ML110310093

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2011/01/25 Diablo Canyon Lr - Draft Implementation Plan
ML110310093
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 01/25/2011
From:
- No Known Affiliation
To:
Division of License Renewal
References
Download: ML110310093 (23)


Text

DiabloCanyonNPEm Resource From: Sizemore, Brandy [BNSM@pge.com]

Sent: Tuesday, January 25, 2011 3:19 PM To: Pick, Greg Cc: Grebel, Terence; Tan, Miranda; Sharp, Loren

Subject:

Draft Implementation Plan Attachments: DCPP License Renewal Implementation Project Plan 010410.doc

Hello, Attached is the most updated copy of the draft implementation plan. The master notification tracking the plan is 50371663.

Thanks Brandy Sizemore DCPP License Renewal Engineer Phone: (805) 781-9417

<<DCPP License Renewal Implementation Project Plan 010410.doc>>

1

Hearing Identifier: DiabloCanyon_LicenseRenewal_NonPublic Email Number: 2447 Mail Envelope Properties (D776CF09EA15C644831E2FD161423956033BCDAA)

Subject:

Draft Implementation Plan Sent Date: 1/25/2011 3:18:45 PM Received Date: 1/25/2011 3:18:53 PM From: Sizemore, Brandy Created By: BNSM@pge.com Recipients:

"Grebel, Terence" <TLG1@pge.com>

Tracking Status: None "Tan, Miranda" <M1TF@pge.com>

Tracking Status: None "Sharp, Loren" <LDSL@PGE.COM>

Tracking Status: None "Pick, Greg" <Greg.Pick@nrc.gov>

Tracking Status: None Post Office: exchange18.Utility.pge.com Files Size Date & Time MESSAGE 291 1/25/2011 3:18:53 PM DCPP License Renewal Implementation Project Plan 010410.doc 379968 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Diablo Canyon Power Plant Draft Project Plan for License Renewal Implementation Approval:

Date

=

Background===

On November 23, 2009 Pacific Gas and Electric (PG&E) submitted a License Renewal Application (LRA) for Diablo Canyon Power Plant (DCPP). The License Renewal Implementation (LRI) phase refers to the phase prior to the issuance of the renewed license and into the period of extended operation (PEO).

The purpose of this document is to identify activities that are to take place, pursuant to the requirements of 10 CFR 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, upon receipt of a renewed license for DCPP To facilitate knowledge transfer DCPP management has requested that the License Renewal Project staff and plant staff prepare an implementation plan with a target date of December 2011 to the extent possible. This includes preparing and implementing all required procedure and procedure revisions necessary to implement license renewal. Some of these procedures may be issued with an effective date being the period of extended operation.

Management directed that this target goal be implemented such that it does not adversely impact other required plant 2011 activities. The license renewal staff will work with the plant staff to finalize the individual aging management program implementation plans and to determine to what extent the license renewal implementation can be accomplished in 2011. The target schedule for finalizing the implementation plan is March 2011.

Overview of Work Activities The actions associated with LRI will fall into 4 categories:

1. Revise the 10 Element AMPs to reflect the RAIs - May 2011
2. Update PCD to reflect the LRA and RAIs for existing procedures - May 2011
3. Determine the equipment database revisions required to implement LR -

April 2011. This includes developing a schedule for completing equipment database modifications.

4. Perform annual updates in accordance with 10 CFR 54.21(b). February 2011 (If required by NRC PM)
5. Perform annual updates in accordance with 10 CFR 54.37(b).December 2011
6. Update equipment database modifications and issue work orders for LR required activities - December 2011
7. Develop AMP Program Administrative Procedure to determine requirements for each AMP (effectiveness, OE, maintenance of LR Licensing Basis, implementation, hardcopy notebooks and electronic etc.)

- December 2011

8. Perform STARS Peer Assessment of DCPP LR Implementation -October 2011
9. Perform DCPP QA assessment of DCPP LR Implementation -January 2012
10. Revise procedures/10 Element AMPs to reflect the Final SER - December 2011
11. Implement all new/enhanced programs whose implementation is not tied to the PEO-December 2011. See attachment 1 for specific AMPs.
12. Implement new programs tied to the PEO with an effective date of the PEO - See attachment 1 for AMPs.
13. Issue License Renewal Design Basis Package - December 2011
14. Determine if revisions are required to design modification procedures -

December 2011

15. Develop PEO entry schedule including performance of assessments -

December 2011

16. Develop a plan to prepare for NRC inspections associated with entering the PEO. - 2012 A DCM will be developed in order to define the actions, schedule, and personnel responsibilities necessary for LRI.

Development and Performance of Aging Management Programs Aging management programs (AMP), which were developed to meet the requirements of NUREG 1801, must be developed and performed. Aging management activities are to be performed as described in the LRA. AMP activities that are currently performed by the plant will be maintained by utilizing the PCD.

Integration of AMP Activities and Commitment Tracking Commitments were made in the LRA to create new AMPs and modify existing AMPs. These commitments are by a SAP notification. A schedule will be created to determine the appropriate time to complete each AMP activity. AMP activities include developing and implementing new procedures and performing inspections. Work orders will be used to track inspections and inspection activities. shows AMPs and their corresponding implementation action. A schedule for completing each task in Attachment 1 will be created.

Annual Updates in Accordance with 10 CFR 54.37(b) 10 CFR 54.37(b) states:

After the renewed license is issued, the UFSAR update required by 10 CFR 50.71(e) must include any systems, structures, and components newly identified that would have been subject to an aging management review or evaluation of time-limited aging analyses in accordance with § 54.21. This UFSAR update must describe how the effects of aging will be managed such that the intended function(s) in § 54.4(b) will be effectively maintained during the period of extended operation.

COMPLETE the License Renewal UFSAR Update describing how the effects of aging on intended function(s) will be managed during the period of extended operation. The update must include the following:

1. Name and description of the newly identified systems, structures, and components. For systems, the boundary of the system must be described and a list of passive, long-lived components provided.
2. Material of construction
3. Internal and external environments
4. Aging effects for the material/environment combinations
5. Search for any aging-related analyses related to the newly identified SSC and screen against the six TLAA criteria. (Refer to the definition of a TLAA)
6. Aging Management Program(s) (AMPs) that will be used to manage the effects of aging.
a. For existing AMPs, the name of the AMP is adequate.
b. If a new AMP is needed, then a description of the AMP that demonstrates how the effects of aging will be managed must be included.
c. Determine if revision to implementing documents is required or if new implementing documents need to be developed.
d. Update commitment tracking items as necessary CF3.ID9, Design Change Development, will need to be revised to ensure that changes to the plant remain in compliance with license renewal.

Preparation for NRC Inspection Activities The NRC will conduct post-renewal inspections in accordance with IP 71003.

Current industry feedback indicates that there are 3 inspections associated with implementation. The first consists of observations of LR related activities, such as one-time inspections, and will be conducted during one of the last 4 refueling outages prior to entering the PEO. The second is an extensive inspection of completion of renewed license conditions and LR commitments. It occurs a few months prior to entry into the PEO, and after the licensee has notified the NRC that they have completed their commitments. The third inspection is a follow-up inspection after entry into the PEO. Its purpose is primarily to look at commitments that had completion dates after entry into the PEO.

Attachment 1- Aging Management Programs and Corresponding Implementation Activities NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section N/A Plant-Specific Transmission B2.1.40 Create new Procedure, TS1.DC1, "License Renewal Electrical December 2011 Conductor, Connections, Aging Management" (Elements 1, 5, 7)

Insulators and Switchyard Bus and Draft complete; Connections N/A Plant-Specific Transmission B2.1.40 Modify/create work orders to state that there is a regulatory December 2011 Conductor, Connections, requirement Insulators and Switchyard Bus and Connections N/A Plant-Specific Transmission B2.1.40 Enhance program procedures to identify components to support December 2011 50333342 Conductor, Connections, SBO recovery which are in scope of LR, include gathering and Insulators and Switchyard Bus and reviewing completed maintenance and inspection results, and Connections identify an engineering evaluation to conduct when a degraded condition is identified.

X.E1 Environmental Qualification (EQ) B3.2 Complete additional work on EQ files whose qualified life needs TBD of Electrical Components to be extended to 60 years.

X.M1 Metal Fatigue of Reactor Coolant B3.1 The scope of locations monitored by the DCPP Fatigue December 2011 50333282 Pressure Boundary Management Program will be enhanced to include additional locations which are not covered by the current Fatigue Management Program. Additional locations will include the NUREG/CR-6260 locations for the effects of the reactor coolant environment on fatigue. Usage factors in the NUREG/CR-6260 sample locations will include the environmental factors, F(en),

calculated by NUREG/CR-6583 and NUREG/CR-5704 or appropriate alternative methods (Elements 1, 2, and 5).

X.M1 Metal Fatigue of Reactor Coolant B3.1 The scope of transients monitored by the DCPP Fatigue December 2011 50333282 Pressure Boundary Management Program will be enhanced to include additional transients that contribute to fatigue usage, which are not covered by the current Fatigue Management Program. Usage factors in the NUREG/CR-6260 sample locations will include the environmental factors, F(en), calculated by NUREG/CR-6583 and NUREG/CR-5704 or appropriate alternative methods (Elements 1 and 3).

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section X.M1 Metal Fatigue of Reactor Coolant B3.1 The procedures governing the DCPP Fatigue Management December 2011 50333282 Pressure Boundary Program will be enhanced to specify the frequency of periodic reviews of the results of the monitored cycle count and CUF data at least once per fuel cycle. This review will compare the results against the corrective action limits to determine any approach to action limits and any necessary revisions to the fatigue analyses will be included in the corrective actions (Element 4).

X.M1 Metal Fatigue of Reactor Coolant B3.1 The procedures governing the DCPP Fatigue Management December 2011 50333282 Pressure Boundary Program will be enhanced to include additional cycle count and fatigue usage action limits, which will invoke appropriate corrective actions if a component approaches a cycle count action limit or a fatigue usage action limit. Action limits permit completion of corrective actions before the design limits are exceeded (Elements 2 and 6).

Cycle Count Action Limits:

An action limit initiates corrective action when the cycle count for any of the critical thermal or pressure transients is projected to reach the action limit defined in the program before the end of the next fuel cycle. In order to assure sufficient margin to accommodate occurrence of a low probability transient, corrective actions must be initiated before the remaining number of allowable cycles for any specified transient becomes less than one (

Reference:

TLAA Report, Section 3.1.3).

Cumulative Fatigue Usage (CUF) Action Limits:

An action limit requires corrective action when calculated cumulative usage factor (CUF) for any monitored location is projected to reach 1.0 within the next 3 fuel cycles (

Reference:

TLAA Report, Section 3.1.3).

X.M1 Metal Fatigue of Reactor Coolant B3.1 The procedures governing the DCPP Fatigue Management December 2011 50333282 Pressure Boundary Program will be enhanced to include appropriate corrective actions to be invoked if a component approaches a cycle count action limit or a fatigue usage action limit. The corrective action options for a component that has exceeded action limits include a revised fatigue analysis or repair or replacement of the component (Element 7).

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.E1 Electrical Cables and Connections B2.1.24 Implement program as described in B2.1.24 1. Complete initial 50332312 Not Subject to 10 CFR 50.49 identification of Environmental Qualification Hazardous Requirements Localized Areas

- June 2011

2. Issue procedure with an effective date of PEO December 2011 XI.E1 Electrical Cables and Connections B2.1.24 Create new procedure, TS1.DC1, "License Renewal Electrical See abovet Not Subject to 10 CFR 50.49 Aging Management' (Elements 1, 3, 4, 6, and 7)

Environmental Qualification Requirements XI.E1 Electrical Cables and Connections B2.1.24 Perform inspections See above Not Subject to 10 CFR 50.49 Environmental Qualification Requirements XI.E2 Electrical Cables and Connections B2.1.25 Implement program as described in B2.1.25 December 2011 50332314 Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits XI.E2 Electrical Cables and Connections B2.1.25 STP I-39-R44A.B will be enhanced to require an engineering Markup complete. See E-Not Subject to 10 CFR 50.49 evaluation per TS1.DC1 when the calibration or surveillance 2 above.t Environmental Qualification results fail to meet acceptance criteria. (Elements 4, 7)

Requirements Used in Instrumentation Circuits XI.E2 Electrical Cables and Connections B2.1.25 STP I-39-R44B.B will be enhanced to require an engineering Markup complete. See E-Not Subject to 10 CFR 50.49 evaluation per TS1.DC1 when the calibration or surveillance 2 above.

Environmental Qualification results fail to meet acceptance criteria. (Elements 4, 7)

Requirements Used in Instrumentation Circuits

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.E2 Electrical Cables and Connections B2.1.25 STP I-118B2 will be enhanced to require an engineering Markup complete. See E-Not Subject to 10 CFR 50.49 evaluation per TS1.DC1 when the calibration or surveillance 2 above.

Environmental Qualification results fail to meet acceptance criteria. (Elements 4, 7)

Requirements Used in Instrumentation Circuits XI.E2 Electrical Cables and Connections B2.1.25 STP I-119B3 will be enhanced to require an engineering Markup complete. See E-Not Subject to 10 CFR 50.49 evaluation per TS1.DC1 when the calibration or surveillance 2 above.

Environmental Qualification results fail to meet acceptance criteria. (Elements 4, 7)

Requirements Used in Instrumentation Circuits XI.E2 Electrical Cables and Connections B2.1.25 New Procedure, TS1.DC1, "License Renewal Electrical Aging Draft complete.

Not Subject to 10 CFR 50.49 Management" (Elements 1, 3, 4, 6, 7) December 2011 Environmental Qualification Requirements Used in Instrumentation Circuits XI.E2 Electrical Cables and Connections B2.1.25 Create program health report  ?

Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits XI.E2 Electrical Cables and Connections B2.1.25 Create test procedure December 2011 Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits XI.E3 Inaccessible Medium Voltage B2.1.26 Implement program as described in B2.1.26 December 2011 50333088 Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements XI.E3 Inaccessible Medium Voltage B2.1.26 Create TS1.DC1, "License Renewal Electrical Aging Draft complete. See E-3 Cables Not Subject to Management" (Elements 1, 3, 4, 6, 7) above 10 CFR 50.49 Environmental Qualification Requirements

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.E3 Inaccessible Medium Voltage B2.1.26 Modify existing work orders for pullbox inspections to note that December 2011 Cables Not Subject to they are a regulatory requirement 10 CFR 50.49 Environmental Qualification Requirements XI.E3 Inaccessible Medium Voltage B2.1.26 Review actual pullbox inspection frequencies versus Complete?

Cables Not Subject to winter/rainstorm result 10 CFR 50.49 Environmental Qualification Requirements XI.E4 Metal Enclosed Bus B2.1.36 The existing bus work order inspection activities for inspection December 2011 50333175 and testing of the MEBs will be proceduralized to include specific inspection scope, frequencies, actions to be taken when acceptance criteria are not met.

XI.E4 Metal Enclosed Bus B2.1.36 Create TS1.DC1, "License Renewal Electrical Aging Draft complete. See E-4 Management" (Elements 1, 3, 4, 6, 7) above XI.E4 Metal Enclosed Bus B2.1.36 Modify existing work orders for pullbox inspections to note that December 2011 they are a regulatory requirement XI.E5 Fuse Holders B2.1.34 Implement program as described in B2.1.34 Issue procedure by 50332313 December 2011with an implementation date of PEO.

XI.E5 Fuse Holders B2.1.34 Prior to AMP audit, create new Procedure, TS1.DC1, "License Draft complete. See E-5 Renewal Electrical Aging Management" (Elements 1, 3, 4, 6, 7) above.

XI.E5 Fuse Holders B2.1.34 Need work orders which state that there is a regulatory Issue work order revisions requirement December 2011 XI.E6 Electrical Cable Connections Not B2.1.35 Implement program as described in B2.1.35 Prior to PEO. WE NEED 50332314 Subject to 10 CFR 50.49 MORE DETAIL ON WHAT Environmental Qualification IS REQUIRED SO THAT Requirements WE CAN DETERMINE THE ACTION PLAN XI.E6 Electrical Cable Connections Not B2.1.35 Create new Procedure, TS1.DC1, "License Renewal Electrical Draft complete. See E-6 Subject to 10 CFR 50.49 Aging Management" (Elements 1, 3, 4, 6, 7) above Environmental Qualification Requirements

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.E6 Electrical Cable Connections Not B2.1.35 Need a basis document for sample selection December 2011 Subject to 10 CFR 50.49 Environmental Qualification Requirements XI.M12 Thermal Aging Embrittlement of B2.1.39 Implement a program as described in B2.1.39 Issue procedure 50332315 Cast Austenitic Stainless Steel December 2011 with an (CASS) effective date of 2014 ( 10 years prior to PEO)

XI.M12 Thermal Aging Embrittlement of B2.1.39 Finalize basis document for determining the potentially December 2011 Cast Austenitic Stainless Steel susceptible locations (Complete but not accepted by plant yet)

(CASS)

XI.M12 Thermal Aging Embrittlement of B2.1.39 Create implementation procedure December 2011 Cast Austenitic Stainless Steel (CASS)

XI.M12 Thermal Aging Embrittlement of B2.1.39 Perform inspections See M12 above.

Cast Austenitic Stainless Steel (CASS)

XI.M12 Thermal Aging Embrittlement of B2.1.39 Participate in the EPRI working group on CASS (C. Beard) On-going Cast Austenitic Stainless Steel (CASS)

XI.M12 Thermal Aging Embrittlement of B2.1.39 Create program health report  ?

Cast Austenitic Stainless Steel (CASS)

XI.M21 Closed-Cycle Cooling Water B2.1.10 Periodic internal inspections of the CCW supply isolation check Implement procedure 50333808 System valves to the reactor coolant pumps (valves CCW-1-585 and December 2011 with an CCW-2-585) will provide a leading indicator of the condition of effective date of PEO the interior of piping components otherwise inaccessible for visual inspection. This periodic internal inspection will detect loss of material and fouling and are scheduled to be performed at least once every 5 years.

XI.M21 Closed-Cycle Cooling Water B2.1.10 Plant procedures will be enhanced to include the acceptance December 2011 System criteria.

XI.M21 Closed-Cycle Cooling Water B2.1.10 Evaluate current plans to open the valves that will be inspected. December 2011 System XI.M21 Closed-Cycle Cooling Water B2.1.10 Create work orders to perform inspections. The commitment December 2011 System needs to be in the work order

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.M21 Closed-Cycle Cooling Water B2.1.10 Revise procedures to monitor the corrosion of closed cooling Issue procedure revisions 50321512/2 System water components by inspecting the condition of corrosion by December 2011 with coupons installed in the system and perform internal inspections an effective date of PEO of select components within the systems.

XI.M26 Fire Protection B2.1.12 Procedure STP M-70C (or a general fire protection program Revise procedures by 50332107 plan) will be enhanced to include inspection of all fire rated doors December 2011 with an listed in Appendix 9.5A, the DCPP Fire Hazards Analysis. effective date of PEO (Elements 1 & 3)

XI.M26 Fire Protection B2.1.12 Develop action plan to identify fire doors to include inspection of December 2011 50332107 all fire rated doors listed in Appendix 9.5A, the DCPP Fire Hazards Analysis that are not included in the procedure.

XI.M26 Fire Protection B2.1.12 Procedure STP M-70B (or a general fire protection program plan) December 2011 will be enhanced to include qualification criteria for individuals performing inspections of fire dampers in accordance with NUREG-1801. (Element 4)

XI.M26 Fire Protection B2.1.12 Procedure STP M-70C (or a general fire protection program December 2011 plan) will be enhanced to include qualification criteria for individuals performing inspections of fire doors in accordance with NUREG-1801. (Element 4)

XI.M27 Fire Water System B2.1.13 1) The Fire Protection Program will be enhanced so sprinkler Revise procedures by heads in service for 50 years will be replaced or representative December 2011 with an samples from one or more sample areas will be tested consistent effective date of the PEO.

with guidance of NFPA 25, "Inspection, Testing and Maintenance of Water-Based Fire Protection Systems." Test procedures will be repeated at 10-year intervals during the period of extended operation, for sprinkler heads that were not replaced, prior to being in service for 50 years, to ensure that signs of degradation, such as corrosion, are detected prior to the loss of intended function. (Element 4) Note: That the 50 year period begins at the date of installation/replacement.

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.M27 Fire Water System B2.1.13 Procedures will be enhanced for either periodic, non-intrusive Revise procedures by volumetric examinations or visual inspections on fire water December 2011 with an piping, in accordance with NUREG-1801. Non-intrusive effective date of the PEO volumetric examinations would detect any loss of material due to corrosion, to ensure that aging effects are managed, wall thickness is within acceptable limits and degradation will be detected before the loss of intended function. Visual inspections would evaluate (1) wall thickness as it applies to avoidance of catastrophic failure, and (2) the inner diameter of the piping as it applies to the design flow of the Fire Protection System. The volumetric examination technique employed will be one that is generally accepted in the industry, such as ultrasonic or eddy current. See Open Item 1. (Element 4)

XI.M27 Fire Water System B2.1.13 Procedure STP M-71 will be enhanced to state trending December 2011 requirements. (Element 5)

XI.M27 Fire Water System B2.1.13 Update the PM basis documents for STR-97 and STR-98 to state December 2011 50342432/2 that there is a license renewal commitment to inspect the strainers on a 24 month frequency XI.M30 Fuel Oil Chemistry B2.1.14 Revise STP M-91A, the Diesel Fuel Oil Storage Tank 10 Year Revise procedure by Drain, Clean, and Internal Inspection procedure, to include the December 2011 with an periodic draining, cleaning, and visual inspection of the diesel effective date of the PEO.

generator day tanks, portable diesel driven fire pump fuel oil tanks, and portable caddy fuel oil tanks.

XI.M30 Fuel Oil Chemistry B2.1.14 Revise STP P-24 to include sampling of the new fuel oil prior to Issue procedure by introduction into the portable diesel driven fire pump tanks and December 2011 with an portable caddy fuel oil tanks. effective date of the PEO.

XI.M30 Fuel Oil Chemistry B2.1.14 Revise STP M-91A, the Diesel Fuel Oil Storage Tank 10 Year Issue procedure by Drain, Clean, and Internal Inspection procedure, to provide for December 2011 with an supplemental ultrasonic thickness measurements if there are effective date of the PEO.

indications of reduced cross sectional thickness found during the visual inspection of the diesel fuel oil storage tanks, diesel generator day tanks, portable diesel driven fire pump fuel oil tanks, and portable caddy fuel oil tanks.

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.M30 Fuel Oil Chemistry B2.1.14 Revise STP M-10B, the Diesel Fuel Oil Testing procedure for the December 2011 diesel fuel oil storage tanks and diesel generator day tanks to state that trending of water and particulate levels is controlled in accordance with DCPP Technical Specifications and plant procedures.

XI.M30 Fuel Oil Chemistry B2.1.14 Revise STP P-24 and CAP A-9 to include monitoring and December 2011 trending of water and sediment levels of new fuel oil for the portable diesel driven fire pump fuel oil tanks and portable caddy fuel oil tanks.

XI.M30 Fuel Oil Chemistry B2.1.14 Revise STP P-24 to state acceptance criteria for new fuel oil Revise procedure by being introduced into the portable diesel driven fire pump fuel oil December 2011. Add tanks or portable caddy fuel oil tanks. inspection port prior to the

7) Add the inspection port PEO.

XI.M30 Fuel Oil Chemistry B2.1.14 Revise program commitment, Provide for one-time supplemental Issue procedure and ultrasonic thickness measurements of accessible portions of fuel associated work orders by oil tank bottoms. December 2011 with an effective date of the PEO.

XI.M32 One-Time Inspection B2.1.16 Finalize basis document for determining the sample size and June 2011 locations prior to NRC AMP audit XI.M32 One-Time Inspection B2.1.16 During the 10 years prior to PEO, implement program as Issue procedure by 50332273 described in LRA Section B2.1.16 December 2011 with an effective date of 2014.

XI.M32 One-Time Inspection B2.1.16 Need to determine actual inspection locations. December 2011 XI.M32 One-Time Inspection B2.1.16 Create implementation procedure Draft complete. Issue procedure December 2011 XI.M32 One-Time Inspection B2.1.16 Perform one time inspections During the 10 years prior to PEO.

XI.M32 One-Time Inspection B2.1.16 Create program health report  ?

XI.M32 One-Time Inspection B2.1.16 A one time UT examination of the firewater tank bottom will Issue procedure and work be performed as part of the One-Time Inspection aging orders by December 2011 management program, LRA Section B2.1.16. with an effective date of 2014.

XI.M32 One-Time Inspection B2.1.16 DCPP will perform 100 percent eddy current testing of one non- 2014 - 2024 50343158/2 regenerative heat exchanger XI.M34 Buried Piping and Tanks B2.1.18 During the 10 years prior to PEO, implement a program as December 2011 50332277 Inspection described in LRA section B2.1.18

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.M34 Buried Piping and Tanks B2.1.18 Develop action plan for EPRI Buried Piping Complete Inspection XI.M34 Buried Piping and Tanks B2.1.18 Create implementation procedure Complete Inspection XI.M34 Buried Piping and Tanks B2.1.18 Perform inspections during 10 years prior to PEO 2014-2024 Inspection XI.M34 Buried Piping and Tanks B2.1.18 Create program health report  ?

Inspection XI.M35 One-Time Inspection of ASME B2.1.19 Determine appropriate sample size DCL-10-146 - complete 50340356/1 Code Class 1 Small-Bore Piping XI.M35 One-Time Inspection of ASME B2.1.19 Determine inspection locations December 2011 and issue Code Class 1 Small-Bore Piping work orders with an effective date of 2024?

XI.M35 One-Time Inspection of ASME B2.1.19 DCPP will volumetrically examine 10%, with a maximum of 25, of During 6 years prior to 50340356/1 Code Class 1 Small-Bore Piping the small bore socket welds and 10%, with a maximum of 25, of PEO the butt welds within the population of ASME Class-1 piping NPS less than 4-inches on each unit. Currently, DCPP has 696 socket welds in Unit 1, 841 socket welds in Unit 2, 134 butt welds in Unit 1, and 133 butt welds in Unit 2. Based on the current weld count, this would result in the examination of 25 socket welds for Unit 1, 25 socket welds for Unit 2, 13 butt welds for Unit 1 and 13 butt welds for Unit 2. DCPP may perform opportunistic destructive examination of welds in lieu of volumetric examination with 1 destructive examination being equivalent to 2 volumetric examinations.

XI.M35 One-Time Inspection of ASME B2.1.19 Schedule and perform inspections Schedule inspections by Code Class 1 Small-Bore Piping December 2011.

XI.M36 External Surfaces Monitoring B2.1.20 During the 10 years prior to PEO, implement as described in December 2011 50332220 Program B2.1.20 XI.M36 External Surfaces Monitoring B2.1.20 Create implementation procedure (Draft is created, need to December 2011. Draft Program determine when to implement) complete XI.M36 External Surfaces Monitoring B2.1.20 Generate AMR table that shows where this AMP is credited (R. December 2011 Program Davis)

XI.M36 External Surfaces Monitoring B2.1.20 Develop and implement training for system engineers December 2011 50335453 Program

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.M36 External Surfaces Monitoring B2.1.20 Perform inspections December 2011 Program XI.M36 External Surfaces Monitoring B2.1.20 The DCPP external surfaces monitoring program will be Prior to PEO Program revised to include visual inspections of the ASW system to inspect for cracking and leakage of the titanium tubing components in scope for license renewal at intervals no longer than once per refueling cycle.

XI.M38 Inspection of Internal Surfaces in B2.1.22 Implement a program as described in B2.1.22 Issue procedure 50332278 Miscellaneous Piping and Ducting December 2011 with an Components effective date of 2024.

XI.M38 Inspection of Internal Surfaces in B2.1.22 Create basis document for sample locations . December 2011. Draft Miscellaneous Piping and Ducting complete Components XI.M38 Inspection of Internal Surfaces in B2.1.22 Create implementation procedure December 2011. Draft Miscellaneous Piping and Ducting complete Components XI.M38 Inspection of Internal Surfaces in B2.1.22 Perform inspections 2024-2044 Miscellaneous Piping and Ducting Components XI.M38 Inspection of Internal Surfaces in B2.1.22 Create program health report  ?

Miscellaneous Piping and Ducting Components XI.M39 Lubricating Oil Analysis B2.1.23 New Procedure MA1.DC53, Lubricating Oil Analysis will be December 2011. Draft 50333087 developed to govern the Lubricating Oil Analysis program complete testing, evaluation, and disposition for in-scope equipment.

(Element 1)

XI.M39 Lubricating Oil Analysis B2.1.23 DCPP will include guidance for oil sampling for chemical and December 2011. Draft 50333087 physical properties in new procedure MA1.DC53. (Element 2) complete XI.M39 Lubricating Oil Analysis B2.1.23 DCPP will include standard analyses that will be performed on December 2011. Draft 50333087 oils in new procedure MA1.DC53. (Element 3) complete

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.M39 Lubricating Oil Analysis B2.1.23 DCPP acceptance criteria for each of the lubricating oils December 2011. Draft 50333087 commonly used on-site, including the oils associated with each complete of the equipments within the scope of the Lubrication Analysis Program (see Element 1) will be included new procedure MA1.DC53, with provision for future adjustment in acceptance criteria. DCPP acceptance criteria for lubricating oil analysis will be derived from Original Equipment Manufacturer (OEM) Vendor Manuals, industry guidance, and qualified offsite laboratories.

(Elements 4 and 6)

XI.M39 Lubricating Oil Analysis B2.1.23 DCPP will include trending in new procedure MA1.DC53. December 2011. Draft 50333087 (Element 5) complete XI.M39 Lubricating Oil Analysis B2.1.23 Procedure will be enhanced to state actions to address December 2011. Draft 50333087 conditions where action limits are reached or exceeded. complete (Element 7)

XI.M39 Lubricating Oil Analysis B2.1.23 Create a program health report  ?

XI.S1 ASME Section XI, Subsection IWE B2.1.27 Include in Commitment Tracking May 2011 XI.S1 ASME Section XI, Subsection IWE B2.1.27 The Unit 2 gap repair work will be completed prior to the period 2024 50323785 of extended operation.

XI.S2 ASME Section XI, Subsection IWL B2.1.28 Include in Commitment Tracking. May 2011 XI.S2 ASME Section XI, Subsection IWL B2.1.28 DCPP procedures will be revised to perform concrete inspections June 2011 50323785 per ASME Section XI Subsection IWL within a 5 year interval.

XI.S2 ASME Section XI, Subsection IWL B2.1.28 Calculation No. 2305C will be revised by November 1, 2010 to Complete be consistent with the latest revision of Procedure NDE VT 3C-1.

XI.S2 ASME Section XI, Subsection IWL B2.1.28 Calculation No. 2305C acceptance criteria will be consistent with Complete the latest revision of Procedure NDE VT 3C-1. Any long term planning and decisions on potential repair will be made on a case by case basis and based on review of trends in the inspection findings and will be implemented via DCPP corrective action program.

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.S2 ASME Section XI, Subsection IWL B2.1.28 Procedure NDE VT 3C-1 and Calculation No. 2305C acceptance Complete criteria will be revised to be consistent with ACI 349.3R Chapter 5 detailed quantitative acceptance criteria with the exception that the First Tier, the allowable crack width of 0.015 (per ACI 349.3, Section 5.1) is increased to 0.025 for areas not around penetrations and embedments.

XI.S6 Structures Monitoring Program B2.1.32 Include in Commitment Tracking. May 2011 XI.S6 Structures Monitoring Program B2.1.32 DCPP work control procedures will be revised to include June 2011 50323785 evaluation of reinforced concrete exposed during excavations.

XI.S6 Structures Monitoring Program B2.1.32 Prior to the period of extended operation, the acceptance criteria June 2011 for concrete structural elements provided in the implementing procedures for the Structures Monitoring Program for safety-related structures will be revised to incorporate the quantitative evaluation criteria provided in ACI 349.3R, Evaluation of Existing Nuclear Safety Related Concrete Structures, Chapter 5, Evaluation Criteria.

XI.S6 Structures Monitoring Program B2.1.32 The Structures Monitoring Program inspection interval will be June 2011 revised to be aligned with the guidance in ACI 349.3R, Evaluation of Existing Nuclear Safety Related Concrete Structures, Chapter 6, Evaluation Frequency, except for the exterior of non-safety related structures, for which all accessible areas of both units will be inspected at an interval of no more than ten years.

XI.S6 Structures Monitoring Program B2.1.32 A one-time video inspection of the Unit 2 leak chase will be Issue work order performed during the period of extended operation December 2011. Perform inspection 2024-2044 XI.S6 Structures Monitoring Program B2.1.32 Revise the work control procedure to require that whenever an June 2011 50324705 in-scope pullbox is opened that the Structural Monitoring AMP personnel are notified to allow them to determine if an opportunistic inspection should be performed.

XI.S7 RG 1.127, Inspection of Water- B2.1.33 Include in Commitment Tracking. May 2011 Control Structures Associated with Nuclear Power Plants XI.S7 RG 1.127, Inspection of Water- B2.1.33 Program will be enhanced to commit to a 5 year inspection June 2011 Control Structures Associated with frequency for all structures captured in this program for the Nuclear Power Plants period of extended operation

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section N/A Plant-Specific Nickel-Alloy Aging B2.1.37 Include in Commitment Tracking. May 2011 Management Program N/A Reactor Coolant System Include in Commitment Tracking. May 2011 Supplement XI.M1 ASME Section XI Inservice B2.1.1 Include in Commitment Tracking. May 2011 Inspection, Subsections IWB, IWC, and IWD XI.M10 Boric Acid Corrosion B2.1.4 Include in Commitment Tracking. May 2011 XI.M11A Nickel-Alloy Penetration Nozzles B2.1.5 Include in Commitment Tracking. May 2011 Welded To The Upper Reactor Vessel Closure Heads of Pressurized Water Reactors XI.M17 Flow-Accelerated Corrosion B2.1.6 Include in Commitment Tracking. May 2011 XI.M18 Bolting Integrity B2.1.7 Include in Commitment Tracking. May 2011 XI.M19 Steam Generator Tube Integrity B2.1.8 Include in Commitment Tracking. May 2011 XI.M2 Water Chemistry B2.1.2 Include in Commitment Tracking. May 2011 XI.M20 Open-Cycle Cooling Water System B2.1.9 Include in Commitment Tracking. May 2011 XI.M23 Inspection of Overhead Heavy B2.1.11 Revise plant procedures to specify that visual inspection for December 2011 50329611/2 Load and Light Load (Related to corrosion of structural members of the containment dome service Refueling) Handling Systems crane and special service hoists, jib cranes, and monorails XI.M3 Reactor Head Closure Studs B2.1.3 Include in Commitment Tracking. May 2011 XI.M31 Reactor Vessel Surveillance B2.1.15 Include in Commitment Tracking. May 2011 XI.M33 Selective Leaching of Materials B2.1.17 During the 10 years prior to PEO, implement program a 2014-2024 50332275 described in B2.1.17 XI.M37 Flux Thimble Tube Inspection B2.1.21 Revise the test procedure acceptance criteria to specifically April 2011 50329603 preclude repositioning a tube more than once without capping or replacing. This will include repositioning a tube having chrome plated surfaces from the chrome being moved out of the areas of known wear.

XI.S1 ASME Section XI, Subsection IWE B2.1.27 Include in Commitment Tracking. May 2011 XI.S3 ASME Section XI, Subsection IWF B2.1.29 Include in Commitment Tracking. May 2011

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.S4 10 CFR Part 50, Appendix J B2.1.30 Include in Commitment Tracking. May 2011 XI.S5 Masonry Wall Program B2.1.31 Include in Commitment Tracking. May 2011 Pressurized Thermal Shock A3.1.2 At least 3 years prior to exceeding the PTS screening criterion of Determine action plan 50333287 10 CFR 50.61, PG&E will implement the revised PTS rule (10 December 2011 CFR 50.61a)

Pressure-Temperature Limits A3.1.4 Prior to operation beyond 23 EFPY, DCPP will re-evaluate the Determine action plan 50334705 RCS pressure-temperature limits and COMS setpoints as necessary to comply with 10 CFR 50 Appendix G.

Effects of the RCS Environment on A3.2.3 DCPP will repair or replace the hot leg surge nozzle, or augment Determine action plan 50333220 Fatigue Life of Piping Components the ISI program to require ASME Section XI volumetric December 2011 (GSI 190) examination at regular intervals TLAA 4.3 The actual plant transient cycles related to the SWOL and January 31, 2011 Model 93A Reactor Coolant Pumps fatigue crack growth analyses will be included in the existing plant transient monitoring program by January 31, 2011 to ensure that the actual plant transients do not exceed the L fatigue analysis limits.

3.1.2.1. Aluminum tape currently installed on the seems of the Unit 1 Complete 2 RMI insulation panels of the pressurizer loop seals is currently scheduled to be removed during the Unit 1 sixteenth refueling outage (12R16) outage, October 2010.

2.3.3.5 Procedures will be enhanced to provide specific valves that March 1, 2011 50347309 need to be repositioned to provide Class I makeup to the spent fuel pool including the correct position of any normally open code break valves. Reference PG&E Letter DCL 133

NUREG- NUREG-1801 PROGRAM LRA Implementation Action(s) Implementation Tracking 1801 Section Schedule SAPN/ Task Section XI.S6 Structures Monitoring Program B2.1.32 Enhance the Structures Monitoring program procedures 01/01/12 50340501 to:

Monitor groundwater samples every five years for pH, sulfates and chloride concentrations, including consideration for potential seasonal variations, and Specify inspections of bar racks and associated structural components in the intake structure.

Inspect the administration building, the elevated walkway connecting the turbine building to the administration building, and the structural members that support the walkway.