ML23205A117
| ML23205A117 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/26/2023 |
| From: | Ryan Lantz NRC/RGN-IV/DORS |
| To: | Beverly Smith NRC Region 4 |
| References | |
| Download: ML23205A117 (1) | |
Text
MEMORANDUM TO: Brian Smith, Director Division of New and Renewed Licenses FROM:
Ryan Lantz, Director Division of Operating Reactor Safety
SUBJECT:
DIABLO CANYON LICENSE RENEWAL INSPECTION STRATEGY Region IV (RIV) will implement the strategy described below to support the operating license renewal inspections for an anticipated license renewal application for the Diablo Canyon Nuclear Power Plant, (Diablo Canyon) Units 1 and 2. By letter dated March 2, 2023 (ML23026A102), the NRC granted Pacific Gas and Electric Company (PG&E, the licensee), a one-time exemption for Diablo Canyon from 10 CFR 2.109(b). This allows PG&E to submit a license renewal application for Diablo Canyon less than 5 years prior to the expiration of its operating licenses, but no later than December 31, 2023. Therefore, the NRC expects PG&E to submit a license renewal application for Diablo Canyon before December 31, 2023. This memorandum documents the regional decision-making process regarding the scheduling of the license renewal inspections that would be required to support such an application.
The inspections detailed below provide reasonable assurance that the licensee will implement activities that manage the effects of aging on passive, long-lived components both prior to and during the timely renewal period. During a May 24, 2023, public meeting (ML23143A128), the licensee identified several items related to aging management programs that would require the use of the timely renewal period to allow for proper planning around outages, procurement, work planning, and training.
Region IV plans to implement license renewal inspections at Diablo Canyon in accordance with the guidance in Inspection Manual Chapter 2516, Policy and Guidance for the License Renewal Inspection Programs, Inspection Procedure (IP) 71002, License Renewal Inspection, and IP 71013, Site Inspection for Plants with a Timely Renewal Application. These inspections will evaluate whether the licensees activities provide reasonable assurance for managing the effects of aging on structures, systems, and components. If, during the planning, execution, or documentation of these inspections, the NRC determines that the operating license will not be renewed, inspection efforts will cease.
July 26, 2023 Signed by Lantz, Ryan on 07/26/23
B. Smith 2
Upon the issuance of any renewed licenses and the completion of Phase 3 of IP 71013, RIV inspection efforts will shift to the corresponding portion of IP 71003, Post-Approval Site Inspection for License Renewal.
This strategy includes inspection and evaluation activities from July 2023 into the timely renewal period. Because of the time constraints due to any receipt of a license renewal application necessarily being less than 5 years prior to the expiration of the operating licenses, RIV will conduct inspections prior to the receipt of a license renewal application in anticipation of such an application being submitted. Additionally, to maximize the efficient use of resources, the NRC regional inspectors will leverage information from the previously submitted (and subsequently withdrawn) license renewal application for Diablo Canyon from 2009 (ML093340086), the NRCs safety evaluation report (ML11153A103), licensing correspondence, and prior inspections in support of the 2009 license renewal application, and relevant Reactor Oversight Program inspection history for the facility. After receipt of a new license renewal application, RIV will adjust its inspection activities, as needed, to account for any changes to the commitments or aging management programs.
License Renewal Inspection Strategy Timeline Details Diablo Canyon License Renewal Inspection Milestones Expected Start Date Inspection October 2023 Unit 1, IP 71013 Phase 1 Outage Inspection April 2024 Unit 2, IP 71013 Phase 1 Outage Inspection June 2024 Units 1 and 2, IP 71002 Licensing Inspection August 2024 Unit 1, IP 71013 Phase 2 Commitment Inspection November 2, 2024 Unit 1 original license expiration date February 2025 Unit 2, IP 71013 Phase 2 Commitment Inspection August 26, 2025 Unit 2 original license expiration date TBD Units 1 and 2, IP 71013 or IP 71003 Phase 3 renewal follow-up inspections As stated above, the NRC regional inspectors will perform Phase 1 of IP 71013 for Diablo Canyon, Unit 1 during the upcoming October 2023 Unit 1 refueling outage. This is the last refueling outage before the expiration date of the Unit 1 original license on November 2, 2024.
It is anticipated that this inspection will occur before any submission by the licensee of a license renewal application. The inspectors will walk down normally inaccessible areas during the refueling outage to assess the material condition of structures, systems, and components. The inspectors will evaluate planned aging management activities and perform inspections associated with aging management programs as described in PG&E Letter DCL 23-020, Responses to NRC Questions Regarding Diablo Canyon Power Plant License Renewal Efforts, dated March 17, 2023 (ML23076A210). In addition, the inspectors will leverage the previous license renewal inspection efforts. Specifically, the inspectors will review the open items, and any associated corrective actions, from the previous inspection activities related to the 2009 license renewal application, as documented in NRC inspection report 05000275; 05000323/2010008 (ML103220205). The results of Phase 1 of IP 71013 for Diablo Canyon, Unit 1 will be documented in a standalone inspection report.
The NRC regional inspectors will perform Phase 1 of IP 71013 for Diablo Canyon, Unit 2 after any license renewal application is received. The inspectors will review additional aging
B. Smith 3
management activities and commitments, as specified in the application. The inspectors will document the results of this inspection in a standalone inspection report.
The NRC regional inspectors will perform Phase 2 of IP 71013 for Diablo Canyon, Unit 1 after any license renewal application is received and after the Division of New and Renewed Licenses personnel complete the scoping and screening and the aging management program audits. It is anticipated that this inspection for Diablo Canyon, Unit 1 will be completed before the expiration date of the original license. Region IV will document this inspection in a standalone inspection report.
Region IV will coordinate closely with the Division of New and Renewed Licenses safety project manager to include relevant insights for conducting a modified IP 71002 review to support license renewal. Region IV will document this inspection in a standalone inspection report.
The NRC regional inspectors will perform Phase 2 of IP 71013 for Diablo Canyon, Unit 2 for commitment evaluations and assessment of aging management programs prior to the expiration date of the Unit 2 original license. Because aging management programs apply to both units, RIV anticipates that the Phase 2 of IP 71013 inspection for Unit 2 will require fewer resources than the inspection for Unit 1 since fewer programs will remain unreviewed. Region IV will document the inspection for each unit in standalone inspection reports.
The NRC regional inspectors will perform Phase 3 inspections after any issuance of renewed licenses. These inspections will assess licensee actions on commitments implemented during the timely renewal period and follow-up on any additional outstanding activities or commitments.
Depending on the number of inspections needed, RIV will document each Phase 3 inspection in a standalone inspection report.
B. Smith 4
DIABLO CANYON LICENSE RENEWAL INSPECTION STRATEGY DATE JULY 26, 2023 DISTRIBUTION:
CSmith,DORS GPick,DORS NTaylor,DORS FSacko,DORS BSmith, NRR SUNSI Review ADAMS:
Non-Publicly Available x Non-Sensitive Keyword:
By: GAP Yes No Publicly Available
Sensitive OFFICE RIV/DORS/EB2 RIV/DORS/EB2 BC:RIV/DORS/EB2 D:RIV/DORS NAME CSmith GPick FSacko RLantz DATE 07/24/2023 07/24/2023 07/25/2023 07/26/2023 OFFICIAL RECORD COPY