DCL-09-031, Submittal of 2008 Annual Commitment Change Summary Report

Submittal of 2008 Annual Commitment Change Summary Report

ML091410046
Person / Time
Site:	Diablo Canyon
Issue date:	05/07/2009
From:	Becker J Pacific Gas & Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-09-031, NEI 99-04, SECY-00-0045
Download: ML091410046 (3)

Text

PacificGas and Tib~I Electric Company James R. Becker Diablo Canyon Power Plant Site Vice President Mail Code 104/5/601 P 0. Box 56 Avila Beach, CA 93424 805.545.3462 May 7, 2009 Internal: 691.3462 Fax: 805.545.6445 PG&E Letter DCL-09-031 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 Power Plant Units 1 and 2 2008 Annual Commitment Change Summary Report

Dear Commissioners and Staff:

In accordance with NEI 99-04, "Guidelines for Managing NRC Commitment Changes," Revision 0, endorsed by the NRC in SECY-00-0045, Pacific Gas and Electric Company (PG&E) is submitting the enclosed Commitment Change Summary Report for Diablo Canyon Power Plant, Units 1 and 2. The report provides a summary of the regulatory commitment changes that occurred during the period January 1, 2008, through December 31, 2008. The summary for each change includes identification of the source document(s), a description of the original and revised commitments, and a justification for the change.

The regulatory commitment changes described in the report were processed in accordance with the NEI guideline, and were determined to 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.

sszl/64002710 Enclosure cc: Elmo E. Collins, Regional Administrator, NRC Region IV Michael S. Peck, NRC Senior Resident Inspector Alan B. Wang, NRC Project Manager A member of the STARS (Strategic Teaming and Resource Sharing) Alliance ADO' Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• San Onofre 0 South Texas Project

• Wolf Creek

Enclosure PG&E Letter DCL-09-031

SUMMARY

OF REGULATORY COMMITMENT CHANGES JANUARY 1, 2008, THROUGH DECEMBER 31, 2008 CONTENTS.

Item Commitment Subject Page 1.0 Plant Staff Review for TS 3.0.4 Mode Changes 1

Enclosure PG&E Letter DCL-09-031 1.0 Plant Staff Review for TS 3.0.4 Mode Changes Source Document(s)

• License Amendment 55 and 54, dated June 11, 1990.

• Pacific Gas and Electric Company (PG&E) Letter DCL-89-320, "Diablo Canyon Units 1 and 2 Additional Information and Certification Regarding License Amendment Request 88-05, Revision of Technical Specification (TS) Sections 3.0 and 4.0 'Applicability' and Associated Bases (Generic Letter 87-09)" dated December 21, 1989.

Original Commitment "1. Operating Procedure (OP) L-0, "Mode Transition Checklists," (has been) revised to require that reliance on the provisions contained in TS 3.0.4 must be reviewed by the Plant Staff Review Committee (PSRC) and approved by the plant manager (or designated alternate) prior to transition to a more restrictive operational mode or specified condition ... As part of the mode transition review, the PSRC will review the priority and schedule for equipment repair or maintenance related to items affected by the proposed change to TS 3.0.4 (Attachment 9.9 to procedure) (DCL 89-320)

2. The licensee has provided confirmation and certification that appropriate administrative controls and procedures are in place for limiting the use of specification 3.0.4 exceptions in conjunction with its proposed TS."

Revised Commitment "1. Operating Procedure (OP) L-0, "Mode Transition Checklists," (has been) revised to require that reliance on the provisions contained in TS 3.0.4b must be reviewed by the Plant Staff Review Committee (PSRC) and approved by the plant manager (or designated alternate) prior to transition to a more restrictive operational mode or specified condition. ... As part of the mode transition review, the PSRC will review the priority and schedule for equipment repair or maintenance related to items affected by the proposed change to TS 3.0.4b (Attachment 9.9 to procedure) (DCL 89-320)

2. The licensee has provided confirmation and certification that appropriate administrative controls and procedures are in place for limiting the use of specification 3.0.4 exceptions in conjunction with its proposed TS."

Justification for Change The intent of TS 3.0.4a is to allow mode transition when the action statement allows operation in the mode for an unlimited period of time. The intent of TS 3.0.4c is to allow mode transition when there is a specific exception in the limiting condition for operation (LCO). This commitment, therefore, should only apply when employing TS 3.0.4b to justify a mode transition. The commitment was clarified to add this specificity.

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