DCL-16-062, Response to RAI Regarding License Amendment Request 13-02, Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times - Ritstf..
| ML16189A282 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/07/2016 |
| From: | Gerfen P Pacific Gas & Electric Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| DCL-16-062 | |
| Download: ML16189A282 (19) | |
Text
Pacific Gas and Electric Company Paula Gerfen Diablo Canyon Power Plant Station Director Mail code 104/5/502 P.O. Box 56 Avila Beach, CA 93424 805.545.4596 Internal: 691.4596 fax: 545.4234 July 7, 2016 PG&E Letter DCL-16-062 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 Response to NRC Request for Additional Information Regarding License Amendment Request 13-02. "Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505. Revision 1. *Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48'"
Reference:
- 1. PG&E Letter DCL-13-106, License Amendment Request 13-02, Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48," dated November 25, 2013
Dear Commissioners and Staff:
In Reference 1, Pacific Gas and Electric Company (PG&E) submitted License Amendment Request (LAR) 13-02 that proposes an amendment that would modify technical specification (TS) requirements to permit the use of risk informed completion times in accordance with Technical Specifications Task Force-5.05 (TSTF-505), Revision 1, "Provide Risk-Informed Extended Completion Times -
RITSTF Initiative 4b."
On June 29, 2015, the NRC staff requested additional information required to complete the review of LAR 13-02. PG&E's responses to the staff's questions are provided in the Enclosure.
This information does not affect the results of the technical evaluation or the no significant hazards consideration determination previously transmitted in Reference 1.
This letter contains new proposed license conditions for TSTF-505. The new proposed license conditions are contained in Attachment 1 to the Enclosure.
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk PG&E Letter DCL-16-062 July 7, 2016 Page2 This communication contains revised commitments (as defined in NEI 99-04). The revised commitments are described in Attachment 2 to the Enclosure.
If you have any questions, or require additional information, please contact Mr. Hossein Hamzehee at (805) 545-4720 .
I state under penalty of perjury that the foregoing is true and correct.
Sira Executed on July 7, 2016.
Paula Gerfen Station Director
~
kjse/4328 50467285 Enclosure cc: Diablo Distribution cc/enc: Kriss M. Kennedy, NRC Region IV Administrator Gonzalo L. Perez, Branch Chief, California Dept of Public Health John P. Reynoso, NRC Acting Senior Resident Inspector Balwant K. Singal, Senior NRC Project Manager A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Enclosure PG&E Letter DCL-16-062 PG&E Response to NRC Request for Additional Information Regarding License Amendment Request 13-02, "Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide , Risk-Informed Extended Completion Times - RITSTF Initiative 48" NRC Question 1:
By letter dated November 25, 2013 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML13330A557), as supplemented by letters dated February 5 and May 28, 2015 (ADAMS Accession Nos. ML15036A592 and ML15148A480, respectively), Pacific Gas and Electric Company (PG&E, the licensee) submitted a license amendment request (LAR) associated with Technical Specification Task Force (TSTF) traveler, TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times- RITSTF [Risk-Informed TSTF]Initiative 4b."
The proposed LAR would, in part, modify selected Required Actions to permit extending the Completion Times in accordance with a new TS-required risk-informed completion time program. The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is needed for the staff to complete its review.
- NRC approved Topical Report (TR) NEI 06-09, "Risk-Informed Technical Specifications Initiative 4b: Risk-Managed Technical Specification (RMTS)
Guidelines," Revision 0-A (ADAMS Accession No. ML12286A322), includes the NRC Safety Evaluation (SE) for NEI 06-09 (ADAMS Accession No. ML071200238),
which approved and provided limitations and conditions for use of the TR. Section
- 4. 0, Item 6, of the NRC SE requires that the licensee provide the plant-specific total Core Damage Frequency (CDF) and Large Early Release Frequency (LERF) to confirm that these are less than 1E-4/year and 1E-5/year, respectively. This is consistent with the risk acceptance guidelines in Regulatory Guide (RG) 1.174 (ADAMS Accession No. ML100910006).
In Attachment 9 of the application, the licensee states that the Diablo Canyon Unit 1 CDF and LERF are 9.47E-05/year and 7.99E-06/year, respectively, and that the Unit 2 CDF and LERF are 9. 06E-05/year and 8. 83E-06/year, respectively. The licensee also notes that "these values reflect the anticipated configuration of the plant upon full implementation of [National Fire Protection Association] NFPA 805 and related plant modifications to resolve fire protection issues. At the time of implementation of the [Risk-Informed Completion Time] RICT Program, the
[Probabilistic Risk Assessment] PRA model used will reflect the existing configuration of the plant."
Similarly, in Attachment 12 of the application, the licensee states: "In addition, the fire and internal events PRA models include credit for a committed plant modification (described in Reference 6) to install a passive shutdown seal for each of the reactor coolant pumps (RCPs). For RICT Program calculations, the PRA models will reflect-
Enclosure PG&E Letter DCL-16-062 the actual configuration of the RCP seals." The NRC staff understands that the RICT program will reflect the actual configuration of the plant; however, this does not address the total baseline risk before implementation of the RICT program.
The NRC staff notes that the reported CDF and LERF for Diablo Canyon are near the limits of the risk acceptance guidelines identified in NEI 06-09, Revision 0-A.
The NRC staff also notes that RCP seal credit can significantly reduce both internal events and fire risk at Pressurized Water Reactors. Please provide the plant risk without credit for RCP seals, or any other credited NFPA 805 related modifications that are not completed at this time, and assess these values against the applicable risk acceptance guidelines. If the acceptance guidelines are not met, please identify what plant modifications would be necessary to meet RG 1. 174 and propose a license condition to perform these modifications if RCP seal credit cannot be achieved. Also, please describe how RICTwi/1 be fully implemented after NFPA 805 (i.e., after completing the modifications, resolving concerns with RCP credit, and self- approval is allowed), such that the risk acceptance guidelines are met.
PG&E Response:
PG&E has made the decision to implement the RICT Program after all credited NFPA 805 related modifications have been installed. The modifications to complete the transition to full compliance with 10 CFR 50.48(c) are described in Attachment-S, Table S-2, "Plant Modifications Committed," of PG&E Letter DCL-16-014, Supplement to License Amendment Request 13-03, "License Amendment Request to Adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants (2001 Edition)," dated January 28, 2016, and will be installed by the end of the Units 1 and 2 refueling outages currently scheduled for April/May 2017 (1 R20) and February /March 2018 (2R20). Attachment 1 to the Enclosure of this letter contains proposed license conditions to complete the credited NFPA 805 related modifications that have not already been installed.
Diablo Canyon Power Plant (DCPP) has developed an NFPA 805 fire PRA model for the transition to NFPA 805. The NFPA 805 related plant modifications credited in the NFPA 805 fire PRA model include the Westinghouse Generation Ill passive thermal shutdown reactor coolant pump (RCP) seals, electrical raceway fire barrier system (ERFBS), incipient detection installation in the Cable Spreading and Solid State Protection System (SSPS) Rooms, and Hot Shutdown Panel (HSDP) upgrade modifications. A post installation test of the Westinghouse Generation Ill shutdown seal from the Beaver Valley plant was successfully performed by Westinghouse on October 4, 2015.
For DCPP Unit 1, the Westinghouse Generation Ill passive thermal shutdown RCP seals and ERFBS modifications were completed in the fall 2015 outage. The incipient detection and HSDP upgrade modifications are scheduled to be installed in the April/May 2017 refueling outage.
2
Enclosure PG&E Letter DCL-16-062 For DCPP Unit 2, the Westinghouse Generation Ill passive thermal shutdown RCP seals, ERFBS, and HSDP upgrade modifications were installed in the spring 2016 refueling outage. The incipient detection modification is scheduled to be installed in the February/March 2018 refueling outage.
To ensure that the RICT Program is not implemented until all credited NFPA 805 related modifications have been installed, proposed license conditions are provided to not permit use of a RICT until the installation of the outstanding NFPA 805 modifications for each unit have been completed. PG&E has put appropriate compensatory measures in place until completion of the modifications. The license condition for the NFPA 805 Amendments 225 for DCPP Unit 1 and 227 for Unit 2 contain the sentence "PG&E shall maintain appropriate compensatory measures in place until completion of the modifications delineated above." In a phone call with the NRC staff on August 25, 2015, the NRC staff requested that the sentence regarding compensatory measures be included in the license condition for the TSTF-505 LARin order to prevent a conflict in the license conditions.
Unit 1 This amendment authorizes the use of Risk Informed Completion Times (RICT) in accordance with Technical Specification Task Force TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times- RITSTF Initiative 4b."
The use of a RICT is not permitted until installations are completed of the NFPA 805 associated Hot Shutdown Panel and Incipient Detection modifications described in Attachment-S, Table S-2, "Plant Modifications Committed," of PG&E Letter DCL-16-014, dated January 28, 2016, by the end of the Units 1 refueling outage currently scheduled for April/May 2017 (1 R20). PG&E shall maintain appropriate compensatory measures in place until completion of the modifications delineated above.
Unit 2 This amendment authorizes the use of Risk Informed Completion Times (RICT) in accordance with Technical Specification Task Force TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times- RITSTF Initiative 4b."
The use of a RICT is not permitted until installation is completed of the NFPA 805 associated Incipient Detection modification described in Attachment-S, Table S-2, "Plant Modifications Committed," of PG&E Letter DCL-16-014, dated January 28, 2016, by the end of the Unit 2 refueling outage currently scheduled for February /March 2018 (2R20). PG&E shall 3
Enclosure PG&E Letter DCL-16-062 maintain appropriate compensatory measures in place until completion of the modifications delineated above.
The proposed license conditions are contained in Attachment 1 to the Enclosure.
Table 1 below provides the CDF and LERF values with all the NFPA 805 associated modifications credited resulting from a quantification of the baseline average annual models, which include contributions from internal events (including internal flooding),
fire, and seismic hazards. Other external hazards are below accepted screening criteria and therefore have insignificant contributions to total risk values.
Currently, there are measures implemented to reduce the plant fire risk without all of the NFPA 805 modifications installed. Administrative controls are instituted for the Cable Spreading Room and SSPS Room until all of the NFPA 805 modifications are complete. "No combustible storage area" controls are procedurally implemented for these areas, which reduces the potential.for a transient fire. Fire Protection also reviews all hot work permits for these areas, which is required by procedure.
Table 1: Total Average Annual CDF/LERF NFPA 805 Fire PRA Model-All Modifications Credited (rounded to two significant digits)
Unit 1 Unit 2 CDF LERF CDF LERF Hazard (per rx-yr) (per rx-yr) (per rx-yr) (per rx-yr)
Internal Events ******-****-****-***-***-*******-**-
~. . ... . ......... . . .. ......... . .............. . ..... . .. .. .. ....
1.13E-05 1. 70E-06 _,, ,
1.13E-05 1. 70E-06
. . . . ~. ~.!~r-~_§.'_ I._Fiog_~J~.9.... . . . . . ... . .Z_:. ~J. §..:.9..?.. . . . . . . . . . . . . . . . . . .?.:. ~.~-~-~-Q.Z___. . . . . . .-******* * -~-~.?..~.~~.9...?.. . . _. . . . . . . . . ._:. . .?. ~. ~~-§.:9..?.. ..
Seismic 2.62E-05
- 2. 71 E-06 ,
2.62E-05 _ ............_,_,_..2.
71 E-06 Fire 4.83E-05 2.45E-06 5.24E-05 2.17E-06 Total 9.37E-05 7.14E-06 9.55E-05 6.78E-06 As previously stated in Table S-3, "Implementation Items," item S-3.24 contained in to the Enclosure of PG&E Letter DCL-15-119,"Response to NRC Request for Additional Information - National Fire Protection Association Standard 805," dated October 15, 2015, related to the NFPA 805 modifications credited in the PRA model, if the actual change-in-risk and/or total risk exceeds the acceptance guidelines of Regulatory Guide 1.174, the PRA model will be reassessed and new modifications or refinements will be implem~nted, as necessary, to meet the ,
acceptance guidelines prior to its use in the Change Evaluation. This ensures that Regulatory Guide 1.174 acceptance guidelines are met after the NFPA 805 modifications are installed and when the RICT Program is implemented.
NRC Question 2:
The NRC staff has determined that the proposed regulatory commitments in Attachment 4 of the application are necessary for implementation of the Diablo 4
Enclosure PG&E Letter DCL-16-062 Canyon RICT program. Identify if any of the proposed regulatory commitments have already been addressed due to recent PRA model updates. Please propose a license condition with associated implementation items to address the remaining items listed in Attachment 4.
PG&E Response: of LAR 13-02 (PG&E Letter DCL-13-106, License Amendment Request 13-02, "Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, 'Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48,"' dated November 25, 2013) contained proposed regulatory commitments for implementation of the RICT Program. The proposed commitments were made because at the time of the submittal of LAR 13-02, there were outstanding actions needed to support the RICT program, such as development of configuration risk management program (CRMP) and PRA Program procedures, development of CRMP model and PRA model software changes, completion of PRA model revisions to address peer review facts and observations, and establishment of compensatory actions needed prior to NFPA 805 modifications being installed. The current status of addressing these commitments is documented below along with an evaluation as to whether they have been completed or need to be proposed as a license condition since they are not completed.
Commitment 1 Commitment 1 states:
Plant procedures will be developed to incorporate the following with regards to probabilistic risk assessment (PRA) model update process:
- Plant changes affecting systems, structures, and components within the scope of the configuration risk management program (CRMP) will be reviewed prior to implementation to identify if an interim update of the CRMP model or other interim administrative control for the Risk Informed Completion Time (RICT) Program is required; and,
- Discovered conditions affecting the CRMP model will be addressed in the corrective action program.
The DCPP Administrative Work Procedure AWP E-028, "PRA Model Maintenance and Upgrades" states that conditions affecting the CRMP shall be addressed in the Corrective Action Program. The list of conditions affecting the CRMP in the Corrective Action Program will be reviewed prior to implementation of the RICT Program to identify if an interim update of the CRMP model or other interim administrative control for the RICT Program is required. Therefore, this commitment has been completed and does not need to be a license condition.
5
Enclosure PG&E Letter DCL-16-062 Commitment 2 Commitment 2 states:
The CRMP model used for the RICT Program will include logic for the pressurizer heaters to require at least one group of functional heaters in order to credit secondary heat removal prior to any application of the RICT Program for a RICT for Technical Specification (TS) 3.4.9.
Modeling has been added to the current CRMP model to include logic that fails secondary heat removal when all four pressurizer heaters are not PRA functional.
Therefore, this commitment has been completed and does not need to be a license condition.
Commitment 3 Commitment 3 states:
Shared systems and equipment between the two units will be identified in plant procedures used for establishing risk management actions when required by the RICT Program.
This commitment has not yet been completed and will need to be included in the RICT Program procedures as part of implementation of the amendment for each unit. Therefore, this commitment is not completed and is included in the proposed-license conditions contained in Attachment 1 to the Enclosure.
Commitment 4 Commitment 4 states:
The error in the PRA model related to not modeling shorter containment sump recirculation time window for small loss-of-coolant accidents (LOCAs) when the containment fan cooling system fails will be corrected in the CRMP model before the RICT Program is implemented.
Modeling has been added to the current CRMP model to include logic that uses an increased human error probability for aligning containment sump recirculation when the containment fan coolers fail and containment spray is successful. Since this modeling has already been completed, this commitment has been completed and does not need to be a license condition.
6
Enclosure PG&E Letter DCL-16-062 Commitment 5 Commitment 5 states:
The emergency core cooling system charging pump recovery factor will not be credited in the RICT Program whenever an emergency core cooling system charging pump is made unavailable.
Logic has been added to the CRMP model such that this emergency core cooling system charging pump recovery factor is not credited whenever an emergency core cooling system charging pump is made unavailable. Therefore, this commitment has been completed and does not need to be a license condition.
Commitment 6 Commitment 6 states:
The 24-hour mission time will be applied to the emergency diesel generators and fuel oil transfer pumps in the RICT program whenever the offsite power 230 kV system is made unavailable.
Changes have been made to the CRMP software, which will be used for the RICT Program, to apply a 24-hour mission time in the PRA model to the emergency diesel generators and fuel oil transfer pumps whenever the 230-kV system is made unavailable. Therefore this commitment has been completed and does not need to be a license condition.
Commitment 7 Commitment 7 states:
The RICT Program will assume inoperability of the auxiliary saltwater train if one or more vacuum breakers are nonfunctional.
This commitment has not yet been completed and will need to be included in the RICT Program procedures as part of implementation of the amendment for each unit. Therefore, this commitment is not completed and is included in the proposed license conditions contained in Attachment 1 to the Enclosure.
Commitment 8 Commitment 8 states:
At any time when a RICT is in effect, a continuous fire watch will be established in the Cable Spreading and Solid State Protection System 7
Enclosure PG&E Letter DCL-16-062 (SSPS) rooms until incipient detection and hot shutdown panel modifications are implemented.
This commitment was a compensatory measure to be put in place during use of a RICT prior to the installation of the incipient detection and hot shutdown panel modifications. PG&E has made the decision to implement the RICT Program after all credited NFPA 805 related modifications have been installed. The proposed license conditions contained in Attachment 1 to this Enclosure do not permit use of a RICT prior to installation of the incipient detection and hot shutdown panel modifications. Therefore this commitment is no longer required and does not need to be a license condition.
Commitment 9 Commitment 9 states:
At any time when a RICT is in effect, welding and cutting activities will be prohibited in the following fire areas until fire wrap and circuit rerouting modifications in these areas are implemented:
- Unit 1, Fire Area 3-88, Elevation 115
- Unit 2, Fire Area 5-8-4 This commitment was a compensatory measure to be put in place during use of a RICT prior to the installation of the fire wrap and circuit rerouting modifications (referred to as the ERF8S modification). The ERF8S modifications have been completed for each Unit and this compensatory measure will no longer need to be put in place during use of a RICT. Therefore this commitment is no longer required and does not need to be a license condition.
Commitment 10 Commitment 10 states:
The following peer review facts and observations identified and discussed in Table A6-1, will be resolved prior to implementation of the RICT Program:
- AS-83-01
- SC-A5-01
- SC-A5-02
- SY-A16-01
- SY-81 0-01
- SY-815-01 8
Enclosure PG&E Letter DCL-16-062
- HR-A1-01
- HR-C3-01
- HR-03-01
- HR-G?-01
- DA-C1-01
- QU-C2-01 These peer review facts and observations have been addressed and resolved in the current PRA model of record. The disposition of these facts and observations was as described in the "Disposition" column contained in Table A6-1 in Attachment 6 to the Enclosure of LAR 13-02. Therefore this commitment has been completed and does not need to be a license condition.
In summary, LAR 13-02 commitments 1, 2, 4 through 6, and 8 through 10 either have been completed or are no longer required. The LAR 13-02 commitments 3 and 7 are not complete and therefore are proposed as license conditions, instead of regulatory commitments. The proposed license conditions are contained in Attachment 1 to the Enclosure. The ten LAR 13-02 commitments are no longer required and are withdrawn. The commitment changes are contained in Attachment 2 to the Enclosure of this letter.
NRC Question 3: .
In Table A 13-1 of the application, for the assumption regarding designation of certain systems/components as guaranteed failures in the fire PRA model," the disposition for the RICT program states: ((Those systems that are within the RICT Program and guaranteed failed in the fire model are assumed 100% successful in the baseline PRA model used to calculate the RICT." The staff interprets this statement to mean that the equipment is always considered available (i.e., ((100%
successful") in the model used to calculate the RICT. This could misrepresent risk
- insights as it may not account for the non-fire-induced (random) failure probabilities of these components. For example:
Attachment 12, Attributes of the Configuration Risk Management Program (CRMP) Model, Table A 12-3 lists SSG functions not in TS that impact RICT calculations, including:
Feed and bleed using emergency core cooling system (EGGS) pumps and power operated relief valves (PORVs)
- Instrument air system Main feedwater and condensate systems pumps and valves The response to NFPA Standard NFPA 805 PRA RAI1 (a) (ADAMS Accession No. ML14330A635) discussed the systems (i.e., 500kV back-feed, 12kV non-essential power, Anticipated Transient Without Scram Mitigating System Actuation Circuitry (AMSAC), Instrument Air, Feedwater and condensate systems, containment fan coolers, containment spray, and make up to refueling water storage tank from the 9
Enclosure PG&E Letter DCL-16-062 fuel pool) that are assumed to be unavailable in the Fire PRA. The response also states: ((The dependency of RCS-PCV-474 on the [Instrument Air System} /AS significantly impacts the reliability of the [Feed and Bleed} F&B function, especially in fire events."
Assuming that Instrument Air is always available may not accurately represent the plant configuration when entering a RICT and could lead to overestimating the RICT by allowing too much credit for the feed and bleed function.
It is unclear how these systems are being modeled in the internal events portion of the ((baseline PRA model used to calculate the RICT." Assuming the equipment is always available in the model (i.e., ((100% successful) used to calculate the RICT may not reflect the plant configuration at the time the RICT is entered and could misrepresent risk insights. Please elaborate on this disposition to more clearly explain how this will affect RICT calculations. Will any additional risk-model analyses be required for the associated systems/components based on this assumption?
PG&E Response:
As stated in the LAR 13-02, Table A 13-1, there are systems/components which are guaranteed failure in the fire PRA model. This introduces non-conservatism in the RICT calculation, since the baseline (zero-maintenance) configuration risk is over-estimated by always assuming these systems/components fail for any fire scenario.
This reduces the calculated delta-risk and hence results in longer RICTs. In order to eliminate this non-conservatism in the RICT Program calculations, for the baseline zero-maintenance configuration, the fire-induced failure is not assumed . This maximizes the fire delta risk since the affected systems/components are always
- failed for fire scenarios for the actual plant configuration risk (which maximizes this risk calculation), but only failed due to random causes for the baseline zero-maintenance configuration (which minimizes this risk calculation); hence the difference in risk between the two cases is conservatively calculated for fire risk.
Therefore, the maximum possible change in fire risk is always applied to any RICT calculation, regardless of the actual status of the guaranteed failure systems/components.
This assumption is applied to systems/components which are in the scope of the CRMP model and which are assumed to be guaranteed failure in the fire PRA model. The use of the phrase "1 00°/o successful" in Table A 13-1 of the LAR 13-02 was intended to convey that the affected system would not fail due to any fire impact in the baseline case; however, random failures are still assumed in the baseline configuration. Note that this assumption of not failing the system due to fire effects in the baseline configuration has no other impact except on the fire risk calculation.
10
Enclosure Attachment 1 PG&E Letter DCL-16-062 Revisions to Facility Operating Licenses Facility Operating License No. DPR-80 REMOVE INSERT Appendix D page 3 Appendix D page 3 Appendix D page 4 Facility Operating License No. DPR-82 REMOVE INSERT Appendix D page 3 Appendix D page 3 Appendix D page 4
Appendix D (Continued)
Amendment Implementation Number Additional Conditions Date
. Following implementation, this condition will be performed as stated in the condition:
The first performance of SR 3.7.1 0.5, in accordance with Specification 5.5.19.c.(i),
shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from February 3, 2005, the date of the most recent successful tracer gas test, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
The first performance of the periodic assessment of CRE habitability, Specification 5.5.19.q.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from February 3, 2005, the date of the most recent successful tracer gas test, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
The first performance of the periodic measurement of CRE pressure, Specification 5.5.19.d, shall be within 24 months, plus the 182 days allowed by SR 3.0.2, as measured from February 3, 2005, the date' of the most recent successful pressure measurement test, or within 182 days if not performed previously.
INSERT #1 DIABLO CANYON - UNIT 1 Unit 1 - Amendment No. +d-S,+4+;£M Rev 1 Page 3 of 3 '
Additionai_Conditionsu1 r01.DOC 1109.1453
Insert #1 XXX This amendment authorizes the use of risk The amendment is informed completion times (RICT) in accordance effective as of the date with Technical Specification Task Fo~ce TSTF- of its issuance and the 505, Revision 1, "Provide Risk-Informed condition shall be Extended Completion Times- RITSTF Initiative implemented within 4b." 120 days of its issuance.
The use of a RICT is not permitted until installations are completed of the NFPA 805 associated Hot Shutdown Panel and Incipient Detection modifications described in Attachment-S, Table S-2, "Plant Modifications Committed," of PG&E Letter DCL-16-014, dated January 28, 2016, by the end of the Unit 1 refueling outage currently scheduled for April/May 2017 (1 R20). PG&E shall maintain appropriate compensatory measures in place until completion of the modifications delineated above.
Shared systems and equipment between the two units must be identified in plant procedures used for establishing risk management actions when required by the RICT Program.
The RICT Program must assume inoperability of the auxiliary saltwater train if one or more vacuum breakers are nonfunctional.
Appendix D (Continued)
Amendment Implementation Number Additional Conditions Date Following implementation, this condition will be performed as stated in the condition:
- The first performance of SR 3.7.1 0.5, in accordance with Specification 5.5.19.c.(i),
shall be within the specified Frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from February 3, 2005, the date of the most recent successful tracer gas test, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
The first performance of the periodic assessment of CRE habitability, Specification 5.5.19.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from February 3, 2005, the date of the most recent successful tracer gas test, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
The first performance of the periodic measurement of CRE pressure, Specification 5.5.19.d, shall be within 24 months, plus the 182 days allowed by SR 3.0.2, as measured from February 3, 2005, the date of the most recent successful pressure measurement test, or within 182 days if not performed previously.
INSERT#2 DIABLO CANYON- UNIT 2 Unit 2- Amendment No.- ~ ..f-4.+,-2e2"',
Rev 1 Page 3 of 3 Additionai_Conditionsu2r01.DOC 1028.1149
Insert #2 XXX This amendment authorizes the use of risk The amendment is informed completion times (RICT) in accordance effective as of the date with Technical Specification Task Force TSTF- of its issuance and the 505, Revision 1, "Provide Risk-Informed condition shall be Extended Completion Times- RITSTF Initiative implemented within 4b." 120 days of its issuance.
The use of a RICT is not permitted until installation is completed of the NFPA 805 associated Incipient Detection modification described in Attachment-S, Table S-2, "Plant Modifications Committed," of PG&E Letter DCL-16-014, dated January 28, 2016, by the end of the Unit 2 refueling outage currently scheduled for February/March 2018 (2R20). PG&E shall maintain appropriate compensatory measures in place until completion of the modifications delineated above.
Shared systems and equipment between the two units will be identified in plant procedures used for establishing risk management actions when required by the RICT Program.
The RICT Program must assume inoperability of the auxiliary saltwater train if one or more vacuum breakers are nonfunctional.
Enclosure Attachment 2 PG&E Letter DCL-16-062 Revision to Regulatory Commitments The ten regulatory commitments contained in Attachment 4 of the Enclosure of PG&E Letter DCL-13-1 06, License Amendment Request (LAR) 13-02, Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48," dated November 25, 2013, are listed below. The LAR 13-02 commitments 1, 2, 4 through 6, and 8 through 10 either have been completed or are no longer required. The LAR 13-02 commitments 3 and 7 are not complete and therefore are proposed as license conditions contained in Attachment 1 to the Enclosure of this letter. Therefore, the ten LAR 13-02 commitments (listed below) are no longer required and are withdrawn:
- 1. Plant procedures will be developed to incorporate the following with regards to probabilistic risk assessment (PRA) model update process:
- Plant changes affecting systems, structures, and components within the scope of the configuration risk management program (CRMP)_will be reviewed prior to implementation to identify if an interim update of the CRMP model or other interim administrative control for the Risk Informed Completion Time (RICT)
Program is required; and,
- Discovered conditions affecting the CRMP model will be addressed in the corrective action program.
- 2. The CRMP model used for the RICT Program will include logic for the pressurizer heaters to require at least one group of functional heaters in order to credit secondary heat removal prior to any application of the RICT Program for a RICT for Technical Specification (TS) 3.4.9.
- 3. Shared systems and equipment between the two units will be identified in plant procedures used for establishing risk management actions when required by the RICT Program.
- 4. The error in the PRA model related to not modeling shorter containment sump recirculation time window for small loss-of-coolant accidents (LOCAs) when the containment fan cooling system fails will be corrected in the CRMP model before the RICT Program is implemented.
- 5. The emergency core cooling system charging pump recovery factor will not be credited in the RICT Program whenever an emergency core cooling system charging pump is made unavailable.
- 6. The 24-hour mission time will be applied to the emergency diesel generators and fuel oil transfer pumps in the RICT program whenever the offsite power 230 kV system is made unavailable.
Enclosure Attachment 2 PG&E Letter DCL~16-062
- 7. The RICT Program will assume inoperability of the auxiliary saltwater train if one or more vacuum breakers are nonfunctional.
- 8. At any time when a RICT is in effect, a continuous fire watch will be established in the Cable Spreading and Solid State Protection System (SSPS) rooms until incipient detection and hot shutdown panel modifications are implemented.
- 9. At any time when a RICT is in effect, welding and cutting activities will be prohibited in the following fire areas until fire wrap and circuit rerouting modifications in these areas are implemented:
- Unit 1, Fire Area 3-88, Elevation 115
- Unit 2, Fire Area 5-8-4
- 10. The following peer review findings and observations, identified and discussed in Table A6-1, will be resolved prior to implementation of the RICT Program:
- AS-83-01
- SC-A5-01
- SC-A5-02
- SY-A16-01
- SY-810-01
- SY-815-01
- HR-A1-01
- HR-C3-01
- HR-03-01
- HR-G7-01
- DA-C1-01
- QU-C2-01 2