ML15300A006

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Submittal of Response to NRC Request for Additional Information - National Fire Protection Association Standard 805
ML15300A006
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 10/15/2015
From: Allen B
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15300A005 List:
References
DCL-15-119, TAC MF2333, TAC MF2334
Download: ML15300A006 (4)


Text

Paifc asan The Enclosure, Attachment 2 Contains El ctric asasecurity-Related Information - Withhold Under 10 CFR 2.390 Barry S. Allen Diahlo Canyon Power Plant Vice President, Nuclear Services Mail Code 104/6 P. 0. Box 56

~Avila Beach, CA 93424 October 15, 2015 805.545.4888 Internal: 691.4888 Fax: 805.545.6445 PG&E Letter DCL-1 5-119 U.S. Nuclear Regulatory Commission 10 CFR 50.90 ATTN: Document Control Desk Washington, D.C. 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units I and 2 Response to NRC Request for Additional Information - National Fire Protection Association Standard 805 References

1) PG&E Letter DCL-1 3-065, "License Amendment Request 13-03, License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition),"

dated June 26, 2013

2) NRC Letter, "Diablo Canyon Power Plant, Units 1 and 2 - Request for Additional Information Re: License Amendment Request to Adopt National Fire Protection Association Standard 805 (TAC Nos. MF2333 and MF2334)," dated July 31, 2014
3) PG&E Letter DCL-14-085, "Sixty-Day Response to NRC Request for Additional Information - National Fire Protection Association Standard 805," dated September 29, 2014
4) PG&E Letter DCL-14-098, "Ninety-Day Response to NRC'Request for Additional Information - National Fire Protection Association Standard 805," dated October 29, 2014
5) PG&E Letter DCL-14-110, "One Hundred Twenty Day Response to NRC Request for Additional Information - National Fire Protection Association Standard 805," dated November 26, 2014 A

member of the STARS (Strategic Teaming and Resource Sharing)

Alliance Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek The Enclosure, Attachment 2 Contains 12/0&-'

Security-Related Information - Withhold Under 10 CFR 2.390

/*

When separated from these attachments, this document is decontrolled.

The Enclosure, Attachment 2 Contains Security-Related Information -Withhold Under 10 CFR 2.390 Document Control Desk PG&E Letter DCL-15-119 October 15, 2015 Page 2

6) NRC Email from S. Lingam, Project Manager (NRRIDORLILPL4-1), "Diablo
  • Canyon, Units I and 2 - Requests for Additional Information (RAls) for Fire Protection* (NFPA-:805) License Amendment Request (LAR) (TAC Nos. MF2333 and MF2334)," dated February 4, 2015
7) PG&E Letter DCL-1 5-031, "Proposed Commitment for Response to NRC Request for Additional Information Regarding Submittal Date of the Integrated Analysis - National Fire Protection Association Standard 805," dated February 25, 2015
8) PG&E Letter DCL-1 5-032, "Response to NRC Request for Additional Information

- National Fire Protection Association Standard 805," dated February 25, 2015

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted License Amendment Request (LAR) 13-03 to adopt National Fire Protection Association Standard 805 (NFPA 805).

In Reference 2, the NRC provided a request for additional information (RAI) as part of an audit performed at Diabio Canyon Power Plant during the week of July 14, 2014.

In Reference 3, 4, and 5, PG&E submitted 60-day, 90-day, and 120-day RAI responses, respectively, to the NRC RAI - NFPA 805 regarding LAR 13-03.

Probabilistic Risk Assessment (PRA) RAI 03 and follow-on RAI questions (Reference 6) were discussed in draft form in teleconferences with the NRC, along.

with the associated response submittal dates, on January 21, 2015, and on February 4, 2015.

In Reference 6, the NRC emailed PG&E follow up RAIs to PG&E's120-day RAI responses (Reference 5) regarding LAR 13-03.

On January 29, 2015, PG&E held a conference call with the NRC Fire Protection and PRA Branch Chiefs, NRC NFPA 805 technical personnel, and the NRC Project A

member of the STARS (Strategic Teaming and Resource Sharing)

Alliance Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek The Enclosure, Attachment 2 Contains Security-Related Information - Withhold Under 10 CFR 2.390 When separated from these attachments, this document is decontrolled.

The Enclosure, Attachment 2 Contains Security-Related Information - Withhold Under 10 CFR 2,390 Document Control Desk PG&E Letter DCL-15-1 19 October 15,. 2015 Page 3 Manager for Diablo Canyon Power Plant (DCPP). The call discussed the schedule for the License Amendment and Safety Evaluation (LA/SE) for DCPP.

In Reference 7, PG&E submitted a letter to the NRC proposing a regulatory commitment to revise the submittal date of PRA RAI-03 response to the NRC RAI -

NFPA 805 regarding [AR 13-03. PG&E provided the following commitment:

"PG&E will provide the response to PRA RAI 3 eight weeks following verification that seal testing data conforms to the Westinghouse Topical report and NRC acceptance of the Westinghouse Topical report for quantitative use in FPRA.

Concurrent with the PRA RAI 3 submittal, PG&E will submit a frozen FPRA, updated [AR tables, and a transition report. The transition report will include a revised schedule for an implementation period of 12 months from receipt of the LA/SE."

In Reference 8, PG&E submitted follow up 120-day (Reference 5) RAl responses to the NRC RAl - NFPA 805 regarding [AR 13-03.

Enclosed are PG&E's responses to PRA RAI-03 and PRA RAI-01.h.01. Also enclosed are PG&E's follow-up responses to RAls previously submitted that were impacted by the results of the PRA RAI-03 integrated analysis. of this enclosure includes a list of acronyms used in this response for convenience. Attachment 2 of this enclosure includes an update to Attachments C, D, G, and W. Attachments C, D, G, and W of Enclosure 2 contain security-related information and should be withheld under 10 CFR 2.390. Attachment 3 of this enclosure includes updates to the [AR as a result of updated analyses, editorial changes, and reference corrections.

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 Mr. Philippe Soenen at 805-545-6984.

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

Alliance Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek The Enclosure, Attachment 2 Contains Security-Related Information - Withhold Under 10 CFR 2.390 When separated from these attachments, this document is decontrolled.

The Enclosure, Attachment 2 Contains Security-Related Information -Withhold Under 1 0 CFR 2.390 Document Control Desk October 15, 2015 Page 4 PG&E Letter DCL-15-119 I state under penalty of perjury that the foregoing is true and correct.

Executed on October 15, 2015.

Sincerely, Barry**. *IZe Vice President - Nuclear Services mjrm/4557/5 0709593 Enclosure cc:

Diablo Distribution cc/enc:

Marc L. Dapas, NRC Region IV Thomas P. 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 The Enclosure, Attachment 2 Contains Security-Related Information - Withhold Under 10 CFR 2.390 When separated from these attachments, this document is decontrolled.