ML081260099
| ML081260099 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/28/2008 |
| From: | Wang A NRC/NRR/ADRO/DORL/LPLIV |
| To: | Conway J Pacific Gas & Electric Co |
| Wang, A B, NRR/DORL/LPLIV, 415-1445 | |
| References | |
| GL-08-001, TAC MD7820, TAC MD7821 | |
| Download: ML081260099 (4) | |
Text
August 28,2008 Mr. John Conway Senior Vice President - Station Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P.O. Box 770000 San Francisco, CA 94177-0001
SUBJECT:
DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7820 AND MD7821)
Dear Mr. Conway:
The purpose of Generic Letter (GL) 2008-01, Managing Gas Accumulation In Emergency Core Cooling, Decay Heat Removal, And Containment Spray Systems, is to request licensees to submit information to demonstrate that the emergency core cooling system (ECCS), decay heat removal (DHR) system, and containment spray system (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance. In GL 2008-01, the U.S. Nuclear Regulatory Commission (NRC) requested that each licensee submit the requested information within 9 months. However, if a licensee cannot meet the requested 9-month response date, a 3-month written response is required that describes a proposed alternative course of action and the bases for why the alternative actions are acceptable.
By "DCL-08-032, Three-Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and [[system" contains a listed "[" character as part of the property label and has therefore been classified as invalid. Systems|letter dated April 10, 2008]], Pacific Gas and Electric Company (PG&E, the licensee) submitted a 3-month response to GL 2008-01 for Diablo Canyon Power Plant, Unit Nos. 1 and 2 (DCPP). The licensee stated that requested information in GL 2008-01 includes, A description of all corrective actions, including plant, programmatic, procedure, and licensing basis modifications that you determined were necessary to assure compliance... The licensee states that the requested description of all corrective actions pertaining to plant modifications would require the completion of a thorough physical walkdown of the system piping to confirm such things as adequate vent capability for system high points, and verification that the design drawings reflect the as-built piping. The Unit 2 confirmatory walkdown was satisfactorily performed on ECCS piping during refueling outage fourteen. The licensee believes that confirmatory walkdowns should be conducted to revalidate the Unit 1 piping configuration for ECCS piping segments in containment that connect to the accumulators. The piping described as inaccessible while at power due to excessive heat, poor lighting, and increased radiation levels, and, in addition, access to ECCS piping requires the erection of scaffolding which would result in additional personnel dose. Consequently, the licensee has provided the following commitment:
J. Conway PG&E will perform any necessary confirmatory walkdowns of inaccessible piping in the Unit 1 containment during Unit 1 Refueling Outage Fifteen (1R15), currently scheduled to begin in January 2009. Any corrective actions that are identified that PG&E determines can reasonably be performed during 1R15 will be completed during that refueling outage. Any other corrective actions that are identified during 1R15 which cannot be completed, will be implemented prior to restart following Unit 1 Refueling Outage Sixteen. PG&E will provide a supplemental submittal within 60 days of the completion of 1R15 describing any corrective actions identified and their schedule for completion.
The NRC notes that PG&E has not discussed potential long-term confirmatory programs that maybe necessary to help ensure continued compliance with current licensing and design basis, such as the need for additional pump testing and analysis development to assess gas movement behavior. If such programs are needed at the licensees plant, technical specification (TS) changes or other regulatory approvals maybe necessary. The NRC staff and industry, through the Technical Specifications Task Force (TSTF) program will provide generic examples of TS changes that can be considered and appropriately adopted by licensees. When providing the 9-month response or response associated with a previously submitted alternative course of action, PG&E should identify any such longer term actions such as license amendment requests, and appropriately include these actions in its corrective action plans.
Addressing such long-term conditions under the Corrective Action Program is acceptable.
The licensee proposes to submit a written response within the required 9-month response date of October 11, 2008, to provide the information requested in GL 2008-01 for Units 1 and 2. For Unit 1 the licensee has stated they have not completed the confirmatory walkdowns of inaccessible piping and proposed to complete this action during Refueling Outage 16 with a supplemental submittal within 60 days of the completion of the outage. The NRC staff finds that this alternative course of action is acceptable.
If you have any questions regarding this letter, please feel free to contact me at (301) 415-1445.
Sincerely,
/RA/
Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323 cc: See next page
J. Conway PG&E will perform any necessary confirmatory walkdowns of inaccessible piping in the Unit 1 containment during Unit 1 Refueling Outage Fifteen (1R15), currently scheduled to begin in January 2009. Any corrective actions that are identified that PG&E determines can reasonably be performed during 1R15 will be completed during that refueling outage. Any other corrective actions that are identified during 1R15 which cannot be completed, will be implemented prior to restart following Unit 1 Refueling Outage Sixteen. PG&E will provide a supplemental submittal within 60 days of the completion of 1R15 describing any corrective actions identified and their schedule for completion.
The NRC notes that PG&E has not discussed potential long-term confirmatory programs that maybe necessary to help ensure continued compliance with current licensing and design basis, such as the need for additional pump testing and analysis development to assess gas movement behavior. If such programs are needed at the licensees plant, technical specification (TS) changes or other regulatory approvals maybe necessary. The NRC staff and industry, through the Technical Specifications Task Force (TSTF) program will provide generic examples of TS changes that can be considered and appropriately adopted by licensees. When providing the 9-month response or response associated with a previously submitted alternative course of action, PG&E should identify any such longer term actions such as license amendment requests, and appropriately include these actions in its corrective action plans.
Addressing such long-term conditions under the Corrective Action Program is acceptable.
The licensee proposes to submit a written response within the required 9-month response date of October 11, 2008, to provide the information requested in GL 2008-01 for Units 1 and 2. For Unit 1 the licensee has stated they have not completed the confirmatory walkdowns of inaccessible piping and proposed to complete this action during Refueling Outage 16 with a supplemental submittal within 60 days of the completion of the outage. The NRC staff finds that this alternative course of action is acceptable.
If you have any questions regarding this letter, please feel free to contact me at (301) 415-1445.
Sincerely,
/RA/
Alan Wang, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323 cc: See next page Distribution:
PUBLIC/NON-SENSITIVE LPL4 R/F RidsAcrs&AcnwMailCenter RidsRgn4MailCenter RidsNrrDci RidsNrrDprPgsb RidsNrrDss RidsNrrDorlLpl4 RidsNrrPMAWang RidsNrrLAGLappert RidsOgcRp ADAMS Accession Number: ML081260099 NRR-106 OFFICE NRR/LPL4/PM NRR/LPL4/LA DPR/PGSB/BC DSS/DD NRR/LPL4/BC (A)
NRR/LPL4/PM NAME AWang JND for GLappert MMurphy JWermeil BSingal AWang JND for DATE 8/28/08 5/5/08 5/8/08 5/7/08 8/28/08 8/28/08 OFFICIAL RECORD COPY
Diablo Canyon Power Plant, Units 1 and 2 (3/10/2008) cc:
NRC Resident Inspector Diablo Canyon Power Plant c/o U.S. Nuclear Regulatory Commission P.O. Box 369 Avila Beach, CA 93424 Sierra Club San Lucia Chapter ATTN: Andrew Christie P.O. Box 15755 San Luis Obispo, CA 93406 Ms. Nancy Culver San Luis Obispo Mothers for Peace P.O. Box 164 Pismo Beach, CA 93448 Chairman San Luis Obispo County Board of Supervisors 1055 Monterey Street, Suite D430 San Luis Obispo, CA 93408 Mr. Truman Burns Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, CA 94102 Diablo Canyon Independent Safety Committee Attn: Robert R. Wellington, Esq.
Legal Counsel 857 Cass Street, Suite D Monterey, CA 93940 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Jennifer Post, Esq.
Pacific Gas & Electric Company P.O. Box 7442 San Francisco, CA 94120 City Editor The Tribune 3825 South Higuera Street P.O. Box 112 San Luis, Obispo, CA 94306-0112 Director, Radiologic Health Branch State Department of Health Services P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Mr. James Boyd, Commissioner California Energy Commission 1516 Ninth Street MS (31)
Sacramento, CA 95831 Mr. James R. Becker Site Vice President Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 Jennifer Tang Field Representative United States Senator Barbara Boxer 1700 Montgomery Street, Suite 240 San Francisco, CA 94111