DCL-12-107, Supplement to PG&E Letter DCL-11-059, License Amendment Request 11-04, Revision to Technical Specification (TS) 3.6.6, 'Containment Spray and Cooling Systems,' TS 3.7.5, 'Auxiliary Feedwater (AFW) System,' TS 3.8.1, 'Ac.....

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Supplement to PG&E Letter DCL-11-059, License Amendment Request 11-04, Revision to Technical Specification (TS) 3.6.6, 'Containment Spray and Cooling Systems,' TS 3.7.5, 'Auxiliary Feedwater (AFW) System,' TS 3.8.1, 'Ac.....
ML12306A533
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 11/01/2012
From: Allen B
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-12-107, DCL-11-059
Download: ML12306A533 (8)
v • d • e


Text

__ Pacific Gas and

~&~ Electric Company Diablo Canyon Powe r Plan t PO. Box 56 Av il a Beach, CA 93 424 800.545.6000 November 1,2012 PG&E Letter DCL-12-1 07 U.S. Nuclear Regulatory Commission 10 CFR 50.90 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 Supplement to PG&E Letter DCL-11-059, "License Amendment Request 11-04, Revision to Technical Specification (TS) 3.6.6, 'Containment Spray and Cooling Systems,' TS 3.7.5, 'Auxiliary Feedwater (AFW) System,' TS 3.8.1, 'AC Sources -

Operating,' TS 3.8.9, 'Distribution Systems - Operating,' and TS Example 1.3-3"

Reference:

1. PG&E Letter DCL-11-059, "License Amendment Request 11-04, Revision to Technical Specification (TS) 3.6.6, 'Containment Spray and Cooling Systems,' TS 3.7.5, 'Auxiliary Feedwater (AFW)

System,' TS 3.8.1, 'AC Sources - Operating,' TS 3.8.9, 'Distribution Systems - Operating,' and TS Example 1.3-3," dated June 1, 2011 In Reference 1, Pacific Gas and Electric Company (PG&E) submitted a license amendment request to revise Technical Specification (TS) 3.6.6, "Containment Spray and Cooling Systems," TS 3.7.5, "Auxiliary Feedwater (AFW) System,"

TS 3.8.1, "AC Sources - Operating," TS 3.8.9, "Distribution Systems - Operating,"

and TS Example 1.3-3.

Based on a design change installed in Diablo Canyon Power Plant Unit 1 and scheduled to be installed in Unit 2 during Unit 2 Refueling Outage Seventeen that affects the input to the AFW automatic level control system, the proposed change to add a new TS 3.7.5 Condition B will no longer be needed. This supplement removes portions of the original license amendment request submitted in Reference 1.

PG&E is making a regulatory commitment (as defined by NEI 99-04) in this letter and is revising a previous regulatory commitment associated with the proposed new TS 3.7.5 Condition B, as detailed in the enclosure.

If you have any questions or require additional information, please contact Mr. Tom Baldwin at (805) 545-4720.

A member o f the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway . Comanche Peak . Diablo Canyon . Palo Verde . San Onofre . South Texas Project . Wolf Creek

m Document Control Desk PG&E Letter DCL-12-1 07

~&~ November 1, 2012 I & Page 2 I state under penaHy of perjury that the foregoing is true and correct.

Executed on November 1,2012.

Sincerely,

~~Ie;* 4ft--

Site Vice President Mjrm/4557/50329767 Enclosure cc: Diablo Distribution cc/enc: Gonzalo L. Perez, California Dept of Public Health Elmo E. Collins, NRC Region IV Laura H. Micewski, Acting NRC Senior Resident Inspector Joseph M. Sebrosky, 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

Enclosure PG&E Letter DCL-12-107 Supplement to PG&E Letter DCL-11-059, "License Amendment Request 11-04, Revision to Technical SpeCification (TS) 3.6.6, 'Containment Spray and Cooling Systems,' TS 3.7.5, 'Auxiliary Feedwater (AFW) System,' TS 3.8.1, 'AC Sources-Operating,' TS 3.8.9, 'Distribution Systems - Operating,' and TS Example 1.3-3."

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted license amendment request (LAR) 11-04 to revise Technical Specification (TS) 3.6.6, "Containment Spray and Cooling Systems," TS 3.7.5, "Auxiliary Feedwater (AFW)

System," TS 3.8.1, "AC Sources - Operating," TS 3.8.9, "Distribution Systems -

Operating," and TS Example 1.3-3.

LAR 11-04 included changes consistent with the following NRC-approved Technical Specification Task Force (TSTF) Travelers:

  • TSTF-412, Revision 3, "Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable"
  • TSTF-439, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet an LCO" In addition to the TSTF changes, LAR 11-04 included changes to address a design feature of the AFW system that has not been previously reviewed by the NRC associated with the Eagle-21 system input to the AFW level control system.

Subsequently, PG&E has made a design change (discussed below) to Diablo Canyon Power Plant (DCPP) Unit 1 that addressed the vulnerability, where one AFW level control valve on both motor driven AFW trains would be affected by an Eagle-21 rack lock-up. PG&E plans to perform the same design change to DCPP Unit 2 during Unit 2 Refueling Outage Seventeen.

This design change consists of installing a median signal select that, for each steam generator, takes three level signals processed through three separate Eagle-21 racks and passes the median signal to each AFW automatic level control system. These channels are processed by software using the same level of validation and configuration management used for the digital feedwater control system. Based on the design changes, the proposed revision to add a new TS 3.7.5 Condition B will no longer be needed.

PG&E hereby withdraws the portions of LAR related to the addition of a new TS 3.7.5 Condition B. Because LAR 11-04 identified portions of the LAR related to the TSTFs and the new TS 3.7.5 Condition B, a complete revision of the LAR is not necessary.

This was discussed with the NRC project manager for DCPP on October 11, 2012.

Revised "retyped" TS pages for affected pages are included in Attachment 1 of this 1

Enclosure PG&E Letter DCL-12-1 07 enclosure. These were originally submitted in Reference 1 with a revision to two of the pages revised in Reference 3.

PG&E is making the following regulatory commitment as defined in NEI 99-04:

PG&E plans to install a control system median signal selector on DCPP Unit 2 during Unit 2 Refueling Outage Seventeen, currently scheduled to begin in February 2013, to address the design vulnerability where an Eagle-21 rack lock-up can affect control of one level control valve per motor driven AFW train.

The following regulatory commitment, originally submitted in PG&E Letter DCL-11-059 (Reference 1) and revised in PG&E Letter DCL-12-076 (Reference 4), is being withdrawn:

"If steam generator level control is placed in manual alignment due to a failure of automatic control, PG&E will assign a dedicated operator for manual operation."

Changes to the TS Bases and Updated Final Safety Analysis Report (UFSAR) will be made based on the remaining proposed changes after approval of the LAR in accordance with 10 CFR 50.59. Because the TS Bases and UFSAR pages were originally submitted for information only, no new revised pages are being submitted as a result of withdrawing the proposed new TS 3.7.5 Condition B.

During recent discussions with the NRC, the NRC requested clarification on the response to NRC RAI 2.b provided in Reference 2. Since the proposed change to address the Eagle-21 design vulnerability (new TS 3.7.5 Condition B) is no longer requested, a review of the response provided has been entered into the DCPP corrective action program for evaluation and resolution (reference SAPN 50517827).

REFERENCES:

1. PG&E Letter DCL-11-059, "License Amendment Request 11-04, Revision to Technical Specification (TS) 3.6.6, 'Containment Spray and Cooling Systems,'

TS 3.7.5, 'Auxiliary Feedwater (AFW) System,' TS 3.8.1, 'AC Sources-Operating,' TS 3.8.9, 'Distribution Systems - Operating,' and TS Example 1.3-3,"

dated June 1, 2011

2. PG&E Letter DCL-12-017, "Response to NRC Request for Additional Information regarding PG&E Letter DCL-11-059, License Amendment Request 11-04, Revision to Technical Specification (TS) 3.6.6, 'Containment Spray and Cooling Systems,' TS 3.7.5, 'Auxiliary Feedwater (AFW) System,' TS 3.8.1, 'AC Sources

- Operating,' TS 3.8.9, 'Distribution Systems - Operating,' and TS Example 1.3-3," dated February 6, 2012

3. PG&E Letter DCL-12-057, "Supplement to PG&E Letter DCL-12-017, Response to NRC Request for Additional Information: NRC Question 1," dated May 31, 2012.

2

Enclosure PG&E Letter DCL-12-1 07

4. PG&E Letter DCL-12-076, "Response to NRC Second Request for Additional Information regarding PG&E Letter DCL-11-059, "License Amendment Request 11-04, Revision to Technical Specification (TS) 3.6.6, 'Containment Spray and Cooling Systems,' TS 3.7.5, 'Auxiliary Feedwater (AFW) System,' TS 3.8.1, 'AC Sources - Operating,' TS 3.8.9, 'Distribution Systems - Operating,' and TS Example 1.3-3" 3

Enclosure Attachment 1 PG&E Letter DCL-12-1 07 Revised Proposed Technical Specification Changes (Retyped) to Replace Pages Provided in DCL-11-059 as revised in DCL-12-057 Remove Page Insert Page 3.7-10 3.7-10 3.7-10a 3.7-11 3.7-11 1

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

NOT E---------------------------------------------------

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

NOT E------------------------------------------------------

LCO 3.0.4b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Turbine driven AFW train A.1 Restore affected 7 days inoperable due to one equipment to inoperable steam supply. OPERABLE status.

OR

NOT E-------------

Only applicable if MODE 2 has not been entered following refueling.

Turbine driven AFW pump inoperable in MODE 3 following refueling.

B. One AFW train inoperable B.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in MODE 1, 2 or 3 for OPERABLE status.

reasons other than Condition A.

(continued)

DIABLO CANYON - UNITS 1 & 2 3.7-10 Unit 1 - Amendment No. ~,4-e9, Unit 2 - Amendment No. ~,4+Q,

AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. --------------N 0 TE-------------- C.1 Restore the steam 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Only applicable when the supply to the turbine remaining OPERABLE driven train to motor driven AFW train OPERABLE status.

provides feedwater to the OR steam generator with the inoperable steam supply. C.2 Restore the motor driven 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

AFWtrain to Turbine driven AFW train OPERABLE status.

inoperable due to one inoperable steam supply.

AND One motor driven AFW train inoperable.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion AND Time of Condition A, B, or C not met. 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> D.2 Be in MODE 4.

OR Two AFW trains inoperable in MODE 1,2 or 3 for reasons other than Condition C.

E. Three AFW trains E.1 -----------NOTE---------------

inoperable in MODE 1, 2, or LCO 3.0.3 and all other

3. LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore Immediately one AFW train to OPERABLE status F. Required AFW train F.1 Initiate action to restore Immediately inoperable in MODE 4. AFW train to OPERABLE status.

DIABLO CANYON - UNITS 1 & 2 3.7-11 Unit 1 - Amendment No. ~,.:t-e9, Unit 2 - Amendment No. ~,4-7Q,

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