ML14319A006
| ML14319A006 | |
| Person / Time | |
|---|---|
| Site: | Brunswick, Diablo Canyon  |
| Issue date: | 11/13/2014 |
| From: | Tam P Plant Licensing Branch 1 |
| To: | Baldwin T Pacific Gas & Electric Co |
| References | |
| TAC MF3240, TAC MF3241 | |
| Download: ML14319A006 (8) | |
Text
1 NRR-PMDAPEm Resource From:
Tam, Peter Sent:
Thursday, November 13, 2014 3:28 PM To:
trb1@pge.com Cc:
Oesterle, Eric; Bucholtz, Kristy; Chernoff, Margaret
Subject:
Diablo Canyon proposed amendment using TSTF-505, Rev. 1 Mr. Baldwin:
The NRC staff is reviewing PG&Es November 25, 2013, application for amendment using TSTF-505, Rev. 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b. The NRC staff has written the following draft Request for Additional Information for PG&E to consider. I would be glad to arrange a conference call between the PG&E and NRC staffs to discuss these questions, to agree on how each question can be dispositioned, and to pick a target date for PG&Es formal response.
I am handling the project management of the subject review for your regular project manager, Mr. Eric Oesterle. You can find out more about me at the NRC public website by using my name as shown below for a search.
Peter S. Tam Senior Project Manager (Rehired Annuitant) 301-415-4098 DRAFT EQUEST FOR ADDITIONAL INFORMATION Background for Request #1 PG&E stated in the application that TSTF-505 also includes TS with mode 3 and 4 applicability, which Diablo Canyon is not adopting at this time. In addition, PG&E stated that PG&E is not proposing to apply the Risk-Informed Completion Time (RICT) Program in shutdown modes, but only in modes 1 and 2 and therefore, attachment 10 is not applicable to the Diablo Canyon submittal. PG&E proposes to add insert 2, OR in accordance with the Risk Informed Completion Time Program, to existing TS 3.3.1 Condition K (Re-lettered to Condition M in this amendment request) completion time for required action K.1. Condition K applies only to the source range neutron flux channels in modes 3, 4, or 5. When one source range neutron flux channel becomes inoperable required action K.1 requires that the channel be restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. However, insert 2 adds a RICT that would only be used in modes 3, 4, and 5.
Request for Additional Information #1 Please provide a proposed change without adding a RICT to current TS 3.3.1 required action K.1 or submit the required Probabilistic Risk Assessment (PRA) documentation for review.
Background for Request #2 PG&E proposes to re-letter TS 3.3.1 Condition W to Condition II and adds new insert 15. Current condition W applies to the seismic trip instrumentation and requires that an inoperable channel be placed in the trip position within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> or that the plant be placed in mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. New insert 15 adds condition KK, which requires the plant be in mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> if the required actions and the associated completion times of conditions B, C, E, F, G, H, Z, AA, BB, CC, DD, GG, HH, II, or JJ are not met. To correctly keep the usage
2 structure of TSs, required action W.2 should be deleted or condition II should be removed from new insert 15, since the requirement to be in mode 3 is duplicated.
NCLOSURE
3 Request for Additional Information #2 Please provide a proposed change that is structured in accordance with Section 1.0 use and application section in Diablo Canyons TS.
Background for Request #3 PG&E stated in the application that TSTF-505 also includes TS with mode 3 and 4 applicability, which Diablo Canyon is not adopting at this time. In addition, PG&E stated that PG&E is not proposing to apply the Risk-Informed Completion Time Program in shutdown modes, but only in modes 1 and 2 and therefore, attachment 10 is not applicable to the Diablo Canyon submittal. PG&E proposes to add insert 2, OR in accordance with the Risk Informed Completion Time Program, to existing TS 3.3.2 Condition D (Re-lettered to Condition F in this amendment request) completion time for required action D.1. Condition D applies to functions 1.d, 1.e, 4.d(1), 4.d(2), and 6.d. Function 4.d(2), Steam line isolation, steam line pressure negative rate-high, is required only in mode 3 when below P-11. When one channel becomes inoperable required action D.1 requires that the channel be restored to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. However, insert 2 adds a RICT that is not applicable in modes 3, 4, or 5.
Request for Additional Information #3 Please provide a proposed change without adding a RICT to current TS 3.3.2 function 4.d(2) or submit the required PRA documentation for review.
Background for Request #4 TSTF-505 modifies selected required actions to provide an optional RICT, in accordance with the risk informed completion time program and Nuclear Energy Institute (NEI) 06-09, revision 0, Risk-Managed Technical Specifications (RMTS) Guidelines. Both the risk informed completion time program and NEI 06-09 state that a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be operable. TSTF-505 places a condition note in the conditions that represent a loss of safety function that states that it is not applicable when the second channel/system is intentionally made inoperable. Licensees must add the condition note when requesting to add a RICT to a current TS condition that represents a loss of safety function, without this condition note the proposed change is unacceptable.
PG&E proposes to add insert 2 and change the completion time to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for required action E.4 in TS 3.4.11, Pressurizer Power Operated Relief Valves (PORVs). TS 3.4.11 condition e represents a loss of safety function in Diablo Canyons TSs.
Request for Additional Information #4 Please provide a proposed change to TS 3.4.11 condition e that prevents utilization of a RICT if the licensee intentionally enters the loss of safety function condition, or remove the proposed change.
Background for Request #5 PG&E proposes to: (1) replace TS 3.4.11 required actions e.4 and e.5 with new e.4 that allows one hour to restore Class I PORVs to operable status, (2) adds a RICT to new required action e.4, and current required actions f.2 and f.3, and (3) adds condition e to default condition g. Table 1, Excerpt from Diablo Canyons current TS 3.4.11, is enclosed for reference, if needed. Current condition f contains the type of required actions that specifies a time limit in which the Limiting Conditions for Operation (LCO) must be met. This time limit is the completion time to restore the inoperable components to an operable status. If this type of required action is not completed within the specified completion time, a shutdown may be required to place the unit in a mode in which the specification is not applicable.
4 Current condition g is the default condition for not completing condition f within the specified completion time and required actions g.2 and g.3 are designed to shutdown the plant, which exits the mode of applicability for TS 3.4.11.
However, current required action g.1 requires that action be initiated to restore the block valve(s) to operable status.
Required action g.1 is duplicative of required actions f.2 and f.3, and serves no purpose since, whether stated as a required action or not, correction of the entered condition is an action that may always be considered upon entering actions.
Request for Additional Information #5 Please explain the relevance of required action g.1 if, (1) proposed condition g is entered due to the required actions and associated completion time of proposed condition e not being met, and (2) proposed condition g is entered due to the required actions and associated completion times of condition f not being met, or provide a change that doesnt contain duplicated requirements.
Background for Request #6 PG&E proposes to delete: (1) and at least 100% of the ECCS flow equivalent to a single operable ECCS train available, from TS 3.5.2, condition a, (2) the note that distinguishes which required actions are applicable to which plant operations, in condition as completion time for TS 3.5.2 and TS 3.6.6 and (3) the required actions and completion times associated with TS 3.5.2 a.2.1, a.2.2, and a.2.3, and TS 3.6.6 a.2. These are considered deterministic changes because the proposed RICT is an option, and the condition can be entered and a choice can be made to complete the required actions using the existing completion times without assessing risk.
TSTF-505 doesnt delete any current requirements; it relocates the requirements to default conditions or replaces a LCO 3.0.3 shutdown with a built in shutdown condition.
Request for Additional Information #6 Please provide a technical safety basis for the proposed deterministic changes or remove the proposed changes from the application.
Background for Request #7 TSTF-505 modifies selected required actions to provide an optional RICT, in accordance with the risk informed completion time program and NEI 06-09, revision 0, Risk-Managed Technical Specifications Guidelines.
Both the risk informed completion time program and NEI 06-09 state that a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be operable. TSTF-505 places a condition note in the conditions that represent a loss of safety function that states that it is not applicable when the second channel/system is intentionally made inoperable. To be consistent with TSTF-505 licensees must add the condition note when requesting to add a RICT to a current TS condition that represents a loss of safety function, without this condition note the proposed change is unacceptable.
PG&E proposes to add or more, to conditions a, b, and c, along with adding a RICT to their completion times. This change would allow a RICT for one or more AC/120 VAC/DC buses. In addition, PG&E proposes to delete condition e, which is entered when two required Class 1E AC, DC, or 120 VAC vital buses with inoperable distribution subsystems that results in a loss of safety function. The proposed changes would allow voluntary entry when a loss of safety function exists, along with a RICT for conditions a, b, and c. This is unacceptable and is not permitted in accordance with the risk informed completion time program and NEI 06-09 guidelines.
Furthermore, the proposed changes are considered deterministic changes, which would allow a loss of safety function, in addition to the risk-informed changes because the proposed RICTs are an option, and the conditions can be entered and a choice can be made to complete the required actions using the existing completion times without assessing risk. A technical safety basis for the proposed deterministic changes was not provided in the application.
5 In order, to be consistent with TSTF-505 and to comply with the RICT program, the proposed changes would need to add the condition notes to conditions a, b, and c, as well as, changing the completion times of condition a, b, or c to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Request for Additional Information #7 Loss of safety function is not allowed in Diablo Canyons current TSs therefore; please provide one of the following: (1) a proposed change to TS 3.8.9 that is consistent with TSTF-505, including the loss of safety function condition note(s) and the one hour front stop completion time for new conditions that allow loss of safety function, (2) removal of the proposed changes from the application, or (3) a technical safety basis for the proposed deterministic changes (i.e., adding loss of safety function with the current completion times to conditions a, b, and c), along with proposed changes to TS 3.8.9 that are consistent with TSTF-505, including the loss of safety function condition note(s).
Background for Request #8 An oversight occurred during the U.S. Nuclear Regulatory Commission (NRC) review of TSTF-505, revision 1 and the -A was omitted from the reference to NEI 06-09, Revision 0 in the Risk Informed Completion Time Program in the administrative controls section.
Request for Additional Information #8 Provide a Risk Informed Completion Time Program (insert 38) that references NEI 06-09-A, revision 0.
Background for Request #9 and #10 An oversight occurred during the NRC review of TSTF-505, revision 1 and two specific scenarios were not satisfactorily addressed. PG&E is requested to address the scenarios below.
Request for Additional Information #9 For an emergent condition that has exceeded the front stop completion time, and the RICT has not yet been met, with all trains of equipment required by the TS LCO inoperable and the remaining function(s) considered PRA functional, explain any actions that would be taken and the approached used, if additional degradation did occur that impacts the PRA functionality? In addition, state any applicable TS RICT Program requirements and how they would be utilized?
Request for Additional Information #10 For an emergent condition, with all trains of vital component cooling water required by the TS 3.7.7 LCO inoperable and the remaining function(s) between both trains are considered PRA functional (i.e., neither train by itself is PRA functional but both trains together maintain PRA functionality). Explain the process for calculating the RICT and implementing it in this type of scenario (e.g., if a train is removed from service to perform corrective maintenance)? Include in your discussion the applicable TS RICT Program requirements regarding this condition.
Regulatory Analysis Basis 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit states:
Whenever a holder of a license, including a construction permit and operating license under this part, and an early site permit, combined license, and manufacturing license under part 52 of this chapter, desires to amend the license or permit, application for an amendment must be filed with the Commission, as specified in §§ 50.4 or 52.3 of this chapter, as applicable, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
6
7 Table 1 Excerpt from Diablo Canyons current TS 3.4.11 CONDITION REQUIRED ACTION COMPLETION TIME E. Two Class I PORVs inoperable for reasons other than excessive seat leakage.
E.1 Initiate action to restore Class I PORVs to OPERABLE status.
AND E.2 Close associated block valves.
AND E.3 Remove power from associated block valves.
AND E.4 Be in MODE 3.
AND E.5 Be in MODE 4.
Immediately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 1 hour 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours F. More than one block valve inoperable.
NOTE-------------------
Required Actions do not apply when block valve is inoperable solely as result of complying with Required Actions B.2 or E.3 F.1 Place associated PORVs in manual control.
AND F.2 Restore one block valve for a Class I PORV to OPERABLE status.
AND F.3 Restore remaining block valve for a Class I PORV to OPERABLE status.
OR F.4 If the remaining block valve is associated with the non-Class I PORV, close the block valve and remove its power.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 2 hours 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 72 hours G. Required Action and associated Completion Time of Condition F not met G.1 Initiate action to restore block valve(s) to OPERABLE status.
AND G.2 Be in MODE 3.
AND G.3 Be in MODE 4.
Immediately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours
Hearing Identifier:
NRR_PMDA Email Number:
1687 Mail Envelope Properties (Peter.Tam@nrc.gov20141113152800)
Subject:
Diablo Canyon proposed amendment using TSTF-505, Rev. 1 Sent Date:
11/13/2014 3:28:17 PM Received Date:
11/13/2014 3:28:00 PM From:
Tam, Peter Created By:
Peter.Tam@nrc.gov Recipients:
"Oesterle, Eric" <Eric.Oesterle@nrc.gov>
Tracking Status: None "Bucholtz, Kristy" <Kristy.Bucholtz@nrc.gov>
Tracking Status: None "Chernoff, Margaret" <Margaret.Chernoff@nrc.gov>
Tracking Status: None "trb1@pge.com" <trb1@pge.com>
Tracking Status: None Post Office:
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