DCL-15-055, Response to NRC Request for Additional Information Regarding License Amendment Request 14-03, License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-432, Rev 1, Change in Technical...

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Response to NRC Request for Additional Information Regarding License Amendment Request 14-03, License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-432, Rev 1, Change in Technical...
ML15127A648
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 05/07/2015
From: Allen B
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-15-055
Download: ML15127A648 (4)


Text

Pacific Gas and Electric Company Barry S. Allen Diablo Canyon Power Plant Vice President, Nuclear Services Mail Code 104/6 P. 0. Box 56 Avila Beach, CA 93424 May 7, 2015 805.545.4888 Internal: 6 91.4888 Fax: 805.545.6445 PG&E Letter DCL-15-055 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 Response to NRC Request for Additional Information Regarding License Amendment Request 14-03, "License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-432. Revision 1. 'Change in Technical Specification End States (WCAP-16294)"'

References:

1. PG&E Letter DCL-14-058, License Amendment Request 14-03, "License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-432, Revision 1, 'Change in Technical Specification End States (WCAP-16294),"' dated July 28, 2014 (ADAMS Accession No. ML142098076)
2. NRC Letter, "Diablo Canyon 1 and 2 - Requests for Additional Information to License Amendment Request Associated with Adoption of TSTF-432, 'Rev. 1 (TAC Nos. MF4521 and MF4522),"

dated April 8, 2015

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted License Amendment Request (LAR) 14-03, "License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-432. Revision 1, 'Change in Technical Specification End States (WCAP-16294)."' LAR 14-03 proposed to modify the Technical Specifications to risk-inform requirements regarding selected Required Action End States.

On April 8, 2015, the NRC staff requested additional information required to complete the review of LAR 14-03 (Reference 2). PG&E's responses to the staffs questions are provided in the Enclosure.

This information does not affect the results of the technical evaluation or the no

  • significant hazards consideration determination previously transmitted in Reference 1.

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

  • Diablo Canyon
  • Palo Verde*
  • Wolf Creek

Document Control Desk PG&E Letter DCL-15-055 May 7, 2015 Page2 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, or require additional information, please contact Philippe Soenen at (805) 545-6984.

I state under penalty of perjury that the foregoing is true and correct.

Executed on May 7, 2015.

Sincerely,

~7en 5. A/L_

Vice President, Nuclear Services kjse/4328/50636291 Enclosure cc: Diablo Distribution cc/enc: Marc L. Dapas, NRC Region IV Administrator Thomas R. Hipschman, NRC Senior Resident Inspector Siva P. Lingam, NRR Project Manager Gonzalo L. Perez, Branch Chief, California Dept of Public Health A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

  • Diablo Canyon
  • Palo Verde*
  • Wolf Creek

Enclosure PG&E Letter DCL-15-055 PG&E Response to NRC Request for Additional Information Regarding License Amendment Request 14-03, "License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-432, Revision 1, 'Change in Technical Specification End States (WCAP-16294)"'

NRC Request for Additional Information:

In order to justify adoption of the approved TSTF changes, please confirm that Diablo Canyon's current licensing basis adheres to the RG 1. 160 guidance and commitment to the updated version of NUMARC 93-01.

(For details, you may also refer to the NRC staff's recent letter dated, February 26, 2015 (ADAMS Accession No. ML15033A152), in response to the TSTF Group's letter, dated, September 16, 2014 (ADAMS Accession No. ML14259A575), on the subject matter.)

Also, during review of the application, the NRC staff has identified a typo on TS Bases pages 75-86 of 107 and 93-96 of 109 (ADAMS Accession Nos. ML142098075 and ML14209B079), respectively. The bottom left side of these pages refer to 'DIABLO CANYON' as 'DDIABLO CANYON.' Please correct the error (acceptable if corrected during implementation of the amendment).

PG&E Response:

On November 27, 2012, the NRC published a Federal Register Notice stating that Regulatory Guide (RG) 1.182 has been withdrawn and the subject matter has been incorporated into RG 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." RG 1.160 endorses Revision 4A of NUMARC 93-01, dated April2011.

The NRC Model Safety Evaluation for TSTF-432, Revision 1 (contained in Federal Register Volume 77, Number 92, dated May 11, 2012), references RG 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants,"

which endorses the February 2000 version of NUMARC 93-01, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." References and commitments to RG 1.182 in the NRC Model Safety Evaluation for TSTF-432, Revision 1, are assumed to now refer to RG 1.160 and Revision 4A of NUMARC 93-01 instead of RG 1.182.

Diablo Canyon Power Plant Departmental Administrative Procedure AD7.DC11, "Program Governance for On-Line Maintenance Risk Management," provides expectations for the On-Line Maintenance Risk Management Program structure, content, and implementation. Procedure AD7.DC11 references RG 1.160 as a regulatory standard for the program and references NUMARC 93-01, Revision 4A, as an industry document providing input to the program. Therefore, the Diablo Canyon licensing basis adheres to RG 1.160 and NUMARC 93-01, Revision 4A.

1.

Enclosure PG&E Letter DCL-15-055 The correction of the spelling error in the plant name in the footer of the Technical Specification (TS) Bases pages can be corrected as part of the normal implementation process for the amendment for the license amendment request (LAR) for TSTF-432, Revision 1, since during implementation of the amendments the controlled copy TS Bases pages (which contain the correct plant name spelling in the footer) are marked up with the TS Bases changes identified in the LAR (that do not contain a marked-up change to the plant name in the footer) to create the TS Bases version to be implemented.

2