ML11200A212

Sixty-Day Response to NRC Bulletin 2011-01, Mitigating Strategies

ML11200A212
Person / Time
Site:	Diablo Canyon
Issue date:	07/11/2011
From:	Peters K Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BL-11-001, DCL-11-081
Download: ML11200A212 (18)

Text

Pacific Gas and Electric Company' Kenneth J. Peters VP Engineering & Projects Diablo Canyon Power Plant Mail Code 104/6/603 P. 0. Box 56 Avila Beach, CA 93424 805.545.4888 Internal: 691.4888 Fax: 805.545.4884 July 11,2011 PG&E Letter DCL-11-081 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852-2738 10 CFR 50.54(f)

Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Sixty-Day ResDonse to NRC Bulletin 2011-01. "Mitiaatina Strateaies" On May 11,2011, the NRC issued Bulletin 2011-01, "Mitigating Strategies,"

(referred herein as the Bulletin), to request each licensee to provide a comprehensive verification of its compliance with the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2). The Bulletin requires that Pacific Gas and Electric Company (PG&E) submit written responses within 30 and 60 days of the Bulletin. PG&E submitted its 30-day response in PG&E Letter DCL-1 1-065, dated June 10, 2011 (ML111640426).

The enclosure to this letter provides PG&E's 60-day response to the Bulletin and is being submitted in accordance with 10 CFR 50.54(f).

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

This letter includes no revisions to existing regulatory commitments.

If you have any questions regarding this response, please contact Mr. William Guldemond, Special Assistant to the Site Vice President, at (805) 545-4160.

jwh/50408579 Enclosure cc:

Diablo Distribution cc/enc:

Elmo E. Collins, NRC Region IV Michael S. Peck, NRC Senior Resident Inspector James T. Polickoski, NRC Project Manager NRR Alan B. Wang, NRC Project Manager NRR A4ý0 Qýi-A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak 9 Diablo Canyon e Palo Verde e San Onofre & South Texas Project

• Wolf Creek

PG&E Letter DCL-1 1-081 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

)

Docket No. 50-275 In the Matter of

)

Facility Operating License PACIFIC GAS AND ELECTRIC COMPANY)

No. DPR-80

)

Diablo Canyon Power Plant

)

Docket No. 50-323 Units 1 and 2

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Facility Operating License

)

No. DPR-82 AFFIDAVIT Kenneth J. Peters, of lawful age, first being duly sworn upon oath says that he is Vice President - Engineering Services of Pacific Gas and Electric Company; that he has executed this response to NRC Bulletin 2011-01 on behalf of said company with full power and authority to do so; that he is familiar with the content thereof; and that the facts stated therein provided by his staff are true and correct to the best of his knowledge, information, and belief.

Keneth J. Peter /n VY6 President - En neering Services State of California County of San Luis Obispo Subscribed and sworn to (or affirmed) before me on this 11 th day of July, 2011, by Kenneth J. Peters, proved to me on the basis of satisfactory evidence to be the person who appeared before me.

(Notary Public (gnature)

CHUCK MACKEY

--Commission # 1925174 Notary Public - California z

San Luis Obispo County My C6mm. Expires Mar 4, 2015 (Notary Public Seal)

Enclosure PG&E Letter DCL-1 1-081 Page 1 of 16 PG&E 60-Day Response to NRC Bulletin 2011-01 Mitigating Strategies The NRC has requested the following information:

Within 60 days of the date of this bulletin (May 11, 2011), the NRC requests that licensees provide information regarding their mitigation strategies programs for 10 CFR 50.54(hh)(2).

The Diablo Canyon Power Plant (DCPP) guidelines and strategies are provided in the following primary correspondence on this topic:

(1) PG&E Letter DCL-05-058, "Response to NRC Guidance Regarding Mitigation Strategies," dated May 25, 2005.

(2) PG&E Letter DCL-07-001, "Response Providing Implementation Details for the Phase 2 and 3 Mitigation Strategies," dated January 11, 2007.

(3) PG&E Letter DCL-07-051, "Response to NRC Request for Additional Information Regarding Implementation Details for the Phase 2 and 3 Mitigation Strategies,"

dated May 8, 2007.

Additional equipment that is currently required to be inventoried as part of the mitigating strategies is listed in this response but is not necessarily called out in the above correspondence.

Many of the items described below represent current DCPP practices. Individual items may be revised or adjusted in the future based on new or revised vendor recommendations, industry experience, etc., in accordance with NEI 99-04, Revision 0, "Commitment Management Guidelines."

NRC Question 1:

Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh) (2) in order to ensure that it is functional when needed.

Examples of the types of information to include when providing your response to Question (1) are:

a. Measures implemented to maintain the equipment, including periodicity.

b. Basis for establishing each maintenance item (e.g., manufacturer's recommendation, code or standard applicable to the craft). This should include consideration of storage environment impact on the maintenance necessary.

Enclosure PG&E Letter DCL-1 1-081 Page 2 of 16 These examples are not meant to limit your response if you use other methods to address the issues described above.

PG&E Response 1:

The maintenance activities listed below have been established to ensure that the B.5.b equipment can perform its intended function.

Equipment Preventive Periodicity Basis Maintenance Various sizes of Replace Annually Good practice based on finite disposable batteries battery shelf life Electrical Tape and Replaced if Annually Good practice Duct Tape hardened Fire hoses None None Annually hydro tested in lieu of preventive maintenance Ansul Foam Replaced 25 Years Manufacturer's recommendation based on shelf life Flow Meters Replace Annually Good practice based on finite batteries battery shelf life Fluke Meters Replace Annually Good practice based on finite batteries battery shelf life Monarch Instruments Replace Annually Good practice based on finite Pocket Laser Tach 200 batteries battery shelf life (PLT 200)

Three Portable Long Oil sample /

Annually Manufacturer's Term Cooling Pumps change / clean /

recommendation inspect Hose inspection Annually NFPA 1962, 1998 Edition Portable Diesel Driven Battery check Monthly Manufacturer's Fuel Oil Transfer Pump recommendation Oil change and Biennially Manufacturer's inspection recommendation Suction and 8 Years Manufacturer's discharge hose recommendation replacement

Enclosure PG&E Letter DCL-1 1-081 Page 3 of 16 Equipment Preventive Periodicity Basis Maintenance Mobile Crane Inspection Daily (when Good practice in use)

Inspection Annually CAL-OSHA Title 8, CFR Title 29, Part 1910, Subpart N 1910.180, CFR Title 29, Part 1926, Subpart CC Fire Truck Short inspection 90 days Manufacturer's recommendation Long inspection Annually Manufacturer's recommendation Inspection Daily Good practice Weekly Quarterly Pump Inspection and Annually Vendor recommendation general maintenance Fuel Storage Truck Short inspection 90 days Manufacturer's recommendation Long inspection Annually

Enclosure PG&E Letter DCL-1 1-081 Page 4 of 16 Equipment Preventive Periodicity Basis Maintenance SCBAs Inspection of Monthly NFPA 1981, Manufacturer's SCBA system recommendation Maintenance, Post use or cleaning, and monthly inspection of masks Cylinder visual Monthly inspections Cylinders 15 years replaced Cylinder Weekly pressure check Replace Quarterly batteries Pressure 8 years regulator overhaul Electric Fans Visual inspection Weekly Good practice Gas Powered Fan - on Inspection -

Daily and Good practice Fire Engine check fuel Weekly Gas Powered Fan - in Inspection -

Weekly 85 ft elevation Fire check fuel Brigade Locker Fire rescue truck Visual inspection Weekly Good practice and check fuel Short inspection 90 days Manufacturer's recommendation Long inspection Annually Manufacturer's recommendation Pump mounted on truck Visual inspection Weekly Good practice

Enclosure PG&E Letter DCL-1 1-081 Page 5 of 16 Equipment Preventive Periodicity Basis Maintenance Hazmat trailer Inspection Weekly Good practice (ensure equipment is in trailer, lights work, tires are filled, and gets washed)

Inspection and Annually Manufacturer's maintenance recommendation Portable gas electric Fuel/Oil level Monthly Manufacturer's testing generators check and refill recommendation as necessary Site ambulance Short inspection 90 days Manufacturer's recommendation Long inspection Twice a year Manufacturer's recommendation and good practice Site boundary UPS replaced Biennially Recommended replacement Pressurized Ion frequency of 3 to 6 years per Chambers operating experience Maintenance Field Kits Detectors Various Manufacturer's calibrated frequencies recommendation depending on use

Enclosure PG&E Letter DCL-1 1-081 Page 6 of 16 NRC Question 2:

Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.

Examples of the types of information to include when providing your response to Question (2) are:

a. A description of any testing accomplished to ensure the strategies were initially feasible.

b. A description of any periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

c.

A description of the corrective action process used when the equipment fails to adequately perform its test.

These examples are not meant to limit your response if you use other methods to address the issues described above.

PG&E Response 2a:

The following table is a description of testing accomplished using nonpermanently installed plant equipment to ensure the strategies were initially feasible.

Strategy Description Strategies involving the fire truck Demonstrated that required flow and spray pattern can be achieved to a mock spent fuel pool Strategies demonstrating that the Demonstrated that the necessary flow can be fire protection ring header can be achieved through startup tests using the long filled via external sources term cooling pumps PG&E Response 2b:

The following table describes periodic testing instituted for the equipment, along with the basis for establishing that test requirement.

Equipment Test Periodicity Basis Description Fire hoses Hydrostatic test Annually NFPA 1962 Radios, chargers, and Functional test Quarterly Good practice microphone remote speakers

Enclosure PG&E Letter DCL-1 1-081 Page 7 of 16 Equipment Test Periodicity Basis Description Flow Meters Verify functional Annually Good practice Fluke Meters Verify functional Annually Good practice Monarch Instruments Verify functional Annually Good practice Pocket Laser Tach 200 (PLT 200)

Three Portable Long Operability test Quarterly Operating Experience Term Cooling Pumps Flow test Annually Operating Experience Inspection and Annually National Fire Protection hydrostatic test Association Standard 1962 Portable Diesel Driven Flow test Quarterly Operating Experience Fuel Oil Transfer Pump Mobile Crane Functional checks Daily Good practice Load test Annually CAL-OSHA Title 8, CFR Title 29, Part 1910, 110% Load test Quadrennial Subpart N, 1910.180, CFR Title 29, Part 1926, Subpart CC Fire Truck Pump Flow test Annually NFPA 19 specifications for motor fire apparatus SCBAs Cylinder hydrostatic 5 years NFPA, OSHA, test Manufacturer's recommendation System test Annually Cylinder functional Monthly test Air sample test Quarterly Electric Fans Start/Run Quarterly Good practice Gas Powered Fan - on Run until warm Weekly Good practice Fire Engine Gas Powered Fan - in Run until warm Weekly 85 ft elevation Fire Brigade Pump mounted on fire Run motor for 2 Weekly Good practice rescue truck minutes Portable gas electric Run under load Monthly Manufacturer's generators recommendation

Enclosure PG&E Letter DCL-1 1-081 Page 8 of 16 Equipment Test Periodicity Basis Description Portable lighting Verify operations Daily Security requirements Site boundary Operational check Annually Calibration testing Pressurized Ion requirements Chambers Satellite Phones Functional test Quarterly Good practice Maintenance Field Kits Detector functional Quarterly Good practice tests PG&E Response 2c:

The DCPP 10 CFR 50, Appendix B, Corrective Action Program (CAP) is used for most pieces of equipment to document failures, establish priorities for corrective actions, and perform trending. Some pieces of equipment are maintained by other equipment specific processes.

For that equipment subject to the CAP, when an issue is identified, a Notification is initiated, a Notification Review Team determines the level of review required, and corrective actions are determined and implemented in accordance with the significance.

Enclosure PG&E Letter DCL-1 1-081 Page 9 of 16 NRC Question 3:

Describe in detail the controls for assuring that the equipment is available when needed.

Examples of the types of information to include when providing your response to Question (3) are:

a. A description of any inventory requirements established for the equipment.

b. A listing of deficiencies noted in inventories for the equipment and corrective actions taken to prevent loss.

These examples are not meant to limit your response if you use other methods to address the issues described above.

PG&E Response 3a and 3b:

In addition to the controls described in responses 1 and 2, nonpermanently installed B.5.b equipment is inventoried at least annually in accordance with DCPP processes or procedures. This inventory assures the items are stored in the proper quantities and location, equipment is accessible, and storage locations are controlled. (See Table below.)

Inventory deficiencies are entered into the DCPP CAP. As of the date of this response, there are no outstanding inventory deficiencies that would render the strategies not viable.

Equipment Inventory Special Items Verified (e.g., proper Frequency Storage quantities, locations, pressures, Controls calibrations, shelf life, and equipment is accessible.)

Batteries Annually Note 1 Location, quantity, accessibility Bucket Annually Note 1 Location, quantity, accessibility Lights Annually Note 1 Location, quantity, accessibility Tarpaulin Annually Note 1 Location, quantity, accessibility Personal Annually Note 1 Location, quantity, accessibility Protective Equipment Tool box items Annually Note 1 Location, quantity, accessibility Hose / Tubing Annually Note 1 Location, quantity, accessibility Supports /

Annually Note 1 Location, quantity, accessibility Brackets Adapters Annually Note 1 Location, quantity, accessibility Nozzles Annually Note 1 Location, quantity, accessibility Carts Annually Note 1 Location, quantity, accessibility Splitters Annually Note 1 Location, quantity, accessibility

Enclosure PG&E Letter DCL-1 1-081 Page 10 of 16 Equipment Inventory Special Items Verified (e.g., proper Frequency Storage quantities, locations, pressures, Controls calibrations, shelf life, and equipment is accessible.)

Foam Annually None Location, quantity, accessibility Rope Annually Note 1 Location, quantity, accessibility Communication Quarterly None Location, quantity, accessibility equipment Flow meters Annually Note 1 Location, quantity, accessibility Measuring Annually Note 1 Location, quantity, equipment accessibility Three Portable Quarterly Pumps

Location, Long Term seismically accessibility Cooling Pumps restrained and associated hoses and connectors Portable Diesel Quarterly Pump cart

Location, Driven Fuel Oil seismically accessibility Transfer Pump restrained Mobile crane Annually None Location Fire truck Daily None Location, quantity of supplies Weekly Quarterly Fuel truck Annually None Location Oscillating Annually Note 1 Location, accessibility Monitor Nozzle Additional Quarterly None Location, quantity Monitors Fire Department Weekly None Location, quantity SCBAs Electric fans Weekly None Location, quantity Gas powered Weekly None Location, quantity fans Fire rescue truck Quarterly None Location and pump mounted on truck Hazmat trailer Weekly None Location Portable gas Weekly None Location, quantity generators Portable lighting Daily None Location, quantity Site ambulance Monthly None Location, quantity of supplies TLDs Quarterly None Location, quantity, accessibility

Enclosure PG&E Letter DCL-1 1-081 Page 11 of 16 Equipment Inventory Special Items Verified (e.g., proper Frequency Storage quantities, locations, pressures, Controls calibrations, shelf life, and equipment is accessible.)

Site boundary Annually None Location, calibration, accessibility Pressurized Ion Chambers Maintenance Quarterly None Location, quantity, accessibility, field kits calibration of detectors Note 1: Contained in a locked storage facility.

Enclosure PG&E Letter DCL-1 1-081 Page 12 of 16 NRC Question 4:

Describe in detail how configuration and guidance management is assured so that strategies remain feasible.

Examples of the types of information to include when providing your response to Question (4) are:

a. Measures taken to evaluate any plant configuration changes for their effect on feasibility of the mitigating strategies.

b. Measures taken to validate that the procedures or guidelines developed to support the strategies can be executed. These measures could include drills, exercises, or walk through of the procedures by personnel that would be expected to accomplish the strategies.

c. Measures taken to ensure procedures remain up-to-date and consistent with the current configuration of the plant.

d. A description of the training program implemented in support of the mitigating strategies and the manner in which you evaluate its effectiveness.

These examples are not meant to limit your response if you use other methods to address the issues described above.

PG&E Response 4a:

The current plant design change process requires an evaluation of the impacts of modifications on the mitigation strategies.

PG&E Response 4b:

Initially, mitigating strategies were validated by walkdowns, engineering evaluations, performance of the procedure, and/or table top reviews. Subsequent procedure changes are validated to ensure that the guidelines remain viable. In 2011, B.5.b mitigating strategies were revalidated by similar techniques.

Enclosure PG&E Letter DCL-1 1-081 Page 13 of 16 PG&E Response 4c:

The design change process and procedure controls are utilized so that the mitigating strategy guidelines are maintained up-to-date and consistent with the current configuration of the plant.

PG&E Response 4d:

The following table describes the training in support of the mitigating strategies and the manner in which effectiveness is evaluated.

Station Training Periodicity Evaluation Personnel Operations Initial and continuing 4 years Facilitated discussion, training on Extreme simulator events, or written Damage Mitigation exams Guidelines and B.5.b casualty procedures ERO

• Initial training was N/A Peer evaluation of provided on Extreme emergency callout drills Damage Mitigation Guidelines and B.5.b casualty procedures.

• The need for initial training of new ERO members and recurrent training for existing ERO members was identified as a gap and was entered into the CAP.

In the interim, the training materials have been provided to appropriate ERO members. This training has been completed by current on-call ERO members.

Fire Brigade Initial training on fire Qualifications, table tops, response procedure drills, and exercises Foam applications Biennially Extreme Damage Annually Mitigation Guidelines, B.5.b casualty procedures, and large accelerant fed fires

Enclosure PG&E Letter DCL-1 1-081 Page 14 of 16 Station Training Periodicity Evaluation Personnel Security Initial training on B.5.b Initial security-related table casualty procedures tops and continued facilitated discussions Initial and continuing Annually training on EDMGs

Enclosure PG&E Letter DCL-1 1-081 Page 15 of 16 NRC Question 5:

Describe in detail how you assure availability of off-site support.

Examples of the types of information to include when providing your response to Question (5) are:

a. A listing of off-site organizations you rely on for emergency response.

b. Measures taken to ensure the continuity of memoranda of agreement or understanding or other applicable contractual arrangements. This should include a listing of periods of lapsed contractual arrangements.

c.

A listing of any training or site familiarization provided to off-site responders.

This should include any measures taken to ensure continued familiarity of personnel of the off-site responders in light of turnover and the passage of time.

These examples are not meant to limit your response if you use other methods to address the issues described above.

PG&E Response 5:

Off-site Implementing Validation Training/Familiarization Organization Document and Refresher/Periodicity Periodicity Cambria Community Agreement for Annually Need for training discussed Healthcare District casualty during annual review treatment French Hospital Agreement for Annually Periodic training seminars Medical Center casualty as needed treatment Marian Medical Agreement for Annually Periodic training seminars Center casualty as needed treatment San Luis Agreement for Annually Need for training discussed Ambulance Service, casualty during annual review Inc.

treatment Rogers Helicopters, Agreement for Annually Need for training discussed Inc.

airlifting during annual review capabilities Local Law Agreement for Annually Biennial responder training Enforcement security Agency (LLEA) resources Agreement

Enclosure PG&E Letter DCL-1 1-081 Page 16 of 16 Off-site Implementing Validation Training/Familiarization Organization Document and Refresher/Periodicity Periodicity California Agreement for Annually Initial training and annual Department of fire fighting refresher training; site Forestry and Fire resources familiarization or virtual site Protection familiarization annually (CALFIRE)

Rain for Rent -

Contract for Annually Site familiarization training Contract back up provided as needed 4600014571 pumping and cooling capability Per the Emergency Plan, the implementing documents are reviewed annually and renewed as necessary.

Currently there are no lapsed letters of agreement, memoranda of understanding (MOU), or contractual agreements. PG&E reviewed the DCPP CAP from 2008 through May 2011, and found no lapsed letters of agreement, MOU, or contracts related to B.5.b.