enclosure PG&E Letter DCL-25-046 Page 1 of 4 Supplement - DCPP LRA, Amendment 5 Affected License Renewal Application (LRA) Sections: Section B.2.3.17 LRA Page Numbers: B.2-91 and B.2-92 Description of Change:
LRA Section B.2.3.17 is updated to include an additional exception associated with the follow-up volumetric inspections required to be performed on two of the six portable diesel electric generator fuel oil tanks. The exception is being requested to allow additional time into the period of extended operations (PEO) to perform the follow-up volumetric inspections (required based on findings from the pre-PEO internal visual inspections) on two of the six fuel oil tanks.
Enclosure PG&E Letter DCL-25-046 Page 2 of 4 Supplement - DCPP LRA, Amendment 5 LRA Section B.2.3.17 on pages B.2-91 and B.2-92 (as modified by DCL-24-092,, Attachment XX) is revised as follows:
B.2.3.17 Fuel Oil Chemistry Exceptions to NUREG-1801 The DCPP Fuel Oil Chemistry AMP includes the following exceptions to NUREG-1801 guidance:
Exception 1, Element 2, Preventive Actions:
Water is not removed from the portable caddy fuel oil tanks or the emergency diesel fuel oil pump head (priming) tanks.
Exception 2, Element 3, Parameters Monitored and Inspected:
The emergency diesel fuel oil pump head (priming) tanks will not be periodically sampled.
Exception 3, Element 3, Parameters Monitored and Inspected The new fuel for the EDG DFOSTs, emergency diesel fuel oil day tanks, emergency diesel fuel oil pump head (priming) tanks, the portable diesel generators, portable fire water pumps and portable caddies are not tested for microbiological organisms prior to new fuel oil introduction into these components.
Exception 4, Element 4, Detection of Aging Effects Two of the portable diesel electric generator fuel oil tanks follow-up volumetric inspections (required based on findings from the pre-PEO internal visual inspections) will be performed in the PEO instead of prior to the PEO.
Justification for Exception Justification for Exception 1:
The portable caddy fuel oil tanks are small tanks that do not have provisions to remove water from the tank bottoms. The fuel oil contained in the portable caddy fuel oil tanks is consumed on a regular basis, by quarterly surveillance tests that run the portable diesel driven fire water pumps and the portable diesel generators for at least 30 minutes, and fuel oil is refilled into the tanks after each test. Portable diesel electric generators and portable diesel driven fire water pumps fuel oil tank filtration devices are checked and drained of water prior to use to minimize water entry. The frequent addition of fuel oil, and prior-to-use filtration device water draining obviates the need for periodic water removal from the portable caddy fuel oil tanks.
The emergency diesel fuel oil pump head (priming) tanks are replenished on a daily basis with fuel oil from the day tanks. During this process the excess fuel oil from the emergency
Enclosure PG&E Letter DCL-25-046 Page 3 of 4 Supplement - DCPP LRA, Amendment 5 diesel fuel oil pump head (priming) tanks returns to the day tanks. The fuel oil day tanks are checked for accumulated water every 31 days (monthly), and any water that is present is removed. The frequent addition of fuel oil and the absence of water from the fuel oil supply ensure that water is not being introduced into or accumulating in the emergency diesel fuel oil pump head (priming) tanks.
Justification for Exception 2:
The emergency diesel fuel oil pump head (priming) tanks are filled with fuel oil from the diesel fuel oil day tanks. The fuel oil from the diesel fuel oil day tanks is checked for water monthly and analyzed quarterly for total particulate in accordance with ASTM Standards using the limits specified in the Diesel Fuel Oil Testing AMP.
Justification for Exception 3 Sampling of the EDG DFOSTs and non-emergency portable diesel electric generators, portable fire water pumps and portable caddies for microbiological organisms is performed annually using an offsite laboratory for analysis since DCPP does not have the onsite capability to perform the analysis for microbiological organisms. Plant procedures provide for biocide to be added to new emergency diesel fuel oil for the EDG DFOSTs and non-emergency portable diesel electric generators, portable diesel fire water pumps and caddies.
The DCPP operating experience has shown that the use of biocide and other preventative measures has been effective to prevent microbiological organism contamination of the diesel fuel oil.
The emergency diesel fuel oil day tanks and emergency diesel fuel oil head (priming) tanks receive fuel oil from the EDG DFOSTs which are treated with a biocide, and as discussed above, the EDG DFOSTs are sampled for microbiological organisms annually.
The portable diesel electric generators and portable diesel fire water pumps have filtration devices which capture water. Plant procedures will be enhanced to check and drain water from the portable diesel electric generators and portable diesel driven fire water pumps prior to use which will minimize any water entry.
Justification for Exception 4 NUREG-1801,Section XI.M30, Element 4, recommends the internal surfaces of each diesel fuel oil tank be visually inspected in the 10-year period prior to the PEO with follow-up volumetric inspections performed if evidence of degradation is observed during visual inspection, or if visual inspection is not possible. There are six portable diesel electric generators, each with a fuel oil tank. Three portable diesel electric generator fuel oil tanks had evidence of degradation observed during the pre-PEO visual inspection. One of the three portable diesel electric generator fuel oil tanks that had evidence of degradation was volumetrically inspected. The volumetric inspection did not detect any measurable material loss due to corrosion. Two of the three with evidence of degradation did not have the follow-up volumetric inspections performed prior to the Unit 1 PEO consistent with NUREG-1801,Section XI.M30. The volumetric inspections for these two tanks were delayed due to
Enclosure PG&E Letter DCL-25-046 Page 4 of 4 Supplement - DCPP LRA, Amendment 5 accessibility difficulty based on the design of the portable diesel electric generators.
The portable diesel electric generators were installed during the same timeframe, are operated similarly, and are located in the same environment. These similarities and the results of the UT inspection performed on one of the three tanks provides reasonable assurance that the portable diesel electric generator fuel oil tanks will continue to perform their intended function during the PEO.
Enclosure PG&E Letter DCL-25-046 Page 1 of 6 Supplement - DCPP LRA, Amendment 5 Affected LRA Sections: Section B.1.1; Appendix B Table of Contents; and Tables B-1, B-2, and B-3 LRA Page Numbers: B-3, B.1-2, B.1-11, B.1-13, and B.2-3 Description of Change:
LRA Section B.1.1, Appendix B Table of Contents, and Tables B-1, B-2, and B-3 are revised to align the aging management program title with LRA Section B.2.3.42.
Enclosure PG&E Letter DCL-25-046 Page 2 of 6 Supplement - DCPP LRA, Amendment 5 LRA Appendix B, Table of Contents on page B-3 is revised as follows:
TABLE OF CONTENTS B.2.3.42 Transmission Conductor and Connections, Insulators, and Switchyard Bus and Connections Transmission Conductor and Connections, Switchyard Bus and Connections, and High-Voltage InsulatorsB.2-192
Enclosure PG&E Letter DCL-25-046 Page 3 of 6 Supplement - DCPP LRA, Amendment 5 LRA Section B.1.1 on page B.1-2 (as modified by DCL-24-092, Enclosure 1, Attachment UU) is revised as follows:
B.1.1 Overview There are 2 plant-specific AMPs in the DCPP LRA:
x Periodic Inspections for Selective Leaching (B.2.3.41) x Transmission Conductor and Connections, Insulators, and Switchyard Bus and Connections Transmission Conductor and Connections, Switchyard Bus and Connections, and High-Voltage Insulators (B.2.3.42)
Enclosure PG&E Letter DCL-25-046 Page 4 of 6 Supplement - DCPP LRA, Amendment 5 LRA Table B-1 on page B.1-11 is revised as follows:
Table B-1 List of DCPP Aging Management Programs NUREG-1801 Section Section Aging Management Program Existing AMP or New AMP DCPP Plant-specific Program B.2.3.42 Transmission Conductor and Connections, Insulators, and Switchyard Bus and Connections Transmission Conductor and Connections, Switchyard Bus and Connections, and High-Voltage Insulators Existing
Enclosure PG&E Letter DCL-25-046 Page 5 of 6 Supplement - DCPP LRA, Amendment 5 LRA Table B-2 on page B.1-13 is revised as follows:
Table B-2 Aging Management Programs DCPP Aging Management Program Section NUREG-1801 Section Transmission Conductor and Connections, Insulators, and Switchyard Bus and Connections Transmission Conductor and Connections, Switchyard Bus and Connections, and High-Voltage Insulators B.2.3.42 None
Enclosure PG&E Letter DCL-25-046 Page 6 of 6 Supplement - DCPP LRA, Amendment 5 LRA Table B-3 on page B.2-3 is revised as follows:
Table B-3 Correlation with NUREG-1801 Aging Management Programs NUREG-1801 NUMBER NUREG-1801 PROGRAM PLANT PROGRAM SECTION N/A Plant-Specific Transmission Conductor, Connections, Insulators and Switchyard Bus and Connections Transmission Conductor and Connections, Switchyard Bus and Connections, and High-Voltage Insulators B.2.3.42