Text

Revision to Technical Specifications to Adopt Technical Specifications Task Force TSTF-547, Revision 1, Clarification of Rod Position Requirements (License Amendment Request 17-01)
	ML17271A090
Person / Time
Site:	Diablo Canyon
Issue date:	09/28/2017
From:	Welsch J; Pacific Gas & Electric Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	DCL-17-076, LAR 17-01
	Download: ML17271A090 (47)
	v • d • e

Pacific Gas and Electric Company James M. Welsch

Diablo Canyon Power Plant Vice President, Nuclear Generation Mail Code 104/6 P. 0. Box 56 Avila Beach, CA 93424 805.545.3242 Internal: 691.3242 September 28, 2017 Fax: 805.545.4884 PG&E Letter DCL-17 -076 U.S. Nuclear Regulatory Commission 10 CFR 50.90 ATTN: Document Control Desk Washington, D.C. 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. *: 50-323, OL-DPR-82 License Amendment Request 17-01 Revision to Technical Specifications to Adopt Technical Specifications Task Force TSTF-547. Revision 1. "Clarification of Rod Position Requirements"

Dear Commissioners and Staff:

Pursuant to 10 CFR 50.90, Pacific Gas and Electric Company (PG&E) hereby requests approval of the enclosed proposed amendment to revise the Technical Specifications (TS) to adopt Technical Specification Task Force (TSTF) change TSTF-547, "Clarification of Rod Position Requirements," for Diablo Canyon Power Plant (DCPP) Units 1 and 2 .

The proposed amendment revises the requirements on control and shutdown rods, and rod and bank position indication consistent with NRC-approved TSTF-547 and associated model application. The Enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing DCPP TS pages marked up to show the proposed changes. Attachment 2 provides revised (clean) DCPP TS pages. Attachment 3 provides existing DCPP TS Bases pages marked to show the proposed changes for information only.

Approval of the proposed amendment is requested by September 30, 2018. Once approved, the amendment shall be implemented within 120 days.

PG&E makes no or revised regulatory commitments (as defined by NEI 99-04) in this letter.

In accordance with site administrative procedures and the Quality Assurance Program, the proposed amendment has been reviewed by the Plant Staff Review Committee.

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-17-076 September 28, 2017 Page 2 Pursuant to 10 CFR 50.91, PG&E is notifying the State of California of this License Amendment Request by transmitting a copy of this letter and enclosure to the California Department of Public Health.

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.

Executed on September 28, 2017.

Vice President, Nuclear Generation kjse/4328/50868808 Enclosure cc: Diablo Distribution cc/enc: Scott A. Morris, NRC Region IV Administrator (Acting)

Christopher W. Newport, NRC Senior Resident Inspector Gonzalo L. Perez, Branch Chief, California Dept of Public Health Balwant K. Singal, NRR Project Manager A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

Comanche Peak

Diablo Canyon

Palo Verde

Wolf Creek

Enclosure PG&E Letter DCL-17 -076 Evaluation of the Proposed Change

Subject:

License Amendment Request 17-01, Revision to Technical Specifications To Adopt Technical Specifications Task Force TSTF-547, Revision 1, "Clarification of Rod Position Requirements"

1. DESCRIPTION

2. ASSESSMENT 2.1 Applicability of Safety Evaluation 2.2 Variations

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Analysis 3.2 Conclusions

4. ENVIRONMENTAL EVALUATION ATTACHMENTS:

1. Proposed Technical Specification Changes

2. Revised Technical Specification Pages

3. Technical Specification Bases Changes

Enclosure PG&E Letter DCL-17 -076 EVALUATION

1. DESCRIPTION The proposed license amendment request (LAR) revises the requirements on control and shutdown rods, and rod and bank position indication in Technical Specification (TS) 3.1.4, "Rod Group Alignment Limits," TS 3.1.5, "Shutdown Bank Insertion Limits,"

TS 3.1 .6," "Control Bank Insertion Limits," and TS 3.1.7, "Rod Position Indication," to provide time to repair rod movement failures that do not affect rod Operability, to provide an alternative to frequent use of the movable in core detector system when position indication for a rod is inoperable, to correct conflicts within the TS, to eliminate an unnecessary action, to increase consistency, and to improve the presentation.

2. ASSESSMENT 2.1 Applicability of Safety Evaluation Pacific Gas and Electric Company (PG&E) has reviewed the safety evaluation for TSTF-547, Revision 1 (hereafter TSTF-547) provided to the Technical Specifications Task Force in a letter dated March 4, 2016. This *review included a review of the NRC Staff's evaluation, as well as the information provided in TSTF-547. As described in the subsequent paragraphs, PG&E has concluded that the justifications presented in the TSTF-547 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 for the incorporation of the changes to the DCPP TS.

2.2 Variations PG&E is proposing the following variations from the TS changes described in TSTF-547 or the applicable parts of the NRC Staff's Safety Evaluation dated March 4, 2016.

These differences are administrative and do not affect the applicability of TSTF-54 7 to the DCPP TS.

Current DCPP TS 3.1.4 Required Actions B.2.1.1 and B.2.3, TS 3.1.5 Required Action A.1.1, TS 3.1.6 Required Actions A.1.1 and B.1.1 use the words "provided in the COLR" instead of the words "specified in the COLR" (with underline added for effect) that are used in TSTF-547 for these Required Actions. Therefore, the words "provided in the COLR" are revised to the words "specified in the COLR" for these current Required Actions. This provides consistency with the words "specified in the COLR" used in TSTF-547 for these Required Actions and for the newTS 3.1.5 Required Action A and TS 3.1.6 Required Action A added by TSTF-547. This change was not made to current TS 3.1.4 Required Actions A.1.1 and 0.1.1 because these Required Actions were not revised by TSTF-547.

TSTF-547 revises TS 3.1.7 Required Actions A.1 and C.1 from "Verify the 1

Enclosure PG&E Letter DCL-17 -076 position of the rods with inoperable position indicators indirectly by using movable in core detectors" to "Verify the position of the rod with inoperable DR PI indirectly by using movable incore detectors" (with underline added for effect).

TSTF-547 adds new Required Action A.2.1 to "Verify the position of the rod(s) with inoperable DRPI indirectly by using movable incore detectors" (with underline added for effect).

The DCPP TS 3.1.7 Required Actions A.1 and C.1 use the words "core power distribution measurement information" instead of the Westinghouse Standard TS, Revision 4, words "movable incore detectors," because for DCPP the core power distribution measurement information can be obtained from either the flux maps using the movable incore detectors or from the Power Distribution Monitoring System (PDMS). The TS 3.1.7 Required Action A.1 and C.1 revisions were made in support of use of BEACON that was requested by PG&E in a LAR in PG&E Letter DCL-03-069, "Revision of Technical Specifications 3.1.7, "Rod Position Indication," 3.2.1, "Heat Flux Hot Channel Factor," 3.2.4, "Quadrant Power Tilt Ratio," and 3.3.1, "Reactor Trip System (RTS) Instrumentation," for BEACON Implementation," dated June 11, 2003, and approved by the NRC in Amendments 164 and 166 for Units 1 and 2, respectively, on March 31, 2004.

The PDMS utilizes the BEACON Core Monitoring and Operations Support System software to determine power distribution. The ability to use the movable in core detectors or the PDMS core power distribution measurement information to verify the position of the rod indirectly is described in the DCPP TS 3.1. 7 Action A TS Bases. Therefore, the current TS 3.1. 7 Required Actions A.1 and C.1 words of "core power distribution measurement information" are retained and are used for new Required Action A.2.1.

TSTF-547 contains the following oversight in new Required Action A.2.1 to TS 3.1. 7 (with underline added for effect):

"Verify the position of the rod§ with inoperable DRPI indirectly by using movable incore detectors."

To be consistent with the changes made to Required Action A.1, "rod" (singular) should have been used instead of "rods" (plural). The DCPP markups correct this oversight by using "rod" (singular) for this Required Action.

2

Enclosure PG&E Letter DCL-17 -076

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Analysis PG&E has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

Control and shutdown rods are assumed to insert into the core to shut down the reactor in evaluated accidents. Rod insertion limits ensure that adequate negative reactivity is available to provide the assumed shutdown margin (SDM). Rod alignment and overlap limits maintain an appropriate power distribution and reactivity insertion profile.

Control and shutdown rods are initiators to several accidents previously evaluated, such '

as rod ejection. The proposed change does not change the limiting conditions for operation for the rods or make any technical changes to the Technical Specification (TS) Surveillance Requirements (SRs) governing the rods. Therefore, the proposed change has no effect on the probability of any accident previously evaluated.

Revising the TS Actions to provide a limited time to repair rod movement control has no effect on the SDM assumed in the accident analysis as the proposed Actions require verification that SDM is maintained. The effects on power distribution will not cause a significant increase in the consequences of any accident previously evaluated as all TS requirements on power distribution continue to be applicable.

Revising the TS Actions to provide an alternative to frequent use of the moveable in core detector system or the Power Distribution Monitoring System to verify the position of rods with inoperable rod position indicator does not change the requirement for the rods to be aligned and within the insertion limits.

Therefore, the assumptions used in any accidents previously evaluated are unchanged and there is no significant increase in the consequences.

The proposed change to resolve the differences in the TS ensure that the intended Actions are followed when equipment is inoperable. Actions taken with inoperable equipment are not assumptions in the accidents previously evaluated and have no significant effect on the consequences.

The proposed change to eliminate an unnecessary action has no effect on the consequences of accidents previously evaluated as the analysis of those accidents did not consider the use of the action.

3

Enclosure PG&E Letter DCL-17 -076 The proposed change to increase consistency within the TS has no effect on the consequences of accidents previously evaluated as the proposed change clarifies the application of the existing requirements and does not change the intent.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different accident from any accident previously evaluated?

Response: No.

The proposed change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed). The change does not alter assumptions made in the safety analyses. The proposed change does not alter the limiting conditions for operation for the rods or make any technical changes to the Surveillance Requirements governing the rods. The proposed change maintains or improves safety when equipment is inoperable and does not introduce new failure modes.

Therefore, the proposed change does not create the possibility of a new or different accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change to allow an alternative method of verifying rod position has no effect on the safety margin as actual rod position is not affected. The proposed change to provide time to repair rods that are operable but immovable does not result in a significant reduction in the margin of safety because all rods must be verified to be operable, and all other banks must be within the insertion limits. The remaining proposed changes to make the requirements internally consistent and to eliminate unnecessary actions do not affect the margin of safety as the changes do not affect the ability of the rods to perform their specified safety function.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above evaluation, PG&E concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

4

Enclosure PG&E Letter DCL-17 -076 3.2 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation of Diablo Canyon Units 1 and 2 in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4. ENVIRONMENTAL EVALUATION PG&E has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the proposed amendment.

5

Enclosure Attachment 1 PG&E Letter DCL-17 -076 Proposed Technical Specification Change(s)

Rod Group Alignment Limits 3.1.4 3.1 REACTIVITY CONTROL SYSTEMS 3.1.4 Rod Group Alignment Limits LC03.1.4 All shutdown and control rods shall be OPERABLE.

AND Individual indicated rod positions shall be within 12 steps of their group step counter demand position.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more rod(s) A.1.1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. the limits provided in the COLR.

OR A.1.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

AND A.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B. One rod not within &.4 Rest01 e 1 od to vvitl=lifl T-+tettf alignment limits. alignment limits.

8R B .~ 1.1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months the limits f}rovided in the COLR.

specified

~ OR I (continued)

DIABLO CANYON- UNITS 1 & 2 3.1-7 Unit 1 - Amendment No. 1-858 Unit 2 - Amendment No. 1-3§

Rod Group Alignment Limits 3.1.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2:"1.2 Initiate boration to restore SDM to within limit.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months t

~ AND B.2-:2 Reduce THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months POWER to:::; 75°/o RTP.

~ AND B.Z:: 3 Verify SDM to be within Once per the limits provided in the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months COLR.

~ AND specified -I B. ~ Perform SR 3.2.1.1 [JM. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SR 3.2.1.2. ~

~

I

!INSERT 1 I 8 .2.5 Perferffl SR 3.2.2.1. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

~ AND B.2:6 ~ Re-evaluate safety 5 days analyses and confirm results remain valid for duration of operation under these conditions.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time *at Condition B not met.

D. More than one rod not D.1.1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within alignment limit. the limits provided in the COLR.

OR D.1.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore required SDM to within limit.

AND D.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months DIABLO CANYON - UNITS 1 & 2 3.1-8 Unit 1 - Amendment No. f35~

Unit 2 - Amendment No. rnw

Rod Group Alignment Limits 3.1.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

~

3.1.4.1 INSERT2

V_er~fy individual rod ~

II m Jt. '\ __________:::

~

within alignment s

In accordance with the Surveillance Frequency Control Program It r

SR 3.1.4.2 Verify rod freedom of movement (trippability) by In accordance with the moving each rod not fully inserted in the core ;:::: 10 Surveillance steps in either direction. Frequency Control Program SR 3.1.4.3 Verify rod drop time of each rod, from the fully Prior to reactor withdrawn position, is:::; 2.7 seconds from the criticality after each beginning of decay of stationary gripper coil removal of the reactor voltage to dashpot entry, with: head

a. Tavg;:::: 500 °F; and

b. All reactor coolant pumps operating.

DIABLO CANYON- UNITS 1 & 2 3.1-9 Unit 1 - Amendment No. ~'

Unit 2 - Amendment No. ~' 2:&1 .

zee8

Shutdown Bank Insertion Limits 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Shutdown Bank Insertion Limits LCO 3.1 .5 Each shutdown bank shall be within insertion limits specified in the COLR.

~

APPLICABILITY: MODE 1, MODE 2 with any control bank not fully inserted.

~~()lfE: --------------------------------------------------------

Tfl is LCO is Aet a~~ li eae l e ~vfl il e ~erferffi i A~ SR 3.1.4.2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME T~A. One or more shutdown banks not within limits.

Verify SDM to be within the limits provided in the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months COLR.

specified for reasons other Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months than Condition A restore SDM to within limit.

INSERT 4 Restore shutdown banks 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to within limits.

Required Action and Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY t

SR 3.1.5.1 Verify each shutdown bank is within the limits In accordance with the specified in the COLR. Surveillance Frequency Control Program DIABLO CANYON - UNITS 1 & 2 3.1-1 0 Unit 1 -Amendment No. ~' ffifrQ Unit 2 - Amendment No. ~' 2:&1-0

Control Bank Insertion Limits 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Control Bank Insertion Limits LCO 3.1 .6 Control banks shall be within the insertion, sequence, and overlap limits specified in the COLR.

~

APPLICABILITY: MODES 1, MODE 2 with kett ~ 1.0.

l~()lrt: -----------------------------------------------------

Thi:s LOG i:s MOt applicable oo l li le per fort,, it tg GR 3.1 .4.2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

(§]A. Control bank insertion Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 limits not met.

OR the limits provided in the COLR.

specified for reasons other Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months than Condition A restore SDM to within limit.

INSERT 6 Restore control bank(s) 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to within limits.

Control bank sequence o C 13.1.1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months overlap limits not met. the limits provided in the COLR.

specified OR for reasons other Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months than Condition A restore SDM to within limit.

Restore control bank 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months sequence and overlap to within limits.

[Q]-e. Required Action and Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

DIABLO CANYON- UNITS 1 & 2 3.1-11 Unit 1 - Amendment No. +85Q Unit 2 - Amendment No. 1-35Q

Rod Position Indication 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1. 7 Rod Position Indication LCO 3.1. 7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

NOTE-------------------- -------------------------------

Separate Condition entry is allowed for each inoperable rod po~ition indicator and each demand position indicator.

CONDITION REQUIRED ACTION COMPLETION TIME A. One DRPI per group A.1 Verify the position of the Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable for ~ more rods- with inoperable groups. positioo iodicato(s ~

indirectly by using core r----1 DRPI I power distribution in measurement information.

~ ( OR

!INSERT 7 ~ A ..rz @J Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months T

POWER to~ 50°/o RTP.

B. More than one DRPI per B.1 Place the control rods Immediately under manual control group in? .

AND

~ MG~ i tG~ a~9 ~BGG~9 Q~G@ ~@~ ~ I:!Gbl~

in one or more ~@aGtG~ GGGia~t S)'St@R=I groups ~

AWO (continued)

DIABLO CANYON- UNITS 1 & 2 3.1-13 Unit 1 -Amendment No. ~,+64,~

Unit 2 - Amendment No. ~,+W,~

Rod Position Indication 3.1.7 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) Verify the position of the Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months rods '.vith inoperable position indicators indirectly by using core power distribution measurement information .

ANO B.4 [ ] Restore inoperable 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months One or more DRPI position indicators to inperable in one or OPERABLE status such more groups and that a maximum of one DRPI per group is associated rod has inoperable.

T C. One or more rods with inoperable ORRis have been moved in excess of 24 steps in e direction C.1 Verify the position of the rods with inoperable position indicators indirectly by using core 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months since the last power distribution determinatio of the rod's measurement position. information.

OR C.2 Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months POWER to~ 50°/o RTP.

D. One demand position D.1.1 Verify by administrative Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months indi or. per bank means all DRPis for the inope a e ~ one or affected banks are more a ks. OPERABLE.

AND D.1.2 Verify the most 'Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months withdrawn rod and the least withdrawn rod of the affected banks are

~ 12 steps apart.

OR D.2 Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months POWER to~ 50°/o RTP (continued)

DIABLO CANYON - UNITS 1 & 2 3.1-14 Unit 1 - Amendment No. ~,+G4 Q Unit 2 - Amendment No. ~,~ Q

Rod Position Indication 3.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Once prior to criticality SR 3.1.7.1 ----------------------------NOTE----------------------------

after each removal of Not required to be met for DRPis associated with the reactor vessel rods that do not meet LCO 3.1.4.

head.

Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.

DIABLO CANYON - UNITS 1 & 2 3.1-15 Unit 1 -Amendment No. ~.

Unit 2 -Amendment No. ~.

Rod Position Indication 3.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 ~erify each DRPI agrees within 12 steps of the Once prior to criticality group demand position for the full indicated range after each removal of of rod travel. the reactor vessel head.

I

!INSERT 8 I DIABLO CANYON - UNITS 1 & 2 3.1-15 Unit 1 - Amendment No. 13!{]

Unit 2 - Amendment No. 13E[)

Enclosure Attachment 1 PG&E Letter DCL-17 -076 Technical Specification INSERTs INSERT 1

, and SR 3.2.2.1 INSERT 2

N 0 TE ---------------------------------

Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.

INSERT 3

N0 TE---------------------------------------------------

Not applicable to shutdown banks inserted while performing SR 3.1.4.2.

Enclosure Attachment 1 PG&E Letter DCL-17 -076 Technical Specification INSERTs (continued)

INSERT 4 A. One shutdown bank A.1 Verify all control banks are 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inserted::;; 16 steps within the insertion limits beyond the insertion specified in the COLR.

limits specified in the COLR.

A.2.1 Verify SDM is within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months limits specified in the COLR.

A.2.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

AND A.3 Restore the shutdown 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months bank to within the insertion limits specified in the COLR.

(continued)

INSERT 5

N0 T E---------------------------------------------------

Not applicable to control banks inserted while performing SR 3.1.4.2.

Enclosure Attachment 1 PG&E Letter DCL-17 -076 Technical Specification INSERTs (continued)

INSERT 6 A. Control bank A, B, or C A.1 Verify all shutdown 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inserted ::;; 16 steps banks are within the beyond the insertion, insertion limits specified sequence, or overlap in the COLR.

limits specified in the COLR.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months A.2.1 Verify SDM is within the limits specified in the COLR.

A.2.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

A.3 Restore the control 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months bank to within the insertion, sequence, and overlap limits specified in the COLR.

(continued)

Enclosure Attachment 1 PG&E Letter DCL-17 -076 Technical Specification INSERTs (continued)

INSERT 7 A.2.1 Verify the position of the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months rod with inoperable DRPI indirectly by using AND core power distribution measurement Once per 31 EFPD information. thereafter 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after discovery of each unintended rod movement AND 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after each movement of rod with inoperable DRPI

> 12 steps AND Prior to THERMAL POWER exceeding 50%>RTP AND 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after reaching RTP A.2.2 Restore inoperable DRPI Prior to entering to OPERABLE status. MODE 2 from MODE3 INSERT 8

NOTE------------------------------------

Not required to be met for DRPis associated with rods that do not meet LCO 3.1.4.

Enclosure Attachment 2 PG&E Letter DCL-17-076 Revised Technical Specification Page(s)

Remove Page Insert Page 3.1-7 3.1-7 3.1-8 3.1-8 3.1-9 3.1-9 3.1-10 3.1-10 3.1-1 Oa 3.1-11 3.1-11 3.1-11a 3.1-13 3.1-13 3.1-13a 3.1-14 3.1-14 3.1-15 3.1-15

Rod Group Alignment Limits 3.1.4 3.1 REACTIVITY CONTROL SYSTEMS 3.1.4 Rod Group Alignment Limits LCO 3.1.4 All shutdown and control rods shall be OPERABLE.

AND Individual indicated rod positions shall be within 12 steps of their group step counter demand position.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more rod(s) A.1.1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable. the limits provided in the COLR.

OR A.1.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

AND A.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B. One rod not within B.1.1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months alignment limits. the limits specified in the CO LB..

OR B.1.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

AND (continued)

DIABLO CANYON - UNITS 1 & 2 3.1-7 Unit 1 -Amendment No. ~.

Unit 2 -Amendment No. ~.

Rod Group Alignment Limits 3.1.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2 Reduce THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months POWER to ::;; 75°/o RTP.

AND B.3 Verify SDM to be within Once per the limits specified in the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months COLR.

AND B.4 Perform SR 3.2.1.1, SR 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 3.2.1.2, and SR 3.2.2.1.

AND B.5 Re-evaluate safety 5 days analyses and confirm results remain valid for duration of operation under these conditions.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition B not met.

D. More than one rod not D.1.1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months within alignment limit. the limits provided in the COLR.

OR D.1.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore required SDM to within limit.

AND D.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months DIABLO CANYON - UNITS 1 & 2 3.1-8 Unit 1 -Amendment No. 4-J-a, Unit 2 -Amendment No. 4-J-a,

Rod Group Alignment Limits 3.1.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 ----------------------------NOTE---------------------------- In accordance with the Not required to be performed for rods associated Surveillance with inoperable rod position indicator or demand Frequency Control position indicator. Program Verify position of individual rods within alignment limit.

SR 3.1.4.2 Verify rod freedom of movement (trippability) by In accordance with the moving each rod not fully inserted in the core ; : : 10 Surveillance steps in either direction. Frequency Control Program SR 3.1.4.3 Verify rod drop time of each rod, from the fully Prior to reactor withdrawn position, is:::; 2.7 seconds from the criticality after each beginning of decay of stationary gripper coil removal of the reactor voltage to dashpot entry, with: head

a. Tavg ;;::: 500 oF; and

b. All reactor coolant pumps operating.

DIABLO CANYON - UNITS 1 & 2 3.1-9 Unit 1 -Amendment No. --1-Ja, 2GG, Unit 2 -Amendment No. --1-Ja, ~~

Shutdown Bank Insertion Limits 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS 3.1.5 Shutdown Bank Insertion Limits LC03.1.5 Each shutdown bank shall be within insertion limits specified in the COLR.

NOTE----------------------------------------------

Not applicable to shutdown banks inserted while performing SR 3.1.4.2.

APPLICABILITY: MODE 1, MODE 2 with any control bank not fully inserted.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One shutdown bank A. 1 Verify all control banks 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inserted ::::; 16 steps are within the insertion beyond the insertion limits specified in the limits specified in the COLR.

COLR.

AND A.2.1 Verify SDM is within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months limits specified in the COLR.

OR A.2.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

AND A.3 Restore the shutdown 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months bank to within the insertion limits specified in the COLR.

(continued)

DIABLO CANYON - UNITS 1 & 2 3.1-10 Unit 1 -Amendment No. -iJB, ~~

Unit 2 -Amendment No. -iJB, .2-Q..t,

Shutdown Bank Insertion Limits 3.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One or more shutdown B.1 .1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months banks not within limits for the limits specified in the reasons other than COLR.

Condition A.

OR B.1.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

AND B.2 Restore shutdown banks 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to within limits.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify each shutdown bank is within the limits In accordance with the specified in the COLR. Surveillance Frequency Control Program DIABLO CANYON - UNITS 1 & 2 3.1-10a Unit 1 -Amendment No.

Unit 2 -Amendment No.

Control Bank Insertion Limits 3.1.6 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 Control Bank Insertion Limits LCO 3.1.6 Control banks shall be within the insertion, sequence, and overlap limits specified in the COLR.

NOTE----------------------------------------------

Not applicable to control banks inserted while performing SR 3.1.4.2.

APPLICABILITY: MODES 1, MODE 2 with keff;::: 1.0.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Control bank A, B, or C A.1 Verify all shutdown 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inserted ::::; 16 steps banks are within the beyond the insertion, insertion limits specified sequence, or overlap in the COLR.

limits specified in the COLR.

A.2.1 Verify SDM is within the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months limits specified in the COLR.

OR A.2 .2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

AND A.3 Restore the control 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months bank to within the insertion, sequence, and overlap limits specified in the COLR.

(continued)

DIABLO CANYON - UNITS 1 & 2 3.1-11 Unit 1 -Amendment No. ~.

Unit 2 -Amendment No. ~.

Control Bank Insertion Limits 3.1.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Control bank insertion B.1.1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months limits not met for reasons the limits specified in the other than Condition A. COLR.

- I OR

\

B.1.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

AND B.2 Restore control bank(s) 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to within lirnits.

. C. Control bank sequence or C.1.1 Verify SDM to be within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months overlap limits not met for the limits specified in the reasons other than

COLR.

Condition A.

OR '

C.1.2 Initiate boration to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore SDM to within limit.

AND C.2 Restore control bank 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months sequence and overlap to within limits.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion i Time not met.

DIABLO CANYON - UNITS 1 & 2 3.1-11a Unit 1 -Amendment .No.

Unit 2 -Amendment No.

Rod Position Indication 3.1.7 3.1 REACTIVITY CONTROL SYSTEMS 3.1. 7 Rod Position Indication LCO 3.1. 7 The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS

~OTE----------------------------------~------------------

Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.

CONDITION REQUIRED ACTION COMPLETION TIME A. One DRPI per group A.1 Verify the position of the Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months inoperable in one or more rod with inoperable groups. DRPI indirectly by using core power distribution measurement information.

OR A.2.1 Verify the position of the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months rod with inoperable DRPI indirectly by using core power distribution measurement Once per 31 EFPD information. thereafter 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after discovery of each unintended rod movement (continued)

DIABLO CA~YO~ - UNITS 1 & 2 3.1-13 Unit 1 -Amendment No. ~,-1-94,--1--M, Unit 2 -Amendment No. ~,400,-1-W,

Rod Position Indication 3.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after each movement of rod with inoperable DRPI

> 12 steps AND Prior to THERMAL POWER exceeding 50% RTP AND 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after reaching RTP A.2.2 Restore inoperable Prior to entering DRPI to OPERABLE MODE 2 from status. MODE 3 OR A.3 Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months POWER to::;; 50°/o RTP.

B. More than one DRPI per 8 .1 Place the control rods Immediately group inoperable in one or under manual control more groups.

AND B.2 Restore inoperable 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DRPis to OPERABLE status such that a maximum of one DRPI per group is inoperable.

(continued)

DIABLO CANYON - UNITS 1 & 2 3.1-13a Unit 1 -Amendment No.

Unit 2 -Amendment No.

Rod Position Indication 3.1.7 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more DRPI C.1 Verify the position of the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months inoperable in one or more rods with inoperable groups and associated DRPis indirectly by using rod has been moved > core power distribution 24 steps in one direction measurement since the last information.

determination of the rod's position. OR C.2 Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months POWER to::;; 50% RTP.

D. One or more demand D.1.1 Verify by administrative Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months position indicators per means all DRPis for the bank inoperable in one or affected banks are more banks. OPERABLE.

AND D.1.2 Verify the most Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months withdrawn rod and the least withdrawn rod of the affected banks are

12 steps apart.

OR D.2 Reduce THERMAL 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months POWER to ::;; 50%) RTP (continued)

DIABLO CANYON - UNITS 1 & 2 3.1-14 Unit 1 -Amendment No. 4-Ja,.:t-M, Unit 2 -Amendment No. 4-39,4-00,

Enclosure Attachment 3 PG&E Letter DCL-17 -076 Technical Specification Bases Change(s)

(For information only)

Rod Group Alignment Limits B 3.1.4 BASES ACTIONS ~ jB.1.1 and 8.1.2 (continued)

When a rod becomes misaligned, it can usually be moved and is still trippable (i.e., OPERABLE) . If the rod ean be realigned within the Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , loeal )EOnon redistribution during this short interval will not be signifieant, and operation ma~ proeeed 'Nithout further restrietion .

An alternative to realigning a single misa!i 1ned RCCA to the group demand position is to align the remainder of the group to the position of the misaligned RCCA. However, this must be done without violating the bank sequence, overlap, and insertion limits specified in LCO 3.1.5, "Shutdown Bank Insertion Limits," and LCO 3.1.6, "Control Bank Insertion Limits." The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months gives the operator suffieient time to adjust the rod positions in an orderl~ manner.

B.2.1.1 and B.2.1.2 With a misaligned rod , £DM must be verified to be within limit or boration must be initiated to restore goM to 'Nithin limit In many cases, realigning the remainder of the group to the misaligned rod may not be desirable. For example, realigning control bank B to a rod that is misaligned 15 steps from the top of the core would require a significant power reduction, since control bank D must be fully inserted and control bank C must be inserted to approximately 100 steps.

Power operation may continue with one RCCA misaligned, provided that SDM is verified within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months represents the time necessary for determining the actual unit SDM and, if necessary, aligning and starting the necessary systems and components to initiate boration.

B.2~. B~.3. B~.4. ~. and B~

For continued operation with a misaligned rod, reactor power must be reduced, SDM must periodically be verified within limits, hot channel factors (F 0 (Z) and F~H) must *be verified within limits, and the safety analyses must be re-evaluated to confirm continued operation is permissible. Reduction of power to 75% RTP ensures that local LHR increases due to a misaligned RCCA will not cause the core design criteria to be exceeded (Ref. 3). The Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months gives the operator sufficient time to accomplish an orderly power reduction without challenging the Reactor Protection System.

When a rod is known to be misaligned, there is a potential to impact the SDM. Since the core conditions can change with time, periodic verification of SDM is required. A Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient to ensure this requirement continues to be met.

(continued)

DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 22 of 45 Tab_B3!1 u3r10.DOC 1220.0756

Rod Group Alignment Limits B 3.1.4 BASES ACTIONS D.2 (continued)

If more than one rod is found to be misaligned or becomes misaligned because of bank movement, the unit conditions fall outside of the accident analysis assumptions. Since automatic bank sequencing would continue to cause misalignment, the unit must be brought to a MODE or Condition in which the LCO requirements are not applicable.

To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

The allowed Completion Time is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.1.4. 1 r.the posi~------Js is 1 REQUIREMENTS Verification that individual rod~ V~'lfhrn alignment limits provides a history that allows the operator to detect a rod that is beginning to deviate from its expected position. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program~

SR 3.1.4.2 Verifying each rod is OPERABLE would require that each rod be tripped. However, in MODES 1 and 2, tripping each rod would result in radial or axial power tilts, or oscillations. Exercising each individual rod provides confidence that all rods continue to be OPERABLE without exceeding the alignment limit, even if they are not regularly tripped.

Moving each rod by 10 steps will not cause radial or axial power tilts, or oscillations, to occur. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

Between or during required performances of SR 3.1.4.2 (determination of rod OPERABILITY by movement), if a rod(s) is discovered to be immovable, but remains trippable, the rod(s) is considered to be OPERABLE. At any time, if a rod(s) is immovable, a determination of the trippability (OPERABILITY) of the rod(s) must be made, and appropriate action taken.

SR 3.1.4.3 Verification of rod drop times allows the operator to determine that the maximum rod drop time permitted is consistent with the assumed rod drop time used in the safety analysis. Measuring rod drop times prior (continued)

DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 24 of 45 Tab_B3!1 u3r10.DOC 1220.0756

Shutdown Bank Insertion Limits B 3.1.5 BASES LCO The shutdown banks must be within their insertion limits any time the reactor is critical or approaching criticality. This ensures that a sufficient amount of negative reactivity is available to shut down the reactor and maintain the required SDM following a reactor trip.

~he shutdown bank insertion limits are defined in the COLR.

APPLICABILITY The shutdown banks must be within their insertion limits, with the reactor in MODES 1 and 2. The applicability in MODE 2 begins at initial control bank withdrawal, during an approach to criticality, and continues throughout MODE 2, until all control bank rods are again fully inserted by reactor trip or by shutdown. This ensures that a sufficient amount of negative reactivity is available to shut down the reactor and maintain the required SDM following a reactor trip. The shutdown banks do not have to be within their insertion limits in MODE 3, unless an approach to criticality is being made. In MODE 3, 4, 5, or 6, the shutdown banks are, typically, fully inserted in the core and contribute to the SDM. Refer to LCO 3.1.1 for SDM requirements in MODES 2 with keff <1.0, 3, 4, and 5. LCO 3.9.1, "Boron Concentration," ensures adequate SDM in MODE 6.

The App lioabi lity requ ireR1ents have been R1odified by a ~Jete indioating the LCO requireR1ent is suspended during gR d.1.4.2. This SR verifies the freedoR1 Of the rods to R1ove , and requires the shutdown bani< to R1ove below the LCO liR1its, whioh would norR1ally violate the LCO.

A .1.1 A .1.21and A .2 I 18.1.1 8.1.2. and 8.2 I I I r----'-----.. When one or more shutdown banks is not within insertion limits I

...___ _ _ ____. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is allowed to restore the shutdown banks to within the

limits. This is necessary because the available SDM may be significantly reduced, with one or more of the shutdown banks n within their insertion limits. Also, verification of SDM or initiation f boration within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is required, since the SDM in MODES 1 an 2 is ensured by adhering to the control and shutdown bank insertion li its (refer to LCO 3.1.1 ). If shutdown banks are not within their inserti n limits, then SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the Bases for SR 3.1.1 .1.

The allowed Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provides an acceptable ti ~ e for evaluating and repairing minor problems without allowing the pia t to remain in an unacceptable condition for an extended period of timo.

Additionally, the requirements of LCO 3.1.4, "Rod Group Alignment Limits," app.ly if one or more shutdown rods are not within the require alignment limits.

for reasons other than Condition A, (continued)

DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 28 of 45 Tab_B3!1 u3r10.DOC 1220.0756

Shutdown Bank Insertion Limits B 3.1.5 Required Actions and associated Completion Times are not met BASES ACTIONS 1c.11 B4 (continued) lfthe ~~ew~~~~~~~~~~~~~~~~~~~~

within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the unit must be brought to a MODE where the LCO is not applicable. The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.1.5.1 REQUIREMENTS Verification that the shutdown banks are within their insertion limits prior to an approach to criticality ensures that when the reactor is critical, or being taken critical, the shutdown banks will be available to shut down the reactor, and the required SDM will be maintained following a reactor trip. This SR and Frequency ensure that the shutdown banks are withdrawn before the control banks are withdrawn during a unit startup.

Since the shutdown banks are positioned manually by the control room operator, a verification of shutdown bank position, after the reactor is taken critical, is adequate to ensure that they are within their insertion limits. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 10, 1971; GDC 26, 1971; and GDC 28, 1971

2. 10 CFR 50.46

3. UFSAR, Section 15.4.3.2.4.

DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 29 of 45 Tab_B3!1u3r10.DOC 1220.0756

Control Bank Insertion Limits B 3.1.6 BASES APPLICABLE Operation at the insertion limits or AFD limits may approach the SAFETY maximum allowable linear heat generation rate or peaking factor with ANALYSES the allowed QPTR present. Operation at the insertion limit may also (continued) indicate the maximum ejected RCCA worth could be equal to the limiting value in fuel cycles that have sufficiently high ejected RCCA worths.

The control and shutdown bank insertion limits ensure that safety analyses assumptions for SDM, ejected rod worth, and power distribution peaking factors are preserved (Ref. 5) .

The insertion limits satisfy Criterion 2 of 10CFR50.36(c)(2)(ii), in that they are initial conditions assumed in the safety analysis.

LCO The limits on control banks sequence, overlap, and physical insertion, as defined in the COLR, must be maintained because they serve the function of preserving power distribution, ensuring that the SDM is maintained, ensuring that ejected rod worth is maintained, and ensuring INSERT 4 adequate negative reactivity insertion is available on trip. The overlap between control banks provides more uniform rates of reactivity insertion and withdrawal and is imposed to maintain acceptable power peaking during control bank motion.

APPLICABILITY The control bank sequence, overlap, and physical insertion limits shall be maintained with the reactor in MODES 1 and 2 with keff ~ 1.0. These limits must be maintained , since they preserve the assumed power distribution, ejected rod worth , SDM, and reactivity rate insertion assumptions. Applicability in MODES 3, 4, and 5 is not required, since neither the power distribution nor ejected rod worth assumptions would be exceeded in these MODES.

The applieability requirements have been modified by a ~Jato indieating the LGO requirements are suspended during the pertormanee of SR 8.1.4.2. This gR verifies the freedom of the rods to move, and pNSERT 5 ~==::::~~trol BaR I~ to move Below tRe LCO limits, wRisR woulet ACTIONS 1\.1.1 A .1.21/\.21 8 .1.1 8 .1.21 and 8 .2 18.1.1. 8.1.2. 8.2. C.1.1. C.1.2. and C.21 I I When the control banks are outside the acceptable insertion li * , they 1 must be restored to within those limits. This restoration can two ways:

a. Reducing power to be consistent with rod positi

b. Moving rods to be consistent with power.

for reasons other than Condition A (continued)

DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 32 of 45 Tab B3!1u3r10 .DOC 1220.0756

Control Bank Insertion Limits B 3.1.6 18.1.1, 8.1.2, 8.2, C.1.1, C.1.2, and C.2 \

BASES ACTIONS 1\.1.1. 1\.1.2. /\.2. B.1.1. B.1.2. and B.~ (continued)

Also, verification of SDM or initiation of boration to regain SDM is required within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , since the SDM in MODES 1 and 2 normally ensured by adhering to the control and shutdown bank insertion limits (refer to LCO 3.1.1, "SHUTDOWN MARGIN- (SDM)") has been upset.

If control banks are not within their insertion limits, then SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the Bases for SR 3.1.1.1.

Operation be time period in order to take conservative action because the simultaneous occurrence of either a LOCA, loss of flow accident, ejected rod accident, or other accident during this short time period, together with an inadequate power distribution or reactivity capability, has an acceptably low probability.

The allowed Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for restoring the banks to within the insertion, sequence, and overlap limits provides an acceptable time for evaluating and repairing minoi problems without allowing the plant to remain in an unacceptable condition for an extended period of time.

Additionally, the requirements of LCO 3.1.4, "Rod Group Alignment Limits," apply if one or more control rods are not within the required alignment limits.

G4 jo.1j Required Actions /\.1 and A.2, or B.1 and B.2 cannot be completed ithin the associated Completion Times, the plant must be brought to MODE 3, where the LCO is not applicable. The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.

(continued)

DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 33 of 45 Tab_B3!1u3r10.DOC 1220.0756

~ od Position Indication B 3.1.7 BASES LCO A deviation of less than the allowable limit, given in LCO 3.1.4, in (continued) position indication for a single rod, ensures high confidence that the position uncertainty of the corresponding rod group is within the assumed values used in the analysis (that specified rod group insertion limits).

These requirements ensure that rod position indication during power operation and PHYSICS TESTS is accurate, and that design assumptions are not challenged. OPERABILITY of the position indicator channels ensures that inoperable, misaligned, or mispositioned rods can be detected. Therefore, power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.

APPLICABILITY The requirements on the DRPI and step counters are only applicable in MODES 1 and 2 (consistent with LCO 3.1.4, LCO 3.1.5, and LCO 3.1.6), because these are the only MODES in which power is generated, and the OPERABILITY and alignment of rods have the potential to affect the safety of the plant. In the shutdown MODES, the OPERABILITY of the shutdown and control banks has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the Reactor Coolant System.

ACTIONS The ACTIONS table is modified by a Note indicating that a separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator per bank. This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable position indicator.

A1 1. A.2. 1. and A.2.2 1~ in one or more groups I When one DR PI per group ails, the pos1t1on of the rod may still be I determined indirectly by use of the core power distribution measurement information. Core power distribution measurement information can be obtained from flux maps using the movable incore detectors, or from an OPERABLE Power Distribution Monitoring System (PDMS) (References 4 & 5) . The Required Action may also be ensuring, at least once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , that F0 satisfies LCO 3.2.1, F~H satisfies LCO 3.2.2, and SDM is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Based on experience, normal power operation does not require excessive movement of banks. If a bank has been significantly moved, the Required Action of C.1 or C.2 below is required. Therefore, verification of RCCA position within the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate for allowing continued full power operation, since the probability of simultaneously having a rod significantly out of position and an event jiNSERT 6 ~-tnsitive to that rod position is small.

(continued)

DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 37 of 45 Tab_B3!1 u3r10.DOC 1220.0756

Rod Position Indication B 3.1.7 BASES ACTIONS ~ ,A.31 (continued)

Reduction of THERMAL POWER to~ 50°/o RTP puts the core into a condition where rod position is not significantly affecting core peaking factors (Ref. 3).

The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is reasonable, based on operating experience, for reducing power to ~ 50%> RTP from full power conditions without challenging plant systems and allowing for rod position determination by Required Action A.1 above.

B.1. R2 . B.d, aREI B.4 jB.1 and 8.2 1;-i....--in-on_e_o_r_m_o_re-g-ro_u_p_s__,l When more than one DRPI per group fail, additional actions are necessary to ensure that aooeptable pov1er distribution lin:1its are n:1aintained , ITliniiTlUITl ~OM is ITlaintained , and the potential e#eots of rod ITlisalignn:1ent on assooiated aooident analyses are lin:1ited . Placing the Rod Control System in manual assures unplanned rod motion will not occur. Together with the indireot position detern:1ination available

'via povver distribution n:1easuren:1ent inforn:1ation , this will ITliniiTlize the potential for rod ITlisalignn:lent.

The immediate Completion Time for placing the Rod Control System in manual reflects the urgency with which unplanned rod motion must be prevented while in the Condition. Monitoring and reoording reaotor eoolant Tav 9 help assure that signifioant ohanges in power distribution and SDM are avoided . The onoe per 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Con:1pletion Tin:1e is aooeptable beoause only n:1inor fluotuations in RC~ ten:1perature are m(peoted at steady state plant operating oonditions.

The position of the rods oan be detern:1ined indireotly by use of the power distribution n:1easuren:1ent inforn:1ation . The Required /\otion n:1ay also be satisfied by ensuring at least onee per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months that F0 satisfies LCO d.2.1, ~~ satisfies LCO d.2.2, and SI=IUTDOVV~J MARGM-fs within the lin:1its provided in the COLR, pro'lided that the nonindioating rods have not n:1oved . Verifioation of RCCA position onoe per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate for allowing oontinued full po'tNer operation for a lin:1ited ,

24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period , sinoe the probability of sin:1ultaneously having a rod signifioantly out of position and an event sensitive to that rod position is

~~ The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Allowed Outage Time provides sufficient time to b eshoot and restore the DRPI system to operation while avoiding INSERT 7 the plant challenges associated with a shutdown without full rod position indication.

Based on operating experience, normal power operation does not require excessive rod movement. If one or more control rods has been significantly moved, the Required Action of C.1 or C.2 below is required.

(continued)

DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 38 of 45 Tab_B3!1u3r10.DOC 1220.0756

Rod Position Indication B 3.1.7 BASES ACTIONS C.1 and C.2 (continued)

These Required /\otions olarify that when one or r:nore rods 'il"v'ith inoperable DRPis have been r:noved in mmess of 24 steps in one direotion , sinoe the position was last deterr:nined , the Required Aotions of 1\.1 and A .2 or B.1 are still appropriate but r:nust be initiated pror:nptly under Required Aotion C .1 to begin indireotly verifying that these rods are still properly positioned, relative to their group positions. If, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the rod positions have not been determined, THERMAL POWER must be reduced to :::; 50o/o RTP within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to avoid undesirable power distributions that could result from continued operation at> 50o/o RTP, if one or more rods are misaligned by more than 24 steps. The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable period of time to verify the rod positions using the movable incore detectors, or other power distribution measurement methods.

D.1.1 and D.1.

With one 0

m r ore

~

~ --- *=

mand position indicator per bank inoperable, the L...

in one or more banks ro-d~-'------~

positions can be determined by the DRPI System. Since normal power operation does not require excessive movement of rods, verification by administrative means that the rod position indicators are OPERABLE and the most withdrawn rod and the least withdrawn rod are:::; 12 steps apart within the allowed Completion Time of once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months is adequate.

D.2 Reduction of THERMAL POWER to :::; 50o/o RTP puts the core into a condition where rod position is not significantly affecting core peaking factors (Ref. 3). The allowed Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provides an acceptable period of time to verify the rod positions per Required Actions D.1.1 and D.1.2 or reduce power to :::; 50%> RTP.

E.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.

(continued)

DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 39 of 45 Tab B3!1 u3r1 O.DOC 1220.0756

Rod Position Indication B 3.1.7 BASES (continued)

SURVEILLANCE SR 3.1.7.1 REQUIREMENTS Verification that the DRPI agrees with the demand position within 12 steps ensures that the DRPI is operating correctly. Verification at 24, 48, 120, and 228 steps withdrawn for the control and shutdown banks provides assurance that the DRPI is operating correctly over the full range of indication.

This surveillance is performed prior to reactor criticality after each removal of the reactor head, since there is potential for unnecessary plant transients if the SR were performed with the reactor at power.

10 CFR 50, Appendix A, GDC 13, 1971 (associated with 1967 GDCs 12, 13, 14, and 15 per UFSAR Appendix 3.1A).

UFSAR, Chapter 15.

3. WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control and F0 Surveillance Technical Specification,"

February 1994.

4. WCAP-12472-P-A, "BEACON Core Monitoring and Operations Support System," August 1994.

5. WCAP-12472-P-A, Addendum 4, Revision 0, "BEACON Core Monitoring and Operations Support System," September 2012 DIABLO CANYON - UNITS 1 & 2 Rev 1OA Page 40 of 45 Tab_B3!1 u3r10.DOC 1220.0756

Enclosure Attachment 3 PG&E Letter DCL-17 -076 Technical Specification BASES INSERTs INSERT 1 The SR is modified by a Note that permits it to not be performed for rods associated with an inoperable demand position indicator or an inoperable rod position indicator. The alignment limit is based on the demand position indicator which is not available if the indicator is inoperable. LCO 3.1.7, "Rod Position Indication," provides Actions to verify the rods are in alignment when one or more rod position indicators are inoperable.

INSERT 2 The LCO is modified by a Note indicating the LCO requirement is not applicable to shutdown banks being inserted while performing SR 3.1.4.2. This SR verifies the freedom of the rods to move, and may require the shutdown bank to move below the LCO limits, which would normally violate the LCO. This Note applies to each shutdown bank as it is moved below the insertion limit to perform the SR. This Note is not applicable should a malfunction stop performance of the SR.

INSERT 3 A.1. A.2.1. A.2.2. and A.3 If one shutdown bank is inserted less than or equal to 16 steps below the insertion limit, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to restore the shutdown bank to within the limit. This is necessary because the available SDM may be reduced with a shutdown bank not within its insertion limit. Also, verification of SDM or initiation of boration within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is required, since the SDM in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1 ).

If a shutdown bank is not within its insertion limit, SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.

While the shutdown bank is outside the insertion limit, all control banks must be within their insertion limits to ensure sufficient shutdown margin is available. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is sufficient to repair most rod control failures that would prevent movement of a shutdown bank.

INSERT 4 The LCO is modified by a Note indicating the LCO requirement is not applicable to control banks being inserted while performing SR 3.1.4.2. This SR verifies the freedom of the rods to move, and may require the control bank to move below the LCO limits, which would normally violate the LCO. This Note applies to each control bank as it is moved below the insertion limit to perform the SR. This Note is not applicable should a malfunction stop performance of the SR.

Enclosure Attachment 3 PG&E Letter DCL-17-076 Technical Specification BASES INSERTs (continued)

INSERT 5 A.1, A.2.1, A.2.2, and A.3 If Control Bank A, B, or C is inserted less than or equal to 16 steps below the insertion, sequence, or overlap limits, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to restore the control bank to within the limits.

Verification of SDM or initiation of boration within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is required, since the SDM in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1 ).

If a control bank is not within its insertion limit, SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.

While the control bank is outside the insertion, sequence, or overlap limits, all shutdown banks must be within their insertion limits to ensure sufficient shutdown margin is available and that power distribution is controlled. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is sufficient to repair most rod control failures that would prevent movement of a control bank.

Condition A is limited to Control banks A, B, or C. The allowance is not required for Control Bank D because the full power bank insertion limit can be met during performance of the SR 3.1.4.2 control rod freedom of movement (trippability) testing.

INSERT 6 Required Action A.1 requires verification of the position of a rod with an inoperable DRPI once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months which may put excessive wear and tear on the moveable incore detector system if it is used to meet the Required Action, Required Action A.2.1 provides an alternative. Required Action A.2.1 requires verification of rod position using core power distribution measurement information every 31 EFPD, which coincides with the normal use of the system to verify core power distribution.

Required Action A.2.1 includes six distinct requirements for verification of the position of rods associated with an inoperable DRPI using core power distribution measurement information:

a. Initial verification within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of the inoperability of the DRPI;

b. Re-verification once every 31 Effective Full Power .Days (EFPD) thereafter;

c. Verification within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months if rod control system parameters indicate unintended rod movement. An unintended rod movement is defined as the release of the rod's stationary gripper when no action was demanded either manually or automatically from the rod control system, or a rod motion in a direction other than the direction demanded by the rod control system. Verifying that no unintended rod movement has occurred is performed by monitoring the rod control system stationary gripper coil current for indications of rod movement;

Enclosure Attachment 3 PG&E Letter DCL-17-076 Technical Specification BASES INSERTs (continued)

d. Verification within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months if the rod with an inoperable DRPI is intentionally moved greater than 12 steps;

e. Verification prior to exceeding 50%> RTP if power is reduced below 50% RTP; and

f. Verification within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of reaching 100°/o RTP if power is reduced to less than 100°/o RTP.

Should the rod with the inoperable DRPI be moved more than 12 steps, or if reactor power is changed, the position of the rod with the inoperable DRPI must be verified.

Required Action A.2.2 states that the inoperable DRPI must be restored to OPERABLE status prior to entering MODE 2 from MODE 3. The repair of the inoperable DRPI must be performed prior to returning to power operation following a shutdown.

INSERT 7 The inoperable DRPis must be restored, such that a maximum of one DRPI per group is inoperable, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

INSERT 8 With one DRPI inoperable in one or more groups and the affected groups have moved greater than 24 steps in one direction since the last determination of rod position, additional actions are needed to verify the position of rods within inoperable DRPI. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , the position of the rods with inoperable position indication must be determined using the core power distribution measurement information to verify INSERT 9 The Surveillance is modified by a Note which states it is not required to be met for DRPis associated with rods that do not meet LCO 3.1.4. If a rod is known to not to be within 12 steps of the group demand position, the ACTIONS of LCO 3.1.4 provide the appropriate Actions.

DCL-17-076, Revision to Technical Specifications to Adopt Technical Specifications Task Force TSTF-547, Revision 1, Clarification of Rod Position Requirements (License Amendment Request 17-01)

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DCL-17-076, Revision to Technical Specifications to Adopt Technical Specifications Task Force TSTF-547, Revision 1, Clarification of Rod Position Requirements (License Amendment Request 17-01)

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