DCL-16-014, Supplement to 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)
| ML16028A494 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/28/2016 |
| From: | Welsch J Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CAC MF2333, CAC MF2334, DCL-16-014 | |
| Download: ML16028A494 (19) | |
Text
Pacific Gas and Electric Company"'
January 28, 2016 PG&E Letter DCL-16-014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Supplement to License Amendment Request 13-03 James M. Welsch Diablo Canyon Power Plant Vice President, Nuclear Generation P.O. Box 56 Avila Beach, CA 93424 805.545.3242 E-Mail: JMW 1 @pge.com 10 CFR 50.90 License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)
References:
- 1. PG&E Letter DCL-13-065, "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 E-mail from S. Lingam, "Diablo Canyon 1 and 2 - NFPA-805 LAR (CAC Nos. MF2333 and MF2334 )," dated January 7, 2016
Dear Commissioners and Staff:
Pursuant to 1 0 CFR 50.90, Pacific Gas and Electric Company (PG&E) submitted Reference 1 to request Nuclear Regulatory Commission (NRC) approval for adoption of a new fire protection (FP) licensing basis, which complies with the requirements in 10 CFR 50.48(a), 10 CFR 50.48(c), and the guidance in Regulatory Guide (RG) 1.205, Revision 1, "Risk-Informed, Performance Based Fire Protection for Existing Light-Water Nuclear Power Plants."
In Reference 2, the NRC requested updated license condition inserts and a final set of License Amendment Request AttachmentS tables to reflect changes made during the review process. provides updated proposed license condition inserts. Enclosure 2 provides updated proposed AttachmentS tables to be implemented following NRC approval of the LAR.
A member of the STARS (Strategic Teaming and Resource Sharing)
Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk January 28, 2016 Page 2 PG&E Letter DCL-16-014 PG&E makes no new regulatory commitments (as defined in NEI 99-04) in this letter.
If you have any questions or require additional information, please contact Mr. Michael Richardson at 805-545-4557.
I state under penalty of perjury that the foregoing is true and correct.
Executed on January 28, 2016.
Sincerely, 6-A~
James M. Welsch Vice President, Nuclear Generation mjrm/4557/50037 411 Enclosure cc:
cc/enc:
Diablo Distribution Marc L. Dapas, NRC Region IV Administrator Siva P. Lingam, NRR Project Manager Gonzalo L. Perez, California Department of Public Health Binesh K. Tharakan, Acting NRC Senior Resident Inspector A
member of the STARS (Strategic Teaming and Resource Sharing)
Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek PG&E Letter DCL-16-014 Revised OPERATING LICENSE INSERT (Unit 1 condition C.2.(5) and Unit 2 condition C.2.(4))
- a.
PG&E shall implement and maintain all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the PG&E amendment request dated June 26, 2013, as supplemented by letters dated October 3, 2013, September 29, 2014, October 27, 2014, October 29, 2014, November 26, 2014, December 31, 2014, February 25, 2015, May 7, 2015, October 15,2015, December 31, 2015, and January 28, 2016, and as approved in the safety evaluation dated
_____. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, PG&E may make changes to the Fire Protection Program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
- b.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of a change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at DCPP. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed Fire Probabilistic Risk Assessment model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact:
(1)
Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
1 PG&E Letter DCL-16-014 (2)
Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 1 o-7 /year (yr) for CDF and less than 1 x10-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
- c.
Other Changes that May Be Made Without Prior NRC Approval (1)
Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental Fire Protection Program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. PG&E may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer
- shall perform the engineering evaluation and conclude that the change will not affect the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
PG&E may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change will not affect the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:
"Fire Alarm and Detection Systems" (Section 3.8);
"Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);
"Gaseous Fire Suppression Systems" (Section 3.1 0);
- and, 2
PG&E Letter DCL-16-014 "Passive Fire Protection Features" (Section 3.11 ).
This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
(2)
Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to PG&E's Fire Protection Program that have been demonstrated to have no more than a minimal risk impact.
PG&E may use its screening process as approved in the NRC safety evaluation report dated to determine that certain Fire Protection Program changes meet the minimal criterion. PG&E shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the Fire Protection Program.
This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.
- d.
Transition License Conditions:
(1)
Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) and (3) below, risk-informed changes to PG&E's Fire Protection Program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in c.(2) above.
(2)
PG&E shall implement the modifications described in AttachmentS, Table S-2, "Plant Modifications Committed,"
of PG&E Letter DCL-16-014, dated January 28, 2016, by the end of the Units 1 and 2 refueling outages currently scheduled for April/May 2017 (1 R20) and February/March 2018 (2R20). PG&E shall maintain appropriate compensatory measures in place until completion of the modifications delineated above.
(3)
PG&E shall implement the items as listed in AttachmentS, Table S-3, "Implementation Items," of PG&E Letter DCL-16-014, dated January 28, 2016, within 365 days after receipt of the safety evaluation/license amendment with the exception of Implementation Item S-3.24, which will be completed for each unit within 90 days after all modifications for the respective unit are operable (as listed in Attachment -
S, Table S-2).
3 PG&E Letter DCL-16-014 Revised Attachment 5 Tables - Modifications and Implementation Items
Pacific Gas and Electric Company AttachmentS-Modifications and Implementation Items Modifications and Implementation Items (13 Pages)
Page S-1
Pacific Gas and Electric Company - Modifications and Implementation Items Table S-1, Plant Modifications Completed, and Table S-2, Plant Modifications Committed, provided below, include descriptions of the modifications along with the following information:
A problem statement, Risk ranking of the modification, An indication if the modification is currently included in the Fire Probabilistic Risk Assessment (FPRA),
Compensatory Measure in place, and A risk-informed characterization of the modification and compensatory measure.
The following legend should be used when reviewing the tables:
o High = Modification would have an appreciable impact on reducing overall fire Core Damage Frequency (CDF)/Large Early Release Frequency (LERF) (or 11CDF/L1LERF for a Fire Area).
o Medium= Modification would have a measurable impact on reducing overall fire CDF/LERF (or 11CDF/L1LERF for a Fire Area).
o Low= Modification would have either an insignificant or no impact on reducing overall fire CDF/LERF.
Table S-1 Plant Modifications Completed Item Rank Unit Problem Statement Proposed Modification In FPRA Comp Measure Risk Informed Characterization None Page S-2
Pacific Gas and Electric Company - Modifications and Implementation Items Item Rank Unit S-2.1 Medium 1
Table S-2 Plant Modifications Committed Problem Statement Steam Generator Level Transmitter MS-1-LT-529 associated Conduit KT351 requires protection to ensure success of one Decay Heat Removal success path in case of a fire in Fire Area 3-88, 115 foot.
Additional detail is provided in Section 4.8.2 of the Transition Report.
Proposed Modification Electrical Raceway Fire Barrier System (ERFBS)
Installation In FPRA Yes Comp Measure Yes Risk informed Characterization This modification will eliminate the need for a Recovery Action associated with ensuring decay heat removal capability is maintained in the event of a fire in Fire Area 3-88, 115 foot. This modification provides an improvement in ~CDF and
~LERF.
Compensatory Measure for NFPA 805:
Appropriate compensatory measures will be established per Plant Procedure OM8.1D2, "Fire System Impairment," as required, until the modification is implemented.
Compensatory Measure for 10 CFR 50 Appendix R:
Appropriate compensatory measures have been established per OM8.1D2, and will remain in place until the modification is implemented.
Page S-3
Pacific Gas and Electric Company AttachmentS-Modifications and Implementation Items Item Rank Unit S-2.2 High 1,2 Table S-2 Plant Modifications Committed Problem Statement Various modifications to the Hot Shutdown Panels (HSDPs) are required to reduce risk associated with fires in the Main Control Room (MCR),
Cable Spreading room (CSR), or HSDP area. Additional detail is provided in Section 4.8.2 of the Transition Report.
Proposed Modification Hot Shutdown Panel Modifications In FPRA Yes Comp Measure Yes Risk informed Characterization This modification will ensure isolation is available, which will allow for achievement of performance criteria in the case of a fire in the MCR, CSR, or HSDP area. This modification provides an improvement in.LlCDF and.LlLERF.
Compensatory Measure for NFPA 805:
Appropriate compensatory measures will be established per OM8.1D2, as required, until the modification is implemented.
Compensatory Measure for 10 CFR 50 Appendix R:
Alternate compensatory measures have been established in accordance with OM8.1D2 and applicable equipment control guidelines to address existing deviations.
Page S-4
Pacific Gas and Electric Company AttachmentS-Modifications and Implementation Items Item Rank Unit S-2.3 High 1,2 Table S-2 Plant Modifications Committed Problem Statement Modification is required to reduce the risk associated with a loss of seal cooling-induced Loss of Coolant Accident (LOCA) that could result from a fire in multiple areas.
Additional detail is provided in Section 4.8.2 of the Transition Report.
Proposed Modification Reactor Coolant Pump (RCP) Seal Cooling Modification In FPRA Yes Comp Measure Yes Risk informed Characterization This modification will reduce the risk of a LOCA resulting from a loss of RCP seal cooling. This modification provides an improvement in CDF and LERF.
Compensatory Measure for NFPA 805:
Appropriate compensatory measures will be established per OM8.1 02, as required, until the modification is implemented.
Compensatory Measure for 10 CFR 50 Appendix R:
Appropriate compensatory measures have been established per OM8.1D2, as required, until the modification is implemented.
Page S-5
Pacific Gas and Electric Company AttachmentS-Modifications and Implementation Items Item Rank Unit S-2.4 High 1,2 Table S-2 Plant Modifications Committed Problem Statement Installation of incipient fire detection equipment is required to reduce the risk associated with fires initiating in cabinets in the CSRs and Solid Station Protection System (SSPS) rooms. Additional detail is provided in Section 4.8.2 of the Transition Report.
Proposed Modification Incipient Detection System Installation In FPRA Yes Comp Measure Yes Risk informed Characterization This modification will improve Diablo Canyon Power Plant's (DCPP's) ability to detect incipient fires in the CSR and SSPS rooms, resulting in a reduction of risk that a fire will start.
This modification provides an improvement in CDF and LERF.
Compensatory Measure for NFPA 805:
Appropriate compensatory measures will be established per OM8.1 D2, as required, until the modification is implemented.
Compensatory Measure for 10 CFR 50 Appendix R:
None. This modification is not required to satisfy the requirements of 1 0 CFR 50, Appendix R.
Page S-6
Pacific Gas and Electric Company AttachmentS-Modifications and Implementation Items Item Rank Unit S-2.5 Medium 2
Table S-2 Plant Modifications Committed Problem Statement ERFBS enhancement for cable associated with MS-2-FCV-95 is necessary to reduce the risk associated with a fire in Fire Area 5-B-4. This modification will also resolve a VFDR in Fire Area 6-B-4.
Additional detail is provided in Section 4.8.2 of the Transition Report.
Proposed Modification ERFBS Enhancement In FPRA Yes Comp Measure Yes Risk informed Characterization This modification will eliminate the need for a Recovery Action associated with ensuring steam is available to the turbine-driven Auxiliary Feedwater pump, thus reducing the risk of a loss of decay heat removal capability. This modification provides an improvement in.LlCDF and.LlLERF.
Compensatory Measure for NFPA 805:
Appropriate compensatory measures will be established per OM8.1D2, as required, until the modification is implemented.
Compensatory Measure for 1 0 CFR 50 Appendix R:
Appropriate compensatory measures have been established per OM8.102, and will remain in place until the modification is implemented.
Page S-7
Pacific Gas and Electric Company - Modifications and Implementation Items Table S-3, Implementation Items, provided below are those items (procedure changes, process updates, and training to affected plant personnel) that will be completed prior to the implementation of new NFPA 805 Fire Protection Program (FPP), as defined in Section 5.5 of this LAR. Each of the following items in Table S-3 will be implemented within 365 days after receipt of the NFPA 805 SE/LA. An exception to this statement is for the completion date for Item S-3.24. This item will be completed for each unit at a time not to exceed 90 days after all modifications for the respective unit are operable (as listed in Table S-2).
Item Unit S-3.1 1' 2 S-3.2 1' 2 S-3.3 1' 2 S-3.4 1' 2 S-3.5 1' 2 S-3.6 1' 2 Table S Implementation Items Description SAP Notification 50399288 was issued to track the development and
.implementation of the NFPA 805 monitoring program for DCPP.
SAP Notification 50294777-27 was issued to track the revision of OM8.1D4 to incorporate the requirements of NFPA 805, Section 3.3.1.2.(1), which discusses wood used within the power block.
SAP Notification 50294777-3 was issued to track the revision of OM8.1D4, Section 5.1.1.f, to address basis of flame retardant plastic sheeting material.
SAP Notification 50294777-15 was issued to track the revision of OM8.1D4 to comply with the requirements of NFPA 805, Section 3.3.1.2(3), for removal of incident combustible materials at the end of the shift or when work is complete, whichever comes first. Also, OM8.1D4 will be revised to specify labeling and limits on combustible storage areas per NFPA 805, Section 3.3.1.2(4).
SAP Notification 50294777-6 was issued to track the revision of Plant Procedure MA1.1D9 to include requirements that management ensure that only approved apparatus, such as torches, manifolds, regulators or pressure reducing valves, and acetylene generators, be used in accordance with NFPA 51 B requirements.
SAP Notification 50294777-13 was issued to track the revision of applicable procedure(s) to indicate the operational requirements for cutting/welding equipment with more than one cylinder as required by NFPA 241.
LAR Section/Source 4.6 4.1.2 and Attachment A 4.1.2 and Attachment A 4.1.2 and Attachment A 4.1.2 and Attachment A 4.1.2 and Attachment A Page 5-8
Pacific Gas and Electric Company AttachmentS-Modifications and Implementation Items Table S Implementation Items Item Unit Description LAR Section/Source S-3.7 1' 2 SAP Notification 50294 777-5 was issued to track the revision of OM8.1 04 to address 4.1.2 and combustible liquid in contact with hot pipes. Combustible liquid in contact with hot Attachment A pipes is not specifically addressed in procedures. DCPP will provide documentation to support compliance or revise a document to address the issue.
S-3.8 1' 2 SAP Notification 50294777-7 was issued to track the revision of procedure OM8.1D4 4.1.2 and to include requirements for adequate clearance around all electrical equipment.
Attachment A S-3.9 1' 2 SAP Notification 50294777-16 was issued to track updates to appropriate 4.1.2 and procedures to identify that any future modifications that utilize thermal insulation Attachment A materials, radiation shielding materials, ventilation duct materials, and soundproofing materials that the materials are noncombustible or limited combustible.
S-3.1 0 1' 2 SAP Notification 50401031 was issued to track the revision of DCPP design 4.1.2 and guidance documents associated with the implementation of NFPA 805 Attachment A (2001 Edition), Section 3.3.5.1. This section requires that "Wiring above suspended ceilings shall be kept to a minimum. Where installed, electrical wiring shall be listed for plenum use, routed in armored cable, routed in metallic conduit, or routed in cable trays with solid metal top and bottom covers."
S-3.11 1' 2 SAP Notification 50401046 was issued to track the revision of DCPP design 4.1.2 and guidance documents associated with the implementation of NFPA 805 Attachment A (2001 Edition), Section 3.3.7.2. This section requires that "Outdoor high-pressure flammable gas storage containers shall be located so that the long axis is not pointed at buildings."
S-3.12 1' 2 SAP Notification 50294777-34 was issued to track the revision of OM8.1D4 to 4.1.2 and include requirements to prohibit transfer of flammable or combustible liquids by Attachment A means of air pressure on the container or portable tanks.
Page S-9
Pacific Gas and Electric Company AttachmentS - Modifications and Implementation Items Table S Implementation Items Item Unit Description LAR Section/Source S-3.13 1' 2 SAP Notification 50294777-32 was issued to track the revision of Casualty 4.1.2 and Procedure M-6 to remove the phrase "unless the IC is an operations responder" Attachment A from Section 2.1.1.
S-3.14 1' 2 SAP Notification 50294 777-20 was issued to track plant procedures to ensure that a 4.1.2 and minimum level in the reservoir will be maintained to support a dedicated capacity Attachment A capable of supply maximum fire protection demand per NFPA 805 Section 3.5.16.
Plant procedures will also be revised to require evaluation of prohibiting non-FP use of fire water (FW) when lined up to the FW storage tank.
S-3.15 1' 2 SAP Notification 50399545 was issued to track the development of the FP basis 4.1.2, 4.7 and document in the form of the Fire Safety Analysis (FSA).
Attachment A S-3.16 1' 2 SAP Notification 50541606 was issued to perform and document a confirmatory 4.2.1.3 and demonstration (field verification walk-through) of the feasibility for the credited Attachment G NFPA 805 recovery actions as part of LAR implementation. This will include field verification of transit times (i.e., travel times to/from recovery action manipulated plant equipment) and execution times (i.e., time required to physically perform the action, such as handwheel a valve closed, open a Breaker, etc.) that are identified R2165-042-001, Revision 0. Validation walkdowns will be controlled by approved procedures that will address the performance and acceptance criteria.
S-3.17 1' 2 SAP Notification 50541606 was issued to review the recovery action feasibility and 4.2.1.3 and Human Reliability Analysis (HRA) evaluations and revise as needed in conjunction Attachment G with development/revision of procedures, revisions to the training program to reflect procedure changes, and revisions to the drill development procedure.
Page S-10
Pacific Gas and Electric Company AttachmentS-Modifications and Implementation Items Table S Implementation Items Item Unit Description LAR Section/Source S-3.18 1' 2 SAP Notification 50294 777-31 has been issued to address revisions to applicable 4.3 DCPP procedures to contain guidance developed by the Non-Power Operations (NPO) review. This will include revising procedures as necessary to ensure that FPP, operational controls, administrative controls, and housekeeping requirements are maintained to the extent practical during NPO conditions (i.e., that fire impairment compensatory measures are required when fire barriers are changed during shutdown modes and reduced inventory conditions). The definition of Higher Risk Evolution will be revised to be consistent with criteria in Nuclear Management and Resources Council (NUMARC) 91-06 and Frequently Asked Question (FAQ) 07-0040. A review will be performed to ensure that the feasibility of all NPO recovery actions are assessed in the Recovery Action Feasibility Assessment calculation or in another suitable document.
S-3.19 1' 2 SAP Notification 50401036 has been issued to address revisions to pre-fire plans 4.4 and training materials to address radioactive release requirements of NFPA 805.
S-3.20 1' 2 SAP Notification 50541581 was issued to address incorporating the NFPA 805 4.4 radioactive release review into DCPP's Configuration Control Program.
S-3.21 1' 2 SAP Notification 50399541 has been issued to address the update of system level 4.7 and topical design basis documents (such as drawings, specifications, and calculations) and other relevant documents (such as Design Criteria Memorandums (DCMs)) to reflect the NFPA 805 role that relevant SSCs now play.
S-3.22 1' 2 SAP Notification 50399544 has been issued to address revisions to the 4.7 configuration control procedures which govern the various DCPP documents and databases that currently exist. The procedures will be revised to reflect the new NFPA 805 licensing bases requirements.
Page S-11
Pacific Gas and Electric Company AttachmentS-Modifications and Implementation Items Table S Implementation Items Item Unit Description LAR Section/Source S-3.23 1' 2 SAP Notification 50399538 has been issued to address the development of 4.7 qualification requirements and Task Qualification Guides associated with the NFPA 805 program. This will include personnel performing fire modeling or FPRA development and evaluation.
S-3.24 1' 2 SAP Notification 50541605 was issued to verify the validity of the reported change-PRA RAI 03.b.01 in-risk and total risk upon completion of all Table S-2 modifications, which are credited in the PRA currently and are therefore the best estimates based on current plans, and of other implementation items listed in Table S-3, if determined to impact the post-transition PRA models. If the actual change-in-risk and/or total risk exceeds the acceptance guidelines of Regulatory Guide (RG) 1.17 4, the model will be reassessed and new modifications or refinements will be implemented, as necessary, to meet the acceptance guidelines prior to its use in the Change Evaluation. In addition, the DCPP NFPA 805 Change Evaluation process will include provisions to consider the impact of SOKC on delta CDF and delta LERF against the self-approval acceptance criteria (i.e., delta CDF less than 1 E-07 per year) for post-transition changes.
S-3.25 1' 2 SAP Notification 50294 777-23 was issued to revise applicable plant procedures to Attachment V address seismic fire brigade training as necessary as required by the FPRA to support compliance with Supporting Requirement SF-A5.
S-3.26 1' 2 SAP Notification 50356411 was issued to create new plant administrative work 4.5.1.1 and procedure AWP E-028 to define the process for implementing regularly scheduled Attachment V and interim PRA model updates, for tracking issues identified as potentially affecting the PRA models (e.g., due to changes in the plant, errors or limitations identified in the model, industry operational experience), and for controlling the model and associated computer files.
S-3.27 1' 2 PG&E will create a "No Combustible Storage" area within 5 feet of the north wall of PRA RAI 05 Fire Compartment 6-A-3. This will include the addition of localized visual warnings in accordance with OM8.104 and the addition of Fire Compartment 6-A-3 to Section 5.5.4 of OM8.104.
Page S-12
Pacific Gas and Electric Company - Modifications and Implementation Items Table S Implementation Items Item Unit Description LAR Section/Source S-3.28 1' 2 PG&E will monitor small and infrequent gaps in credited cable tray covers to ensure FM RAI 02.b they do not exceed one inch wide, spaced three or more feet apart as part of the DCPP NFPA 805 monitoring program.
S-3.29 1' 2 PG&E will use NRC accepted SDS failure models as these become available to PRA RAI 01.f confirm, as a minimum, that the transition change-in-risk estimates will not exceed the RG 1.205 acceptance guidelines. The DCPP NFPA 805 Change Evaluation process will include provisions to ensure that self-approved changes that rely on the SDS failure model will not be undertaken before acceptable models have been developed.
S-3.30 1' 2 PG&E will update radioactive storage procedures to incorporate a monitoring RR RAI 04 program to ensure that radioactive materials are not stored in a given area in excess of values determined by related calculations that are part of the NFPA 805 fire protection program.
S-3.31 1' 2 Verification of the condition of electrical cabinet doors to meet fire modeling FM RAI 01.d assumptions will be included in the monitoring program.
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