ML16342C864

Summary of 950310 Meeting W/Util Re Status of Various Licensing Issues.Attendee List,Reorganization Handouts, Licensing functions,24-month Cycle Info,Ts 6.5 & 6.8 Handouts & Fire Penetration Seal Handouts,Encl

ML16342C864
Person / Time
Site:	Diablo Canyon
Issue date:	03/14/1995
From:	Mark Miller NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9503240215
Download: ML16342C864 (70)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 March 14, 1995 LICENSEE:

Pacific Gas and Electric Company FACILITY: Diablo Canyon Nuclear Power Plant, Unit Nos. I and 2

SUMMARY

OF MEETING HELD ON MARCH 10,

1995, TO DISCUSS STATUS OF LICENSING ISSUES On March 10, 1995, the NRC staff met with representatives of Pacific Gas and Electric Company (PGKE) to discuss the status of. various licensing issues.

Persons attending this meeting are listed in Attachment 1.

Highlights of the meeting are summarized below.

The licensee described recent engineering organizational changes and how they came about.

Attachment 2 contains the applicable handouts.

The licensee had created process teams for eight organizational areas in order to assess the company's needs in each of these areas through 1998.

Primary organizational changes include (I) combining the engineering and regulatory interface functions, (2) combining the construction and maintenance organizations, (3) locating most engineering support at the site, (4) organizing the engineering function around systems or groups of equipment rather than engineering disciplines, and (5) reducing the number of design contractors from the current 200 to approximately 14.

Because the largest capital improvement projects have been completed, capital expenditures will fall from the

$80 million of 1994 to $45 million in 1995 to $ 41 million in 1998.

Concurrently, the Diablo staffing is projected to fall from currently more than 2300 to 1825 in 1998.

The organizational changes will occur in four phases through January 1997.

The licensee also discussed revised responsibilities within the licensing organization which are summarized in Attachment 3.

The licensee summarized its plans to move toward 24-month cycles and indicated that it would start with 20-month cycles, with no mid-cycle shutdown, starting in the spring of 1996 on Unit 2.

The ultimate goal is to have one spring outage each year when hydro run-off is maximized and less nuclear power is necessary.

The licensee expressed its interest in having a meeting with the staff in April to discuss several technical issues associated with the longer cycles.

Attachment 4 contains related handouts.

The licensee provided a brief discussion to update its program to assess the recently identified design inadequacy associated with nonisolated circuitry of the solid state protection system (SSPS).

The Integrated Problem

Response

Team is completing a comprehensive assessment of other scenarios besides the main steam line break which may impact electrical isolation (beyond the SSPS) in the plant including seismic and flooding events.

The licensee plans to relocate certain Section 6 Technical Specifications (TS),

and in doing so, wants to make certain changes to its quality assurance 230129 95032402l5 9503i4~i PDR ADOCK 05000275~

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,The staff did not have a problem w'ith the licensee,'s conceptual changes but.'cautioned them about no longer maintaining a list, of qualified technical"reviewers; the licensee should develop a proposal that will provide assurance that only qualified persons perform technical reviews of 'procedural changes.,

Also, the staff stated that (1) "tests and experiments" was,no'onger included in the draft proposed Section 6.5. 1," (2)" language needs 'to;be,included, in 'the audit discussion that if more frequent audits are required they will. be conducted, and (3) the discussion of the temporary-,change pro'cess,should be more detailed.

The staff also suggested that the licensee 'submit',both the'"TS relocation amendment and the discussion of'the gA program changes'imultaneously.

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'I, The licensee describedyits performance-based approach for qualifying fire penetration seals without damming boards.

The approach includes, assessing the fire loading in each

area, and if the fire loading is low, the licensee would propose not meeting the cold-side temperature criteria.

Other standards such as flame and hose stream tests would continue to be met.

The licensee emphasized that this was a Diablo-specific-approach.

The staff emphasized that the ability to base the evaluation on:.tests, whether ones already completed or ones which"the licensee

conducts, is key to staff acceptance of this approach.

The handouts of Attachment 6 summarize the licensee's program.

Licensing priorities of the licensee were also discussed and are identified in.

Original Signed By Melanic A. Hiller, Senior Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos.

50-275 and 50-323 Attachments:

1.

Attendance List 2.

Reorganization Handouts 3.

Licensing Functions 4.

24-Month Cycle Information 5.

TS Sections 6.5 and 6.8 Handouts 6.

Fire Penetration Seal Handouts 7.

Licensing Priorities cc w/atts:

See next page DISTRIBUTION w Atts 1-7:

Docket. Fi 1 e..t PDIV-2 Reading

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W. Russell/F. Hiraglia T. quay E. Jordan, T-4D118 NRC Participants DOCUMENT NAME:

DCHARIO.HTS OFC PDIV-2 LA,PDIV-2 P PUBLIC B. Beach, RIV R.

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Pacific Gas and Electric Company Diablo Canyon CC.

NRC Resident Inspector Diablo Canyon Nuclear Power Plant c/o U.S. Nuclear Regulatory Commission P. 0.

Box 369 Avila Beach, California 93424 Dr. Richard Ferguson, Energy Chair Sierra Club California 6715 Rocky Canyon Creston, California 93432 Ms. Nancy Culver San Luis Obispo Mothers for Peace P. 0.

Box 164 Pismo Beach, California 93448 Ms. Jacquelyn C. Wheeler P.

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Box 164 Pismo Beach, California 93448 Managing Editor The County Telegram Tribune 1321 Johnson Avenue P. 0.

Box 112 San Luis Obispo, California 93406 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, California 93408 Mr. Truman Burns Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, California 94102 Diablo Canyon Independent Safety Committee ATTN:

Robert R. Wellington, Esq.

Legal Counsel 857 Cass Street, Suite D

Monterey, California 93940 Mr. Steve Hsu Radiologic Health Branch State Department of Health Services Post Office Box 942732 Sacramento, California 94234 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower 5 Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mr. Peter H. Kaufman Deputy Attorney General State of California 110 West A Street, Suite 700 San Diego, California 92101 Christopher J. Warner, Esq.

Pacific Gas 5 Electric Company Post Office Box 7442 San Francisco, California 94120 Mr. Warren H. Fujimoto Vice President and Plant Manager Diablo Canyon Nuclear Power Plant P. 0.

Box 56 Avila Beach, California 93424 Mr. Gregory M. Rueger Nuclear Power Generation, B14A Pacific Gas 8 Electric Company 77 Beale Street, Room 1451 P. 0.

Box 770000 San Francisco, California 94106

MEETING ATTENDEES D ablo Can on Licensin Status Heetin March 10 1995 Attachment 1

XAAM',

Mike Angus Terry Grebel Jim Tompkins Melanic Hiller Ted quay Bob Gramm Bob Latta Jit Singh Steve West PGKE PG&E PGKE NRR NRR NRR NRR NRR NRR

ui in rinci es

~ Excellence in safety and generation performance o Strengthen Continuous Improvement culture o Sustainable excellence in cost performance

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~ Quality

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~ Business L Admin e Contracts, Bidding 8 Strategic Alliances

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aor a ita ancements 1988 Low Pressure Turbine Rotor Refurbishment Add Moisture Pre-Separators Install Security Barrier Grating Unit-1 Spent Fuel Pool Reracking Secondary Chemistry Laboratory 1989 Administration Building 2nd Floor Finish Low Pressure Turbine Disc Refurbishment - Phase A PIMS/ICS Graphics Support Upgrade Replace RHR Butterfly Valves, Unit-2 1990 Low Pressure Turbine Disc Refurbishment - Phase B

Replace P-260 Plant Process Computer System Main Annunciator Replacement - Phase B Outage Access Control Facility, Unit-1 Central Alarm System Upgrade Upgrade Telephone system Instrumentation & Control Shop Control Room Ergonomic Reconfiguration Upgrade Security Building Paint Facility 1991 Control Room p-260 Computer Replacement Main Annunciator replacement - Phase C Replace 12-in Main Extraction Steam Piping, Unit-1 Purchase Spare Exciter Process Protection System Upgrade HVAC, Unit-1 Replace NIS Penetrations/Cables, Unit-2 Outage Access Control Facility, Unit-2 Intake Security Reconfiguration

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1992 Low Pressure Turbine Disc Refurbishment - Phase C Radiation Monitoring System upgrade - Phase A Addition of Sixth Diesel Generator Install New Sea Water Reverse Osmosis System Replace NIS Penetrations/Cables, Unit-1 Radiation Monitoring System Upgrade - Phase 8 Replace Vital Batteries - Phase A Purchase Spare Charging Pump Purchase Spare Reactor Coolant Pump Rotor Purchase Spare Circulating Water Pump 1993 Steam Generator Blowdown Modifications, Unit-2 Radiation monitoring System Upgrade - Phase C Replace NIS Penetrations/Cables, Unit-2 Replace PDP Pulsation Dampers Radiation Monitoring System Upgrade - Phase D Replace Vital Batteries - Phase B Condensate Polisher Computer, Unit-2 RHR Valve Replacement 1994 Upgrade Hagen Protection System Racks Process Protection System Upgrade-

, Main Annunciator Replacement - Phase D

Main Annunciator Replacement - Phase E

RTD Bypass Elimination Screen Wash/Other Saltwater Systems Upgrade 120V Vital Instrumentation, Unit-1 Safety Relief Motor Operated Valve, Unit-1 Safety Relief Valve Testing Equipment, Unit-2 Replace NIS Penetrations/Cables, Unit-1 Battery 22 Replacement, Unit-2 Condensate Polishers Computer, Unit-1

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~ Completion of capital upgrade program-Outages will be much shorter o Standardize outages - significantly reduce re-creation of work packages each outage o Increased emphasis on management of outages and efficent use of temporary resources Goal - Consistent 35 to 3Q day outage durations as routine, reduce incremental outage costs to 835M

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trate ies o Completion of capital upgrade program

- focus on ongoing maintenance e Single set of work procedures for all maintenance and special projects

~ Streamline work control process

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b'ate ies o Consolidate support to gain efficiencies, and reduce staff to reflect smaller organization supported

~ Learning Services to focus on core, INPO accreditation programs o Streamline payroll, RMSing, Plant Manuals e Employ improved technologies in Security o Standardize computer software applications

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~ Completion of capital upgrade program

~ Focus on engineering support of on-going operations and reduce the number of modifications

~ Most engineering support located at DCPP

~ Organize engineering support around a systems "product line" to achieve synergies, enhance operating focus, and improve teamwork.

o Bring responsibility and ownership for design basis and licensing basis together and maintain in San Francisco to not be diluted by day-to-day operating needs.

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~ Window 4: 10/30/96 to 01/13/97-Note: Actual relocations from SF to DCPP site can take place during the summer to ease disruption to employee families

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Attachment 3

03/06/95 RLJohnson PRIMARYFUNCTIONS REGULATORYSUPPORT SERVICESXICENSING BASISMANAGEMENT lato Su ort ervices W5-~-+7~o License Amendment Requests (Tech. Spec. changes)

Enforcement Discretion Requests Operability Evaluations Tech. Spec. Interpretations Equipment Control Guidelines Notice ofViolation Responses Special Reports to the NRC Nonconformance Reports/Technical Review Groups Support NRC Interface - Residents/Region/NRR (day-to-day)

Commitment Identification Periodic Status Reports to NRC and NPG Management Submittal Processing/Finalizing Incoming/Outgoing NRC Correspondence Security/Operator Licensing /EP/CERP Submittals Selected Generic Letter Responses art FW Awc&'x~

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+/~cga License Amendment Requests (Major Projects, Generally Cost Beneficial Licensing Actions FSAR Udpate/50.59 Summary Report Commitment Management (PCD, one-time)

Generic Letter/Bulletin Responses NRR Interface (Long-Term Projects)

Licensing Positions Humboldt Licensing Support Committee Support (NSOC, PNAC, ISC)

Nuclear Energy Institute Interface Legislative Analysis/Industry Regulatory Assessments Hearings Support Maintain Electronic Document Management System (EDMS) Regulatory Database Coordinate Licensing Manager's Network

posed Plan

',:, Goal is to attain 24-month long fuel cycles Phase l: 5/o enrichment license (due: mid 'l995)

Phase ll: '20-month'cycles from $ 996 to 200'l.

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No technical concerns

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Significant regulatoryinteractions related to surveillance extensions (1995 and 1996) r Phase III:24-month cycles beginning 2001

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Attachment 5

PROPOSED CHANGES TO SECTIONS 6,5 AND 6,8 (Draft 2/24/95)

We Intend to make the following changes concurrent with moving Sections 6.5 and 6.8 to Chapter 17 of the

. DCPP FSAR, 6

1 rECHNlca R

IE AND UDT We intend to ciarlfy the applicability of procedure review and approval requirements of Specification 6.5.1.

They shall apply when approving plant programs and procedures or changes to plant programs and procedures.

They shall also apply when approving or changing corporate procedures and procedures used by support organizations ifthey can have an Immediate effect on plant operations, or the operational status of safety-related structures,

systems, or components.

They do not apply to editorial or typographical changes.

Justtulcsttcn This ts only a rJarincatlon.

As written, these secgons were dearly intended to apply to activities under the control ofthe Plant Manager, and were not intended to apply to all licensee activities, Including those performed in the corporate headquarters by support otganizatlons.

Logically, review and approval requirements af these sections should only apply to programs and procedures that are under the Plant Manager's control.

The exclusion of editorIal and typographical changes ls appropriate since they cannot affect nuclear safety.'

similar exclusion was previously approved by the NRC In Byron, Units 1&2 Technical specifications, section 6.8.2., and in Farley, Unit 1 Technical specifications, Section 6.5.3.1.a.

6.5.1.1 After the existing paragraph, we Intend to add sections to define a new review function for procedures and programs that are presently reviewed by the Plant Staff Review Committee.

This includes Admlnistratlve Procedures, the Security Plan and its implementing pracedures, the Emergency Plan and its implementing procedures, the Process Control Program, the ODCP, the ERMP, and Radwaste Treatment System procedures.

Changes to these programs and procedures shall be reviewed as presently required by the existing Section 6.5.1.1 and shall be approved by the Plant Manager or his

'esignee prior to implementation.

Reviewers shall meet qualification requirements of paragraph 4.7.2 of ANSI/ANS 3.2-1978. Reviews shall Include a determination as to whether addNonal cro~isclpiinaly reviews are necessary.

Ifso. they shall be performed by review personnel ofthe appropriate discipline, Reviews shall also determine whether a safety evaluation per 10CFR50.59 ls necessary.

Ifso, one shall be written and presented to the Plant Staff Review Committee for review prior to approval.

We also intend to add a section to define the review and approval function for proposed changes or modifications to plant systems or equipment that affect nuclear

safety, Proposed changes or modifications shall be designed by a technically qualified Individual or organization, and reviewed by an individuaVgroup other than the IndlvlduaVgroup who designed the modification, but who may be from the same organization. Reviews shall include a determination as to whether addNonal cross-disciplinary reviews are necessary.

Ifso, they shall be performed by review personnel of the appropriate discipline.

Reviews shall also determine whether a safety evaluation per 10CFR50,59 Is necessary.

Ifso, one shall be written and presented to the Plant Staff Review,Committee for their review prior to approvaI.

Proposed changes or modifications to safety related structures,

systems, or components shall be approved prior to Implementation by the Plant Manager or hfs designee, as specified ln administrative procedures,'prior to implementation.

Justincstion These sections are being added so that ths specified reviews may be performed by qualified individuals, rather than by the Plant Staff Review Committee.

This ls consistent with Section 5.5 in Revision 0 of the Standard Technical Specifications, which states that reviews may be performed by qualified individuals rather than by committees.

It Is also consistent with the McGulre, Units 182, Technical Specifications which have been approved by the NRC.

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6.5.1.2 We intend to change this section to remove the requirement for previous designation of reviewgrs by discipline or procedure category by the Plant Manager.

We will retain the requirement that reviewers meet education and experience requirements of Section 4.7.2 of ANSI/ANS 3.1-1978, but will not require prior designation of reviewers by the Plant Manager.

The approval authority shall ensure that reviewers are knowledgeable in the subject area and meet education and experience requirements.

Justification:

The requirhment to previously designate reviewers by discipline or procedure category does not improve the quality of reviews or nuclear safety.

In practice, the approval authority will not approve a procedure unless someone he knows personally to'be knowledgeable, experienced, and thorough has reviewed it, regardless of prior designations.

Obtaining and maintaining these designations has proven to be a costly administrative burden with essentially no benefit.

In fact, in some instances, they have had a negative affect on the quality or reviews.

Ifthe best person to perform a review wasn' designated for the right review category, the review was performed by someone else.

Revision 0 of the Standard Technical Specifications does not require prior designation of procedure reviewers by the Plant Manager.

6.5.2.6 We Intend to redefine the review and approval functions for changes to programs and procedures listed below and remove them from the list of Plant Staff Review Committee responsibilities.

All proposed changes shall be screened to determine whether a formal safety evaluation ls required.

If one Is required. it will be reviewed by the PSRC. (See Section 6.5.1.1, above, for a description of the revised review process)

Administrative procedures Security Plan and implementing procedures Emergency Plan and implementing procedues Proposed modifications to safety related structures, systems, or components Process Control Program ODCP ERMP Radwaste Treatment System procedures Fire Protection Program and Implementing procedures

~asti cation: This is consistent with the standard Technical specifications, Revision 0, section 5.5, which states that reviews may be performed by capable individuals rather than by a committee, This is also consistent with section 6.8.2 of McGuire's Technical Specifications, which have been approved by the NRC.

6.5.3.8 "Audits".

We intend to change this section so that audit frequencies can be adjusted based on experience and potential safety impact. 'Details and justification to be provided by NQS) 6.8.2 6,8.3 We intend to change this to require procedures identified in Specification 6.8.1 to be approved by the Plant Manager or his designee, In accordance with approved administrative procedures, prior to implementation, We also intend to remove the requirement that Administrative Procedures, procedures implementing the Security Plan, Emergency Plan, Process Control Program, the ODCP and ERMP, and changes thereto.

be reviewed by the PSRC and approved by the Plant Manager prior to implementation. Safety evaluations, lfrequired, will continue to be reviewed by the PSRC.

(See Section 6.5.1.1, above for a description of the new review process)

Justification:

The change In approvaI authority is consistent with Specification 5.7.1.2 of Revision 0 of the Standard Technical Specifications.

See sections 6.5.1.1 and 6.5.2.6, above, for justification of changes to PSRC review requirements.

We intend to change paragraph "b'o that the signature of a Senior Operator Is only required for temporary procedure changes that could affect plant operations or the operational status of plant

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equipment.

Other temporary procedure changes shall be approved by two members of the plant management staff who meet applicable qualification requirements of ANSI/ANS 3.1-1978.

NOTE:

We also Intend to take exception to a similar requirement in paragraph 5.2.2 of American National Standard N18.7-1976/ANS 3.2.

It states that, for approval of temporary changes, at least one individual shall be the supervisor in charge of the shift and hold a senior operators license on the unit affected.

This exception will be listed In Table 17.2 of the Diablo Canyon Power Plant Final Safety Analysis Report Update.

'e also intend to change paragraph "c of Specification 6.8.3 to make the approval authority for temporary procedure changes consistent with Specification 6.8.2, above.

~u~ifi i~t'his change retains the requirement for approval by a Senior Operator when a review by someone with his knowledge and experience is needed.

It atso allows the approval to be performed by a more appropriate staff member when the knowledge and experience of a Senior Operator is not needed, For example, a Senior Maintenance Engineer may be a more appropriate person to approve a technical change to a complex maintenance procedure.

The NRc has approved a similar requirement ln the Wolf creek, Unit 1 Technical Specifications.

Specification 6.8.3 only requires SRO approval of temporary changes to operating procedures.

l

(Draft 2/24/95)

DRAFT SECTION 6 TEXT INCORPORATING PROPOSED CHANGES Replace existing section 6.5.1 In its entirety with the following:

T CH ICA REVIEWANDAU T 6.5.1.1 Procedure review and approval requirements of Specifications 6.5.1 apply when approving plant programs and procedures, or changes to plant programs and procedures.

They also apply when approving or changing corporate procedures and procedures used by support organizations if they can have an Immediate effect on plant operations or the operational status of safety-related structures, systems, or components. They do not apply to editorial or typographical changes.

6.5.1.2 The Emergency Plan, the Security Plan, each procedure or program required by Specification 6.8, and other procedures, tests, and experiments that affect nuclear safety or the treatment of

radwaste, and changes thereto, shall be prepared by a qualified individual/group.

Each such plan, procedure, program, test, or experiment, and changes thereto, shall be reviewed by an IndlviduaI/group other than the individual/group who prepared the proposed document or change, but who may be from the same organization as the individual/group who prepared it.

6.5.1.3 lndlviduafs responsible for the above reviews shall be knowfedgeable fn the document's subject area and shall meet or exceed the qualification requirements of Section 4.7.2 of ANSI/ANS 3.1-1978.

Individuals who approve the above documents are responsible for ensuring that reviewer qualification requirements have been met 6.5:1.4 Proposed change or modlficatfons to plant systems or equfpment that affect nuclear safety shall be designed be qualified individual or organization, and reviewed by an individual/group other than the fndfvf ual/group who prepared the change or modification, but who may be from the same organization.

Each change or modification shall be approved by the Plant Manager or his

desfgnee, as specified in administrative procedures, prior to implementation.

6.5.1.5 The reviews specified In Sections 6.5.1.2 and 6.5.1.4 shall include a determination as to whether additional cross-discipline reviews are necessary.

If deemed necessary, they shall be performed by review personnel of the appropriate discipline(s),

6.5.1.6 The reviews specifie in Sections 6.5.1.2 and 6.5.1.4 shall also hall also etermine whether a safety evaluation per 10CFR50.59 is necessary.

If necessary, on shall be prepared and presented to the Plant Staff Review Committee for review prior to approval.

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Replace existing 6.5.2.6 with the following:

6.5.2.6 The Plant Staff Revfew Committee shall be responsible for.

Review of the documents listed below to verify that proposed actfons do not constitute an unreviewed safety question or require a change to the Technical Specifications, and recommending approval or disapproval In writing to the appropriate approval authority.

1)

Safety evaluations of proposed procedures and procedure

changes, to be completed under the provisions of 10CFR50.59; 2)

~ Safety evaluations of proposed tests or experfments to be completed under the provisions of 10CFR50,59; 3)

Safety evaluations of proposed changes or modifications to plant structures, systems or equipment to be completed under the provisions of 10CFR50,59.

4)

Safety evaluatfons of proposed changes to the following plans and programs completed under the provlsfons of 10CFR50.59:

a. Security Plan

b. Emergency Plan

c. Process Control Program

d. ODCP

e. ERMP

f. Fire Protection Program b.

C.

d.

e.

Review of all proposed changes to Appendix "A"Technical Specifications and advising the Plant Manager on their acceptability; Investfgation of all violations of the Technfcal Specifications including the preparation and forwandfng of reports covering evaluation and recommendations to prevent recurrence to the Senior Vice President and General

Manager, Nuclear Power Generatfon and to the Chairman of the Nuclear Safety Oversight Committee (NSOC);

the assessmant shall Include an assessment of the safety significance of each violation.

Review of all REPORTABLE EVENTS ln order to advise the Plant Manager on the acceptability of proposed corrective

actions, and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Chairman of NSOC; Review of significant plant operating experience or events that may indicate the existence of a nuclear safety hazard, and advising the Plant Manager on an appropriate course of action;

I t l

I J

Review of any accidental, unplanned, or uncontrolled radioactive release Including the preparation and forwarding of reports covering evaluation.

recommendations and disposition of the corrective action to prevent recurrence to the Senior Vice President and General Manager, Nuclear Power Generation, and to the Chairman of NSOC; Replace Seclfon 6.5,2,7 with the folowirig:

6.5.2.7 The Plant Staff Review Committee shall:

a.

Recommend in writing to the appropriate approval authority, approval or disapproval of the items considered under Specification 6.5.2.6a. and b., above; Render determinations ln writing with regard to whether or not each item considered under Specification 6.5,2.6a.

through d.

above, constitutes an unrevlewed safety question; and Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Senior Vice President and General Manager, Nuclear Power Generation of disagreement between the PSRC and the plant Manager; however, the Plant Manager shall have responsibility for resolution of such disagreements pursuant to Specification 6.1.1 above.

Replace Specification 6,5.3.8 with the following:

(To be provided by NQS)

Replace Section 6.8.2 with the following:

6.8.2 Each procedure of section 6.8.1

above, and changes

thereto, and all proposed tests or experiments that affect nuclear safety shall be reviewed and approved prior to fmplementation In accordance with Specification 6.5.1 above. Each procedure of Specification 6.8.1 above, shall also be reviewed periodically as set forth in administrative procedures.

Replace Specification 6.8.3 with the following:

6.8.3 Temporary changes to procedures of Specification 6.8.1 above, may be made provided:

a.

b.

The intent of the original procedure is not altered, The change is approved by at least two menbers of the plant management staff.

For changes that can affect plant operations or the operational status of plant equipment, at least one of the approvers shall hold a Senior Operator license on the unit affected.

For changes that do not affect plant operations or the operational status of plant equfpment, the two management staff members shall meet applicable qualification requirements of ANSI/ANS 3.1, 1978; and The change Is documented,

reviewed, and approved by the appropriate approval authority. in accordance with Specification 6.5.1, within 14 days of Implementation.

C

BACKGROUND

~ Fire Barrier Penetration Seals are intended to provide fire endurance capabilities commensurate with the fire ratings of the barriers (i.e. 1, 2, and 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />).

~ Penetration seal installations should reflect penetration seal designs and be supported by qualified fire tests and documentation.

Additional Requirements

-HVACPressure Rating

-I-IELBFlood Rating

-HELB Steam Pressure

-P..sdiation Barrier FIRE BARRIER PENETRATION SEAL PROGRAM DIABLOCANYON POWER PLANT PRESENT.DOC SLIDE 2

\\

1

PARAMETERS AFFECTING SEAL UALIFICATION

~ Barrier Orientation

~ Barrier Material and Thickness

~ Penetration Opening Size

~ Sleeve

~ Sealant Material and Thickness

~ Penetrant Type

~ Penetrant Size

~ Number OfPenetrants

~ Proximity of Penetrants (Spaces between penetrants and/or between penetrant and opening)

FIRE BARRIER PENETRATION SEAL PROGRAM DIABLOCANYON POWER PLANT PRESENT.DOC SLIDE 7

v

~ -

t I

SEb,L4.QT I

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'd SLC<VE'RA'f cC HAYIJdf EY.IW)

BafzC CASLG5 p cpu L V.

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PIPE'Q Cod DUi'T DAWN)QQ KcYrc.u<L d p.

m<O. C.lgnghuCB Of1 AII (ggP) 8aRP IE,P H<VERIAL,~

IIIgk NEQr, mI<ii<a~,'Oa (<e ~bi.t. /FL<<~)

I

INDUSTRYPROBLEM Difficulties in qualifying Penetration seals

~ Limited number of qualified f:.. test

~ Documentation of qualified firi test not consistent with NRC standards (e.g.,

evolving NRC criteria)

~ existing fire tests do not encompass many field conditions

~ Variations from standard need to be properly documented Vendor supplied seals (i.e.vendor qualified designs) are typically based on a limited number offire tests using extrapolated data.

FIRE BARRIER PENETRATION SEAL PROGRAM DIABLOCANYON POWER PLANT PRESENT.DOC SLIDE 8

- PGAK'S POSITION

~ Penetration seals which can withstand the effects of a fire test without the passage of flame or hot gasses and successfully pass a hose stream test are more than sufficient for applications at DCPP even though the maximum cold side temperature has been exceeded.

I'IRE BARRIER PENETRATION SEAL PROGRAM DIABLOCANYON POWER PLANT PRESENT.DOC A

SLIDE 12

P

PERFORMANCE BASED PENETRATION SEAL PROGRAM

~ Provide a cost effective alternative to the conventional penetration seal programs developed and used at other utilities.

~ Reflects the new philosophy being endorsed by the NRC to reduce the regulatory burden

~ Consistent with guidance provided in Generic Letter 86-10 FIRE BARRIER PENETRATION SEAL PROGRAM DIABLOCANYON POWER PLANT PRESENT.DOC SLIDE 13

4

KKYKj'MKNTSOF THKPROGRAM

~ Reassess all fire barriers for function and performance requirements.

~ Considers realistic or actual" fire conditions

~ Credits attributes ofthe DCPP Defense-In-Depth philosophy FIRE BARRIER PENETRATION SEAL PROGRAM DIABLOCANYON POWER PLANT PRESENT.DOC SLIDE l4

V l

DEFENSE-IN DEPTH PHILOSOPHY

~ Fire Prevention*

~ Early Detection and SuppressIt

~ Limitspread offire (i.e. Mitigaie Damage)

FIRE BAK<IERPENETRATION SEAL PROGRAM DIABLOCANYON POWER PLANT PRESENT.DOC SLIDE 15

~'

l

'C

DCPP SPECIFIC This program is considered DCPP specific and may not be applicable to other plants. It is possible for DCPP due to the following:

~ Low combustible loading in most fire areas (80% ofall fire areas have less than a 45 minute postulated fire duration

~ Minimal use of cable trays

~ OM8-ID1-Fire Prevention Procedure

-~control oftransient combustibles

-open flame and welding controls FIRE HAIRIERPENETRATION SEAL PROGRA1VI DIABLOCANYON POWER PLANT PRESENT.DOC SLIDE 19

I

CRITICALTASKS FOR PENt=TRATION SEAL PROGRAM ID Task Finalize FHARE Qtr2,1896 Qtr3,1996 Qtr1 1896 Res nsible Jan Feb Mar A

Ma Jun JW Au Se Qtr 4, 1896 Qtr 1, 1886 Oct Nov Dec Jan Feb Mar Qtr 2, 1888 Qtr 3, 1986 Qtr 4, 1995 A

Ma Jun Jul A

Se Oct Nov Dec

'2 Finalize ECG revision 3

klantifybarnet lo be eliminated 4

Issue DCN for revised bamers 5

DavaIop typbal details 6

Promalac tesl 7

Watkdown procedure davabpment 8

Perform walkdown Gragerson Gragerson Porter.Yashar 428 m~ 428 428

.Igg 5/16 9

Evaluate walkdown results 10 Program procedure tevbw and update Cosgrove,Porter Issue typbal detailed and bastion drawln Baker Schedule pen saaNre proln DCN tevlslo Gtegerson FHARE AnsI revision Perform necessary repairs 11/30~ 12l16 12/16 12/16 12/15

'e/2e 16 Panetratbn seal computer program Porter

e/28 Lead

Jim Gregerson x8780 Planner: Lawrence Lo x3-9985 Status Date: 02/21/95 C.'LGOFCSTUAGNPP Task Progress Milestone +

Summary Page 1 of 1

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t

Attachment 7

LARs UNDER REVIEWBY NRC (PRIORITIZED) 40-Year Operating License Appl'ion (Submitted 7/9/92)

This I.ARwould change th

iration date for thc Unit I Operating License from Aprd 23, 2008, to Septcnker 2, 2021, and the expiration date forthe Unit 2 Operating License from Deccndx, 20 l0, to April26. 2025.

The ASLB has cl thc hearing for the )iccnse recapture and found no reason to deny the rntuest.

tu isproccssinetheLAtt.~

sl jt (

ysrs Revise Pressure/I'crnperuturc LimitCurves g S 3.4.9) (Submitted 8/l7/94)

This LARwould change thc appliahilityofthe prcssure and turuperaturc hcatup and cooldown curves for the reactor vessel from "through 8 eQective fuH power yaeste to "through 12 effective fullpo>vcr years." This LARneeds to be issued by Aprill, 1995 to support continued opcretion ofUnit i, Unit i tcsches 8 trppY epprordtoelcty Apn1 l3.

Increase Fuel Enrichment l,imits to 5% (Submitted 2/6/95)

This LARwould increase the fuel enrichment limits to 5% weight percent uranium dioxide. DCPF wishes to transition to higher enrichment fuel to reduce thc number of assemblics required to be replaced each outage and to bc positioned for increasing to 2 year cycles.

PG&E desires to load 5% fue! during 2R7. 2R7 is scheduled for approximatciy March 1996. To support thc outage, fbel must bc ordered by approximately March 15, 1995.

Approval ofthe LARhas been requested to support this date.

However, the cnrichmcnt ofthe fuel oould be changed as late as 6/95, or the fuel could bc dHutcd by Westinghouse during fabricrrtion up to September 1995. This could result in additicnral fuel cost ofup to $1.000,000.

Thc NRC requested additional information on this submittal. The submittal is currently being drafted and is scheduled to bc submiued no later than 3/l7/95.

Appcndh J Testing (TS 4.6.1.2) (Submitted 2/16/94)

This LARproposes to delete the requirements to perform an ILRTevery 40+/- 10 months and during the tcn you 1SI, and instead require that 3 ILRTs bc performed every ten years at approximately equal lntcrvais.

The NRC is currently reviewing this LARin lightofpending tulcrnaking that would allow ILRTs to be pcrforrncd once every ten years instead of thc current schedule.

The HRC is prepared to issue the exemption from thc requircnhcnt ofperforming an ILRT during the tcn year 1SI. They arc prcparcd to issue this exemption because it is needed to support a reasonable ILRTperformance schedule.

However, thc NRC is not willlttg to issue thc change to the 40+/- 10 months requirement since it is not required to support a reasonable ILRTperformance schedule at this time. Thc NRC feels that the research required to issue this part ofthc LARwould hamper issuance ofthc rule changes.

The NRC is aqxcred to approve the LARby August 1994. Issuance ofan LA is required by September 1995 to avoid performing an unnecessary ILRTduring 1R7.

/

, (i.

MJREG-1366/Generic Letter 93%5 (Submitted 9/20/94) j Tlus LARwould implement survcillancc reiaxatioas speci6cd ia thc HUREG. The NUREG surveillance relavatioas are based on thc premise that excessive surveillance testing can do more harm than good for some components.

Thc potential cost havings tave been reviewed with thc affecte directors, and an implementation plan developed.

The NRC has requested additional information regarding this submittal. This additional inforuration is scheduled for NSOC review by 4/5/95, and submittal by 4/10/95.

Relocation ofSelected Section 7 TS lo Plant Administrative Control (Submitted 2/16/94)

This LAR proposes to relocate sclccted TS ia Sec!ion 3/4.7 to plant administrative control. Thc TS are being relocated based on the ncw standard TS contained in NUREG-l.431. During thc development ofNTiREG-1431, the NRC determined that many requirements cuncnQy located in plant TS are adrninisuativc ln nature and could be turned over to plant control. Thc LARwould allow affected TS to be changed in accordance i~ith 10 CPR 50.59.

Slave Relay Test Relaxation (Submitted 11/14/94)

This LARwouM rcbx the surveillance test intcnai for aH slave relays from quarterly to-n refuleing frequency.

This LARis based on WCAP-13878, which was developed as part ofa WOG program.

Increase RWST AOTfor OutMTolerance Paraneters (TS 3.5.5) (Subnutted 8/17/94)

This LARwould increase AOTfor boron ooncentration and mter temperature outM-tolerance in the R%'ST from 1 to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> consistent with NUREG-143 1, WOG STS. An analysis has determined that based on past site meteorological data, thc RNST temperature weal never reach the maximum or minimum temperatures assumed in Ole design accidents.

ConsequenQy, thc temperatures willbe removed front the TS.

This LARcurrently willnot provide any finn cost savings. A potential cost savings exists in the extension ofthe A(Ã. Thc extension ofthis AOTcould prevent a unit shutdown, and thc regulatory costs (LERs, ERPs, etc.) associate withil A unit shutdown has been initiated as a result ofthe RWST boron concentration being out of spec.

Relocate SelecLed 3/4.4 Tec (Submitted 8/17/94)

This LARwould cate selected 3/4.4. Tech Specs to plant control. included irtthe relocation ar Modes S and 6 requirements for piessurimr safety valves, RCS Chcinl

'ts, pressurizer temperature limits, vessel hc'ui vents. and RCS structural in ty. The changes arc ofthe itn tcmentation ofthc new Wcstiaghouse dard Tech Specs.

Eagle 21 Cleanup LAR(TS 3/4.3.2) (Submitted 12/30/94)

This f.ARrevsics the lttstrtuuetttation portion of thc TS to correct enors introduced as a result of a license atncndment issued to support the insta! latlon ofthe Eagle 2l protection system.

C