ML20215E296

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Forwards Comments from Review of Proposed Combined Tech Specs for Units 1 & 2
ML20215E296
Person / Time
Site: Diablo Canyon, 05000000
Issue date: 07/17/1985
From: Kirsch D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Novak T
Office of Nuclear Reactor Regulation
Shared Package
ML20215E267 List:
References
FOIA-86-197 NUDOCS 8610150207
Download: ML20215E296 (17)


Text

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p rew,D i o, UNITED STATES 3 NUCLEAR REGULATORY COMMISSION

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MEMORANDUM FOR: Thomas M. Novak, Assistant Director l f/

for Licensing a '

Division of Licensing FROM: Dennis F. Kirsch, Acting Director c-Division of Reactor Safety and Projects Region V

SUBJECT:

DIABLO CANYON UNITS 1 AND 2 COMBINED TECH. SPECS.

The attached comments resulted from review of proposed combined Technical Specifications for Diablo Canyon Units 1 and 2.

^

-) s i Kir , Acting Director Division of Reactor Safety and Projects

Enclosure:

As Stated cc:

H. Schierling, NRR R. Dodds, RV J. Burdoin, RV M. Mendonca, SRI, Diablo Canyon G. Yuhas, RV 8610150207 FOIA e61003 PDR MEG 86-197

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. 1 DIABLO CANYON UNITS 1 AND 2 COMBINED TECHNICAL SPECIFICATIONS REVIEW COMMENTS

1. See attachment 1 - Re: Changes in definitions related to determination of E-Average Disintegration. It should be noted that the change is not consistent with the Standard Technical Specifications or from that imposed on other licensee's such as San Onofre/ Rancho Seco. However, I feel the explaination provided in the bases provides the justification for the change and therefore I do not see problems with it.
2. See attachment (2). The only change here involves the type of analysis and LLD. The recommended change is consistent with that requested of other licensees. It should not be a problem.
3. See attachment (3).
a. The frequency for performing Direct Radiation _ measurements were brought in line with the Standard Technical Specifications and what is requested of other licensees. I do not see any problem with changing the frequency from 31 days to quarterly.
b. The changes with respect to Waterborne Pathway sampling, type and frequency of sampling and analysis is not consistent with the Standard Technical Specifications and that requested of another licensee having similar release pathways (e.g., San Onofre). I'm not in agreement with the changes recommended. I would request that the changes from what is currently required at Unit 1 continue or impose that which is provided in the Standard Technical Specifications /or at San Onofre.

4 .- See Section 6.8 of Administrative Requirements (attachment 4). We disagree with the proposed change as it relates to deleting the requirement for using R. G. 4.15, December 1977, (e.g., compare 6.8.l(i) of Unit 1 vs that proposed under 6.8.1(g) for Units 1 and 2. Please leave it as is. There may be other changes in this area that affect operations (e.g., such as the deletion for having refueling procedures and procedures for survillance of safety-related equipment.

5. Section 6.9, Reporting Requirements - I noted major changes in this area none of which appear to affect radiation protection; however, I'm not sure,if the changes may affect some other group.
6. Table 3.12-1 Item 3, Waterbore Sampling is not consistent with the Standard Technical Specifications and other Region V licensees in that, outfall, shoreline and ocean bottom sediments have been deleted.
7. TS 6.8.1.(g) has deleted reference to Regulatory Guide 4.15. This reference is presently in Unit 1 TS 6.8.1(i) and we believe it should continue to be applied to both units.
8. Also noted is that the proposed section 6.8 has deleted such procedure areas as refueling and surveillance of safety-related equipment.

2

9. Page 3/4 2-12 in 3.2.3, Action statement c, $4.2.3.2, and $4.2.3.3.

Whereever has statement " Figure 3.2-3 for Unit 2..." should be replaced with: Figure 3.2-3a for Unit I and Figure 3.2-3b for Unit 2. The curves are unit specific.

10. Page 3/4 2-17 for Unit I actual pressurizer pressure should be greater than or equal to sign (>) instead of less than or equal to (<).
11. Plant staff and inspectors need more specificity on radiation monitors that are applicable to Technical Specifications. Therefore, a) On page'3/4 3-37 should have following descriptions:
a. Spent Fuel Pool (RM58)
b. New Fuel Storage (RM57)
2. Control Room Ventilation Mode Change (RM 25 and 26)
3. Containment...
a. Gaseous Activity...
1) Containment Ventilation Isolation (RM14A or 148)...
2) RCS Leakage (RM12) ...
b. Particulate Activity RCS Leakage (RM 11) ...

Note recommended changes are underlined.

Same changes should be implemented on page 3/4 3-39.

b) On page 3/4 3-52 should have following description:

17. Main Steam Line Radiation Monitor (RM 71, 72, 73 & 74)
18. Containment Area Radiation Monitor - High Range (RM 30 and 31)
19. Plant' Vent Radiation Monitor - High Range (RM 29) ...

Note changes are underlined.

Same changes apply to page 3/4 3-53.

c) Page 3/4 3-65 and 67

b. Iodine Sampler (Collecting Medium associated with RM 24)
c. Particulate Sampler (Collecting Medium associated with RM 24)
e. Iodine Sampler Flow Rule Monitor (FIS-24)

l 3

y Note changes underlined.

d) Page 3/4 4-18

a. The Containment Atmosphere Particulate Radioactivity Monitoring System (RM 11)
c. Either the Containment Fan Cooler Collection Monitoring System or the Containment Atmosphere Gaseous Radioactivity Monitoring System (RM 12).

Note underlined changes.

12. Page 3/4 5-2 item 4.5.1.1.c is not the same as standard tech specs, i.e.,

it requires sealed open breakers. Standard Tech Specs require: _"c. at least once per 31 days when the RCS pressure is above 1000 psig by verifying that power to the isolation valve operator is disconnected by removal of the breaker from the circuit...."

The SRI believes that a spec consistent with other ECCS valves (page 3/4 5-4 4.5.2.a) would be appropriate. That is, in addition to " verifying that each accumulator isolation valve is open" in 3 4.5:1.1.a.2 the breaker should also be verified open every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This spec (4.5.1.1.c) has been the subject of a potential LER with relation to the requirement to seal the breaker and is inconsistent with the industry, standard Tech Specs and the relative importance of the valve. Therefore, it should be changed.

13. Pages B 3/4 2/4 and 5 same comment as on comment I wherever has reference to "... figure 3.2-3..." should be changed to: Figure 3.2-3d for Unit'l and Figure 3.2-3b for Unit 2.
14. Page 6-1, " Plant Staff" TS 6.2.2.b Comment 10 CFR 50.54 (m)(2)(iii) requires a licensed operator in the control room for each unit.

Additionally, while either unit is in modes 1, 2, 3 or 4 a Senior Licensed Operator is required in the control room. TS 6.2.2.b does not clearly establish these requirements, the following changes are recommended (consistent with McGuire combined TS):

b. At least one licensed operator "for each" unit shall be in the control room.... In addition, while "either" unit is in Mode 1, 2, 3 or 4 at least one licensed Senior Operator shall. . ..
15. Page 6-4, Table 6.2-1 comment on the paragraph concerning shift supervisor command function, the following changes are suggested:

During absence of the Shift Supervisor from the control room while "either" unit is mode.... During any absence of the Shift Supervisor from the control room while "both" units are in mode 5 or 6....

Directly beneath Table 6.2-1 the definitions for SS and SOL should specify dual unit qualification to be consistent with 10 CFR 50.54(m)(ii). For example:

c 4

SS -

Shift supervisor with a Senior Operator's License for both units.

SOL -

Individual with a Senior Operator License for both units.

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DEFINITIONS

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00SE EQUIVALENT I-131 1.11 DOSE EQUIVALENT I-131 shall be that concentration 'of I-131 (microcuries/ gram) which alone would produce the same thyroid dose as the quantity and iso-topic mixture of I-131, I-132, I-133, I-134, and I-135 actually present.

The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-14844, " Calculation of Distance Factors for Power and Test Reactor Sites."

E - AVERAGE DISINTEGRATION ENERGY 1.12 E shall be the average sum (weighted in proportion to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half lives greater than 15 minutes, making up at least 95% of the total non-iodine activity in the coolant.

ENGINEERED SAFETY FEATURE RESPONSE TIME p 1.13 The ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e. , the valves travel to their required positions, pump discharge pressures reach their required values, etc.).

Times shall include diesel generator starting and sequence loading delays where applicable.

ENVIRONMENTAL RADIOLOGICAL MONITORING PROCEDURE 1.14 The ENVIRONMENTAL RADIOLOGICAL MONITORING PROCEDURE (ERMP) shall be contained in PG&E's Department of Engineering Research Environmental Radiological Monitoring Manual. It shall contain a description of sample locations, types of sample locations, methods and frequency of analysis, and reporting requirements.

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FREQUENCY NOTATION 1.15 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.2.

DIABLOCANY(N-UNIT 1 1-3

pr q - r.-,=

Om h.,ds*M JUN 2,6 mo6 DEFINITIONS V

_00SE EQUIVALENT I-131 1:11 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/ gram) which alone would produce the same thyroid dose as the quantity and iso-topic mixture of I-131, I-132, I-133, I-134, and I-135 actually present.

The thyroid dose conversion factors used for this calculation shall be those listed in Table III of TID-14844, " Calculation of Distance Factors for Power and Test Reactor Sites," or Table E-7 of NRC Regulatory -

Guide 1.109, Revision 1, October 1977.

[- AVERAGE DISINTEGRATION ENERGY 1.12 I shall be the average (weighted in proportion to the concentration of each radionuclide in the sample) of the sum of the tverage beta and gamma energies per disintegration (MeV/d) for the radionuclides in the sample.

ENGINEERED SAFETY FEATURES RESPONSE TIME 1.13 The. ENGINEERED SAFETY FEATURES (ESF) RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation Setpoint at the channel sensor until the ESF equipment is capable of performing its safety i function (i.e., the valves travel to their required positions, pump dis-charge pressures reach their required values, etc.). Times shall include i diesel generator starting and sequence loading delays where applicable.

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ENVIRONMENTAL RADIOLOGICAL MONITORING PROCEDURE l 1.14 The ENVIRONMENTAL RADIOLOGICAL MONITORING PROCEDURE (ERMP) shall be contain 1 in PG&E's Department of Engineering Research Environmental Radiological  !

Monitoring Manual. It shall contain a description of sample locations, types of sample locations, methods and frequency of analysis, and reporting requirements.

j FREQUENCY NOTATION 1.15 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.1.

GASE0US R4DWASTE SYSTEM 1.16 A GASEOUS RADWASTE SYSTEM shall be any system designed and installed to reduce radioactive gaseous effluents by collecting Reactor Coolant System offgases from the Reactor Coolant System and providing for delay or holdup i

for the purpose of reducing the total radioactivity prior to release to the environment.

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DIA8LO CANYpN - UNITS 1 & 2 1-3

- , . - - - ,- , , . , . , , - , . ,,-,,-.,,,.,--m.,,------..ww,, ,, . , , , - - , - - - ,v.--,, , -w, ,m-e,w ,.,,,_,,>---,,.,,-e...- ,,.

c. m ---- - - -,we,- , , - , - - - , - - , , , .

. DEFINITIONS ,

i' DOSE EQUIVALENT I-131 1.10 DOSE EQUIVALENT I-131 shall be that concentration of I-131 (microcuries/

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gram) which alone would produce the same thyroid dose as the quantity and i isotopic mixture of I-131, I-132, I-133, I-134 and I-135 actually present. j

The thyroid dose conversion factors used for this calculation shall be those ,

listed in Table'III of TID-14844, " Calculation of Distance Factors for Power  !

and Test Reactor Sites."

E - AVERAGE DISINTEGRATION ENERGY l 1.11 i shall be the average (weighted in proportion to the concentration of each ladionuclide,__in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half lives greater than 15 minutes, making up at least 95% of the total non-iodine activity in the coolant.

ENGINEERED SAFETY FEATURES RESPONSE TIME 1.12 The ENGINEERED SAFETY FEATURES RESPONSE TIME shall be that time interval ,

from when the monitored parameter exceeds its ESF actuation setpoint at the '

channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequenct loading delays where applicable.

FREQUENCY NOTATION 1.13 The FREQUENCY NOTATION specified for the performance of Surveillance Requirements shall correspond to the intervals defined in Table 1.2.

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GASEOUS RADWASTE TREATMENT SYSTEM 1.14 A GASEOUS RADWASTE TREATMENT SYSTEM is any system designed and installed to reduce radioactive gaseous effluents by collecting primary canlant system offgases from the primary system and providing for delay or holdup for the purpose of reducing the total radioactivity prior to release to the envircnment.

l IDENTIFIED LEAKAGE l

4 1.15 IDENTIFIED LEAKAGE shall be:

l a. Leakage into closed systems, such as pump seal or valve packing leaks that are captured, and conducted to a sump or collecting tank, or

b. Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems or not to be PRESSURE BOUNDARY ,

LEAKAGE, or  !

c. Reactor coolant system leakage through a steam generator to the i secondary system. l l

M8MOFRd4NIIT 3? 1-3 i

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y , - - -, - - , ._-,--,.-ir,---me-- -w --- cy-,,,---y-, .- .- wi.ra---emm-- - - - ---pe-s---r- + , - , n-,, -- - --,,---ww-y ,,- - - - -,-=, + - ,-- - - - - - ---- ---s w-

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h b.i. hwmdd TABLE 4.11-1 0 I305 l

RADI0 ACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM  !

--. LOWER LIMIT MINIMUM OF DETECTION i LIQUID RELEASE SAMPLING ANALYSIS TYPE OF ACTIVITY (LLD)

TYPE FREQUENCY FREQUENCY ANALYSIS (pCi/ml)(1)

1. Batch Waste P P Release Each Batch Each Batch Principal Gamma 5x10

-7 Tanks C4) Emitters (6)

I-131 1x10

-6 P M Dissolved and 1x10

-5 One Batch /M Entrained Gases

, (Gamma emitters)

. . _P M H-3 1x10

-5 )

Each Batch Composite ( )

Gross Alpha 1x10'7 P Q Sr-89, Sr-90 5x10

-8 Each Batch Composite (2)

Fe-55 -6' 1x10 l D W Principal Gamma ~7 *

2. Continuo'us(5) 5x10 Releases Grab Sample Composite (3) Emitters (6)

Steam -6 Generator I-131 1x10 {'

Blowdown -5 Tank M M Dissolved and 1x10 Grab Sample Entrained Gases (Gamma Emitters)

O M H-3 1x10

-5 Grab Sampic Composite I3)

Gross Alpha -7 1x10 0 Q Sr-89, Sr-90 5x10 I Grab Sample Composite (3)

Fe-55 1x10

-6

3. Continuous .

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Releases (5) Grab ample Compos te(3) Principal Gamma - 5x10

-7 Oily Water Emitters (6) ,

Separator Effluent i DIABLOCANYON-UNITS 1&2 3/4 11-2

TABLE 4.11-1 RADIOACTIVE LIQUID WASTE SAMPLING AND ANALYSIS PROGRAM Lower Limit Minimum of Detection Liquid Release Sampling Analysis Type Type of Activity (LLD)

Frequency Frequency Analysis (pCi/ml)a A. Batch Waste P P Release Each Batch Each Batch -7 d Principa} Gamma 5x10 Tanks Emitters I-131 1x10

-6 P M -5 Dissolved and 1x10 One Batch /M Entrained Gases (Gamma emitters)

P M H-3 1x10

-5

. Each Batch Composite b Gross Alpha _7 1x10 P-32 1x10

-6 P

Q Sr-89, Sr-90 5x10

-8 Each Batch Composite b 0

Fe-55 1x10

-6 B. Continuous' D W Principa ~7 5x10 Releases Grab Sample Composite c Emitters} Gamma

1. Steam Generator I-131 lx10 -6 Blowdown Tank M Grab Sample M Dissolved and lx10 -5 Entrained Gases (Gamma Emitters)

O M H-3 1x10

-5 Grab Sample Composite c Gross Alpha lx10 ; _

P-32 -6 1x10 0 Q Sr-89, Sr-90 5x10

-8 Grab Sample Composite c Fe-55 1x10

-6

2. Oily Water D W Separator Grab Sample Composite c -7 Gross Gamma 1x10 Effluent '

DIABLO CANYON - UNIT 1 3/4 11-2 i \.

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. 't o TABLE 3.12-1 -

3; RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM 5

n NUMBER OF g REPRESENTATIVE o EXPOSURE PATHWAY ' SAMPLES AND SAMPLING.AND

  • TYPE AND FREQUENCY AND/OR SAMPLE SAMPLE LOCATIONS (1) COLLECTION FREQUENCY OF ANALYSIS E 1. Direct RadiationI2} Thirty-one routine Quarterly. ' Gamma dose quarterly Q
  • monitoring stations * ,

" either with two or

  • more dosimeters or with

" one instrument for measuring and recording dose rate continuously, placed as follows:

An inner ring of stations, R

  • one in each terrestrial meteorological sector in the M general area of the SITE J, BOUNDARY; An outer ring of stations, one in each terrestrial meteorological sector in the 2.5 to 12 km range from ~

the site; and The balance of the stations to be placed in special 9 interest areas such as C' population centers, nearby S l' residences, schools, and in

! p-one or two areas to serve 1

as control stations. p e

I

  • Inner ring stations: 051, WN1, 052,151, 251, 351, '451, 551, 553, 651, 751, 851, 852, 951, and MT1. [

Outer ring stations: 1A1, 081,1C1, 201, 301, 4C1, SC1, 601, and 7C1  ; s.

Special interest stations: 401, SF1, 7F1, 7DI, 702, and 7C2 '

Control station: 2F2 ac.

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re o TABLE 3.12-1

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O RADIOLOGICAL ENVIROMENTAL MONITORING PROGRAM n

E .

Number of Samples -

g Exposure Pathway and Sampling and

, and/or Sample Sample Locations ** Type and Frequency Collection Frequency of Analysis

_E 1. AIRBORNE

-4 w Radiciodine and > 4 stations Continuous operation of Particulates sampler with sample col- Radioiodine canister.

Analyze at least once lection as required by per 7 days for I-131.

dust loading but at least once per 7 days. Particulate sampler.

Analyze for gross beta w radioactivity > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> D following filter change.

w Perform gamma isotopic 7

" analysis on each sample when gross beta activity is > 10 times the yearly mean of control samples.

Perform gamma isotopic analysis on composite i

(by location) sample at least once per i 92 days.

2. DIRECT RADIATION

> 30 stations, At least once per 31 days.*

> 2 dosimeters Gamma dose. At least -

t at each location. once per 31 days.*

"" Sample locations are given on the figure and table in the ODCM.

4

R TABLE 3.12-1 (Continued) .

RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM n NUPEER OF F REPRESENTATIVE n EXPOSURE PATHWAY SAMPLES AND SAMPLING AND AND/0R SAMPLE TYPE AND FREQUENCY f SAMPLE LOCATIONSII) COLLECTION FREQUENCY OF ANALYSIS E 3. Waterborne Q

a. Surface

" One sample from Diablo Monthly. Gamma isotopic analysis I Creek (552). monthly. Composite for tritium analysis quarterly.

b. Drinking One sample of plant Monthly grab sample. Gamma isotopic drinking water (DW1) analysesI4) monthly.

w agfg *y - [g Compositefortritiumj A analysis quarterly.

~ 4. Ingestion

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a. Milk Samples from milking Semimonthly when Gamma isotopicI4) and animals in three locations animals are on pasture; I-131 analysis semi-within 5 km distance having monthly at other times. monthly when animals 4

the highest dose potential. are on pasture; monthly If there are none, then one at other times.

sample from milking animals in each of three areas l between 5 to 8 km distant Y where doses are calculated to be greater than 1 arem E[3 C. . 18

) per yr. One sample from r ,s. milking animals at a control [:53 location 15 to 30 km distant i gs and in the least prevalent wind direction. 6 F-7)

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d

. . ._ _- . . . _ - _ = _ . .-

ew

. S TABLE 3.12-1 (Continued) .

RADIOLOGICAL ENVIR0fMENTAL MONITORING PROGRAM i 5 i n i R Number of Samples y Exposure Pathway and/or Sample and Sample Locations **

Sampling and Type and Frequency i Collection Frequency of Analysis E

3. imTER90RNE i  %

~ a. Outfall 1 station Grab sample collected at Gamma isotopic analysis least every 31 days and l and tritium analysis 1

composited at least every at least every 92 days. -

92 days.

i

b. Drinking 1 station Grab sample collected i I-131 analysis, gross

! w at least every 31 days. beta and gamma isotopic i 1 analysis and tritium i analysis at least once i 7 per 31 days,

c. Diablo Canyon 1 station Grab sample collected

! Creek Gamma isotopic analysis at least every 31 days and tritium analysis

, and composited at least at least every 92 days.

every 92 days.

j 4. INGESTION

a. Milk 1 2 stations At least once per 31 days.

Gamma isotopic and I-131 analysis.

! b. Fish and 2 stations j One sample in season, or at Gamma isotopic analysis Invertebrates least once per 184 days if

on edible portions.

not seasonal.

l c. Food 'roducts 1 2 stations At least once per 31 days, Gamma isotopic analysis when available, on edible portion.

I j "Except for one station which is inaccessible and sampled and analyzed at least once per 92 days.

    • Sample locations are shown on the figure in the ERMP Procedure No. A-8.

4 i

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9

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  • , TABLE 3.12-1 (Continued) 4 RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM .

Ki l

k Exposure Pathway Number of Samples and Sarple Locations" Sampling and a

and/or Sample Collection Frequency Type and Frequency of Analyses

3. WATERBORNE
a. Ocean 4 Locations At least once per Gamma isotopic analysis of each f

month and composited monthly sample. Tritium analysis quarterly of composite sample at least once per 92 days.

b. Drinking 2 Locations Monthly at each Gamma isotopic and tritium location. analyses of each sample.

R c. Sediment 4 Locations At least once per Gamma isotopic analysis of each

  • from 184 days. sample.

M Shoreline i

d. Ocean 5 Locations At least once per Gamma isotopic analysis of each Bottom 184 days. sample.

Sediments i.

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ADMINISTRATIVE CONTROLS JUN 2 8 lati l

REPORTABLE EVENT ACTION (Continued)

b. Each REPORTABLE EVENT shall be reviewed by the PSRC and Abe results of this review submitted to GONPRAC and the Vice President, Nuclear Power Generation.

6.7 SAFETY LIMIT VIOLATION 6.7 The following actions shall be taken in the event a Safety Limit i's violated:

a. The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The Executive Vice President, Facilities and Electric Resources Development and GONPRAC shall be

_ notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />;

b. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the PSRC. This report shall describe: (1) applicable c.ircumstances preceding the violation, (2) effects of the violation upon unit components, systems or structures, and (3) corrective action taken to prevent recurrence;
c. The Safety Limit Violation Report shall be submitted to the Commis-  !

sion, GONPRAC and the Executive Vice President, Facilities and Elec- '

tric Resources Development within 14 days of the violation; and

d. Critical operation of the unit shall not be resumed until authorized l by the Commission. l

~

6.8 PROCEDURES AND PROGRAMS l

6.8.1 Written procedures shall be established, iaplemented and maintained covering the activities referenced below:

a. The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978;
b. ..The emergency operating procedures required to implement the

' requirements of NUREG-0737 and Supplement 1 to NUREG-0737 as stated 1 i

in Generic Letter No. 82-33; i

c. Security Plan implementation;
d. Emergency Plan implementation; i.
e. PROCESS CONTROL PROGRAM implementation; -

n

f. ODCP and EFMP implementation; and
g. Quality Assurance Program for effluent and environmental monitoring.

DIABLOCAh0N-UNITS 1&2 6-13

l 6 .

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ADMINISTRATIVE CONTROLS 6.8 PROCEDURES AND PROGRAMS p i

6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:

a. The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978,
b. Refueling operations, /
c. Surveillance and test activities of safety related equipment, [
d. Security Plan implementation,
e. Emergency Plan implementation, .
f. Fire Protection Program implementation,
g. PROCESS CONTROL PROGRAM implementation,
h. OFFSITE DOSE CALCULATION PROCEDURE and ERMP implementation, and i.

Quality Assurance Program for effluent and environmental monitoring, using the guidance in Regulatory Guide 4.1,5, December 1977.

~

6.8.2 Each procedure of Specification 6.8.1 above, and changes thereto, shall be reviewed by the PSRC and approved by the Plant Manager prior to implementa-tion and reviewed periodically as set forth in administrative procedures.

6.8.3 Temporary changes to procedures of Specification 6.8.1 above may be made provided:

a. The intent of the original procedure is not altered;
b. The change is approved by two members of the plant management staff, at least one of whom holds a Senior Operator license on the unit ,

affected; and

c. The change is documented, reviewed by the PSRC and approved by the Plant Manager within 14 days of implementation.

6.8.4 The following programs shall be established, implemented, and maintained:

a. Primary Coolant Sources Outside Containment A" program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The j

systems include portions of the Recirculation Spray System. Safety Injection System, Chemical And Volume Control System, Residual Heat Removal System, RCS Sample a stem, and Liquid and Gaseous Radwaste Systems. The program shall include the following:

1) Preventive maintenance and periodic visual inspection "

requirements, and

2) Integrated leak test requirements for each system at refueling cycle intervals or less.

DIABLO CANYON - UNIT 1 6-13

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