Text

Response to NRC Request for Additional Information Regarding License Amendment Request 13-02, Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision, 1...
	ML15036A592
Person / Time
Site:	Diablo Canyon
Issue date:	02/05/2015
From:	Welsch J; Pacific Gas & Electric Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PG&E Letter DCL-15-007
	Download: ML15036A592 (45)
	v • d • e

m Pacific Gas and

~&~ Electric Company James M. Welsch Diablo Canyon Power Plant Site Vice President Mail Code 104/6 P. 0. Box 56 Avila Beach, CA 93424 February 5, 2015 805.545.3242 Internal: 691.3242 Fax : 805.545.4884 PG&E Letter DCL-15-007 U.S. Nuclear Regulatory Commission 10 CFR 50.90 ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Response to NRC Request for Additional Information Regarding License Amendment Request 13-02. "Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505. Revision 1. 'Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48'"

Reference:

1. PG&E Letter DCL-13-1 06, License Amendment Request 13-02, Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, "Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48," dated November 25, 2013

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted License Amendment Request (LAR) 13-02 that proposes an amendment that would modify Technical Specification (TS) requirements to permit the use of Risk Informed Completion Times in accordance with Technical Specifications Task Force-505, Revision 1, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b."

On November 13, 2014, the NRC staff requested additional information required to complete the review of LAR 13-02. PG&E's responses to the staff's questions are provided in the Enclosure.

In LAR 13-02, forTS 3.8.4, "DC Sources- Operating," PG&E proposed a revised ConditionE for "Two DC electrical power subsystems inoperable." The Diablo Canyon direct current (DC) bus design includes three Class 1E DC electrical power subsystems. In LAR 13-02, PG&E could have proposed a TS 3.8.4 Condition E that applies to "Two or more electrical power subsystems inoperable" to be consistent with the Diablo Canyon design that includes three DC electrical power subsystems. Therefore, PG&E proposes a revised change to TS 3.8.4 Condition E, such that it also applies to three DC electrical power subsystems inoperable. The description and basis for the additional TS 3.8.4 change is included in the Enclosure.

A member of the STARS (Strategic Team ing and Resource Sharing) Alliance Callaway

Diablo Canyon

Palo Verde

Wolf Creek

Document Control Desk PG&E Letter DCL-15-007 February 5, 2015 Page2 In addition, two typographical errors contained in the TS markup Inserts in Reference 1 are corrected iri the Enclosure. to the Enclosure provides marked-up TS pages, Attachment 2 to the Enclosure provides retyped TS pages, and Attachment 3 to the Enclosure provides marked-up TS Bases pages for information only. The pages contained in these three enclosures supersede those same pages previously provided in Attachments 1, 2, and 3 of the Enclosure of Reference 1.

This information does not affect the results of the technical evaluation or the no significant hazards consideration determination previously transmitted in Reference 1.

This communication contains a new commitment (as defined in NEI 99-04) to be implemented following NRC approval of the LAR. The commitment is contained in Attachment 4 to the Enclosure.

In accordance with site administrative procedures and the Quality Assurance Program, this response to the staff requested additional information has been reviewed by the Plant Staff Review Committee.

If you have any questions, or require additional information, please contact Philippe Soenen at (805) 545-6984.

I state under penalty of perjury that the foregoing is true and correct.

Executed on February 5, 2015.

Sincerely, r-A__- ~~.-._t_...,

);J,;s~. Welsch Site Vice President kjse/4328 50672902 Enclosure cc: Diablo Distribution cc/enc: Marc L. Dapas, NRC Region IV Administrator Thomas R. Hipschman, NRC Senior Resident Inspector Siva P. Lingam, NRR Project Manager Gonzalo L. Perez, Branch _Chief, California Dept of Public Health A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

Diablo Canyon

Palo Verde

Wolf Creek

Enclosure PG&E Letter DCL-15-007 PG&E Response to NRC Request for Additional Information Regarding License Amendment Request 13-02, "Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times- RITSTF Initiative 48" '

NRC Question 1:

Background for Request #1 PG&E stated in the application that TSTF-505 also includes [Technical Specification] (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 Min 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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

However, insert 2 adds a RICT that would only be used in modes 3, 4, and 5.

Request for ~dditionallnformation #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.

PG&E Response:

PG&E will delete Insert 2 for current Technical Specification (TS) 3.3.1 Required Action K.1 (proposed TS 3.3.1 Required Action M.1) on TS page 3.3-4 contained in to the Enclosure of License Amendment Request (LAR) 13-02. With this change, a RICT is no longer added to current TS Required Action K.1. The revised TS marked-up and retyped pages are contained in Attachments 1 and 2 to the Enclosure, respectively.

NRC Question 2:

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months or that the plant be placed in mode 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . New insert 15 adds condition 1

Enclosure PG&E Letter DC L-15-007 KK, which requires the plant be in mode 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months if the required actions and the associated completion times of conditions B, C, E, F, G, H, Z, AA, BB, CC, DO, GG, HH, II, or JJ are not met. To correctly keep the usage 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.

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 Canyon's TS.

PG&E Response:

PG&E will revise the TS 3.3.1 Insert 15 to delete new Condition II from new Condition Action KK. With this change, the requirement to be in Mode 3 will not be duplicated. The revised (TS marked-up) Insert 15, retyped TS 3.3.1 page, and (TS Bases marked-up) Insert B-15 pages are contained in Attachments 1, 2, and 3 to the Enclosure, respectively.

NRC Question 3:

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 an*d 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 0 (Re-lettered to Condition Fin this amendment request) completion time for required action D. 1. Condition 0 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . However, insert 2 adds a Rlc;T 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.

PG&E Response:

PG&E agrees that a RICT is not applicable to engineered safety features actuation system (ESFAS) function 4.d(2) because its MODE of applicability does not include 2

Enclosure PG&E Letter DCL-15-007 MODEs 1 and 2. However, Condition F is also applicable to other ESFAS functions which do include MODEs 1 and 2 applicability, and therefore a RICT would be appropriate to those functions while in MODEs 1 and 2. Each of these functions also has applicability in MODE 3. Technical Specifications Task Force (TSTF)-505 did not provide separate Conditions for these cases where the MODE of applicability included both MODEs 1 and 2 and lower MODEs. The Administrative Controls section identifies the MODE of applicability for the RICT Program as MODEs 1 and 2, and so if a Condition with provision to use the RICT Program is entered while in a lower MODE, the RICT Program is not applicable. This is implemented in the Diablo Canyon proposed TS in TS 5.5.20.b. Operations personnel have been trained that a RICT cannot be utilized in MODES 3-5, and therefore they would not attempt to use the software to calculate a RICT in MODEs 3, 4, or 5. In addition, the proposed TS 5.5.20.b restriction that "A RICT may only be utilized in MODE 1 and 2," is being incorporated in the plant procedures for the Risk Informed Completion Time

Program to provide a reminder to operations personnel that a RICT cannot be utilized in MODES 3-5. This, in part, meets existing TS 5.4.1 that states written procedures shall be established, implemented, and maintained covering all programs specified in Specification 5.5.

While it would be possible to provide a new, separate Condition to address Function 4.d(2) which does not include the provision to apply the RICT Program, this would not be consistent with TSTF-505, and PG&E believes this is not necessary based on the required provisions of proposed TS 5.5.20.b.

NRC Question 4:

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 hot 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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 Canyon's TSs.

3

Enclosure PG&E Letter DCL-15-007 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.

PG&E Response:

PG&E will revise the TS 3.4.11 to add a note in the Condition E column to state, "Not applicable when second Class I PORV intentionally made inoperable." This change prevents utilization of a RICT if proposed TS 3.4.11 Condition E is intentionally entered. The revised TS marked-up, retyped, and TS Bases marked-up pages are contained in Attachments 1, 2, and 3 to the Enclosure, respectively.

NRC Question 5:

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 conditione to default condition g. Table 1, "Excerpt from Diablo Canyon's 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.

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 doesn't contain duplicated requirements.

4

Enclosure PG&E Letter DCL-15-007 PG&E Response:

PG&E will revise the TS 3.4.11 to remove Required Action G.1, renumber Required Action G.2 to G.1, and renumber Required Action G.3 to G.2. This change eliminates duplicative requirements to initiate action to restore block valves to OPERABLE status. The revised TS marked-up, retyped, and TS Bases marked-up pages are contained in Attachments 1, 2, and 3 to the Enclosure, respectively.

NRC Question 6:

Background for Request #6 PG&E proposes to delete: (1) ({and at least 100% of the EGGS flow equivalent to a single operable EGGS 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 a's completion time forTS 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 RIGT 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 doesn't delete any current requirements; it relocates the requirements to default conditions or replaces a LGO 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.

PG&E Response:

The plant-specific changes were identified in page 6 of the Enclosure of LAR 13-02.

Technical Specification 3.5.2 Condition B is a new Condition implemented in TSTF-505 which explicitly addresses emergency core cooling system (ECCS) inoperability where 100 percent of the ECCS flow equivalent is unavailable and adds a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months completion time or the option to use a RICT. With this new Condition B in place, the proposed TS Condition A would then only be applicable when 100 percent of the ECCS flow equivalent is available. Therefore, including the words "and at least 100°/o of the ECCS flow equivalent to a single operable ECCS train available," in proposed TS 3.5.2 Condition A becomes unnecessary. The words "and at least 1OOo/o of the ECCS flow equivalent to a single operable ECCS train available," are not included in Standard TS or in TSTF-505 for Condition A, and were proposed to be eliminated for Diablo Canyon in order to provide consistency with TSTF-505.

Deletion of the words "and at least 100°/o of the ECCS flow equivalent to a single operable ECCS train available," in current TS 3.5.2 Condition A, given the proposed Condition B, is considered only an editorial change.

5

Enclosure PG&E Letter DCL-15-007 Diablo Canyon TS 3.5.2 and 3.6.6 were previously amended as noted to provide separate Required Actions applicable to unplanned corrective maintenance or inspections on a single ECCS subsystem or a single containment spray train, with an extended Completion Time of 14 days, instead of the previously applicable 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . Since the RICT Program is applicable to unplanned corrective maintenance or inspections, PG&E is proposing to eliminate the separate Required Actions and extended Completion Times, and instead apply the more restrictive 72-hour Completion Time to both planned and unplanned activities. The deletion of TS 3.5.2 Required Actions A.2.1, A.2.2, and A.2.3, TS 3.6.6 Required Action A.2, and the notes which prescribe when these Required Actions apply, restores the structure of TS 3.5.2 Condition A and TS 3.6.6 Condition A to the previously acceptable configurations before Amendments 203 (Unit 1) and 202 (Unit 2) were approved. In effect, the proposed changes simply "roll back" Amendments 203 and 202, and therefore are expected to be acceptable as a starting point to implement TSTF-505.

TS 3.5.2 Required Action A.2.1 restricts the use of Condition A to emergent failures on a single ECCS subsystem. Since the extended Completion Time is being eliminated, this restriction is no longer required since Condition A provides a more restrictive 72-hour Completion Time for one inoperable train, regardless of the cause of inoperability of the ECCS train.

TS 3.5.2 Required Action A.2.2, regarding disposition of common cause failure mechanisms within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , is also no longer required since disposition and mitigation of common cause failures is already required by the RICT Program for emergent failures, and would be applicable when the RICT Program is entered for Condition A at the end of the 72-hour Completion Time of Condition A.

NRC Question 7:

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-5051icensees 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 6

Enclosure PG&E Letter DCL-15-007 AC/120 VAC/DC buses. In addition, PG&E proposes to delete conditione, 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.

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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

Request for Additional Information #7 Loss of safety function is not allowed in Diablo Canyon's current T~s 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 deterf!1inistic 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).

PG&E Response:

During a pre-submittal conference between PG&E and NRC staff, conducted on September 26, 2013, PG&E identified concerns with TSTF-505 forTS 3.8.9 on electrical power distribution systems. Specifically, it was identified that new Condition D addressing two or more inoperable subsystems "that result in a loss of

.safety function" is explicitly prohibited from applying a RICT by TS 5.5.20.e.

Therefore, PG&E identified during the meeting that it did not intend to adopt this newTS 3.8.9 Condition D in the LAR.

Further discussion with the staff has identified that the intent of the TSTF-505 TS 3.8.9 phrase "that result in a loss of safety function" is intended to address the situation where two (or more) electrical busses result in a loss of OPERABILITY of the safety function and that is does not indicate the status of PRA Functionality to 7

Enclosure PG&E Letter DCL-15-007 permit application of the RICT Program. With this increased understanding, PG&E agrees the proposed changes toTS 3.8.9 require revision.

The Diablo Canyon plant-specific TS 3.8.9 does not have the same structure as the Standard TS. Specifically, Conditions A, B, and C for Diablo Canyon only apply when one electrical distribution subsystem is inoperable, while the Standard TS apply to one or more inoperable electrical distribution subsystems. Therefore, when two (or more) electrical distribution subsystems are inoperable for Diablo Canyon, the condition may or may not result in inoperability of a safety function, depending upon exactly which electrical components are inoperable. Adopting TSTF-505 directly, including the phrase "that result in a loss of safety function" in Condition D, would not provide any Condition to address two or more inoperable electrical distribution subsystems where a safety function is not lost. Such conditions are addressed in TSTF-505 Conditions A, B, and C which apply to "one or more" inoperable electrical distribution subsystems.

In order to provide for all possible impacts of inoperability of two or more electrical distribution subsystems, PG&E proposes to use TSTF-505 TS 3.8.9 Condition D, but to exclude the phrase "that result in a loss of safety function" in the Diablo Canyon plant-specific Condition D. This is a conservative change compared to TSTF-505, since it provides for a one-hour Completion Time when more than one electrical distribution subsystem is inoperable, and precludes intentionally making a second electrical distribution subsystem inoperable. TSTF-505 provides either an 8-hour Completion Time for Condition A or a 2-hour Completion Time for Conditions B and C, and permits intentionally making multiple subsystems inoperable when a safety function is not lost.

The revised proposed TS 3.8.9 includes the Condition D from TSTF-505 for two or more electrical power distribution subsystems inoperable including the Note that it is (Not applicable when two or more electrical power distribution subsystems intentionally made inoperable." The revised TS marked-up, retyped, and TS Bases marked-up pages are contained in Attachments 1, 2, and 3 to the Enclosure, respectively.

NRC Question 8:

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 (inserl 38) that references ((NEI 06-09-A, revision 0."

8

Enclosure PG&E Letter DCL-15-007 PG&E Response:

The revised Insert 38 for newTS 5.5.20 is revised to reference "NEI 06-09, Revision 0-A." The revised (TS marked-up) Insert 38 and retyped TS 5.5.20 pages are contained in Attachments 1 and 2 to the Enclosure, respectively.

NRC Question 9:

Background for Request #9 and #1 0 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?

PG&E Response:

While a RICT is in effect, proposed TS 5.5.20.c requires reevaluation of the RICT for any plant configuration change within the scope of the RICT Program. If a RICT were in effect and was reliant on PRA Functionality to comply with proposed TS 5.5.20.e to assure at least one required train was PRA Functional, then additional degradation impacting PRA would be a configuration change, since equipment status would potentially change from PRA Functional to Not PRA Functional. In this hypothetical situation, if the required train was determined no longer to be PRA Functional, then the provisions of proposed TS 5.5.20.e would no longer be satisfied, and the RICT ,would be immediately exited. Per proposed TS 5.5.20.c.2, this emergent configuration change must be evaluated within the time limits of the Required Action Completion Time not to exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the configuration change.

NRC Question 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 9

Enclosure PG&E Letter DCL-15-007 service to perform corrective maintenance)? Include in your discussion the applicable TS RICT Program requirements regarding this condition.

PG&E Response:

For the hypothetical condition with both component cooling water (CCW) trains inoperable, but with each CCW train having some functionality such that the combined capability of both trains would accomplish the required safety functions contained in the PRA (i.e., the established basis for being able to declare PRA Functional for this situation), the RICT Program could only continue to be applicable as long as the "PRA Functional" equivalent of one train of CCW remained available to accomplish the safety functions of TS 3. 7. 7, per the requirements of proposed TS 5.5.20.e. Note, the maximum time allowed in this emergent condition is limited to 30 days by the proposed TS 5.5.20.a RICT Program requirement. If the configuration changed such that this was no longer the case, then the RICT would be exited and the next Condition and Required Action (a MODE 3 shutdown in the case of proposed TS 3.7.7) would apply.

If restoration of at least one train to OPERABLE could not be accomplished without causing the loss of a function of the LCO (i.e., loss of "PRA Functionality") and restoration could not be completed within the 6-hour shutdown time of TS 3. 7. 7 Condition C (which would be applicable after PRA Functionality was lost), then PG&E would normally plan for an orderly plant shutdown to MODE 5 in order to permit repairs. While PRA Functionality is maintained and the RICT is in effect prior to completion of the shutdown to MODE 3, PG&E would use the RICT to prepare for the plant shutdown, including consideration of such factors as availability of other plant equipment needed for safe shutdown operations, external conditions such as g~id demand, weather forecast, ocean conditions, or other externalities which might impact safe operation while shutdown. However, it is possible that regulatory relief might be pursued on a case-by-case basis, if the specific causes of inoperability and configuration risk justified continued operation while repairs were completed.

The reporting requirements of 10 CFR 50.72 would apply when both CCW trains are inoperable, regardless of the applicability of the RICT Program to permit continued plant operation. Therefore, the NRC will be informed of situations where a loss of TS specified safety function exists and continued plant operation occurs through use of a RICT and existence of PRA Functionality.

The plant-specific procedure implementing the RICT Program will specifically address situations where TS 5.5.20.e is utilized for an emergent condition that PRA functionality exists, but neither train by itself is PRA functional. The following administrative controls will be established to assure limited plant operation, management authorization, and NRC awareness:

The RICT Program should not be used to extend operation to the limit of 30 days specified by TS 5.5.20.a when all safety trains are inoperable, and 10

Enclosure PG&E Letter DCL-15-007 restoration of the LCO cannot be accomplished by maintaining PRA Functionality in at least one train as required by TS 5.5.20.e.

In the event of such a configuration, the RICT may be used to provide additional time only for the purpose of preparing for an orderly plant shutdown considering the status of plant equipment required to implement and maintain shutdown conditions, including consideration of external plant conditions potentially affecting safe unit operations during transition and shutdown modes.

The Plant Manager shall approve within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months continued operation using a RICT in this configuration.

The NRC resident inspector shall be notified within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of continued operation using a RICT in this configuration.

Correction to TS 3.3.2 Proposed TS Change In LAR 13-02, forTS 3.3.2, ESFAS Instrumentation, PG&E proposed an Insert 18 in to the Enclosure that contained a typographical error. The Insert 18 proposed a revised Condition G and a revised Required Action "E.1" that should have been numbered Required Action "G.1." The retyped TS pages contained in to the Enclosure of LAR 13-02 did correctly number the revised TS 3.3.2 Condition G Required Action as "G.1." The revised Insert 18 is contained in to the Enclosure.

Additional Change to TS 3.8.4 In LAR 13-02, forTS 3.8.4, "DC Sources- Operating," PG&E proposed a revised Condition E for "Two DC electrical power subsystems inoperable" (added by Insert 36 toTS 3.8.4). The Diablo Canyon direct current (DC) bus design includes three Class 1E DC electrical power subsystems. In LAR 13-02, PG&E could have proposed a TS 3.8.4 Condition E that applies to "Two or more electrical power subsystems inoperable" to be consistent with the Diablo Canyon design that includes three DC electrical power subsystems. A RICT may be applied if three DC electrical power subsystems are inoperable, provided that the third DC electrical power subsystem is not intentionally made inoperable and one or more of the DC electrical power subsystems is "PRA functional" per proposed TS 5.5.20.e.

Therefore, PG&E proposes to revise TS 3.8.4 Condition E to state, "Two or more DC electrical power subsystems inoperable" and to revise the TS 3.8.4 Condition E note to state, "Not applicable when two or more DC electrical power subsystems intentionally made inoperable."

This additional change to TS 3.8.4 is consistent with TSTF-505 for the Diablo Canyon specific DC electrical power system design and is consistent with proposed TS 3.8.9 in which a RICT applies when multiple DC electrical power distribution 11

Enclosure PG&E Letter DCL-15-007 subsystems are inoperable. The revised (TS marked-up) Insert 36 forTS 3.8.4, retyped TS 3.8.4, and (TS Bases marked-up) Insert B-36 pages are contained in Attachments 1, 2, and 3 to the Enclosure, respectively. Also, the TS markup for Insert 36 applicable toTS 3.8.4 Condition E contained in LAR 13-02 inadvertently mislabeled the Required Action as H.1 instead of E.1. Insert 36 is corrected in to the Enclosure.

12

Enclosure Attachment 1 PG&E Letter DCL-15-007 Proposed Technical Specification Changes (marked-up)

RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

~*One Source Range ~.1 Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Neutron Flux channel OPERABLE status.

inoperable.

00 K.2.1 Initiate action to fully 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months insert all rods.

ANG K.2.2 ~lace the Gontrol Rod 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months 6 ~ysteffi in a condition incaJ3a91e of rod withdrawal.

-b&l. Required Source Range h!Qj.1 -----------N0 T E-------------

Neutron Flux channel Plant temperature inoperable. changes are allowed provided the temperature change is accounted for in the calculated SDM.

Suspend operations Immediately involving positive reactivity additions.

AND h!Qj.2 Perform SR 3.1.1.1. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter (continued)

DIABLO CANYON- UNITS 1 & 2 3.3-4 Unit 1 - Amendment No. ~ ~, 4-7-dQ Unit 2 -Amendment No. ~ 4-W, 4-+aQ

Pressurizer PORVs 3.4.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 If the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months associated with a Class I PORV:

Restore block valve to OPERABLE status.

OR C.3 If the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months associated with the non-Class I PORV:

Close the block valve and remove its power.

D. Required Action and D.1 Initiate action to restore Immediately associated Completion Class I PORV and/or Time of Condition A, B, or C associated block valves(s) not met. to OPERABLE status.

AND D.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND D.3 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. Two Class ~ PORVs E.1 Initiate action to restore inoperable for reasons other Class I PORVs to than excel: sive seat OPERABLE status.

leakage. AND E.2 Close associated block 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months valves.

AND E.3 Remove power from

N 0 T E--------- associated block valves.

Not applicable when AND second Class I PORV intentionally E.4 Restore Class I PORVs to made inoperable. OPERABLE status. -Be--ffi

MODE 3.

ANQ E.a ge iR MODE 4. ~ 2 R9l::IFS (continued)

DIABLO CANYON - UNITS 1 & 2 3.4-20 Unit 1 -Amendment No. 4-d-9, +4{J Unit 2- Amendment No. 4-d-9, 4-72/J

Pressurizer PORVs 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. More than one block valve ------------------ N 0 T E------------------

inoperable. 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 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months PORVs in manual control.

AND F.2 Restore one block valve 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 'INSERT 2 for a Class I PORV to OPERABLE status.

AND F.3 Restore remaining block 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months valve for a Class I PORV to OPERABLE status.

OR F.4 If the remaining block 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months valve is associated with the non-Class I PORV, close the block valve and remove its power.

G. Required Action and G.~ IRitiate aetieR te FesteFe IFRFReEiiately associated Completion sleek valve~s~ te Time of Condition IE orl F OPERABLE status.

not met. ANG G.1~ Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND G.2~ Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months DIABLO CANYON- UNITS 1 & 2 3.4-21 Unit 1 -Amendment No. ~

Unit 2- Amendment No. ~

Distribution Systems- Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems-Operating LCO 3.8.9 The required Class 1E AC, DC, and 120 VAC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

I INSERT 2 I ACTIONS A.

CONDITION One AC electrical power distribution subsystem inoperable.

A.1 REQUIRED ACTION Restore AC electrical power distribution subsystem to Bho~ 4?-f COMPLETION TIM B. One 120 VAC vital bus subsystem inoperable.

8 .1 OPERABLE status.

Restore 120 VAC vital bus subsystem to OPERABLE status.

2hou~ I A C. One DC electrical power C.1 Restore DC electrical 2hou1 INSERT 39 distribution subsystem

~perable.

power.distribution subsystem to OPERABLE status.

?f c;

G{§. Required Action and fi[§.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. AND q§.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months I

E. :PNe reEjt~ireEi Glass ~ E AG, E. ~ Enter LGO 3.0.3. lmmeEiiately QG, er ~20 ~l.P.~G vital 81:1ses

.witR inef3erasle Eiistrist~tien st~esystems tl:lat rest~lt in a less ef safety ft~nstien.

DIABLO CANYON - UNITS 1 & 2 3.8-29 Unit 1 -Amendment No. 4;>l;, ~:~

Unit 2- Amendment No. 4d-a, ,

INSERT 14 HH. ------------- NOTE--------- HH.1 Restore trip mechanisms 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to OPERABLE status.

Not applicable when one OR trip mechanism for two or In accordance with the more RTBs intentionally Risk Informed made inoperable.

Completion Time Program One trip mechanism inoperable for two or more RTBs.

INSERT 15 KK. Required Action and KK.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, C, E, F, G, H, Z, AA, BB, CC, DO, GG, HH, or JJ not met.

INSERT 16 C. ------------ NOTE ----------- C.1 Restore at least one 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months channel or train to Not applicable when second OR OPERABLE status.

channel or train intentionally In accordance with the made inoperable.

Risk Informed Completion Time Program Two channels or trains inoperable.

INSERT 18 G. ------------ N0 TE ----------- G. 1 Restore channels to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OPERABLE status.

Not applicable when tvito or OR more required channels or In accordance with the one channel in more than Risk Informed one loop, steam line, or Completion Time steam generator intentionally Program made inoperable.

Two or more required channels inoperable or one channel inoperable in more than one loop, steam line, or steam generator.

INSERT 36 E. ------------ NOTE ----------- E.1 Restore at least one DC 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months electrical power subsystem OR Not applicable when two or to OPERABLE status .

more DC electrical power In accordance with the subsystems intentionally Risk Informed made inoperable.

Completion Time Program Two or more DC electrical power subsystems inoperable.

INSERT 37 B. ------------ NOTE ----------- 8.1 Restore inverters to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OPERABLE status.

Not applicable when two or OR more required inverters In accordance with the intentionally made Risk Informed inoperable.

Completion Time Program Two or more required inverters inoperable.

INSERT 38 5.5.20 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09, R~vision 0-A, *'Risk-Managed Technical Specifications (RMTS) Guidelines.~~ The program shall include the following:

a. The Rl CT may not exceed 30 days;

b. A RICT may only be utilized in MODE 1 and 2;

c. When a RICT is being used, any plant configuration change within the scope of the Risk Informed Completion Time Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3. Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d. Use of 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.

e. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system 11 required to be OPERABLE if one or more of the trains are considered PRA functional~~ as defined in Section 2.3.1 of NEI 06-09.

INSERT 39 D. ------------ NOTE ----------- 0 .1 Restore electrical power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months distribution subsystems to Not applicable when two or OR OPERABLE status.

more electrical power In accordance with the distribution subsystems Risk Informed intentionally made Completion Time inoperable.

Program Two or more electric power distribution subsystems inoperable.

Enclosure Attachment 2 PG&E Letter DCL-15-007 Proposed Technical Specification Changes (retyped)

Remove Page Insert Page 3.4-18 3.4-18 3.4-18a 3.4-19 3.4-19 3.4-20 3.4-20 3.4-21 3.4-21 3.5-1 3.5-1 3.5-1 a 3.5-3 3.5-3 3.5-7 3.5-7 3.5-7a 3.6-4 3.6-4 3.6-5 3.6-5 3.6-6 3.6-6 3.6-7 3.6-7 3.6-8 3.6-8 3.6-13 3.6-13 3.6-14 3.6-14 3.7-4 3.7-4 3.7-8 3.7-8 3.7-10 3.7-10 3.7-11 3.7-11 3.7-13 3.7-13 3.7-14 3.7-14 3.7-15 3.7-15 3.7-16 3.7-16 3.7-16a 3.8-1 3.8-1 3.8-2 3.8-2 3.8-3 3.8-3 3.8-3a 3.8-16 3.8-16 3.8-18 3.8-18 3.8-18a 3.8-18a 3.8-26 3.8-26 3.8-26a 3.8-29 3.8-29 3.8-30 3.8-30 5.0-17a 5.0-17a 5.0-17b

RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME M. One Source Range M.1 Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Neutron Flux channel OPERABLE status.

inoperable.

N. Required Action and N.1 Initiate action to fully Immediately associated Completion Time insert all rods.

of Condition D or M not met.

AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months N.2 Place the Rod Control System in a condition incapable of rod withdrawal.

0. Required Source Range 0.1 -----------N0 T E-------------

Neutron Flux channel Plant temperature inoperable. changes are allowed I

provided the temperature change is accounted for in the calculated SDM.

Suspend operations Immediately involving positive reactivity additions.

AND 0.2 Perform SR 3.1.1.1. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter (continued)

DIABLO CANYON - UNITS 1 & 2 3.3-4 Unit 1 -Amendment No. ~. e-8, +J, Unit 2 -Amendment No. ~. e9, +e,

RTS Instrumentation 3.3.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME JJ. One or more SG Water ------------------NOTE------------------

Level Low - Low Trip For function 14.b, the inoperable Time Delay channel(s) TTD channel (processor) and/or inoperable. one additional TTD channel (processor) may be surveillance tested with the affected steam generator low-low water level channels for one TTD channel (processor) in bypass and the affected SG low-low water level channels for the other TTD channel (processor) in trip for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This note is not intended to allow simultaneous testing of multiple TTD channels (processors) on a routine basis.

JJ.1 Set the Trip Time Delay to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months zero seconds.

OR JJ.2 Place the affected SG 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Water Level Low- Low OR channel(s) in trip.

In accordance with the Risk Informed Completion Time Program KK. Required Action and KK.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, C, E, F,G, H,Z,AA,BB,CC, DO, GG, HH, or JJ not met.

DIABLO CANYON - UNITS 1 & 2 3.3-7 Unit 1 -Amendment No. ~' ~, 4+9, Unit 2 -Amendment No. ~, 79, &i,

Pressurizer PORVs 3.4.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. (continued) C.2 If the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months associated with a Class I PORV: OR Restore block valve to In accordance with the OPERABLE status. Risk Informed Completion Time OR Program C.3 If the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months associated with the non-Class I PORV:

Close the block valve and remove its power.

D. Required Action and D.1 Initiate action to restore Immediately associated Completion Class I PORV and/or Time of Condition A, B, or C associated block valves(s) not met. to OPERABLE status.

AND D.2 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND D.3 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E. ----------- NOTE ----------- E.1 Initiate action to restore Immediately Not applicable when second Class I PORVs to Class I PORV intentionally OPERABLE status.

made inoperable. AND

E.2 Close associated block 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Two Class I PORVs valves.

inoperable for reasons other AND than excessive seat leakage. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months E.3 Remove power from associated block valves.

AND E.4 Restore Class I PORVs to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program (continued)

DIABLO CANYON - UNITS 1 & 2 3.4-20 Unit 1 -Amendment No. ~. 4-7-i, Unit 2 - Amendment No. ~. ~.

Pressurizer PORVs 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. More than one block valve ------------------NOTE---------------~--

inoperable. Required Actions do not apply when block valve is inoperable solely as result of complying with Required Actions 8.2 or E.3.

F.1 Place associated 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months PORVs in manual control.

AND F.2 Restore one block valve 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for a Class I PORV to OPERABLE status. OR In accordance with the Risk Informed Completion Time AND Program F.3 Restore remaining block 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months valve for a Class I PORV to OPERABLE status. OR In accordance with the Risk Informed Completion Time OR Program F.4 If the remaining block 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months valve is associated with the non-Class I PORV, close the block valve and remove its power.

G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion AND Time of Condition E or F not met. G.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months DIABLO CANYON - UNITS 1 & 2 3.4-21 Unit 1 -Amendment No. ~.

Unit 2 - Amendment No. ~.

DC Sources - Operating 3.8.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One battery inoperable. B.1 Restore battery to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program C. One DC electrical power C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months subsystem inoperable for power subsystem to reasons other than OPERABLE status. OR Condition A or B.

In accordance with the Risk Informed Completion Time Program D. More than one full capacity D.1 Restore the DC 14 days charger receiving power electrical power simultaneously from a subsystem to a single 480 V vital bus. configuration wherein each charger is powered from its associated 480 volt vital bus.

E. ------------ NOTE ----------- E.1 Restore at least one DC 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Not applicable when two or electrical power subystem OR more DC electrical power to OPERABLE status.

subsystems intentionally In accordance with the made inoperable. Risk Informed

Completion Time Two or more DC electrical Program power subsystems inoperable.

F. Required Action and F.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. AND F.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months DIABLO CANYON - UNITS 1 & 2 3.8-18a Unit 1 -Amendment No. 4-6e,-1-72-,4.9G, Unit 2 -Amendment No. 4-6e,-t-74,

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8 .9 Distribution Systems-Operating LCO 3.8.9 The required Class 1E ACJ DC) and 120 VAC vital bus electrical power distribution subsystems shall be OPERABLE.

APPLICABILITY: MODES 1J 2 3) and 4.

1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One AC electrical power A. 1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months distribution subsystem power distribution inoperable. subsystem to OR OPERABLE status.

In accordance with the Risk Informed Completion Time Program B. One 120 VAC vital bus B.1 Restore .120 VAC vital 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months subsystem inoperable. bus subsystem to OPERABLE status. OR In accordance with the Risk Informed Completion Time Program C. One DC electrical power C.1 Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months distribution subsystem power distribution inoperable. subsystem to OR OPERABLE status .

In accordance with the Risk Informed Completion Time Program (continued)

DIABLO CANYON - UNITS 1 & 2 3.8-29 Unit 1 -Amendment No. 135) 215)

Unit 2 -Amendment No. 135 1 217 1

Distribution Systems - Operating 3.8.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. --------------N0 TE -----:---------- D.1 Restore electrical power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months distribution subsystems Not applicable when two or OR to OPERABLE status.

more electrical power In accordance with the distribution subsystems Risk Informed intentionally made Completion Time inoperable.

Program Two or more electric power distribution subsystems inoperable.

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. AND E.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to In accordance with required AC, DC, and 120 VAC vital bus electrical the Surveillance power distribution subsystems. Frequency Control Program DIABLO CANYON - UNITS 1 & 2 3.8-30 Unit 1 -Amendment No. ~' 2-00, Unit 2- Amendment No.~~ 2-G+,

Programs and Manuals 5.5 5.5 Programs and Manuals (continued) 5.5.20 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09, Revision 0-A, ,Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a. The RICT may not exceed 30 days;

b. A RICT may only be utilized in MODE 1 and 2;

c. When a RICT is being used, any plant configuration change within the scope of the Risk Informed Completion Time Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3. Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d. Use of 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.

e. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE if one or more of the trains are considered ,PRA functional, as defined in Section 2.3.1 of NEI 06-09.

5.0-17b Unit 1 -Amendment No.

DIABLO CANYON - UNITS 1 & 2 Unit 2 -Amendment No.

Enclosure Attachment 3 PG&E Letter DCL-15-007 Changes to Technical Specification Bases Pages (For information only)

Pressurizer PORVs B 3.4.11 BASES ACTIONS D.1, D.2, and D.3 (continued)

If the Required Action of Condition A, B, or C is not met, then the plant must be brought to a MODE in which the LCO 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 and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4, 5, and 6 INSERT B-1 with the reactor vessel head closure bolts not fully de-tensioned,

ning Class I PORV OPERABILITY is required by LCO 3.4.12.

E.1

s inoperable for reasons other than excessive seat leakage, it is neces to either.restore at least one valve, within the Completion Time of 1 ho , or isolate the flow path by

closing and removing the power to the associated block valves. The INSERT 8-39 Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. If one Class I PORV is restored and one Class I PORV remains inoperable, then the plant will be in Condition 8 with the time clock started at the original declaration of having two Class I PORVs inoperable. If no Class I PORVs are restored within the Completion Time, then the plant must be brought to a MODE in v:hich the LCO 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 and to MODE 4 vvithin 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The allowed Completion Times are reasonable , based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

In MODES 4, 5, and 6 \Vith the reactor vessel head closure bolts not fully de tensioned, maintaining Class I PORV OPERABILITY is required by LCO 3.4.12.

(continued)

DIABLO CANYON - UNITS 1 & 2

Pressurizer PORVs B 3.4.11 BASES ACTIONS (continued)

G.~G.i . .

If the Required Actions of Condition IE orl Fare not met, then the plant must be brought to a MODE in which the LCO 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 and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required piant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4, 5, and 6 with the reactor vessel head closure bolts not fully de-

tensioned, maintaining Class I PORV OPERABILITY is required by LCO 3.4.12.

SURVEILLANCE o SR 3.4.11.1 REQUIREMENTS Block valve cycling verifies that the valve(s) can b_e closed if needed.

The Surveillance Frequency is based on operating experience, equipment reliability, and. plant risk and is controlled under the Surveillance Frequency Control Program.

The Note modifies this SR by stating that it is not required to be ,', .

performed with the block valve closed in accordance* with the Required Action of this LCO. Opening the block valve in this condition increases the risk of an unisolable leak from the RCS since the PORV is already inoperable.

SR 3.4.11.2 SR 3.4.11.2 requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be manually actuated for mitigation of.an SGTR. Op.erating experience has shown that these valves usually pass the surveillance when performed at the required lnservice Testin*g Program frequency. The frequency is acc~ptable form a reliability standpoint:

The Note modifies this SR to allow entry into an operation in MODE 3 prior to performing the SR. This allows the surveillance to be performed in MODE 3 or 4.

The Note that mqdified this SR to allow entry into ~md operation in MODE 3 prior to performing the SR. This allows the test to be

performed in MODE 3 under operating temperature and pressure conditions, prior to entering MODE 1 or 2. In accordance with Reference 4, administrative controls require this test be performed in MODE 3 or 4 t6 adequately si11Julate operating temperature and pressure effects on .

PORV. operation.

(continued) (

I' DIABLO .CANYON- UNITS 1 & 2

Distribution Systems- Operating B 3.8.9 BASES LCO In addition, tie breakers between redundant safety related Class 1E (continued) AC, DC, and 120 VAC vital bus power distribution subsystems, if they exist, must be open. This prevents any electrical malfunction in any power distribution subsystem from propagating to the redundant subsystem, that could cause the failure of a redundant subsystem and a loss of essential safety function(s) .. If any tie breakers are closed , the affected redundant electrical power distribution subsystems are considered inoperable. This applies to the onsite, safety related redundant electrical power distribution subsystems. It does not, however, preclude redundant Class 1E 4.16 kV buses from being powered from the same offsite circuit.

APPLICABILITY The electrical power distribution subsystems are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients; and

b. Adequate core cooling is provided, and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

Electrical power distribution subsystem requirements for MODES 5 and 6 are covered in the Bases for LCQ 3.8.1 0, "Distribution Systems-Shutdown."

ACTIONS A .1 With one required Class 1E AC electrical power subsystem inoperable, the remaining portions of the AC electrical power distribution subsystems are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, INSERT B-1 wever, because a single failure in the remaining portions of the powe

ibution subsystems could result iJl the minimum required ESF functions eing supported. Therefore, the required Class 1E AC buses, load centers, motor control centers must be restored to OPERABLE status within 8 hou .

Condition A worst scenario is one AC electrical power distribution subsystem without AC power (i.e. , no offsite power to the 4160 V ESF bus and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power. It is, therefore,_

imperative that the unit operator's attention be focused on minimizing the potential for loss of power to the remaining AC electrical power (continued)

DIABLO CANYON - UNITS 1 & 2

Distribution Systems- Operating B 3.8.9 BASES ACTIONS A.1 (continued) distribution subsystems by stabilizing the unit, and on restoring power to the affected subsystem. The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because of:

a. The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected subsystem, to the actions associated with taking the unit to shutdown within this time limit; and

b. The potential for an event in conjunction with a single failure of a redundant component in the other AC electrical power distribution subsystems with AC power.

8.1 With one 120 VAC vital bus subsystem inoperable, the remaining OPERABLE 120 VAC vital buses are capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition. Overall reliability is reduced, however, since an additional single failure could result in the minimum required ESF functions not being supported. Therefore, the required AC vital bus subsystem must be powered from an alternate source within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated inverter via inverted DC, inverter using internal AC source, or Class 1E (continued)

DIABLO CANYON - UNITS 1 & 2

Distribution Systems- Operating B 3.8.9 INSERT 8-2 BASES ACTIONS fL.1 (continued) constant voltage transformer. The required AC vital bus subsystems must then be re-powered by *restoring it~s associated inverter to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months under LCO 3.8 .7. ACTION A.1.

Condition B represents one 120 VAC vital bus without power; potentially both the DC source and the associated AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all non interruptible power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining vital buses and restoring power to the affected 120 VAC vital bus subsystem.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that are without adequate 120 VAC power. Taking exception to LCO 3.0.2 for components without adequate vital 120 VAC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if deClared inoperable, is acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) and not allowing stable operations to continue;

b. The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions for components without adequate vital 120 VAC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected subsystem; and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time takes into account the importance to safety of restoring the 120 VAC vital bus to OPERABLE status, the redundant capability afforded by_the other OPERABLE 120 VAC vital buses, and the low probability of a DBA occurring during this period.

(continued)

DIABLO CANYON - UNITS 1 & 2

Distribution Systems- Operating B 3.8.9 BASES ACTIONS C.1 With one DC electrical power distribution subsystem inoperable, the remaining portions of the DC electrical power distribution subsystem are capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure. The overall reliability is reduced, however, because a single failure in the remaining portion of the DC electrical

. INSERT 8-2 power distribution subsystems could result in the minimum required tions not being supported. Therefore, the DC buses must be restored to 0 status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or char Condition C represents one DC electrical power distribution subsystem without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning for the affected bus. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power. It is, therefore, imperative that the operator's attention focus on stabilizing the unit, minimizing the potential for loss of power to the remaining DC electrical power distribution subsystems and restoring power to the affected subsystem .

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that would be without power.

Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is .acceptable because of:

a. The potential for decreased safety by requiring a change in unit conditions (i.e. , requiring a shutdown) while allowing stable operations to continue; (continued)

DIABLO CANYON - UNITS 1 & 2

Distribution Systems - Operating B 3.8.9 BASES ACTIONS C.1 (continued)

b. The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected subsystem; and

c. The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with Regulatory Guide 1.93 (Ref. 3).

INSERTB-40 1 - - - -.......

L . _ __ _ _ _____, £Jl§.1 and £Jl§.2 If the inoperable distribution subsysteml{i] cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. 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 and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

DIABLO CANYON - UNITS 1 & 2

INSERT B-13 If the Required Action and associated Completion Time of Condition EE is not met, the unit must be placed in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The 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, to reach MODE 2 from full power in an orderly manner and without challenging unit systems.

INSERT B-14 With one trip mechanism inoperable for two or more RTBs, the Required Action is to restore sufficient inoperable trip mechanisms to OPERABLE status to reduce total inoperable RTBs to one within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration of the trip mechanisms. Alternately, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

The Condition is modified by a Note stating it is not applicable when one trip mechanism for two or more RTBs is intentionally made inoperable. This Required Action is not intended for voluntary removal of redundant systems or components from service. The Required Action is only applicable if the trip mechanisms for two or more RTBs are inoperable for any reason and additional trip mechanisms for two or more RTBs are found to be inoperable, or if two or more trip mechanisms for two or more RTBs are found to be inoperable at the same time.

INSERT B-15 If the Required Action and associated Completion Time of Condition 8, C, E, F, G, H, Z, AA, 88, CC, DO, GG, HH, or JJ is not met, the unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is a reasonable time, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging unit systems . With the unit in MODE 3, ACTION D would apply to any inoperable RTB, RTB trip mechanism, or to any inoperable Manual Reactor Trip Function if the Rod Control System is capable of rod withdrawal or one or more rods are not fully inserted.

INSERT B-36 E.1 With two or more DC electrical power subsystems inoperable, the Required Action is to restore at least one of the required inoperable DC electrical power subsystems to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to regain control power for the AC emergency power system . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration of at least one DC electrical power subsystem. Alternately, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

The Condition is modified by a Note stating it is not applicable when two or more DC electrical power subsystems are intentionally made inoperable. This Required Action is not intended for voluntary removal of redundant systems or components from ~ervice. The Required Action is only applicable if one DC electrical power subsystem is inoperable for any reason and two or more DC electrical power subsystems are found to be inoperable, or if two or more DC electrical power subsystem are found to be inoperable at the same time.

INSERT B-37 B.1 With two or more required inverters inoperable the Required Action is to restore at least one of the required inverters to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to regain AC electrical power to the vital buses. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration of at least one [required] inverter. Alternately, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

The Condition is modified by a Note stating it is not applicable when two or more required inverters are intentionally made inoperable. This Required Action is not intended for voluntary removal of redundant systems or components from service. The Required Action is only applicable if one required inverter is inoperable for any reason and additional required inverters are found to be inoperable, or if two or more required inverters are found to be inoperable at the same time.

INSERT B-38 Alternately, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program except for Steam Line Isolation - Steam Line Pressure- Negative Rate -High, which is not applicable in MODES 1 or 2.

INSERT B-39 The Condition is modified by a Note stating it is not applicable when two Class I PORVs are intentionally made inoperable. The RICT Program is not intended for voluntary removal of redundant systems or components from service. The use of the RICT Program is only applicable if one required Class I PORV is inoperable and the second Class I PORV is found to be inoperable, or if two Class I PORVs are found to be inoperable at the same time.

INSERT B-40 With two or more electrical power distribution subsystems inoperable, the Required Action is to restore sufficient electrical power distribution subsystems within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration of sufficient electrical power distribution subsystems. Alternately, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program if a loss of safety function has not occurred .

The Condition is modified by a Note stating it is not applicable when the two or more electrical power distribution subsystems are intentionally made inoperable. This Required Action is not intended for voluntary removal of redundant systems or components from service. The Required Action is only applicable if one electrical power distribution subsystem is inoperable for any reason and a second electrical power distribution subsystem is found to be inoperable, or if two or more electrical power distribution subsystems are found to be inoperable at the same time.

Enclosure Attachment 4 PG&E Letter DCL-15-007 Commitment Commitment 1 The plant-specific procedure implementing the RICT Program will specifically address situations where TS 5.5.20.e is utilized for an emergent condition that PRA functionality exists but neither train by itself is PRA functional. The following administrative controls will be established to assure limited plant operation, management authorization, and NRC awareness:

The RICT Program should not be used to extend operation to the limit of 30 days specified by TS 5.5.20.a when all safety trains are inoperable, and restoration of the LCO cannot be accomplished by maintaining PRA Functionality in at least one train as required by Technical Specification 5.5.20.e.

In the event of such a configuration, the RICT may be used to provide additional time only for the purpose of preparing for an orderly plant shutdown considering the status of plant equipment required to implement and maintain shutdown conditions, including consideration of external plant conditions potentially affecting safe unit operations during transition and shutdown modes.

The Plant Manager shall approve within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months continued operation using a RICT in this configuration.

The NRC resident inspector shall be notified within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of continued operation using a RICT in this configuration.

v t e Letter Sequence Response to RAI
CAC:MF3240, (Withdrawn, Closed)
Initiation Acceptance... Administration Meeting Questions Answers 5 February 2015 28 May 2015 Results Withdrawal Other:
MONTHYEAR2015-05-28 [Table View]

DCL-15-007, Response to NRC Request for Additional Information Regarding License Amendment Request 13-02, Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision, 1...

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DCL-15-007, Response to NRC Request for Additional Information Regarding License Amendment Request 13-02, Revision to Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision, 1...

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