DCL-13-058, Annual Commitment Change Summary Report

Annual Commitment Change Summary Report

ML13151A109
Person / Time
Site:	Diablo Canyon
Issue date:	05/30/2013
From:	Allen B Pacific Gas & Electric Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
DCL-13-058
Download: ML13151A109 (6)

Text

Pacific Gas and Electric Company M a y 30, 2 01 3 PG&E Letter DCL-13-058 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 2012 Annual Commitment Change Summary Report Dear Commissioners and Staff: Barry S. Allen Site Vice President Diablo Canyon Power Plant Mail Code 104/6 P. O. Box 56 Avila Beach, CA 93424 805.545.4888 Internal: 691.4888 Fax: 805.545.6445 In accordance with Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes," Revision 0, endorsed by the U.S. Nuclear Regulatory Commission (NRC) in SECY-00-0045, "Acceptance Of NEI 99-04, 'Guidelines for Managing NRC Commitments,'" Pacific Gas and Electric Company (PG&E) is submitting the enclosed summary of regulatory commitment changes report for Diablo Canyon Power Plant, Units 1 and 2. The report provides a summary of the regulatory commitment changes that were considered by NEI 99-04 to require notification and occurred during the period January 1, 2012, through December 31 , 2012. The summary for each change identifies the source document(s), describes the original and revised commitments, and justifies the change. I n cases where the Original Commitment and the Revised Commitment are both listed, the relevant changes are marked in bold text. PG&E processed the regulatory commitment changes described in the report in accordance with the NEI guideline, and determined that they did not require prior NRC approval.

The report does not include commitment changes that are contained in 10 CFR 50.59 evaluation summary reports, or in other submittals previously transmitted to the NRC. PG&E makes no regulatory commitments (as defined by NEI 99-04) in this letter. If you have any questions or require additional information, please contact Steven Zawalick at (805) 545-4040.

Sincerely, 5, ;ftt--Barry S.(Alien A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway.

Comanche Peak. Diablo Canyon

• Palo Verde. San Onofre. South Texas Project. Wolf Creek Document Control Desk May 30,2013 Page 2 ssz/640 18345 Enclosure PG&E Letter DCL-13-058 cc/enc: Thomas R. Hipschman, NRC Senior Resident Inspector Arthur T. Howell, III, NRC Region IV James T. Polickoski, NRR Project Manager A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway.

Comanche Peak. Diablo Canyon

• Palo Verde. San Onofre. South Texas Project. Wolf Creek PG&E Letter DCL-13-058 Enclosure

SUMMARY

OF REGULATORY COMMITMENT CHANGES JANUARY 1, 2012, THROUGH DECEMBER 31, 2012 CONTENTS Item Commitment Subject 1.0 Steam Generator Tube Integrity Commitments T19173, T19174, T19175, T19176 2.0 Timeliness of Corrective Actions on Quality Problems 3.0 Non-Destructive Examination of Lifting Rig PG&E letter DCl-13-058 Enclosure 1.0 Steam Generator Tube Integrity Commitments T19173, T19174, T19175, T19176 Source Document(s)

PG&E letter DCl 85-215 NRC Generic letter 85-02 Original Commitment Various commitments in PG&E's response to NRC Generic letter 85-02, Steam Generator (SG) Tube Integrity:

T19173: Visual inspection of the SG Tube Sheet secondary side. T19174: Housekeeping and Foreign Material Exclusion T19175: Water Chemistry T19176: Condenser Inspection Program Revised Commitment None; they have been deleted. Justification for Change These four commitments are the remaining active Diablo Canyon Power Plant (DCPP) Procedure Commitment Database (PCD) commitments from PG&E letter DCl 85-215, the PG&E response to Generic letter 85-02. All other PCD commitments from DCl 85-215 have been previously deleted for various reasons, including SG replacement.

These remaining commitments may be deleted because the program for SG tube integrity is now described in the DCPP Technical Specification (TS) Surveillance Requirement (SR) 3.4.17 and DCPP TS 5.5.9, as implemented in PG&E adoption of TS Task Force (TSTF) 449. The NRC issued License Amendment 194/195 in a letter to PG&E dated March 21, 2007 (License Amendment Request 06-04). These new TSs are performance-based and are programmatically consistent with the industry's NEI 97-06 SG program initiative.

The TS Bases for SR 3.4.17.1 state that NEI 97-06 and its referenced EPRI guidelines establish the content of the SG program. The following six EPRI guidelines describe acceptable methods for SG Programs and are referenced in NEI 97-06: "PWR Steam Generator Examination Guidelines," "PWR Primary-to-Secondary leak Guidelines," "PWR Secondary Water Chemistry Guidelines," "PWR Primary Water Chemistry Guidelines," "Steam Generator Integrity Assessment Guidelines," and "Steam Generator In Situ Pressure Test Guidelines." Per NEI 03-08, "Guideline for the Management of Materials Issues," and DCPP Inter-Departmental Administrative Procedure (IDAP) TS1.ID1 0, "Reactor Coolant System Materials Degradation Management Program," PG&E must adhere to the requirements of these EPRI guidelines, or justify exceptions by developing technical justifications.

In conclusion, after adoption of TSTF-449 into the TS, prior PG&E commitments made in DCl 85-215 related to maintenance of SG tube integrity are considered superseded by the requirements in the EPRI guidelines referenced above.

2.0 Timeliness of Corrective Actions on Quality Problems Source Document(s)

PG&E letter DCl 87-136 PG&E letter DCl 89-006 Original Commitment PG&E letter DCl-13-058 Enclosure To improve timeliness of corrective actions on quality problems, an action plan was written. The action plan requires:

-Quality Evaluation coordinators (Corrective Action Program (CAP) Coordinator) to be established in each department

-improved communication between Quality Control and departmental coordinators

-re-evaluation of the present priority system -procedure revisions to streamline and clarify the problem reporting program Revised Commitment To improve timeliness of corrective actions for quality problems, an action plan was written. The action plan requires:

-re-evaluation of the present priority system -procedure revisions to streamline and clarify the problem-reporting program Justification for Change This commitment was made to address a Notice of Violation documented in NRC Inspection Report 50-275/88-15 and 50-323/88-14, issued on September 6,1988. The timeliness of the corrective actions is being monitored by each line organization independently of the CAP Coordinators

[currently, Performance Improvement Coordinators (PICOs)].

Specifically, each line organization can monitor the status of the pertinent corrective actions via different tools, such as the CAP Index report, Plant Performance Improvement Reports, or CAP searches (ZDCITEMS), regardless of whether or not a PICO is assigned to that line organization.

A portion of DCPP Commitment T36490, "Corrective Action Program Expectations," which is implemented via PG&E IDAP OM7.ID1, "Problem Identification and Resolution," calls for the clarification of the PICOs' roles and responsibilities.

Therefore, T36490 incorporates the intent of those portions of T31401 that should be deleted.

3.0 Non-Destructive Examination of Lifting Rig Source Document( s) PG&E letter DCl 83-509 PG&E letter DCl 83-729 NUREG 0612, "Control of Heavy loads at Nuclear Power Plants" PG&E letter DCl 058 Enclosure ANSI N14.6 -1978, "Special Lifting Devices for Shipping Containers Weighing 10000 Pounds (4500 Kg) or More for Nuclear Materials" ASME N45.2.15 -1981, "Quality Assurance Program Requirements for Nuclear Power Plants" Original Commitment The major load-bearing welds and critical areas shall be non-destructively examined when the (reactor pressure vessel head and internals) lift (rigs) are repainted every ten years. This examination may be in accordance with Westinghouse specifications used in the original examination, in accordance with ANSI N14.6 -1978, Section 5.5, or ANSI N45.2.15-1981, Section 6.2. Revised Commitment The major load-bearing welds and critical areas (reactor pressure vessel head and internals lift rigs) shall be non-destructively examined every ten years. This examination may be in accordance with Westinghouse specifications used in the original examination, in accordance with ANSI N14.6 -1978, Section 5.5, or ANSI N45.2.15-1981, Section 6.2. Areas where coating repair are deemed necessary as the result of any observed damage and/or degradation of coating shall be repaired.

Justification for Change PG&E made the original commitment as part of the implementation of an alternate program for continued testing and maintenance of the special lifting devices (Le. SlD1 and SlD2) for the reactor internals.

The commitment was to satisfy the intent of the NUREG-0612 and ANSI N14.6-1978 requirements, yet would not subject the lifting devices to unnecessarily conservative annual testing requirements, namely, load test to 150 percent of maximum design load or to dimensional testing, visual inspection, and non-destructive testing of load carrying welds. This commitment change was to clarify that the ten-year interval requirement applied to the non-destructive examination only and not the coating or painting.

CAP Notification 50477942 Task 1 clarifies the intent of the commitment for repainting.