DCL-11-021, Comments on the Safety Evaluation Report with Open Items Related to License Renewal

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Comments on the Safety Evaluation Report with Open Items Related to License Renewal
ML110880188
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 03/25/2011
From: Becker J
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-11-021, OL-DPR-80, OL-DPR-82
Download: ML110880188 (35)
v • d • e


Text

Pacific Gas and Electric Company James R. Becker Diablo Canyon Power Plant Site Vice President Mail Code 104/5/601

p. O. Box 56 Avila Beach, CA 93424 805.545.3462 Internal: 691.3462 March 25, 2011 Fax: 805.545.6445 PG&E Letter DC L-11 -021 U.S. Nuclear Regulatory Commission 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 Comments on the Safety Evaluation Report with Open Items Related to the Diablo Canyon Power Plant License Renewal

Dear Commissioners and Staff:

By letter dated November 23, 2009, Pacific Gas and Electric Company (PG&E) submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for the renewal of Facility Operating Licenses DPR-80 and DPR-82, for Diablo Canyon Power Plant (DCPP) Units 1 and 2, respectively. The application included the license renewal application (LRA), and Applicant's Environmental Report-Operating License Renewal Stage.

By letter dated January 10, 2011, the NRC staff provided PG&E with the "Safety Evaluation Report With Open Items Related to the License Renewal of the Diablo Canyon Nuclear Power Plant, Units 1 and 2" (SER). The staff requested that PG&E review the SER and verify its accuracy.

Enclosure 1 contains PG&E's technical comments and Enclosure 2 contains PG&E's editorial comments. The enclosures contain references to the SER, the related comment, and a recommended resolution for staff consideration.

PG&E makes no regulatory commitments (as defined in NEI 99-04) in this letter.

If you have any questions regarding this submittal, please contact Mr. Terence L. Grebel, License Renewal Project Manager, at (805) 545-4160.

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

  • Comanche Peak
  • Diablo Canyon
  • Palo Ve rde
  • San Onofre
  • Wolf Creek

Document Control Desk PG&E Letter DCL-11-021 March 25, 2011 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on March 25,2011.

"-

Bec~

Site Vice President gwh/50369777 Enclosures cc: Diablo Distribution cc/enc: Elmo E. Collins, NRC Region IV Regional Administrator Nathanial B. Ferrer, NRC Project Manager, License Renewal Kimberly J. Green, NRC Project Manager, License Renewal Michael S. Peck, NRC Senior Resident Inspector Alan B. Wang, NRC Licensing Project Manager A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • San Onofre
  • Wolf Creek

Enclosure 1 PG&E Letter DCL-11-021 Page 1 of 26 Pacific Gas and Electric Company Comments on the Safety Evaluation Report With Open Items Related to the License Renewal of Diablo Canyon Power Plant, Units 1 and 2 SER SER Comment Suggested Resolution Page Section Open Item 3.0.3.2.12-1: In the last sentence, the 01 refers to SER Section 3.0.3.2.12 instead of Revise the 01 number to 3.0.3.1.12-1 and the 1-7 1.4 SER Section 3.0.3.1.12. reference to 3.0.3.1.12.

The 01 number should be 3.0.3.1.12-1.

Revise the 1st paragraph, last sentence of the The last sentence for Open Item 2.1-1 should paragraph for Open Item 2.1-1 to read: "See 1-7 1.5 refer to SER Section 2.3.3.19, since 2.3.3.19 SER Sections 2.1.4.1.2; 2.3, 2.3.3.7; and refers back to Open Item 2.1-1.

2.3.3.19."

1st sentence in RAI4.3-13 states: "The staff noted that the applicant dispositioned the CUF Revise 1st sentence in RAI 4.3-13 to read: "The values for the 2009 replacement Unit 2 upper staff noted that the applicant dispositioned the reactor vessel (RV) closure head components, CUF values for the 2009 replacement Unit 2 1-10 1.5 and its control rod driver mechanism (CRDM) ... " upper reactor vessel (RV) closure head components, and its control rod drive Gfi.vef Change "driver mechanism" to "drive mechanism (CRDM) ... "

mechanism" per SER, page xv, Abbreviations.

Change "P&ID" to "OVIDs", which are highlighted Replace "system piping and instrumentation 2-27 2.1.4.5.2 for Boundary Drawings. See LRA diagrams (P&IDs)" with "Operating Valve Section 2.1.3.1. Identification Diagrams (OVIDs)"

Last paragraph: Change "P&ID" to "OVIDs",

2-31 2.1.5.2.2 which are highlighted for Boundary Drawings. Replace "P&IDs" with "OVIDs" See LRA Section 2.1.3.1.

Enclosure 1 PG&E Letter DCL-11-021 Page 2 of 26 SER SER Comment Suggested Resolution Page Section 1st paragraph: Change "P&IDs" to "OVIDs",

2-32 2.1.5.2.2 which are highlighted for Boundary Drawings. Replace "P&IDs" with "OVIDs" See LRA Section 2.1.3.1.

1st paragraph, 6th sentence states: "The vessel is supported by pads on the bottom of each of these six nozzles." To be consistent with LRA Section 2.3.1.1, revise the sentence to read: "The vessel is nozzle 2-45 2.3.1.1.1 LRA Section 2.3.1.1 states that the vessel is supported by pads on the bottom of each of nozzle supported. Per FSAR Figures 5.4.1 and these six nozzles."

5.4.2, the reactor vessel is supported by two inlet nozzles and two outlet nozzles.

1st paragraph, last sentence, states: "A reactor head vent system is provided for the removal of Recommend revising the last sentence of the 1st non-condensable gases and for additional paragraph to read: "A reactor vessel head vent 2-46 2.3.1.2.1 letdown capability from the RCS." system is provided for the removal of non-This function is not consistent with LRA Section condensable gases and for additional letdown 2.3.1.2. The reactor head vent system does not capability from the ReS."

provide letdown capability for RCS.

2nd paragraph: The intended functions listed includes: "provides for ... additional letdown capability from the RCS using the reactor vessel Revise system intended function to read:

head vent system." "provides for the removal of non-condensable 2-46 2.3.1.2.1 This intended function is not consistent with LRA gases and for additional letdov/n capability from Section 2.3.1.2. The system intended function the RCS using the reactor vessel head vent does not provide for additional letdown capability system."

from the RCS using the reactor vessel head vent system.

Enclosure 1 PG&E Letter DCL-11-021 Page 3 of 26 SER SER Comment Suggested Resolution Page Section 1st paragraph, states: "LRA Section 2.3.3.4 describes the containment heating, ventilation, Revise 1st paragraph to read: "LRA and air conditioning ... " Section 2.3.2.4 2.3.3.4 describes the containment heating, ventilation, and air Change LRA Section 2.3.3.4 to LRA conditioning ... "

2-53 2.3.2.4.1 Section 2.3.2.4.

Revise the 3rd paragraph, last sentence, to read:

3rd paragraph, last sentence, states: "LRA Table "LRA Table 2.3.2-4 2.3.3 4 lists containment 2.3.3-4 lists containment HVAC system HVAC system component types subject to an component types subject to an AMR" AMR" Change LRA Table 2.3.3-4 to LRA Table 2.3.2-4.

1st sentence in the 3rd complete paragraph, states: "In its supplemental response dated October 27, 2010, the applicant indicated that Revise the 1st sentence in the 3rd paragraph to design changes were made to the fire water read: "In its supplemental response dated storage and transfer tank to eliminate reliance on October 27, 2010, the applicant indicated that them for additional feedwater supply." design changes were made to the condensate 2-60 2.3.3.5.2 In response to RAI 2.3.3.5-1, PG&E Letter storage tanks fire water storage and transfer tank DCL-1 0-133, dated October 27, 2010, states that to eliminate reliance on the firewater storage tank the design changes were made to the tAem for additional seismically-qualified condensate storage tank to eliminate reliance on feedwater supply."

the firewater storage tank for additional feedwater supply.

Enclosure 1 PG&E Letter DCL-11-021 Page 4 of 26 SER SER Comment Suggested Resolution Page Section Last paragraph, 1st sentence, states: "In a letter dated August 17, 2010, the applicant responded by discussing the internal plenums that it Revise the last paragraph, 1st sentence, to read:

installed for all nonsafety-related CST "In a letter dated August 17, 2010, the applicant connections to maintain safety-related inventory responded by discussing the internal plenums 2-60 2.3.3.5.2 in the CST." that it installed for any aU nonseismically qualified nonsafety related CST connections in the usable Per PG&E Letter DCL-10-104, dated August 17, volume region to maintain safety-related 2010, plenums were installed around any inventory in the CST."

nonseismically qualified CST connections in the usable volume region 3rd and 4th full paragraph, states: "Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-3 acceptable. The staff confirmed that the applicant added the piping attached to the reservoirs into the scope for license renewal Revise the 4th full paragraph to read: "Based on and revised the license renewal boundary its review, the staff finds the applicant's response drawing for makeup water system to reflect the to RAI 2.3.3.5-3 acceptable. The staff confirmed in-scope piping. Therefore, the staff's concern that the applicant added the long term cooling described in RAI 2.3.3.5-3 is resolved." flow Qath using the Qortable firewater QumQ at 2-61 2.3.3.5.2 location 114-A (LR-DCPP-16-106716-11}. The The SER should be clarified. The RAI pertained QiQing at location 112-C was not added in scoQe to piping at location 112-C (LR-DCPP because the comQonents at location 112-C did 106716-11), which was not added in scope not Qenetrate the reservoir. Therefore, the staff's because the components at location 112-C did concern described in RAI 2.3.3.5-3 is resolved."

not penetrate the reservoir. The piping added in scope was the long-term cooling flow path using the portable firewater pump at location 114-A (LR-DCPP-16-106716-11).

Enclosure 1 PG&E Letter DCL-11-021 Page 5 of 26 SER SER Comment Suggested Resolution Page Section Revise sentence to read: "In addition, portions of 1st paragraph, 3rd sentence: Add the word 2-90 2.3.4.3.1 the system support fire protection, EQ, and SSO "support" after the word system".

requirements."

1st paragraph, 2nd sentence, reads: "There are two RWSTs and two CSTs, one for unit of the Revise 2nd sentence in 1st paragraph of section 2-106 2.4.13.1 plant." Add the word "each" before the word 2.4.13.1 to read: "There are two RWSTs and two "unit" in the 2nd sentence. (Refer to LRA CSTs, one for each unit of the plant."

Section 2.4.13)

Operating Experience, 1st paragraph, last sentence, states: "The applicant included the Revise the 1st paragraph, last sentence, to read:

following as part of the operating experience: All "The applicant included the following as part of degradation indications to date are from wear the operating experience: All degradation (fretting) due to loose parts, tube supports, anti- indications to date are from wear (fretting) due to 3-22 3.0.3.1.6 vibration bars, and manufacturing or handling loose parts, tube supports, anti-vibration bars, anomalies. The tubing and secondary internals and manufacturing or handling anomalies. The in these units are not susceptible to corrosion tubing and secondary internals in these units are due to advanced material design." not susceptible more resistant to corrosion due to This does not reflect the change made in PG&E advanced material design."

Letter DCL-1 0-073, dated July 7,2010.

(5) This section states: "Units 1 and 2 both have several capsules with low lead factors that will remain in the RV during the period of extended (5) Change sentence to read:

operation."

3-29 3.0.3.1.9 "Units 1 and 2 both have has several capsules This statement is inconsistent with the SER, with low lead factors that will remain in the RV page 3-30, 2nd paragraph, last sentence, which during the period of extended operation."

states: "No capsules will remain in the RV during the period of extended operation." The 2nd paragraph discusses Unit 2.

Enclosure 1 PG&E Letter DCL-11-021 Page 6 of 26 SER SER Comment Suggested Resolution Page Section Last paragraph on page, 3rd and 4th sentences, Change 3rd sentence as follows: "By letter dated state: "By letter dated August 26, 2010, the staff August 26July 20, 2010, the staff issued RAI issued RAI B2.1.15-1 ... " "In its September 1, B2.1.15-1 ... "

2010, response, the applicant. .. "

3-29 3.0.3.1.9 Change 4th sentence as follows: "In its The dates do not appear to be correct. The RAI September 22 August 17, 2010, response, the was issued on July 20, 2010, and the response applicant clarified that four surveillance was sent August 17, 2010. Refer to PG&E Letter capsules ... "

DCL-1 0-1 00.

FSAR Supplement, 1st paragraph, last sentence, states: "The staff also noted that the applicant committed (Commitment No.6) to implement the Revise FSAR Supplement, 1st paragraph, last new Selective Leaching of Materials Program sentence, to read: "The staff also noted that the prior to entering the period of extended operation applicant committed (Commitment 6) to 3-36 3.0.3.1.11 for managing aging of applicable components:" implement the new Selective Leaching of Materials Program during the 5 years prior to PG&E Letter DCL-10-164, dated December 13, entering the period of extended operation for 2010, states that the implementation schedule for managing aging of applicable components."

the Selective Leaching of Materials Program is "5 years prior to the period of extended operation."

Last paragraph, 2nd sentence, states: " ... the staff noted that the tube developed a leak within Revise last paragraph, 2nd sentence to state:

three months of returning to power operations " ... the staff noted that the tube developed a leak 3-39 3.0.3.1.12 during Unit 2 Operating Cycle 14." within tfl.ree four months of returning to power Other references to the leak in this section operations during Unit 2 Operating Cycle 14."

correctly state: " ... within 4 months ... "

Enclosure 1 PG&E Letter DCL-11-021 Page 7 of 26 SER SER Comment Suggested Resolution Page Section SER, under Summary of Technical Information in the Application, 2nd sentence, states: "The applicant stated that the EO of Electrical Components Program manages component Revise SER, under Summary of Technical thermal, radiation, and cyclic aging through use Information in the Application, 2nd sentence, to of aging evaluations based on the methods noted read: "The applicant stated that the EO of in 10 CFR 50.49(f) and RG 1.89 Revision 1." Electrical Components Program manages 3-64 3.0.3.1.20 component thermal, radiation, and cyclic aging LRA Section 83.2 states that evaluations are through use of aging evaluations based on the based on 10 CFR 50.49(f) qualification methods. methods noted in 10 CFR 50.49(f) and RG 1.89 DCPP EO program considers but is not Revision 1.

committed RG 1.89 Revision for qualification of new and replacement equipment installed since the promulgation of the Guide.

The SER states: "Exception 5. LRA Section 82.1.10 states an exception to the 'preventive Revise sentence to read:

actions,' 'parameters monitored or inspected,' Exception 5. LRA Section 82.1.10 states an

'detection of aging affects,' 'monitoring and exception to the 'preventive actions,' 'parameters 3-84 3.0.3.2.4 trending,' and 'acceptance criteria' program monitored or inspected,' 'detection of aging elements." affects,' 'monitoring and trending,' 'corrective The SER does not list "Corrective Actions" as an actions,' and 'acceptance criteria' program exception whereas LRA Section 82.1.10 lists elements.

"Corrective Actions" as an exception.

, ...

Enclosure 1 PG&E Letter DCL-11-021 Page 8 of 26 SER SER Comment Suggested Resolution Page Section FSAR Supplement, 4th sentence, states: "The Revise FSAR Supplement, 4th sentence, to read:

staff further noted that the applicant committed (Commitment No.2) to enhance the Fire "The staff further noted that the applicant Protection Program procedures to include committed (Commitment No.2) to enhance the inspections for all fire-rated doors and Fire Protection Program procedures to include 3-90 3.0.3.2.5 qualifications for personnel performing fire inspections for all fire-rated doors listed in the damper and fire door inspections prior to entering DCPP Fire Hazards Analysis and qualification the period of extended operation." criteria for personnel performing fire damper and fire door inspections prior to entering the period This is inconsistent with LRA Table A4-1, of extended operation Commitment 2.

Enclosure 1 PG&E Letter DCL-11-021 Page 9 of 26 SER SER Comment Suggested Resolution Page Section Add the underlined wording to the FSAR Supplement, 1st paragraph:

"Specifically, the applicant committed to f)eFferm Sf)riAkler Reaa testiAJ er ref)laGemeAt iA aGGeraaAGe JllitR NFPA 2§; te eARaAGe tRe f)reJram f)reGeal::lres te iAGll::lae eitRer f)erieaiG, AeA iAtrl::lsive vell::lmetriG e*amiAatieAs, er visl::lal iAsf)eGtieAs ef fire Jllater f)if)iAJ; aAa te eARaAGe tRe f)reJram f)reGeal::lres te state treAaiAJ reEll::liremeAts enhance the Fire Water System FSAR Supplement, 1st paragraph, states: program:

"Specifically, the applicant committed to perform Sprinkler heads in service for 50 years will be sprinkler head testing or replacement in replaced or representative samples from one or accordance with NFPA 25; to enhance the more sample areas will be tested consistent with program procedures to include either periodic, NFPA 25 1 In s12. e ction I Testing and Maintenance 3-94 3.0.3.2.6 non-intrusive volumetric examinations, or visual of Water-Based Fire Protection S't,stems inspections of fire water piping; and to enhance guidance. Test procedures will be repeated at the program procedures to state trending 10-year intervals during the period of extended requirements. operation for sprinkler heads that were not l

This is inconsistent with LRA Table A4-1, replaced prior to being in service for 50 years z to Commitment 3. ensure that signs of degradation such as l corrosion z are detected prior to the loss of intended function z and For either periodic z non-intrusive volumetric examinations z or visual inspections on firewater piping. Non-intrusive volumetric examinations would detect any loss of material due to corrosion to ensure that aging effects are managed z wall thickness is within acceptable limits and degradation would be detected before the loss of intended function. Visual

Enclosure 1 PG&E Letter DCL-11-021 Page 10 of 26 SER SER Comment Suggested Resolution Page Section insQections would evaluate (1) wall thickness as it aQQlies to avoidance of catastroQhic failure! and (2) the inner diameter of the QiQing as it aQQlies to the design flow of the fire Qrotection system.

The volumetric examination technigue emQloyed will be one that is generally acceQted in the industry! such as ultrasonic or eddy current! and to state trending reguirements Summary of Technical Information in the Revise Summary of Technical Information in the Application, 1st paragraph, 13th line, states:

II Application, 1st paragraph, 13th line, to state:

... ultrasonic wall thickness measurements of the II fuel oil storage tanks if there are indications of ... one-time ultrasonic wall thickness 3-95 3.0.3.2.7 reduced cross sectional thickness found during measurements of #le-accessible Qortions of fuel the visual inspection ... II oil storage tanks bottoms if there are indications of reduced cross sectional thickness found during The SER is not consistent with LRA Section the visual inspection ... II 82.1.14, Program description part (d).

Enclosure 1 PG&E Letter DCL-11-021 Page 11 of 26 SER SER Comment Suggested Resolution Page Section Exception 2, 3rd sentence, states: "The applicant stated that it does not remove water from the portable diesel driven fire pump fuel oil tanks and the portable caddy fuel oil tanks, as they are small tanks that do not have provisions Revise SER Exception 2, 3rd sentence, to read:

to remove water from the tank bottoms." "The applicant stated that it does not remove water from the portable diesel driven fire pump The SER does not address the fuel oil pump

. 3-96 3.0.3.2.7 fuel oil tanksJ. afltI--the portable caddy fuel oil head tanks.

tanks, or the fuel oil QumQ head tanks as they are LRA Section 82.1.14, Preventive Actions - small tanks that do not have provisions to Element 2 and Monitoring and Trending - remove water from the tank bottoms."

Element 5, second sentence, states: "Water is not removed from the portable diesel driven fire pump fuel oil tanks, portable caddy fuel oil tanks, or the fuel oil pump head tanks."

Enclosure 1 PG&E Letter DCL-11-021 Page 12 of 26 SER SER Comment Suggested Resolution Page Section Add the following to Exception 3, prior to the last sentence:

"The agglicant stated the fuel oil in the fuel oil gumg head tanks will not be anal~zed for garticulate concentration since the fuel oil in the fuel oil gumg head tanks is reglenished with fuel Exception 3 as stated in the SER is consistent oil from the da~ tanks on a dail~ c~cle. The with LRA Section 82.1.14, Parameters Monitored agglicant further stated that grovisions do not or Inspected - Element 3, first paragraph. exist to samgle for garticulates directl~ from the fuel oil gumg head tanks. The fuel oil gumg head 3-96 3.0.3.2.7 Exception 3 does not address LRA Section tanks are filled with fuel oil from the fuel oil da~

82.1.14, Parameters Monitored or Inspected -

tanks. The fuel oil from the diesel fuel oil da~

Element 3, second paragraph. The fuel oil pump tanks is anal~zed guarterl~ for total garticulate head tanks will not be analyzed for particulate contamination in accordance with ASTM 02276 concentration.

using the limits sgecified in the OCPP Technical Sgecifications. The agglicant further stated that freguent addition of fuel oil and the absence of elevated levels of garticulates from the fuel suggl~ assure that high levels of garticulates are not being introduced into or accumulating in the fuel oil gumg head tanks."

Enclosure 1 PG&E Letter DCL-11-021 Page 13 of 26 SER SER Comment Suggested Resolution Page Section Exception 2, 3rd sentence, states: "The applicant stated that it does not remove water from the portable diesel driven fire pump fuel oil tanks and the portable caddy fuel oil tanks, as they are small tanks that do not have provisions Revise SER Exception 2, 3rd sentence, as to remove water from the tank bottoms." follows: "The applicant stated that it does not remove water from the portable diesel driven fire The SER does not address the fuel oil pump 3-96 3.0.3.2.7 pump fuel oil tanks.1. aR4-the portable caddy fuel head tanks.

oil tanks, or the fuel oil QumQ head tanks as they LRA Section 82.1.14, Preventive Actions - are small tanks that do not have provisions to Element 2 and Monitoring and Trending - remove water from the tank bottoms."

Element 5, second sentence, states: "Water is not removed from the portable diesel driven fire pump fuel oil tanks, portable caddy fuel oil tanks, or the fuel oil pump head tanks."

Add the following to SER Exception 4:

SER Exception 4 does not mention that the fuel "Provisions do not exist to take samQles directly oil pump head tanks have no provisions to take from the fuel oil QumQ head tanks. The fuel oil sample directly from the head tanks. Refer to QumQ head tanks are filled with fuel oil from the LRA Section 82.1.14, Parameters Monitored or fuel oil day tanks. The samQles taken from the 3-96 3.0.3.2.7 Inspected - Element 3 and Detection of Aging fuel oil day tanks are taken in accordance with Effects - Element 4, second paragraph. ASTM 04057 1 with the exceQtion of the Qortable diesel driven fire QumQ fuel oil tanks fuel oil l

QumQ head tanks and the Qortable caddy fuel oil l

tanks."

Enclosure 1 PG&E Letter DCL-11-021 Page 14 of 26 SER SER Comment Suggested Resolution Page Section Change 3rd bullet to reflect amended FSAR Supplement, 3rd bullet, states: "provide Commitment 4 in PG&E Letter DCL-1 0-096, for supplemental UT thickness measurements if which states:

there are indications of reduced cross sectional thickness found during the visual inspection of "provide for one-time supplemental UT thickness the diesel fuel oil storage tanks, diesel generator measurements of accessible portions of fuel oil 3-100 3.0.3.2.7 day tanks, portable diesel-driven fire pump fuel tank bottoms." if there are indications of reduced oil tanks, and portable caddy fuel oil tanks." cross sectional thickness found during the visual inspection of the diesel fuel oil storage tanks, The bullet is not consistent with amended diesel generator day tanks, portable diesel driven Commitment 4 in PG&E Letter DCL-10-096, fire pump fuel oil tanks, and portable caddy fuel dated August 12, 2010.

oil tanks."

2nd paragraph, 1st bullet, reads: "The inlet Align the SER wording with PG&E Letter DCL-piping for the auxiliary saltwater system has10-148 by revising the 1st bullet to state:

cathodic protection installed on its entire length "The inlet piping for the auxiliary saltwater system 3-103 3.0.3.2.8 or it is encased in the concrete floor of the turbine has cathodic protection installed on its entire building." length in contact with soil. The segments eF-iHs The wording does not reflect PG&E Letter DCL- encased in the concrete floor of the turbine 10-148. building do not have cathodic protection."

FSAR Supplement, 3rd sentence, states: "The staff also noted that the applicant committed (Commitment No.7) to implement the new Revised FSAR Supplement, 3rd sentence, to Buried Piping and Tanks Inspection Program read: "The staff also noted that the applicant prior to entering the period of extended operation committed (Commitment No.7) to implement the 3-104 3.0.3.2.8 for managing aging of applicable components." new Buried Piping and Tanks Inspection Program during the 10 years prior to entering the LRA Table A4-1, Commitment 7, indicates that period of extended operation for managing aging the Buried Piping and Tanks Inspection Program of applicable components."

will be implemented during the 10 years prior to the period of extended operation.

Enclosure 1 PG&E Letter DCL-11-021 Page 15 of 26 SER SER Comment Suggested Resolution Page Section In the final paragraph on the page, 3rd line down, the SER states: "By letter dated December 13, 2010, the applicant supplemented its response to

~evise the final paragraph on Page 3-106, 3rd RAI B2.1.19-2 and stated that it will line, to state:

volumetrically examine 10 percent, with a maximum of 25, socket welds and 10 percent, "By letter dated November 241 2010 1 QeeerneeF with a maximum of 25, butt welds within the 13, 2010, the applicant supplemented its population of ASME Code Class 1 small-bore response to RAI B2.1.19-2 and stated that it will 3-106 3.0.3.2.9 piping in each unit." volumetrically examine 10 percent, with a maximum of 25, of the small bore socket welds PG&E Letter DCL-10-146, dated November 24, and 10 percent, with a maximum of 25 of the 2010, states: "Diablo Canyon Power Plant butt welds within the population of ASME GaGe (DCPP) will volumetrically examine 10 % , with a Class 1 NPS less than 4 inches small eOFe piping maximum of 25, of the small bore socket welds in each unit."

and 10 % , with a maximum of 25, of the butt welds within the population of ASME Class-1 piping NPS less than 4-inches on each unit."

Operating Experience, 1st paragraph, 7th line, states: "In the second example, a four-inch excess letdown piping reducer segment socket Change sentence to read: "In the second weld showed a crack indication that was example, a fetl.F-one-inch excess letdown piping attributed to IGSCC caused by sensitization of reducer segment socket weld showed a crack 3-108 3.0.3.2.9 the base metal as a result of the initial welding indication that was attributed to IGSCC caused process." by sensitization of the base metal as a result of the initial welding process."

Per PG&E Letter DCL-10-073, dated July 7, 2010, four-inch should be one-inch.

Enclosure 1 PG&E Letter DCL-11-021 Page 16 of 26 SER SER Comment Suggested Resolution Page Section Operating Experience, 1st paragraph, on page 3-108, last sentence, states: During its Revise Operating Experience, 1st paragraph, on audit, the applicant stated in discussions with the page 3-108, last sentence to read:

staff that this failure was not considered to be its aU~Jt, P~f that this failure was not

. a licant stated in within the program scope because the unusual "During

. sions with the sta the diSCUS n geometry of the component resulted in a second considered to be within the program scope re-heating of the affected region during welding because the unusual geometry of the component and produced an atypical, highly-sensitized resulted in a second re heating of the affected 3-108 3.0.3.2.9 microstructure that was especially susceptible to region during 'Nelding and produced an atypical, SCC." highly sensitized microstructure that "Nas PG&E Letter DCL-1 0-126, dated September 30, especially susceptible to SCC. The applicant 2010, states: "LRA Section B2.1.19 identified states in a letter dated September 30, 2010, that that stress corrosion cracking occurred on the this failure is not considered to be within the excess letdown reducer segment socket weld. program scope because the stress corrosion After further review, this stress corrosion crack crack occurred on the ASME Class-2 portion of occurred on the ASME Class-2 portion of the the piping."

piping."

FSAR Supplement, 3rd sentence, states: "The staff noted that the applicant committed (Commitment No. 39) to implement the One- Change the 3rd sentence to read: "The staff Time Inspection of ASME Code Class 1 Sma"- noted that the applicant committed (Commitment Bore Piping Program prior to entering the period No. 39) to implement the One-Time Inspection of 3-109 3.0.3.2.9 of extended operation for managing aging of ASME Code Class 1 Small-Bore Piping Program applicable components." durina the 6 years prior to entering the period of n for managing aging of LRA Table A4-1, Commitment 39, indicates that applicable components."

the commitment will be implemented during the 6 years prior to the period of extended operation.

Enclosure 1 PG&E Letter DCL-11-021 Page 17 of 26 SER SER Comment Suggested Resolution Page Section 1st full paragraph on page, 7th line, states: "The applicant evaluated 50 locations in Unit 1 and 40 Revise sentence to read: "The applicant locations in Unit 2, as part of the extent of evaluated 50 locations in Unit 1 and 40 locations 3-109 3.0.3.2.9 condition. The staff noted that of these 94 in Unit 2, as part of the extent of condition. The locations evaluated ... " staff noted that of these 94 90 locations This was an error in PG&E Letter DCL-10-126, evaluated ... "

which used 94. The total number should be 90.

1st full paragraph, 1st sentence, states: "In its response dated July 7, 2010, and supplement Change the 1st full paragraph, 1st sentence, to dated September 1, 2010, the applicant read: "In its response dated July 7, 2010, and summarized and clarified the plant-specific supplement dated September 304, 2010, the 3-109 3.0.3.2.9 operating experience related to Class 1 small- applicant summarized and clarified the plant-bore piping." specific operating experience related to Class 1 The supplement was dated September 30,2010. small-bore piping."

Refer to PG&E Letter DCL-10-126.

FSAR Supplement, 4th sentence: The words "this new program" is not accurate. Commitment 20 states that operating experience will be FSAR Supplement, 4th sentence: change "this 3-116 3.0.3.2.11 evaluated and appropriately incorporated into the new program" to the new programs."

"new programs", of which 9 are listed in the LRA Section of LRA Table A4-1.

FSAR Supplement, 2nd paragraph, 3rd sentence, states: "(energized greater 25 Revise FSAR Supplement, 2nd paragraph, 3-130 3.0.3.2.14 percent of the time)" 3rd sentence, to read: "(energized greater than 25 percent of the time)"

The word "than" is missing before 25.

Enclosure 1 PG&E Letter DCL-11-021 Page 18 of 26 SER SER Comment Suggested Resolution Page Section 4th paragraph, last sentence, states: "The applicant further stated that since the crack does affect the performance characteristics of the Change 4th paragraph, last sentence, to read:

structure, its potential for propagation is not "The applicant further stated that since the crack present, and it acts as a control joint, repair is not does not affect the performance characteristics of 3-148 3.0.3.2.18 required." the structure, its potential for propagation is not present, and it acts as a control joint, repair is not Refer to PG&E Letter DCL-1 0-077, dated required."

July 19, 2010. Change "does affect. .. " to "does not affect. .. "

FSAR Supplement, 1st bullet, states: "monitor groundwater samples every 5 years for pH, Revise FSAR Supplement, 1st bullet, to read:

sulfates, and chloride concentrations, including "monitor groundwater samples every 5 years for 3-149 3.0.3.2.18 seasonal variations." pH, sulfates, and chloride concentrations, LRA Table A4-1, Commitment 14, bullet 1, including consideration for Qotential seasonal includes the words "consideration for potential" variations."

prior to seasonal variations ..

2nd paragraph, 4th line, states: "The applicant also clarified that the new 50-year TLAA for these components is addressed in LRA Section 4.3.2.5 Revise 2nd paragraph, 4th line, to read: "The and that the 50-year CUF values for these applicant also clarified that the new 50-year nozzles are being dispositioned in accordance TLAA for these components is addressed in LRA 3-158 3.0.3.2.19 with 10 CFR 54.21 (c)(1)(iii)." Section 4.3.2.5 and that the 50-year CUF values 10 CFR 54.21 (c)(1)(iii) should be changed to for these nozzles are being dispositioned in 10 CFR 54.21 (c)(1)(i) to be consistent with LRA accordance with 10 CFR 54.21(c)(1)(i)."

Section 4.3.2.2 and PG&E Letter DCL-1 0-121, dated September 22, 2010.

Enclosure 1 PG&E Letter DCL-11-021 Page 19 of 26 SER SER Comment Suggested Resolution Page Section 4th paragraph, 5th sentence, the SER states that the LRA was revised to use the Selective Revise 4th paragraph, 5th sentence, to read:

Leaching Program instead of the External Surfaces Monitoring Program to monitor for "In its response dated October 12, 2010, the material loss in solenoid valves and regulators applicant revised these AMR line items to use the 3-311 3.3.2.3.7 Selective Leaching of Material Program in made of copper-alloy (greater than 15% zinc).

Based on LRA Table 3.3.2-7, pages 3.3-143 and addition to the External Surfaces Monitoring 3.3-144, the External Surfaces Monitoring Program to manage the loss of material aging Program was retained, and the Selective effect."

Leaching Program was added.

Revise 3rd paragraph of section 3.3.2.3.10 to read:

3-315 3rd paragraph, 1st sentence uses the term "dry 3.3.2.3.10 gas-interior" instead of "dry gas (internal)" as "In LRA Tables 3.3.2-10 and 3.5.2-4, the 3-316 indicated in LRA Table 3.3.2-10. applicant stated that for piping constructed of glass exposed to dry gas-interior internal and glass ... "

2nd paragraph, 1st sentence, states: "In LRA Table 3.4.2-4, the applicant stated that elastomer Revise 2nd paragraph, 1st sentence, to read:

expansion joints exposed to plant indoor air (internal) are managed for hardening and loss of "In LRA Table 3.4.2-4, the applicant stated that strength by the Inspection of Internal Surfaces in elastomer expansion joints exposed to secondary 3-356 3.4.2.3.4 Miscellaneous Piping and Ducting Components water plant indoor air (internal) are managed for Program." hardening and loss of strength by the Inspection of Internal Surfaces in Miscellaneous Piping and Per LRA Table 3.4.2-4, page 3.4-83, Row 4, Ducting Components Program."

"plant indoor air (internal)" should be "secondary water (internal)."

Enclosure 1 PG&E letter DCl-11-021 Page 20 of 26 SER SER Comment Suggested Resolution Page Section 1st paragraph, 1st sentence, states: "The staff reviewed LRA Table 3.5.2-14, which summarizes the results of AMR evaluations for the outdoor Revise 1st sentence in 1st paragraph of Section 3-391 3.5.2.3.13 water storage tank foundations and encasements 3.5.2.3.13 to read: "The staff reviewed LRA component groups." Table 3.5.2-13 3.5.2 14, which summarizes ... "

The LRA Table that summarizes the above is LRA Table 3.5.2-13.

2nd paragraph, 1st sentence, states: "In LRA Table 3.5.2-14, the applicant stated that stainless steel traveling screens and non-ASME Code Revise 2nd paragraph, 1st sentence to read:

supports for mechanical equipment that are submerged are managed for loss of material by "In LRA Tables 3.5.2-10 and 3.5.2-14, the the Structures Monitoring Program, citing generic applicant stated that stainless steel traveling 3-392 3.5.2.3.14 screens and non-ASME Code supports for note J."

mechanical equipment that are submerged are LRA Table 3.5.2-10 states that stainless steel managed for loss of material by the Structures traveling screens that are submerged are Monitoring Program, citing generic note J."

managed for loss of material by the Structures Monitoring Program, citing generic note J.

5th bullet from top of page states:

"Flow-Induced Vibration Endurance Limit, Revise bullet to read:

Transient Cycle Count Assumptions, and Ductility Reduction of Fracture Toughness for the Reactor - Flow-Induced Vibration Endurance Limit, 4:"'3 4.1.1 Transient Cycle Count Assumptions, and Vessel Internals" that PG&E identified as not being TLAAs. Ductility Reduction of Fracture Toughness for the Reactor Vessel Internals LRA Table 4.1-2, page 4.1-10 states that transient cycle count assumptions are a TLAA.

--

Enclosure 1 PG&E Letter DCL-11-021 Page 21 of 26 SER SER Comment Suggested Resolution Page Section Last paragraph in section states: "Pursuant to 10 CFR 54.21 (c)(2) , the applicant stated that it did not identify any exemptions granted under 10 To be consistent with the LRA and SER CFR 50.12 based on a TLAA, as defined in 10 Section 4.1.2.2, it should state that PG&E 4-3 4.1.1 CFR 54.3." identified the LBB evaluation as an exemption based on a TLAA.

The SER is not consistent with LRA Section 4.1.4, pg. 4.1-5 and LRA Section 4.8, pg. 4.8-1.

Paragraph prior to Section 4.1.3, 1st sentence, reads: "In its response dated October 21, 2010, Revise paragraph prior to Section 4.1.3, 1st the applicant amended LRA Sections 4.1.2 and sentence, to read: "In its response dated 4.8 to identify the exemption on use of ASME October 21, 2010, the applicant amended LRA Code Case N-514 to establish the LTOP system Sections ~ 4.1.4 and 4.8 to identify the 4-5 4.1.2.2 setpoints for Units 1 and 2 as an additional exemption on use of ASME Code Case N-514 to exemption based on a TLAA." establish the LTOP system setpoints for Units 1 Change Section 4.1.2 to Section 4.1.4 per PG&E and 2 as an additional exemption based on a Letter DCL-1 0-131, dated October 21, 2010. The TLAA.

DCL did not amend Section 4.1.2.

3rd paragraph, line 3, states: "The applicant also stated that Unit 1 calculations account for an uprate from 3338 MWt to 3411 MWt at the end of Revise the 3rd paragraph, line 3 to read:

Cycle 11." "The applicant also stated that Unit 1 calculations 4-6 4.2.1.1 This is inconsistent with LRA Section 4.2.1, account for an uprate from 3338 MWt to 3411 which states: "The calculations account for a MWt at the onset eRG of Cycle 11."

Unit 1 core power uprate from 3338 MWt to 3411 MWt at the onset of Cycle 11."

Enclosure 1 PG&E Letter DCL-11-021 Page 22 of 26 SER SER Comment Suggested Resolution Page Section 3rd full paragraph on page, last sentence, reads:

"8y letter dated July 20, 2010, the staff issued RAI 4.2-1, and requested that the applicant Revise 3rd full paragraph on page, last sentence, supply the source reference for the Cu and Ni to read: 8y tetter dated July 20, 2010, the staff content for Intermediate Shell Plates 84106-1, issued RAI 4.2.2-1, and requested that the 4-9 4.2.2.2 84106-2, and 84107-3." applicant supply the source reference for the Cu and Ni content for Intermediate Shell Plates The RAI number that the staff issued by letter 84106-1,84106-2, and 84107-3."

dated July 20, 2010, was RAI 4.2.2-1 and not RAI4.2-1.

Staff Evaluation, 5th paragraph, line 6 states:

"Intermediate shell plate 85454-3 (heat no. Revise Staff Evaluation, 5th paragraph, line 6, to C5168-2) actually has a higher RTPTS ... " state:

4-9 4.2.2.2 This should be "intermediate shell plate 85454-2 "Intermediate shell plate 85454-2a (heat no.

(heat no. C5168-2) actually has a higher RTPTS C5168-2) actually has a higher RTPTS ... "

... "

3rd paragraph, 1st sentence states: "The applicant also stated that it would implement alternate options, such as flux reduction, as Revise 3rd paragraph, 1st sentence to read:

provided in 10 CFR 50.61, if the provisions of "The applicant also stated that it would 4-11 4.2.2.2 10 CFR 50.61 cannot be met." implement alternate options, such as flux LRA Section 4.2.2 states: "In the event that the reduction, as provided in 10 CFR 50.61, if the provisions of 10 CFR 50.61 a cannot be met, provisions of 10 CFR 50.61~ cannot be met."

PG&E will implement alternate options, such as flux reduction, as provided in 10 CFR 50.61.

-

Enclosure 1 PG&E Letter DCL-11-021 Page 23 of 26 SER SER Comment Suggested Resolution Page Section 2nd paragraph, 2nd sentence, states: " ... CUF values for these nozzles are being dispositioned Change the 2nd paragraph, 2nd sentence, to in accordance with 10 CFR 54.21 (c)(1 )(iii)."

read:

4-23 4.3.1.2.1 This is inconsistent with PG&E Letter

" ... CUF values for these nozzles are being DCL-1 0-121, dated September 22, 2010, dispositioned in accordance with Enclosure 1, page 6. SG FW nozzles were 10 CFR 54.21 (c)(1)(i)."

dispositioned in accordance with 10 CFR 54.21 (c)(1)(i).

To be consistent with PG&E Letter DCL-10-121 and SER Section 4.3.1.2.1, page 4-24, revise the last sentence on page 4-23 to read:

Last sentence on 4-23 states: " ... that the liThe staff also noted that the applicant's applicant will submit the corrective action option response also clarifies one critical factor with selected for NRC approval." regard to selecting one of these corrective action 4-23 4.3.1.2.1 options, that the applicant will submit the This statement is inconsistent with SER Section corrective action option selected for NRC 4.3.1.2.1 and PG&E Letter DCL-10-121 ,

approval. II that the applicant will submit tAe Enclosure 1, page 6.

corrective action options selected fe.F to the NRC for approval, only if the corrective action oQtion is subject to an aQQlicable NRC review and aQQroval requirement. II

Enclosure 1 PG&E Letter DCL-11-021 Page 24 of 26 SER SER Comment Suggested Resolution Page Section 2nd paragraph, 4th line, states: "The applicant also clarified that the new 50-year TLAA for these components is addressed in LRA Section 4.3.2.5 Revise SER to read, and that the 50-year CUF values for these "The applicant also clarified that the new 50-year nozzles are being dispositioned in accordance TLAA for these components is addressed in LRA 4-23 4.3.1.2.1 with 10 CFR 54.21 (c)(1)(iii)." Section 4.3.2.5 and that the 50-year CUF values for these nozzles are being dispositioned in 10 CFR 54.21(c)(1)(iii) should be changed to accordance with 10 CFR 54.21 (c)(1 )(i)."

10 CFR 54.21 (c)(1)(i) to be consistent with LRA Section 4.3.2.2 and PG&E Letter DCL-10-121.

2nd paragraph in section, 7th line: cites FSAR Revise to FSAR Table 5.2-4, which lists 4-24 4.3.1.2.2 Table 5.2-3. The FSAR Table to cite is 5.2-4. transients for DCPP 1st paragraph, 2nd sentence, states: "The applicant stated that the reactor pressure boundary components associated with the RV Revise the 1st paragraph in section, 7th line, to closure heads are the control rod driver read: "The applicant stated that the reactor 4-35 4.3.2.2.1 mechanism (CRDM) pressure housings ... " pressure boundary components associated with the RV closure heads are the control rod drivef LRA Section 1.5, Acronyms, shows the CRDM as mechanism (CRDM) pressure housings ... "

being the control rod drive mechanism. Change "driver" to "drive." I

.

1st line and throughout remainder of section -

the SER states "Unit 1 Nos. 1 and 2 main flange Revise the SER to state that main flange 4-38 4.3.2.3.2 hydraulic nuts and studs." hydraulic nuts and studs are only applicable to The LRA Section 4.3.2.3, pages 4.3-19 and 4.3- Unit 1 RCP 1-2.

20 state "Unit 1 RCP 1-2."

-_ ..*..*... __ ....... _----

Enclosure 1 PG&E Letter DCL-11-021 Page 25 of 26 SER SER Comment Suggested Resolution Page Section 1st paragraph, last sentence: The reference to 4-57 4.3.2.11.2 SER Section 4.3.2.2 should be changed to See Comment SER 4.3.2.12.

9th line from the page bottom: When discussing Revise to state "unit load and unloading transient 4-64 4.3.3.3 the unit load and unloading transient, it should at 5% of power/minute" not state "55 of power/minute" 2nd paragraph: while discussing the Fen factor that was used, the SER quotes 2.45 and then 4-68 4.3.4.2 2.46 later on in the same paragraph. Revise to be consistent with LRA Table 4.3-8.

LRA Table 4.3-8 states 2.455.

The Source for Item Numbers 1, 2, and 3 in the Change the Source for Item Numbers 1, 2, and 3 A-1 Table A-1 SER is DCL-10-079 and should be DCL-09-079. from DCL-10-079 to DCL-09.;.079.

The Source for Item Numbers 5, 6, 7, 8, 9, 10, Change the Source for Item Numbers 5,6,7,8, A-2, A-3, Table A-1 11, 12, 13, and 19 in the SER is DCL-10-096 and 9, 10, 11, 12, 13, and 19 from DCL-1 0-096 to A-4 should be DCL-09-079. DCL-09-079.

The Enhancement or Implementation Schedule Change the Enhancement or Implementation for Item Number 6 should read: "During the 5 Schedule for Item Number 6 to read:

A-2 Table A-1 years prior to the period of extended operation" "During the 5 years prior to the period of per PG&E Letter DCL-10-164, dated extended operation." Add DCL-10-164 as the December 13, 2010. Source.

The Source for Item Numbers 15, 16, 17, 18, 20, Change Source for Item Numbers 15, 16, 17, 18, A-4, A-5, Table A-1 21, 22, 23, 24, 25, 26, 27, 28, and 29 in the SER 20,21,22,23,24,25,26,27,28, and 29 from A-6, A-7 is DCL-10-067 and should be DCL-09-079. DCL-10-067 to DCL-09-079.

I The Source for Item Numbers 22, 23, 24, and 25 Change Source for Item Numbers 22, 23, 24, and A-6 Table A-1 should be DCL-09-079. 25 from DCL-10-067 to DCL-09-079.

Enclosure 1 PG&E Letter DCL-11-021 Page 26 of 26 SER SER Comment Suggested Resolution Page Section The SER states the following for Commitment 44:

Revise Commitment to read: "The Structures "The Structures Monitoring Program inspection Monitoring Program inspection interval for safety-interval will be revised to be aligned with the related and non-safety related structures will be guidance in ACI 349.3R, Evaluation of Existing revised to be aligned with the guidance in ACI Nuclear Safety Related Concrete Structures, 349.3R, Evaluation of Existing Nuclear Safety Chapter 6, Evaluation Frequency, except for the A-9 Table A-1 Related Concrete Structures, Chapter 6, exterior of non-safety related structures, for Evaluation Frequency.", except for the exterior of which all accessible areas of both units will be ROR safety relates stFl:lctl:lFeS, for Jllhich all inspected at an interval of no more than ten accessiele areas of eoth I:lRits Jllill ee iRspectes at years."

aR iRtePJal of RO more thaR teR years."

Commitment 44 was amended by PG&E Letter Add DCL-10-164 as the Source.

DCL-1 0-164, dated December 13, 2010.

Item Number 54: The FSAR Supplement Section

/ LRA Section reads 82. 1. 18. Change the FSAR Supplement Section / LRA A-10 Table A-1 LRS Table A4-1 indicated that the FSAR Section in Item Number 54 from 82.1.18 to Supplement Section / LRA Section should be 82.1.26.

82.1.26.

Enclosure 2 PG&E Letter DCL-11-021 Page 1 of. 7 Pacific Gas and Electric Company Editorial Comments on the Safety Evaluation Report With Open Items Related to the License Renewal of Diablo Canyon Power Plant, Units 1 and 2 SER SER Commen't I Suggested Resolution Page Section 1-6 Table 1.4-1 1st row: Remove one "." in SER Section 3.0.3.1.4 1-8 1.5 Last line on page 1-8: add an "I" to "RA" 1-9 1.5 Last line in RAI 4.3-4: Change SEE to See.

1-10 1.5 2nd sentence in RAI4.3-14: add space in between "50" and "year."

4th sentence: "The LRA states that that ... "

2-6 2.1.4 Remove duplicate word "that" 2-9 2.1.4.1.2 4th paragraph on page 2-9, 3rd sentence: change "consistently" to "consistent" 2-19 2.1.4.2.2 1st bullet, 1st paragraph, last sentence: add a space between "above" and "mentioned."

1st paragraph, 2nd sentence: add the word 'renewal' after "... in scope of' (Refer to LRA Section 2.1.4.2) 2-32 2.1.5.3.1 Revise to read: "... in scope of license renewal, the .... "

1st paragraph, 2nd sentence: change "post-LOCA sample cooler" to "post-LOCA sample coolers" (plural).

2-58 2.3.3.4.1 Reference LR-OCPP-14-106714-09 and LR-OCPP-11-106711-04 show more than one post-LOCA cooler.

2-67 2.3.3.7.2 In the 4th sentence, next to last paragraph, use "effect" instead of "affect."

Enclosure 2 PG&E Letter DCL-11-021 Page 2 of 7 SER SER Comment I Suggested Resolution Page Section 2-77 2.3.3.12.2 In paragraph just before Section 2.3.3.12.3, add a space between 2.3.3.12 and "is."

Most AMP titles in table have "Program" at the end of the title. Seven AMP titles do not have the word 3-7 Table 3.0.1 "Program" at the end of the title.

Add "Program" to titles for 82.1.8, 82.1.21, 82.1.33, 82.1.38, 82.1.39, 83.1, and 83.2.

8y letter dated October 22, 2010, the applicant revised lRA Section A 1.15 to reflect that four, not five, 3-30 3.0.3.1.9 standby capsules will remain in the Unit 1 RV during the period of extended operation.

DCl 10-131 was dated October 21,2010 4th line from top of page reads: " ... degradation in Unit 2 l3 flux thimble tube ... "

3-42 3.0.3.1.12 Unit 2 l3 should be Unit 2 l13 last paragraph on page 3-59 states that the "intake structure is expected to resume monitoring under 3-59 3.0.3.1.19 Maintenance Rule (a)(2) status by 2010".

PG&E has not met this expectation. The new date is July 2011.

3rd paragraph, 3rd sentence, states: "The staff finds the applicant's response to RAI 82.1.3 1 acceptable 3-70 3.0.3.2.1 because ... "

Change RAI 82.1.3 1" to "82.1.3-1" (add a dash after "3".)

Enclosure 2 PG&E Letter DCL-11-021 Page 3 of7 SER SER Comment I Suggested Resolution Page Section 2nd full paragraph, 6th sentence states: "In addition, the applicant explained that the RV closure studs are not metal-plated."

This section needs to add a key element to managing stress corrosion cracking as stated in PG&E Letter 3-71 3.0.3.2.1 DCL-10-073. DCPP uses compatible lubricants wflich reduce the probability of stress corrosion cracking.

Revise 2nd full paragraph, 6th sentence, to state: "In addition, the applicant explained that the RV closure studs are not metal-plated and lubricants used z Fel-Pro 5000 and Neolube z are comQatible with the bolting material at oQerating temQerature for concerns related to stress corrosion cracking."

3-76 3.0.3.2.3 2nd to last line on page 3-76: eliminate comma between "issued" and "82.1.7-5."

Operating Experience, 1st paragraph, 4th sentence, states: " ... including the replacement of the diesel and 3-102 3.0.3.2.8 fuel oil storage and transfer system piping ..... "

Revise to read: " ... including the replacement of the diesel aM fuel oil storage and transfer system piping ..... "

3-105 3.0.3.2.8 In Conclusion, 4th line, remove space between "and" and "concludes."

3-113 3.0.3.2.11 In middle paragraph, first line, change "In it response" to "In its response ... "

3-126 3.0.3.2.14 In middle paragraph, 4th sentence: correct typo at "perofrmed."

Under Operating Experience, 3rd sentence, there is a period between "Unit 2" and "14th RO", instead of a 3-137 3.0.3.2.17 comma.

3-138 3.0.3.2.17 1st sentence on the page says "Ins" instead of INs (referring to NRC Information Notices).

Enclosure 2 PG&E Letter DCL-11-021 Page 4 of?

SER SER Comment I Suggested Resolution Page Section FSAR Supplement, 2nd paragraph, 1st sentence, states "procedures" whereas LRA Table A4-1, Commitment 3-149 3.0.3.2.18 34 states "work control" procedures.

Add the words "work control" prior to "procedures" to be consistent with LRA Table A4-1, Commitment 34.

3-152 3.0.3.2.19 Last line on page: Change "addition" to "additional."

3-303 3.3.2.3.4 Line 18 of paragraph: change "in these system" to "in these systems."

3-315 3.3.2.3.8 Line 18 on page 3-315: Add space between "SSC" and "of."

3-337 3.4.2.1.2 3rd paragraph, 9th line, change "open-cycle cooing water" to "open-cycle cooling water ... "

3-354 3.4.2.3.2 All instances of "Iexan" should be "Lexan."

4-18 4.3.1.2.1 Last paragraph on page 4-18, 3rd line: Change "action limited is reached" to "action limits are reached .. "

4-20 4.3.1.2.1 2nd paragraph, 5th line from bottom: add space between "use" and "stress" 1st bullet states that NRC independently calculated the number of feedwater initiation events through 60 years of operation. Refer to LRA Table 4.3-2, #12 & DCL-10-121, Encl. 1, pg. 10.

4-26 4.3.1.2.2 Revise the bullet to say that the independently calculated number of initiations is through 2008, not through the 60-year period. This matches the preceding para in the SER and matches the LRA.

4-29 4.3.1.2.2 3rd paragraph, 1st sentence: change "emphasize" to "emphasis."

1st paragraph, line 8: change "The staff noted that the Unit 1 RPV head was replaced scheduled .. " to "The 4-35 4.3.2.2.1 staff noted that the Unit 1 RPV head was replaced as scheduled ... "

- - -

Enclosure 2 PG&E Letter DCL-11-021 Page 5 of 7 SER SER Comment I Suggested Resolution Page Section 2nd paragraph: The SER makes references to ASME Code Case N-41S.1 and ASME Code Case N-416.2.

The references used are ASME Code,Section III, 1968 Editions paragraphs. Refer to LRA Section 4.3.

4-37 4.3.2.3 Change the reference to "ASME Code Case N-41S.1" or "ASME Code Case N-416.2" to "ASME III Paragraph N-41S.1" and "ASME III Paragraph N-416.2" 4-40 4.3.2.3.2 4th line from top of page 4-40: delete "for the components" as it appears twice.

4-41 4.3.2.4.2 2nd paragraph, last line: change "support bracket remain valid ... " to "support bracket remains valid ... "

2nd paragraph, Sth line: states "the TLAAs for the for all pressurizer... "

4-42 4.3.2.4.2 Remove "the for" before "all pressurizer" 4-43 4.3.2.4.2 2nd line on page 4-43: remove space between "an" and "acceptable."

4-49 4.3.2.6.2 Sth bullet: remove"\" before the word "valve."

4-49 4.3.2.6.2 1st paragraph, 3rd line: change "was procured" to "were procured ... "

4th paragraph, last line: states "fatigue analyses would not need to identified as applicable ... "

4-49 4.3.2.6.2 Add the word "be" before the word "identified."

6th line in paragraph: "ANSE 831.1-1967" should be "ANSI 831.1-1967" 4-S0 4.3.2.7.1 Change "ANSE" to "ANSI" Title of section should be FSAR instead of SAR.

4-S2 4.3.2.8.3 Change SAR to FSAR

Enclosure 2 PG&E Letter DCL-11-021 Page 6 of?

SER SER Comment I Suggested Resolution Page Section 1st paragraph, 12th line states: "WCAP-13045 would not need to identified as ... "

4-55 4.3.2.10.2 Add the word "be" before the word "identified."

4-56 4.3.2.10.3 1st sentence: change "to included" to "to include."

4-64 4.3.3.3 2nd paragraph, 6th line: add the word "to" between "relative the."

4-69 4.3.4.2.2 1st paragraph, 3rd line: delete the word "with" in "through with the Metal Fatigue ... "

4-73 4.3.6.2 Paragraph under (3), last line: change "5 occurrence" to "5 occurrences."

4-73 4.3.6.2 3rd paragraph under (3), 3rd sentence: Add "of' after the word "resolution."

Page 4-79, sentence beginning with "The applicant's August 18, 2010, response ... " Items 1 and 2: refers to the "main steam generator blowdown". The August 18, 2010, response refers to "steam generator 4-79 4.6.2.2 blowdown".

Change "main steam generator blowdown ... " to "steam generator blowdown ... "

4-80 4.6.2.2 In paragraph before Section 4.6.2.3, 8th line, change Sm to Sm 4-82 4.7.1.2 Remove one period at the end of the paragraph.

4-87 4.7.3.2 3rd bullet at the bottom of the page: change "is" to "in" in the term "flaw growth analysis is WCAP ... "

4-88 4.7.4.1 1st line: change "lRA Section 4.7.4 sates .. " to "lRA Section 4.7.4 states ... "

4-90 4.7.5.2.1 6th line: DCI should be DCl for Diablo Canyon letter.

Enclosure 2 PG&E Letter DCL-11-021 Page 7 of 7 SER SER Comment I Suggested Resolution Page Section 4-93 4.7.5.2.2 3rd paragraph, 5th line" change "analyzed" to "analyze" 4-94 4.7.5.2.2 Paragraph before Section 4.7.5.2.3, line 8: remove the word "to" before the word "challenge" 4-100 4.8.1 2nd sentence: remove the word "to" between "list" and "those" The Source for Item Numbers 4 should also reference DCL-09-079. The Source listed (DCL-10-096),

A-2 amended part of Item Number 4 from DCL-09-079.

Add DCL-09-079 to Source Item Number 4.

The Source for Item Number 14 should also reference DCL-09-079. The Source listed (DCL-10-067),

A-3 amended part of Item Number 14 from DCL-09-079.

Add DCL-09-079 to Source for Item Number 14.

The Source for Item Number 38 should also reference DCL-10-120. The Source listed (DCL-10-131),

A-8 amended part of Item Number 38 from DCL-10-120.

Add DCL-1 0-120 to Source for Item Number 38 The Source for Item Number 43 should also reference DCL-10-126. The Source listed (DCL-10-162),

A-8 amended part of Item Number 43 from DCL-10-126.

Add DCL-10-126 to Source for Item Number 43.

Item Number 52: In the Commitment, 3rd bullet, add a space between "four" and "excavations." In the A-10 Commitment, 4th bullet, add a space between "of' and "polyvinyl."

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