ML042790255

Issuance of Amendments 174 & 176, Re Technical Specifications on Ac/Dc Sources

ML042790255
Person / Time
Site:	Diablo Canyon
Issue date:	09/28/2004
From:	Donohew J NRC/NRR/DLPM/LPD2
To:	Rueger G Pacific Gas & Electric Co
Donohew J N, NRR/DLPM,415-1307
Shared Package
ML042790160	List: ML042790255
References
TAC MB9476, TAC MB9477
Download: ML042790255 (23)

Text

September 28, 2004 Mr. Gregory M. Rueger Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P. O. Box 3 Avila Beach, CA 93424

SUBJECT:

DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS - TECHNICAL SPECIFICATIONS 3.8.1 AND 3.8.4 - AC AND DC SOURCES (TAC NOS. MB9476 AND MB9477)

Dear Mr. Rueger:

The Commission has issued the enclosed Amendment No. 174 to Facility Operating License No. DPR-80 and Amendment No. 176 to Facility Operating License No. DPR-82 for the Diablo Canyon Power Plant, Unit Nos. 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TS) in response to your application dated May 29, 2003 (DCL 061), as supplemented by letters dated December 23, 2003 (DCL-03-178), and May 7, 2004 (DCL-04-055).

The amendments revise several surveillance requirements (SRs) in TS 3.8.1 on alternating current sources for plant operation. The revised SRs have notes deleted or modified to adopt in part the staff-approved TSTF-283, Revision 3, which will allow these revised SRs to be performed, or partially performed, in reactor modes that previously were not allowed by the TSs. The proposed changes to SRs 3.8.4.7 and 3.8.4.8 for direct current sources were withdrawn in your "DCL-04-055, Supporting Information for License Amendment Request (LAR) 03-07. Revision to Technical Specifications (TS) 3.8.1 AC Sources - Operating & [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid. DC Sources - Operating Surveillance Requirements|letter dated May 7, 2004]]. The enclosed Notice of Partial Withdrawal of Application for Amendment to Facility Operating License has been forwarded to the Office of the Federal Register for publication.

A copy of the related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-275 and 50-323

Enclosures:

1. Amendment No. 174 to DPR-80

2. Amendment No. 176 to DPR-82

3. Safety Evaluation

4. Notice of Partial Withdrawal

cc w/encls: See next page

September 28, 2004 Mr. Gregory M. Rueger Senior Vice President, Generation and Chief Nuclear Officer Pacific Gas and Electric Company Diablo Canyon Power Plant P. O. Box 3 Avila Beach, CA 93424

SUBJECT:

DIABLO CANYON POWER PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENT - TECHNICAL SPECIFICATIONS 3.8.1 AND 3.8.4 - AC AND DC SOURCES (TAC NOS. MB9476 AND MB9477)

Dear Mr. Rueger:

The Commission has issued the enclosed Amendment No. 174 to Facility Operating License No. DPR-80 and Amendment No. 176 to Facility Operating License No. DPR-82 for the Diablo Canyon Power Plant, Unit Nos. 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TS) in response to your application dated May 29, 2003 (DCL 061), as supplemented by letters dated December 23, 2003 (DCL-03-178), and May 7, 2004 (DCL-04-055).

The amendments revise several surveillance requirements (SRs) in TS 3.8.1 on alternating current sources for plant operation. The revised SRs have notes deleted or modified to adopt in part the Staff-approved TSTF-283, Revision 3, which will allow these revised SRs to be performed, or partially performed, in reactor modes that previously were not allowed by the TSs. The proposed changes to SRs 3.8.4.7 and 3.8.4.8 for direct current sources were withdrawn in your "DCL-04-055, Supporting Information for License Amendment Request (LAR) 03-07. Revision to Technical Specifications (TS) 3.8.1 AC Sources - Operating & [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid. DC Sources - Operating Surveillance Requirements|letter dated May 7, 2004]]. The enclosed Notice of Partial Withdrawal of Application for Amendment to Facility Operating License has been forwarded to the Office of the Federal Register for publication.

A copy of the related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-275 DISTRIBUTION:

and 50-323 PUBLIC GHill (4)

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Enclosures:

1. Amendment No. 174 to DPR-80 RidsNrrDlpmPdiv (HBerkow) GMorris

2. Amendment No. 176 to DPR-82 RidsNrrPMGShukla

3. Safety Evaluation RidsNrrLAEPeyton

4. Notice of Partial Withdrawal RidsOgcRp RidsAcrsAcnwMailCenter cc w/encls: See next page RidsRegion4MailCenter (B. Jones)

RJenkins

• See memo dated 08/09/2004 RidsNrrDlpmPdiv2 (RGramm)

TS: ML: 042780529 NRR-100 ACCESSION NO.: ML042790255 PKG: ML042790160 NRR-058 OFFICE PDIV-2/PM PDIV-2/LA EEIB/SC IROB-A/SC OGC PDIV-2/SC NAME JDonohew EPeyton RJenkins*

TBoyce SZipkin RGramm DATE 8/17/04 8/16/04 08/09/2004 9/16/04 9/24/04 9/27/04 DOCUMENT NAME: OFFICIAL RECORD COPY Corrections made for OGC comments 9/24/04-JND

PACIFIC GAS AND ELECTRIC COMPANY DOCKET NO. 50-275 DIABLO CANYON NUCLEAR POWER PLANT, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 174 License No. DPR-80 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Pacific Gas and Electric Company (the licensee) dated May 29, 2003, as supplemented by letters dated December 23, 2003, and May 7, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-80 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.

174, are hereby incorporated in the license. Pacific Gas and Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance including the incorporation of the changes to the Technical Specification Bases for Technical Specification 3.8.1 as described in the licensees letters dated May 29 and December 23, 2003, and May 7, 2004, and the NRC safety evaluation attached to this amendment. This includes the revision of procedures to instruct operator action to be taken to manually reset the emergency diesel generator, as discussed in Section 4.3 of the licensees May 29, 2003, letter.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Robert A. Gramm, Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 28, 2004

PACIFIC GAS AND ELECTRIC COMPANY DOCKET NO. 50-323 DIABLO CANYON NUCLEAR POWER PLANT, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 176 License No. DPR-82 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Pacific Gas and Electric Company (the licensee) dated May 29, 2003, as supplemented by letter dated December 23, 2003, and May 7, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-82 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No.

176, are hereby incorporated in the license. Pacific Gas and Electric Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 60 days of the date of issuance including the incorporation of the changes to the Technical Specification Bases for Technical Specification 3.8.1 as described in the licensees letters dated May 29 and December 23, 2003, and May 7, 2004, and the NRC safety evaluation attached to this amendment. This includes the revision of procedures to instruct operator action to be taken to manually reset the emergency diesel generator, as discussed in Section 4.3 of the licensees May 29, 2003, letter.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Robert A. Gramm, Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: September 28, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 174 TO FACILITY OPERATING LICENSE NO. DPR-80 AND AMENDMENT NO. 176 TO FACILITY OPERATING LICENSE NO. DPR-82 DOCKET NOS. 50-275 AND 50-323 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.8-5 3.8-5 3.8-6 3.8-6 3.8-7 3.8-7 3.8-8 3.8-8 3.8-9 3.8-9 3.8-10 3.8-10

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.174 TO FACILITY OPERATING LICENSE NO. DPR-80 AND AMENDMENT NO.176 TO FACILITY OPERATING LICENSE NO. DPR-82 PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT, UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323

1.0 INTRODUCTION

By application dated May 29, 2003, as supplemented by letters dated December 23, 2003, and May 7, 2004, Pacific Gas and Electric Company (or the licensee) requested changes to the Technical Specifications (Appendix A to Facility Operating License Nos. DPR-80 and DPR-82) for the Diablo Canyon Power Plant, Units 1 and 2. The amendments would modify several surveillance requirements (SRs) in Technical Specifications (TSs) 3.8.1 and 3.8.4 on alternating current (AC) and direct current (DC) sources, respectively, for plant operation. The revised SRs would have notes deleted or modified to allow the SRs to be performed, or partially performed, in reactor modes that are currently not allowed by the TSs. The current SRs are not allowed to be performed in Modes 1 and 2, and several of the SRs also cannot be performed in Modes 3 and 4. The purpose of the proposed amendments is to allow testing of the following AC and DC electrical sources in modes not currently allowed: the qualified circuits between the offsite transmission network and the onsite Class 1E electrical power distribution system, the emergency diesel generators (EDGs), and the DC electrical power subsystem.

The proposed changes would do the following:

Remove mode restrictions in SR 3.8.1.10 (EDG full-load rejection test), SR 3.8.1.13 (EDG protective-trip bypass test), and SR 3.8.1.14 (EDG endurance and margin test) that prohibit performing the required testing during Modes 1 and 2.

Remove mode restrictions in SR 3.8.1.8 (transfer of AC sources), SR 3.8.1.9 (post accident EDG load rejection test), SR 3.8.1.11 (emergency bus and EDG loss-of-offsite power (LOOP) test), SR 3.8.1.12 (EDG auto-start on safety injection (SI) actuation signal test), SR 3.8.1.16 (EDG synchronizing test), SR 3.8.1.17 (EDG test mode change-over test), SR 3.8.1.18 (load block sequencing test), SR 3.8.1.19 (emergency bus and EDG combined SI actuation signal and LOOP test), SR 3.8.4.7 (battery service test), and SR 3.8.4.8 (battery discharge test) to allow performance or partial performance of the SRs during currently prohibited modes in order to re-establish operability following corrective maintenance, modifications, deficient or incomplete surveillance testing, and other operability concerns during plant operation.

These changes are consistent with the Nuclear Regulatory Commission-approved Industry/Technical Specification Task Force (TSTF) 283, Revision 3 (TSTF-283) on eliminating mode restrictions on the performance of surveillances in TSs 3.8.1 and 3.8.4. The NRC has approved the TSTF for inclusion in the improved Standard Technical Specifications in NUREG-1431 for Westinghouse plants, and for consideration for being added to plant TSs.

The intent of the TSTF is to allow testing of the EDGs and Class 1E batteries in modes not currently allowed for the purpose of maintaining or reestablishing system or component operability (e.g., post maintenance testing), provided a safety assessment is made before the testing for operability.

The proposed changes to SRs 3.8.4.7 and 3.8.4.8, for the DC electric power subsystems were withdrawn by the licensee in its letter of May 7, 2004.

As stated in the application, the above changes in TS 3.8.1 for the AC electric sources would provide the licensee with flexibility in outage scheduling and reduce outage critical path time since these EDG surveillance tests would no longer have to be performed during an outage. In addition, the changes will potentially allow the licensee to avoid a plant shutdown if corrective maintenance (planned or unplanned) performed during power operation results in the need to perform any of the above surveillances to demonstrate operability and to maximize its flexibility in responding to an event during shutdown when other engineered safety feature equipment may be out-of-service.

The licensees description of the proposed changes, technical analysis, and regulatory analysis in support of its proposed license amendments is given in Sections 2.0, 4.0 and 5.2, respectively, of the licensees application. The detailed evaluation below will support the conclusion that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

The licensee also provided responses to questions in e-mails sent to the licensee and clarification about information submitted by letter (see ADAMS Accession Nos. ML040300507 and ML040580134). The questions were to have the licensee clarify information on (1) equivalent bus voltages given in the response to NRC Question 3a and (2) operational restrictions in the licensees application and supplemental letter. The additional information provided in the e-mail and the supplemental letters dated December 23, 2003, and May 7, 2004, does not expand the scope of the application as noticed and does not change the NRC staffs original proposed no significant hazards consideration determination published in the Federal Register on July 8, 2003 (68 FR 40715).

2.0 REGULATORY EVALUATION

The proposed amendments involve the surveillance testing of the emergency buses and EDGs that currently are not allowed in Modes 1 and 2. The regulatory requirements involved are the following regulations:

General Design Criterion (GDC) 17, "Electric power systems," of Appendix A, "General Design Criteria for Nuclear Power Plants," to Title 10, Part 50, of the Code of Federal Regulations (CFR), requires, in part, that nuclear power plants have onsite and offsite electric power systems to permit the functioning of structures, systems, and components that are important to safety. The onsite system is required to have sufficient independence, redundancy, and testability to perform its safety function, assuming a single failure. The offsite power system is required to be supplied by two physically independent circuits that are designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. In addition, this criterion requires provisions to minimize the probability of losing electric power from the remaining electric power supplies as a result of loss of power from the unit, the offsite transmission network, or the onsite power supplies.

GDC-18, "Inspection and testing of electric power systems," requires that electric power systems that are important to safety must be designed to permit appropriate periodic inspection and testing.

10 CFR 50.36(c)(3), "Technical Specifications," requires a licensees TSs to have SRs relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operations are within safety limits, and that the limiting conditions for operation (LCOs) will be met. The SRs may include mode restrictions based on the safety aspects of conducting the surveillances in excluded modes.

The licensee addresses the regulatory guides (RGs) for EDG electrical power systems within the sections of the Diablo Canyon Final Safety Analysis Report Update (FSAR Update) related to EDGs. In Sections 8.1.4.3, "Regulatory Guides," and 8.3.1.1.13.1, "Diesel Generator Unit Description," respectively, the licensee states the following:

Selection of Diesel-Generator Set Capacity for Standby Power Supplies. PG&E [the licensee] was originally licensed with respect to SG [Safety Guide] 9, which the NRC subsequently renamed RG 1.9. Hence, any reference to RG 1.9, Rev. 0, dated 1971, in essence refers to SG 9.

and The diesel generators have a net continuous electrical output rating of 2600 kW at 0.8 power factor (PF), and 2752 kW at 0.8 PF, for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year. Short-term ratings of the diesel generators are 3000 kW at 0.8 PF for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per year, 2860 kW at 0.8 PF for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 24-hour period, and 3250 kW at 0.8 PF for 30 minutes per 24-hour period.

During the starting sequence for the safeguards loads, these machines can also carry short-time overloads. During a design basis loading scenario with nominal timer interval, these machines maintain the electric power frequency within 5 percent, hold voltages to a minimum of 75 percent, and recover successfully by complying with SG 9 in all respects except for frequency recovery criteria. The frequency recovery is met by the applicable criteria of RG 1.9, Revision 2.

The RG 1.9 reference is to RG 1.9, "Selection, Design, Qualification and Testing of Emergency Diesel Generator Units Used As Class 1E Onsite Electric Power Systems at Nuclear Power Plants," Revision 2. RG 1.9 provides recommendations on the reactor modes that the EDGs should be tested, which is the subject of the proposed amendments.

Even though RG 1.9, Revision 2, does not recommend testing of the EDG in Modes 1 and 2, it appears that the licensees commitment to RG 1.9 is only to the frequency recovery criteria in that RG, which is not being changed in these amendments. Therefore, the licensee should not have to revise the Diablo Canyon FSAR Update because of these amendments. Changes to the design of the plant that are approved by the NRC are required to be included in an update of the FSAR on a schedule in accordance with 10 CFR 50.71(e).

3.0 BACKGROUND

The onsite power system for Diablo Canyon is provided with preferred power from the offsite system through two physically independent sources of power in accordance with GDC-17. The onsite Class 1E AC distribution system for each unit is divided into three load groups so that the loss of any one group does not prevent the minimum safety functions from being performed.

Each load group has connections to two offsite power sources and a single diesel generator.

Offsite power is supplied to 230 kV and 500 kV switchyard from the transmission network by two 230 kV transmission lines and three 500 kV transmission lines. These two electrically and physically separated circuits provide AC power through auxiliary and standby startup transformers to the 4.16 kV buses.

The onsite standby power system includes Class 1E AC and DC power supply capability for equipment used to achieve and maintain a cold shutdown of the plant and to mitigate the consequences of a design basis accident. With regard to the Class 1E AC power, each of the three Class 1E load groups, at the 4.16-kV bus level, is capable of being powered from an independent EDG (one per load group) which functions to provide power in the event of a loss of the preferred (offsite) power source. Undervoltage relays are provided for each 4.16-kV bus to detect an Undervoltage condition and automatically start the EDG in response to such a condition. The Class 1E DC system includes three separate 125 V DC battery supplies for Class 1E controls, instrumentation, power, and control inverters.

In the event of a loss-of-coolant accident (LOCA) and/or loss of offsite power (LOOP), the starting of Class 1E electrical loads is controlled by the sequence timers. In the event of a LOCA with preferred (offsite) power available to the 4.16-kV Class 1E bus(es), Class 1E loads are automatically sequentially loaded. The associated EDG will be automatically started but not connected to the bus. However, in the event that preferred (offsite) power is lost, EDG(s) automatically start via the EDG control circuitry. The sequence timers will function to start the required Class 1E loads in programmed time increments.

4.0 TECHNICAL EVALUATION

To allow testing of AC and DC electrical sources in TSs 3.8.1, in modes not currently allowed, the licensee has proposed the following changes to the TSs:

1.

Revise note to allow performance of SR 3.8.1.8, in Modes 1 and 2, to verify automatic and manual transfer to the required offsite circuit, and manual transfer to the delayed access circuit, of AC power sources from the normal offsite circuit.

2.

Revise Note 1 to allow performance of SR 3.8.1.9, in Modes 1 and 2, to verify each EDG rejects a load greater than or equal to its associated single post-accident load following load rejection.

3.

Delete the note stating surveillance shall not be performed in Modes 1 and 2 for SR 3.8.1.10 to verify each EDG at a power factor will not trip and voltage is maintained following a load rejection.

4.

Revise Note 2 to allow performance of portions of SR 3.8.1.11, in Modes 1, 2, 3, or 4, to verify de-energization of emergency buses, load shedding from emergency buses, and EDG auto-starts from standby condition on an actual or simulated loss of offsite power signal.

5.

Revise Note 2 to allow performance of portions of SR 3.8.1.12, in Modes 1 and 2, to verify EDG auto-starts from standby condition on an actual or simulated SI signal (SIS).

6.

Delete the note stating surveillance shall not be performed in Modes 1 and 2 for SR 3.8.1.13 to verify each EDGs automatic trips are bypassed when the EDG trip cutout switch is in the cutout position and the EDG is aligned for automatic operation.

7.

Delete Note 2 (and renumber the remaining notes) stating surveillance shall not be performed in Modes 1 and 2, unless required to demonstrate operability following unplanned maintenance, for SR 3.8.1.14 to verify each EDG operating for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

8.

Revise note to allow performance of SR 3.8.1.16, in Modes 1 through 4, to verify each EDG synchronizes with offsite power source, transfers loads to offsite power source, and returns to ready-to-load operation.

9.

Revise note to allow performance of portions of SR 3.8.1.17, in Modes 1 through 4, to verify, with an EDG operating in test mode and connected to its bus, an actual or simulated SI signal overrides the test mode.

10.

Revise note to allow performance of SR 3.8.1.18, in Modes 1 through 4, to verify each EDG and auto-transfer load sequencing timer is within its limits.

11.

Revise Note 2 to allow performance of portions of SR 3.8.1.19, in Modes 1 through 4, to verify de-energization of emergency buses, load shedding from emergency buses, and EDG auto-starts from standby condition on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated SI signal.

In revising or deleting the notes for the above SRs, the licensee is not changing either the frequency of conducting the SRs, the surveillance to be performed, or the performance criteria specified in the SRs. The only change is to the reactor modes that the surveillance may be performed.

For SRs 3.8.1.8 and 3.8.1.9, the notes would be revised such that the current note stating "This Surveillance shall not be performed in MODE 1 or 2" would be revised to state that "This Surveillance shall not normally be performed in Mode 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced." The changes to the current note are underlined.

Therefore, these SRs to reestablish operability could be performed in Modes 1 and 2, but an assessment must be performed by the licensee before the SRs are performed.

For SRs 3.8.1.10, 3.8.1.13, and 3.8.1.14, the note that states "This Surveillance shall not be performed in MODE 1 or 2" or "This Surveillance shall not be performed in MODE 1 or 2 unless required to demonstrate OPERABILITY following unplanned maintenance" would be deleted.

Therefore, these SRs could be performed in Modes 1 and 2.

For SRs 3.8.1.11, 3.8.1.17 and 3.8.1.19, the notes would be revised such that the current note stating "This Surveillance shall not be performed in MODE 1, 2, 3, or 4" would be revised to state that "This Surveillance shall not normally be performed in Mode 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced." The changes to the current note are underlined. Therefore, portions of these SRs to reestablish operability could be performed in Modes 1 and 2, but an assessment must be performed by the licensee before the SRs are performed.

For SR 3.8.1.12, the note would be revised such that the current note stating "This Surveillance shall not be performed in MODE 1 or 2" would be revised to state that "This Surveillance shall not normally be performed in Mode 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced." The changes to the current note are underlined. Therefore, portions of the SR to reestablish operability could be performed in Modes 1 and 2, but an assessment must be performed by the licensee before the SR is performed.

For SRs 3.8.1.16 and 3.8.1.18, the note would be revised such that the current note stating "This Surveillance shall not be performed in MODE 1, 2, 3, or 4" would be revised to state that "This Surveillance shall not normally be performed in Mode 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced." The changes to the current note are underlined. Therefore, these SRs could be performed in Modes 1 through 4, but an assessment must be performed by the licensee before the SRs are performed.

4.1 AC Sources Discussion The operability requirements for the onsite and offsite AC sources during plant operation in Modes 1, 2, 3, and 4 are specified in TS 3.8.1, AC sources - Operating. TS 3.8.1 includes SRs for monitoring the offsite sources and testing the EDGs. Currently, the SRs required in accordance with SR 3.8.1.10 (full-load rejection test), 3.8.1.13 (protective-trip bypass test), and 3.8.1.14 (endurance and margin test) may not be performed while the plant is at power (i.e.,

Mode 1 or 2). While in Mode 1, 2, 3, or 4, TS 3.8.1 requires that three EDGs remain operable The proposed changes would allow EDG testing to be performed during plant operation (i.e., in Modes 1, 2, 3, and 4) when all three EDGs are required to be operable in accordance with TS 3.8.1. Therefore, the EDG under test would be required to be operable. Any condition associated with the testing that would not allow the EDG to be operable would require the licensee to declare the EDG inoperable and enter the required actions in TS 3.8.1 for an inoperable EDG.

4.1.1 SRs 3.8.1.10, 3.8.1.13, and 3.8.1.14 The proposed changes to SR 3.8.1.10 (EDG full-load rejection test), SR 3.8.1.13 (EDG protective-trip bypass test), and SR 3.8.1.14 (EDG endurance and margin test) would remove the restrictions in the SRs that prohibit performing the required EDG testing in Modes 1 and 2.

The proposed changes are different from the changes to these SRs in TSTF-283 in that the TSTF changes would only allow testing of the EDGs in Modes 1 and 2 for reestablishing the operability of the EDGs. The licensees proposed changes would allow these SRs (1) to be performed during Modes 1 and 2 to meet the surveillance frequency of once per 18 months, and (2) not to be performed during refueling outages as currently scheduled. The licensee stated in its application that it proposed the changes to SRs 3.8.1.10, 3.8.1.13, and 3.8.1.14 to "help reduce the complexity of coordinating work and testing activities during refueling outages and could potentially reduce outage critical path time" (i.e., these SRs are not performed in the outage). The licensees proposed changes to these SRs would also meet the intent of the TSTF to avoid a plant shutdown if maintenance of the EDGs were performed during power operation.

4.1.1.1 SR 3.8.1.10 Performance of the full-load rejection test per SR 3.8.1.10 involves paralleling the EDG under test with the offsite power source (while the offsite source is supplying the bus), loading the EDG to the required load, and then opening the EDG output breaker. The degraded voltage protection remains connected to the bus during this evolution. Opening the EDG output breaker separates the EDG from its associated emergency bus and allows the offsite circuit to continue to supply the bus. If an SIS occurs during testing of the EDG with the EDG paralleled to offsite power, the auxiliary transformer bus feeder breaker would automatically trip, avoiding any potential overload of the EDG being tested. The EDG being tested would maintain bus voltage so there would be no shedding of any loads on the EDG and any additional required loads based on the SIS not on the EDG would be sequenced onto the EDG.

The concern associated with performing the full-load rejection test in Mode 1 or 2, as described in the TS Bases for SR 3.8.1.10, is that disconnecting the EDG while it is supplying power to the vital buses could cause undesirable electrical perturbations on the bus. Additionally, the EDG being tested is susceptible to grid disturbances while it is paralleled to the offsite source, and is potentially more susceptible to tripping due to the extra protection trip relays that are cut in during the test.

The occurrence of a grid disturbance is independent of testing performed pursuant to this SR, and the EDG is paralleled with the offsite source for a limited period of time before tripping the EDG breaker. The licensee stated that if a LOOP would occur from a grid fault or unit trip while the EDG is paralleled to offsite power, the EDG protective circuitry would disconnect the EDG if the auxiliary transformer feeder breaker failed to isolate the bus from the grid. If the auxiliary transformer feeder breaker isolated the bus from the grid during a LOOP, the EDG would continue to power the connected loads. In addition to the above, the licensees normal practices of risk management ensure that SRs of this type are not scheduled during periods in which the potential for grid or bus disturbances exists (such as severe weather or maintenance activities in the switchyard). Furthermore, the licensees experience with this test has shown that the voltage perturbation seen on the bus during and just after the load rejection is within two percent of nominal value and, therefore, not significant.

In the licensees response dated December 23, 2003, to an NRC staff request for additional information (RAI), the licensee noted that for the case when one of the two EDGs not under test becomes inoperable while an EDG test is underway, the decision to abort the test would be based on existing plant conditions, the purpose for performing the test, whether the test is one that affects EDG operability, what plant risk level is entered by the other EDG becoming inoperable, and the cause of the other EDGs inoperability, if known. The licensee also noted that for the case when the EDG under test becomes inoperable, it might be most prudent to complete the test if, for example, the test were being done to re-establish operability following corrective maintenance. If the EDG test had been initiated for routine on-line maintenance, the decision might be made to abort the test, particularly if the decision is made to protect the train associated with the EDG under test.

The decision to abort the test in the event one of the other two EDG becoming inoperable would also be influenced by the resultant entry into a more severe TS action statement for having two of three EDGs inoperable, which requires restoring one of the inoperable EDGs to operable status within two hours. TS 3.8.1, Condition E would be entered for two EDGs inoperable, with Required Action E.1 requiring restoring one EDG to operable status in two hours. The testing remaining on one EDG and the cause of the failure on other EDG would result in determining the shortest time to restore one EDG to operable status. The decision on which EDG to restore first would depend on the current condition of each EDG, including whether the nature and cause of the failure of the other EDG is immediately known. The NRC staff notes that the Maintenance Rule provision contained in 10 CFR 50.65(a)(4) states that before performing maintenance activities, the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The above discussion provides an example of this process. In any case, TS 3.8.1 Condition E adequately governs the situation.

4.1.1.2 SR 3.8.1.13 SR 3.8.1.13 requires verification that the non-emergency automatic protective trip functions for each EDG are bypassed on a loss-of-voltage signal concurrent with an SIS. The licensee currently performs this test apart from testing the EDG because it does not require running the EDG. The test procedure requires putting in place additional protective devices for the associated EDG.

The TS Bases for SR 3.8.1.13 currently note that it is prohibited to perform this surveillance during Modes 1 and 2 since its performance requires placing additional protective devices in place, making the EDG more vulnerable to a possible trip. Performing SR 3.8.1.13 in Modes 1 and 2 would still allow the EDG in test to respond to an auto-start signal and load automatically; however, the licensee explained that the EDG in test could be unavailable when the EDG protective trip features switch is in the cut-in position. For this test, the licensee stated that the duration of EDG unavailability is approximately five minutes and procedures instruct operators to promptly cut-out the protective features switch in an emergency. Because of the procedures and because the 5 minutes is significantly less than the current allowed outage time specified in the TSs for an inoperable EDG (i.e., 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />), the period of potential EDG unavailability is not considered significant. Also, the other two EDGs are operable and capable of mitigating a design basis accident.

4.1.1.3 SR 3.8.1.14 Performance of the endurance and margin test per SR 3.8.1.14 requires synchronizing, paralleling and loading the EDG with the offsite source and then running it continuously while loaded to its full-load capability for not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In accordance with the TSs, during the 24-hour run the EDG must be loaded and run at 110 percent of its continuous duty rating for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> if it has been determined that the auto-connected design loads have increased above the continuous duty rating of the EDG. As stated above, paralleling an EDG with the offsite source for testing does not render the EDG inoperable at Diablo Canyon. An SIS will override the test mode to automatically return the EDG to a standby/ready-to-load condition.

The concerns while performing the 24-hour endurance test in Mode 1 or 2 (as described in the TS Bases for SR 3.8.1.14) are that while the EDG is being tested, it is susceptible to grid disturbances. The EDG being tested is also potentially more vulnerable to a possible trip due to the extra protection trip relays that are operable during testing.

In Modes 1 and 2, during this testing of an EDG, the EDG would be considered inoperable and the licensee would enter TS 3.8.1 Condition B for one EDG being inoperable. The remaining two EDGs are operable, and a design basis accident would be mitigated and safe shutdown provided with the two operable EDGs. If another EDG became inoperable, the licensee would enter TS 3.8.1 Condition E for two EDGs being inoperable, and one of the two inoperable EDGs would be restored to operability within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, or LCO 3.0.4 would require plant shutdown in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (i.e., Mode 3).

The licensee stated that the potential for occurrence of a compounding grid disturbance during the time that an EDG is under test in accordance with this SR is considered remote. The licensees normal practices of risk management ensure that SRs of this type are not scheduled during periods in which the potential for grid or bus disturbances exists (such as during severe weather or maintenance activities in the switchyard). Additionally, the licensee stated that the availability of the other EDG is maintained during such testing since risk-management practices require the redundant, unaffected train (associated with the EDG under test) to be maintained in a protected status during such activities. In its "DCL-04-055, Supporting Information for License Amendment Request (LAR) 03-07. Revision to Technical Specifications (TS) 3.8.1 AC Sources - Operating & [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid. DC Sources - Operating Surveillance Requirements|letter dated May 7, 2004]], the licensee stated that it would add conditions to the TS Bases for SR 3.8.1.14 that encompasses the statements in Section 4.2 of this SE on managing risk in testing the EDGs.

In the event of a grid disturbance occurring while the EDG is paralleled to offsite power, protective relaying and instrumentation exists to mitigate the effects of such disturbances. The licensee noted that if an EDG protective trip were to occur in response to a disturbance in the offsite power system, procedures will instruct operator action to be taken to manually reset the EDG under test (assuming that the condition which caused the trip was promptly cleared or isolated) so that the EDG can be restarted and loads properly sequenced, if required.

4.1.1.4 Conclusion Based on the above, the NRC staff finds that the proposed changes to SR 3.8.1.10, SR 3.8.1.13, and SR 3.8.1.14, to allow testing the EDG in Modes 1 and 2, will not put the plant in an unsafe condition.

4.1.2 SRs 3.8.1.8, 3.8.1.9, 3.8.1.11, 3.8.1.12, and 3.8.1.16 through 3.8.1.19 The licensee proposed changes that would modify SR 3.8.1.8 (transfer of AC sources), SR 3.8.1.9 (post accident EDG load rejection test), SR 3.8.1.11 (emergency bus and EDG LOOP test), SR 3.8.1.12 (EDG safety injection actuation signal test), SR 3.8.1.16 (EDG synchronizing test), SR 3.8.1.17 (EDG test mode change-over test), SR 3.8.1.18 (load block sequencing test),

and SR 3.8.1.19 (emergency bus and EDG combined safety injection actuation signal and LOOP test) to allow the performance, or partial performance, of these surveillances during modes currently prohibited in order to re-establish operability following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated operability concerns during plant operation. The proposed changes will permit testing in additional modes not currently allowed by the TSs and these surveillances can be physically conducted in the proposed additional modes. Because it is only the current requirements in TS 3.8.1 that prevent testing in the additional modes proposed in these amendments, there were no changes to the plant to conduct these SRs in the additional modes.

The proposed changes will revise a note in each affected SR to permit testing of an EDG, emergency bus, or AC power source "provided an assessment determines the safety of the plant is maintained or enhanced." The changes for these SRs are the same as those given in TSTF-283. The licensee stated that it will update the Diablo Canyon TS Bases to be consistent with providing guidance relative to the safety assessment.

The testing of EDGs and emergency buses in SRs 3.8.1.11, 3.8.1.12, 3.8.17, and 3.8.1.19 are more complicated or intrusive than other SRs and would involve too great an impact or perturbation to the plant to be entirely performed during plant operation, therefore the note that would be added to these SRs permits a partial performance (i.e., portions of the surveillance or a partial surveillance) of the applicable SR to reestablish operability.

Because (1) the surveillances are not being changed by the proposed amendments and can be conducted in the modes proposed by the amendments, (2) the proposed notes require a safety assessment to be performed by the licensee before conducting the surveillance to ensure that plant safety is maintained or enhanced, and (3) the full or partial performance of the SR is to demonstrate operability of the EDGs, the NRC staff concludes that an unsafe condition should not exist when the licensee performs any of these SRs in reactor modes not currently allowed.

Allowing the licensee to make the determination, that performance of these SRs in modes not currently allowed is safe, is similar to the regulation 10 CFR 50.59 in which the licensee is allowed to make changes to the plant as described in the FSAR Update if the changes meet the criteria given in the regulation. The criteria for this situation is that the licensee must determine that in conducting the SR, the "safety of the plant is maintained or enhanced."

Based on the above, the NRC staff finds that the proposed changes to SRs 3.8.1.8, 3.8.1.9, 3.8.1.11, 3.8.1.12, and 3.8.1.16 through 3.8.1.19 to allow testing in Modes 1 and 2 and to SRs 3.8.1.11, 3.8.1.16, 3.8.1.17, 3.8.1.18, and 3.8.1.19 to allow testing in Modes 3 and 4, will not put the plant in an unsafe condition, and are consistent with the TSs in TSTF-283, Revision 3, and NUREG-1431, Revision 2.

4.2 On-Line Maintenance Risk Management In its application and in its supplemental letter dated December 23, 2003, which is the licensee's response to the NRC staffs RAI dated September 25, 2003, the licensee described how it would manage the risk of testing the EDG in modes not currently allowed by the TSs.

The licensee provided plant Procedure AD7.DC6, "On-line Maintenance Risk Management,"

Revision 7, dated October 24, 2002, in Enclosure 2 to its supplemental letter dated December 23, 2003.

The NRC staff asked the licensee to clarify if its application and supplemental letter dated December 23, 2003, which includes Procedure AD7.DC6, encompassed the following specific restrictions on the switchyard during the testing of the EDG in Modes 1 and 2 while the EDG is connected to the offsite power supply:

1.

Weather conditions will be evaluated prior to testing the EDG in Modes 1 and 2 connected to the offsite power supply and the testing would not be conducted during severe weather watches or warnings.

2.

The condition of the offsite power supply will be evaluated prior to testing the EDG in Modes 1 and 2 connected to the offsite power supply and testing would not be conducted if the offsite power supply is being challenged.

3.

No discretionary switchyard maintenance, including the main, auxiliary, or startup transformers, will be allowed during testing of the EDG in Modes 1 and 2 connected to the offsite power supply.

4.

No maintenance or testing that affects the reliability of the train not associated with the EDG being tested (i.e., the train associated with the EDG not being tested) will be conducted during testing of the EDG in Modes 1 and 2 connected to the offsite power supply. If any testing or maintenance of train must be performed at this time, then a 10 CFR 50.65(a)(4) evaluation will be performed prior to the EDG testing connected to the offsite power supply.

The licensee's response (ADAMS ML040580134) was that its discussion on risk management in its application dated May 29, 2003, and supplemental letter dated December 23, 2003, encompassed the above restrictions.

In its "DCL-04-055, Supporting Information for License Amendment Request (LAR) 03-07. Revision to Technical Specifications (TS) 3.8.1 AC Sources - Operating & [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid. DC Sources - Operating Surveillance Requirements|letter dated May 7, 2004]], the licensee stated that upon implementation of the amendments it would add information to the TS Bases for SR 3.8.1.14 that encompasses the statements made above. The NRC staff reviewed what would be added to the TS Bases for SR 3.8.1.14 and agrees that it encompasses the statements made above.

Based on the above evaluation, the NRC staff also concludes that the licensees on-line maintenance risk management procedure, which is covered by the licensees controls on revising plant procedures, is sufficient so that the management of risk while testing an EDG connected to the offsite power supply in Modes 1 and 2 is sufficient.

4.3 Conclusions The design of the onsite and offsite electric power systems for Diablo Canyon to permit the functioning of structures, systems, and components that are important to safety is not being changed by the proposed amendments. Further, the amendments do not change the testing of the EDG, only the modes in which the testing is conducted. Therefore, the plant continues to meet GDC-17.

The ability to inspect and test the safety-related electric power systems for Diablo Canyon, which must be designed to permit appropriate periodic inspection and testing, are not being changed by the amendments. Therefore, the plant continues to meet GDC-18.

For the reasons discussed in Sections 4.1 and 4.2 above, the NRC staff concludes that the proposed changes to SRs 3.8.1.8 through 3.8.1.14 and SRs 3.8.1.16 through 3.8.1.19, to allow testing the EDGs in Modes 1 and 2, and for SR 3.8.1.11 and SRs 3.8.1.16 through 3.8.1.19 in Modes 3 and 4, are acceptable. Therefore, based on this, the NRC staff also concludes that the proposed changes to TS 3.8.1 meet 10 CFR 50.36(c)(3).

Based on the evaluation given above and because the proposed amendments to TS 3.8.1 meet GDC-17, GDC-18, and 10 CFR 50.36(c)(3), the NRC staff also concludes that the proposed amendments to SRs 3.8.1.8 through 3.8.1.14 and SRs 3.8.1.16 through 3.8.1.19 are acceptable.

As discussed in Section 4.1.1.3, the licensee stated that procedures will be revised to instruct operator action to be taken to manually reset the EDG. The licensee agreed to revise the procedures during the implementation of the amendments.

4.4 Changes to the TS Bases The licensee presented the changes to the TS Bases for the proposed amendments in to its application and its letters dated December 23, 2003, and May 7, 2004. The NRC staff has reviewed the changes to the TS Bases for TS 3.8.1 and has no disagreement with these changes. The TS Bases changes for TS 3.8.4 will not be made because the proposed changes to SRs 3.8.4.7 and 3.8.4.8 were withdrawn by the licensee. The licensee has agreed to incorporate the TS Bases changes given in its submittals dated December 23, 2003, and May 7, 2004.

5.0 STATE CONSULTATION

In accordance with the Commissions regulations, the California State official was notified of the proposed issuance of the amendments. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendments change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (68 FR 40715). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: G. Morris Date:

7590-01-P UNITED STATES NUCLEAR REGULATORY COMMISSION PACIFIC GAS AND ELECTRIC COMPANY DOCKET NOS. 50-275 AND 50-323 NOTICE OF PARTIAL WITHDRAWAL OF APPLICATION FOR AMENDMENTS TO FACILITY OPERATING LICENSES The U.S. Nuclear Regulatory Commission (the Commission) has granted the request of Pacific Gas and Electric Company (the licensee) to partially withdraw its May 29, 2003, application for proposed amendments to Facility Operating License Nos. DPR-80 and DPR-82 for the Diablo Canyon Power Plant, Unit Nos. 1 and 2, respectively, located in San Luis Obispo County, California.

The proposed amendments would modify several surveillance requirements (SRs) in Technical Specifications (TSs) 3.8.1 and 3.8.4 on alternating current and direct current sources, respectively, for plant operation. The revised SRs would have notes deleted or modified to allow the SRs to be performed, or partially performed, in reactor modes that are currently not allowed by the TSs. The current SRs are not allowed to be performed in Modes 1 and 2.

Several of the current SRs also cannot be performed in Modes 3 and 4.

The Commission had previously issued a Notice of Consideration of Issuance of Amendment published in the Federal Register on July 8, 2003 (68 FR 40715). However, by "DCL-04-055, Supporting Information for License Amendment Request (LAR) 03-07. Revision to Technical Specifications (TS) 3.8.1 AC Sources - Operating & [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid. DC Sources - Operating Surveillance Requirements|letter dated May 7, 2004]], the licensee partially withdrew that portion of the amendment request pertaining to the proposed changes to TS 3.8.4.

For further details with respect to this action, see the application for amendments dated May 29, 2003, and the licensees "DCL-04-055, Supporting Information for License Amendment Request (LAR) 03-07. Revision to Technical Specifications (TS) 3.8.1 AC Sources - Operating & [[TS" contains a listed "[" character as part of the property label and has therefore been classified as invalid. DC Sources - Operating Surveillance Requirements|letter dated May 7, 2004]], which partially withdrew the application for license amendments. Documents may be examined, and/or copied for a fee, at the NRCs Public Document Room (PDR), located at One White Flint North, Public File Area O1 F21, 11555 Rockville Pike (first floor), Rockville, Maryland. Publicly available records will be accessible electronically from the Agencywide Documents Access and Management Systems (ADAMS) Public Electronic Reading Room on the internet at the NRC Web site, http://www.nrc.gov/reading-rm/adams/html. Persons who do not have access to ADAMS or who encounter problems in accessing the documents located in ADAMS, should contact the NRC PDR Reference staff by telephone at 1-800-397-4209, or 301-415-4737 or by email to pdr@nrc.gov.

Dated at Rockville, Maryland, this 28th day of September 2004.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Jack N. Donohew, Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Diablo Canyon Power Plant, Units 1 and 2 cc:

NRC Resident Inspector Diablo Canyon Power Plant c/o U.S. Nuclear Regulatory Commission P.O. Box 369 Avila Beach, CA 93424 Sierra Club San Lucia Chapter c/o Henriette Groot 1000 Montecito Road Cayucos, CA 93430 Ms. Nancy Culver San Luis Obispo Mothers for Peace P.O. Box 164 Pismo Beach, CA 93448 Chairman San Luis Obispo County Board of Supervisors Room 370 County Government Center San Luis Obispo, CA 93408 Mr. Truman Burns Mr. Robert Kinosian California Public Utilities Commission 505 Van Ness, Room 4102 San Francisco, CA 94102 Diablo Canyon Independent Safety Committee ATTN: Robert R. Wellington, Esq.

Legal Counsel 857 Cass Street, Suite D Monterey, CA 93940 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Richard F. Locke, Esq.

Pacific Gas & Electric Company P.O. Box 7442 San Francisco, CA 94120 Mr. David H. Oatley, Vice President and General Manager Diablo Canyon Power Plant P.O. Box 56 Avila Beach, CA 93424 City Editor The Tribune 3825 South Higuera Street P.O. Box 112 San Luis Obispo, CA 93406-0112 Mr. Ed Bailey, Radiation Program Director Radiologic Health Branch State Department of Health Services P.O. Box 942732 (MS 178)

Sacramento, CA 94234-7320 Mr. James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 31)

Sacramento, CA 95814 Mr. James R. Becker, Vice President Diablo Canyon Operations and Station Director Diablo Canyon Power Plant P.O. Box 3 Avila Beach, CA 93424