ML102460050

RAI Related to the Review of the Diablo Canyon Nuclear Power Plant, Units 1 and 2, License Renewal Application (TAC Nos. ME2896 & ME2897) Aging Management Programs

ML102460050
Person / Time
Site:	Diablo Canyon
Issue date:	09/17/2010
From:	Ferrer N License Renewal Projects Branch 2
To:	Conway J Pacific Gas & Electric Co
Nate Ferrer, DLR/RPB2 415-1045
References
TAC ME2896, TAC ME2897
Download: ML102460050 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 17,2010 Mr. John Conway Senior Vice President Generation and Chief Nuclear Officer Pacific Gas and Electric Company 77 Beale Street, MC B32 San Francisco, CA 94105 SUB..IECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME2896 AND ME2897) - AGING MANAGEMENT PROGRAMS

Dear Mr. Conway:

By letter dated November 23, 2009, Pacific Gas & Electric Company submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating licenses for Diablo Canyon Nuclear Power Plant, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

The request for additional information was discussed with Mr. Terry Grebel, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1045 or bye-mail at nathanieIJerrer@nrc.gov.

Sincerely, Nathaniel Ferrer, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

As stated cc w/encl: Distribution via Listserv

Diablo Canyon Nuclear Power Plant, Units 1 and 2 License Renewal Application Request for Additional Information Set 24 Aging Management Programs RAI 82.1.20-2

Background

GALL AMP XI.M36, "External Surfaces Monitoring Program" states, "[s]urfaces that are inaccessible or not readily visible during plant operations are inspected during refueling outages. Surfaces that are inaccessible or not readily visible during both plant operations and refueling outages are inspected at such intervals that would provide reasonable assurance that the effects of aging will be managed such that applicable components will perform their intended function during the period of extended operation."

The Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) Section 3.2.2.4 states, "[t]he summary description of the programs and activities for managing the effects of aging for the period of extended operation in the Final Safety Analysis Report (FSAR) Supplement should be sufficiently comprehensive such that later changes can be controlled by 10 CFR SO.59." It also states that, U[e]xamples of the type of information required are provided in Table 3.2-2 of this SRP-LR." SRP-LR Section 3.2.3.4 states, <<[tJhe reviewer confirms that the applicant has provided information equivalent to that in Table 3.2-2 in the FSAR Supplement for aging management of the auxiliary systems for license renewal." The description of program for the "External Surfaces Monitoring Program" in Tables 3.2-2, 3.3-2 and 3.4-2 includes the following, U[s]urfaces that are inaccessible during plant operations are inspected during refueling outages. Surfaces that are inaccessible during both plant operations and refueling outages are inspected at frequencies to provide reasonable assurance that effect of aging will be managed such that applicable components will perform their intended function during the period of extended operation."

Issue LRA Section B2.1.20 states, U[e]xternal surface inspections will be performed on passive components in scope for license renewal at intervals no longer than once per refueling cycle LRA Section B2.1.20 also states, <<[t]he External Surfaces Monitoring Program will provide clarification for areas, or portions of systems or components, that may be exempted from walkdown inspections based on physical or environmental constraints."

It is not clear to the staff if the applicant has access to all surfaces being age managed by the External Surfaces Monitoring Program during plant operations and refueling outages as is implied in the first quoted statement, but given the second quoted statement, it does appear that the applicant has a process for excluding some external surfaces from walkdowns based on physical or environmental constraints. The License Renewal Application (LRA) does not contain a statement that the applicant will ensure that those components that are "exempted from walkdowns," will be ultimately inspected or evaluated to ensure the components will perform their intended functions during the period of extended operation if an inspection cannot be performed. The staff requires further information to understand how the applicant will evaluate ENCLOSURE

-2 components that are "exempted from walkdowns", thus implying that they will never be inspected.

LRA Section A 1.20, the FSAR Supplement description for the External Surfaces Monitoring Program does not contain information related to inaccessible surfaces during plant operations and inaccessible surfaces during plant operations and refueling outages.

Request

1. Describe the criteria that will be used and evaluation methodology to ensure that components "exempted from walkdown" will be managed such that applicable components will perform their intended function during the period of extended operation.

2. Revise FSAR Supplement Section A 1.20 to ensure that surfaces that are inaccessible during both plant operations and refueling outages are inspected at frequencies to provide reasonable assurance that effect of aging will be managed such that applicable components will perform their intended function during the period of extended operation, or provide justification that a revision is not needed.

RAI 82.1.20-3 LRA Table 3.3.2-7, "Auxiliary Systems - Compressed Air" contains line items for copper alloy

(>15 percent zinc) regulators and solenoid valves exposed to atmospheric weather being managed for loss of material by the External Surfaces Monitoring Program. LRA Section 82.1.20, External Surfaces Monitoring AMP, does not include copper alloy (>15 percent zinc) in the Program Description or "scope of program" exemption.

Given that the External Surfaces Monitoring Program does not include copper alloy (>15 percent zinc) material in LRA Section 82.1.20, the staff cannot conclude that associated AMR line items will be appropriately age managed.

Request:

1. Revise LRA Section 82.1.20 to include copper alloy (>15 percent zinc) or state an alternative aging management program for the above line items.

2. State whether the associated program basis documents include copper alloy (>15 percent zinc) material.

September 17. 2010 Mr. John Conway Senior Vice President Generation and Chief Nuclear Officer Pacific Gas and Electric Company 77 Beale Street. MC B32 San Francisco. CA 94105

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME2896 AND ME2897) - AGING MANAGEMENT PROGRAMS

Dear Mr. Conway:

By letter dated November 23. 2009, Pacific Gas &Electric Company submitted an application pursuant to Title 10 of the Code ofFederal Regulations Part 54, to renew the operating licenses for Diablo Canyon Nuclear Power Plant, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

The request for additional information was discussed with Mr. Terry Grebel, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1045 or e-mail nathaniel.ferrer@nrc.gov.

Sincerely, IRA!

Nathaniel Ferrer, Safety Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

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OFFICE PM:RPB2:DLR BC:RPB2:DLR PM:RPB2:DLR NAME LA:DLR YEdmonds NFerrer DWrona NFerrer DATE 09117/10 09116/10 09/17/10 OFFICIAL RECORD COpy 09/10/10 I

Letter to John Conway from Nathaniel Ferrer dated September 17, 2010

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REVIEW OF THE DIABLO CANYON NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME2896 AND ME2897) - AGING MANAGEMENT PROGRAMS DISTRIBUTION:

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