DCL-02-001, License Amendment Request 02-01, Revision to Technical Specification SR 3.0.3, Missed Surveillances
| ML020420306 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/10/2002 |
| From: | Rueger G Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| DCL-02-001 | |
| Download: ML020420306 (14) | |
Text
Pacific Gas and Electric Company.
Gregory M. Rueger US Mail Senior Vice President- Mail Code B32 Generation and Pacific Gas and Electric Company Chief Nuclear Officer PO Box 770000 January 10, 2002 San Francisco, CA 94177-0001 Overnight Mail.
Mail Code B32 PG&E Letter DCL-02-001 Pacific Gas and Electric Company 77 Beale Street, 32nd Floor San Francisco, CA 94105-1814 U.S. Nuclear Regulatory Commission 4159734684 ATTN: Document Control Desk Fax: 415.973.2313 Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units I and 2 License Amendment Request 02-01 Revision to Technical Specification SR 3.0.3, Missed Surveillances
Dear Commissioners and Staff:
In accordance with 10 CFR 50.90, enclosed is an application for amendment to Facility Operating License Nos. DPR-80 and DPR-82 for Units I and 2 of the Diablo Canyon Power Plant respectively. This license amendment request (LAR) would modify the Technical Specifications (TS) requirements for missed surveillances in surveillance requirement SR 3.0.3, as well as modify the associated TS Bases. The changes are consistent with Nuclear Regulatory Commission approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification change TSTF-358, Revision 6. The availability of this TS improvement was published in the Federal Register on September 28, 2001 (Federal Register Notice 66 FR 49714), as part of the consolidated line item improvement process.
Pacific Gas and Electric Company (PG&E) is submitting this license amendment application in conjunction with an industry consortium of six plants as a result of a mutual agreement known as Strategic Teaming and Resource Sharing (STARS).
The STARS group consists of the six plants operated by PG&E, TXU Electric, Union Electric Company, Wolf Creek Nuclear Operating Corporation, STP Nuclear Operating Company, and Arizona Public Service Company. The other members of the above group can be expected to submit LARs similar to this one, with the exception of STP Nuclear Operating Company due to the vintage of their TS. They will be adopting a TS Bases Control Program.
Enclosure 1 provides a description and assessment of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS pages marked up to show the proposed change.
Enclosure 3 provides revised (clean) TS pages. Enclosure 4 provides the existing TS Bases pages marked up to show the proposed change. Final TS Bases changes will be implemented pursuant to TS 5.5.14, Technical Specifications Bases Control Program. Enclosure 4 is provided for information only; however, PG&E will adopt these TS Bases changes upon implementation of the license amendment.
H-D
Document Control Desk PG&E Letter DCL-02-001 January 10, 2002 Page 2 The changes in this LAR are not required to address an immediate safety concern.
PG&E requests that the NRC staff review this LAR on a medium priority, and requests the LAR be made effective upon NRC issuance, to be implemented within 30 days from the date of issuance.
Sincerely, Gregoy M. Rueger Senior Vice President - Generation and Chief Nuclear Officer cc: Edgar Bailey, DHS Ellis W. Merschoff David L. Proulx Girija S. Shukla Diablo Distribution Enclosures
PG&E letter DCL-02-001 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
) Docket No. 50-275 In the Matter of ) Facility Operating License PACIFIC GAS AND ELECTRIC COMPANY ) No. DPR-80
)
Diablo Canyon Power Plant ) Docket No. 50-323 Units 1 and 2 ) Facility Operating License No. DPR-82 AFFIDAVIT Gregory M. Rueger, of lawful age, first being duly sworn upon oath says that he is Senior Vice President - Generation and Chief Nuclear Officer of Pacific Gas and Electric Company; that he has executed license amendment request 02-01 on behalf of said company with full power and authority to do so; that he is familiar with the content thereof; and that the facts stated therein are true and correct to the best of his knowledge, information, and belief.
Gregor M.R er Seniortice President - Generation and Chief Nuclear Officer Subscribed and sworn to before me this 10th day of January, 2002.
Adcznký CHUCK MACKEY r4;;ýCommission # 1204640 SQ Sz San LudsPubBC NotrY OWPmo County. I
- Car0oml County of San Luis Obispk State of California
Enclosure 1 PG&E Letter DCL-02-001 DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
The proposed amendment would modify Technical Specifications (TS) requirements for missed surveillances in Surveillance Requirement (SR) 3.0.3.
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification (STS) change TSTF-358, Revision 6. TSTF-358, Revision 6, incorporates the modifications made to TSTF-358, Revision 5, by Federal Register Notice 66 FR 32400 of June 14, 2001, and in response to public comments. The availability of this TS improvement was published in the Federal Register on September 28, 2001 (Federal Register Notice 66 FR 49714), as part of the consolidated line item improvement process (CLIIP).
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Pacific Gas and Electric Company (PG&E) has reviewed the proposed safety evaluation dated June 14, 2001, as modified in response to the comments noticed on September 28, 2001, as part of the CLIIP. This review included a review of the NRC staffs evaluation, as well as the information provided to support TSTF-358. PG&E has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Diablo Canyon Power Plant (DCPP) and justify this amendment for the incorporation of the changes to the DCPP TS.
2.2 Optional Changes and Variations PG&E is not proposing any variations or deviations from the TS changes described in TSTF-358, Revision 6, or the NRC staffs model safety evaluation dated June 14, 2001, as modified in response to the comments noticed on September 28, 2001.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination PG&E has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the FederalRegister as part of the CLIIP.
The modifications to TSTF-358 and the proposed safety evaluation noticed on
Enclosure 1 PG&E Letter DCL-02-001 September 28, 2001, as part of the CLIIP, do not affect the NSHCD published in the Federal Register Notice of June 14, 2001. PG&E has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to DCPP and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on September 28, 2001, for this TS improvement, plant-specific verifications were performed as described below.
PG&E has established TS Bases for SR 3.0.3 that state that use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of missed surveillances. The modification will also include changes to the Bases for SR 3.0.3 that provide details on how to implement the new requirements. The Bases changes provide guidance for surveillance frequencies that are not based on time intervals but are based on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases changes state that PG&E is expected to perform a missed surveillance test at the first reasonable opportunity, taking into account appropriate considerations, such as the impact on plant risk and accident analysis assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance. The Bases also state that the risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that missed surveillances for important components should be analyzed quantitatively. The Bases also state that the results of the risk evaluation determine the safest course of action. In addition, the Bases state that all missed surveillances will be placed in the licensee's Corrective Action Program. Finally, PG&E has a Bases Control Program consistent with Section 5.5.14 of the STS.
4.0 ENVIRONMENTAL EVALUATION PG&E has reviewed the environmental evaluation included in the model safety evaluation dated June 14, 2001, as part of the CLIIP. The modifications to TSTF-358 and the proposed safety evaluation noticed on September 28, 2001, as part of the CLIIP, do not affect the environmental evaluation published in the Federal Register Notice of June 14, 2001. PG&E has concluded that the staffs
Enclosure 1 PG&E Letter DCL-02-001 findings presented in that evaluation are applicable to DCPP and the evaluation is hereby incorporated by reference for this application.
Enclosure 2 PG&E Letter DCL-02-001 PROPOSED TECHNICAL SPECIFICATION CHANGES
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ..."
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is-teescC This delay period is permitted to allow performance of the Surveillance.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
SR 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.
DIABLO CANYON - UNITS 1 & 2 3.0-3 Unit 1 - Amendment No. t35" TAB 3.0 - RO 3 Unit 2 - Amendment No. M35
Enclosure 2 PG&E Letter DCL-02-001 TS INSERT 1 A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
Enclosure 3 PG&E Letter DCL-02-001 REVISED TECHNICAL SPECIFICATION PAGES
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.
Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per..."
basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater.
This delay period is permitted to allow performance of the Surveillance.
A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
SR 3.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
SR 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.
DIABLO CANYON - UNITS 1 & 2 3.0-3 Unit 1 - Amendment No. 4-5 TAB 3.0 - RX 3 Unit 2 - Amendment No. 435
Enclosure 4 PG&E Letter DCL-02-001 PROPOSED TECHNICAL SPECIFICATION BASES CHANGES
SR Applicability B 3.0 BASES SR 3.0.2 components or accomplishes the function of the inoperable equipment (continued) in an alternative manner.
The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Fre uenc . A dela eriod of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is applies from the point in time that it is discovered that the Surveillance has not been perfoirmed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.
This delay period provides adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being erformed islt e I.fication of c nformance with the requirements. When a urvei ance h a Frequen based not on/tine intervals, t upon specified un conditions or perational situ tions, is discov red not to have been erformed wh specified, S .0.3 allows th full delay period of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to pe orm the Survei ance.
SR 3.0 also provides/a time limit for ompletion of S eillances that beco e applicable a a consequenc of MODE chan es imposed by e ired Actions.
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.
"Ifa Surveillance is not compleete wtnintnla owed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required (continued)
DIABLO CANYON - UNITS 1 & 2 B 3.0-11 Revision 0 TAB B3.0 - RO 11
Enclosure 4 PG&E Letter DCL-02-001 BASES INSERT 1 When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, SR 3.0.3 allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.
SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.
BASES INSERT 2 While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the Corrective Action Program.