Text

License Amendment Request 05-05 Application for Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process
	ML053000316
Person / Time
Site:	Diablo Canyon
Issue date:	10/19/2005
From:	Oatley D; Pacific Gas & Electric Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	DCL-05-120
	Download: ML053000316 (17)
	v • d • e

V -4 Pacific Gas and Electric Company" David H. Datley Diablo Canyon Power Plant Vice President and General Manager P.0. Box 56 Avila Beach, CA 93424 October 19, 2005 Fax: 805.545.4884 PG&E Letter DCL-05-120 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 License Amendment Request 05-05 Application for Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process

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 1 and 2 of the Diablo Canyon Power Plant (DCPP), respectively. The enclosed license amendment request (LAR) proposes to modify technical specification (TS) requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.8.

The changes are consistent with Nuclear Regulatory Commission approved Industry/Technical Specification Task Force (TSTF), Standard Technical Specifications (STS) change TSTF-372, Revision 4.

Enclosure 1 contains a description of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Enclosures 2 and 3 contain marked-up and retyped (clean) TS pages, respectively. Enclosure 4 provides the marked-up TS Bases changes for information only. TS Bases changes are provided for information only and will be implemented pursuant to TS 5.5.14, "Technical Specifications Bases Control Program," at the time this amendment is implemented.

Pacific Gas and Electric (PG&E) requests approval of the proposed license amendment by October 19, 2006, with the amendment being implemented within 90 days.

If you have any questions or require additional information, please contact Mr. Stan Ketelsen at 805-545-4720.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Ar'p \

Callaway

Comanche Peak

Diablo Canyon

Palo Verde

South Texas Project

Wolf Creek

I6 Document Control Desk PG&E Letter DCL-05-120 October 19, 2005 Page 2 Sincerely,

( 974/7 David H. Oatley Vice President and General Manager mdw/4877 Enclosures cc: Edgar Bailey, DHS Terry W. Jackson Bruce S. Mallett Diablo Distribution cc/enc: Girija S. Shukla A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

Comanche Peak . Diablo Canyon

Palo Verde . South Texas Project

Wolf Creek

PG&E Letter DCL-05-120 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 David H. Oatley, of lawful age, first being duly sworn upon oath states that he is Vice President and General Manager of Pacific Gas and Electric Company; that he has executed license amendment request 05-05 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.

David H. O0 t Vice President and General Manager Subscribed and sworn to before me this 19tI9 day of October, 2005, by David H. Oatley, personally known to me or proved to me on the basis of satisfactory evidence to be the person who appeared before me.

Notary Public SANDRA AIE Y Commission # 1425568 County of San Luis Obispo 9 ; ~Notary Pubic California f State of California ISon luls Obispo County-I ~B MCnEpmtk1.2007

Enclosure I PG&E Letter DCL-05-120 EVALUATION

1.0 DESCRIPTION

The proposed amendment would modify technical specifications (TS) requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.8.

The availability of this TS improvement was published in the Federal Register on May 4, 2005 (70 FR 23252), as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Pacific Gas and Electric (PG&E) has reviewed the safety evaluation dated May 4, 2005, as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support Technical Specification Task Force (TSTF)-372. 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), Units 1 and 2, and justify this amendment request 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 the TSTF-372, Revision 4 or the NRC staffs model safety evaluation dated May 4, 2005.

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 Federal Register as part of the CLIIP. 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).

Enclosure 1 PG&E Letter DCL-05-120 3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on May 4, 2005, for this TS improvement, plant-specific verifications were performed as follows:

PG&E has established TS Bases for LCO 3.0.8 which provide guidance and details on how to implement the new requirements. LCO 3.0.8 requires that risk be managed and assessed. The Bases also state that while the Industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment required by LCO 3.0.8 need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function. Finally, PG&E has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications.

4.0 ENVIRONMENTAL EVALUATION PG&E has reviewed the environmental evaluation included in the model safety evaluation dated May 4, 2005, as part of the CLIIP. PG&E has concluded that the staffs 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-05-120 Proposed Technical Specification Changes (marked-up)

LCO Applicability 3.0 l and LCO 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0.8.

LCO 3.0.1 LCOs shall be met during the MODES or other specified conditionlin the Applicability, except as provided in LCO 3.0.2, and LCO 3 .0.7 I LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications, or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in 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.

(continued)

DIABLO CANYON - UNITS 1 & 2 3.0-1 Unit I - Amendment No. 435,449, Unit 2 - Amendment No. 435,470,

LCO Applicability 3.0 3.0 LCO APPLICABILITY (continued)

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered.

Only the support system LCO ACTIONS are required to be entered.

This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)."

If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

LCO 3.0.7 Test Exception LCO 3.1.8, allows specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional.

When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.

I DIABLO CANYON - UNITS 1 & 2 3.0-2 Unit I - Amendment No. 435, Unit 2 - Amendment No. 435,

Technical Specification Inserts Insert 1 LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:

a. the snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; or

b. the snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected support system LCO(s) shall be declared not met.

Enclosure 3 PG&E Letter DCL-05-120 Proposed Technical Specification Changes (retyped)

Remove Paqe Insert Page 3.0-1 3.0-1 3.0-2 3.0-2

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2, LCO 3.0.7, and LCO 3.0.8.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.