View source for DCL-11-038, License Amendment Request 11-03 Revision to Technical Specification 3.8.1, AC Sources - Operating for Traveler TSTF-163, Revision 2, and Exception to Regulatory Guide 1.9, Revision 0

{{Adams
| number = ML110880202
| issue date = 03/28/2011
| title = License Amendment Request 11-03 Revision to Technical Specification 3.8.1, AC Sources - Operating for Traveler TSTF-163, Revision 2, and Exception to Regulatory Guide 1.9, Revision 0
| author name = Becker J
| author affiliation = Pacific Gas &amp; Electric Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000275, 05000323
| license number = DPR-080, DPR-082
| contact person = 
| case reference number = DCL-11-038, LAR 11-03, OL-DPR-80, OL-DPR-82, RG 1.009, TSTF-163, Rev 2
| document type = Letter type:DCL
| page count = 49
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Pacific Gas and Electric Company                                                    James R. Becker       Diablo Canyon Power Plant Site Vice President   Mail Code 104/5/601
: p. O. Box 56 Avila Beach, CA 93424 805.545.3462 Internal: 691.3462 March 28, 2011                                                                             Fax: 805.545.6445 PG&E Letter DCL-11-038 U.S. Nuclear Regulatory Commission                                                        10 CFR 50.90 ATTN: Document Control Desk Washington, D.C. 20555-0001 Diablo Canyon Units 1 and 2 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 License Amendment Request 11-03 Revision to Technical Specification 3.8.1! "AC Sources - Operating" for Traveler TSTF-163, Revision 2, and Exception to Regulatory Guide 1.9, Revision 0

==Dear Commissioners and Staff:==

Pursuant to 10 CFR 50.90, Pacific Gas & Electric (PG&E) hereby requests to revise the Operating Licenses to revise Technical Specification (TS) 3.8.1, "AC Sources - Operating," to incorporate Technical Specification Task Force (TSTF)
Traveler TSTF-163, Revision 2. The proposed changes would also revise the Final Safety Analysis Report Update to identify an exception to Regulatory Guide 1.9, Revision O.
PG&E requests approval of this license amendment request no later than March 28, 2012. PG&E requests the license amendments be made effective upon NRC issuance, to be implemented within 120 days from the date of issuance.
The enclosure to this letter contains the evaluation of the proposed change.
This letter contains no new regulatory commitments (as defined by NEI 99-04) and contains no revisions to existing regulatory commitments.
Pursuant to 10 CFR 50.91, PG&E is sending a copy of this proposed amendment to the California Department of Public Health.
If you have any questions or require additional information, please contact Mr. Tom Baldwin at 805-545-4720.
A member  of  the   STARS    (Strategic  Teaming  and  Resource     Sharing) Alliance Callaway
* Comanche Peak
* Diablo Canyon
* Palo Verde. San Onofre
* South Texas Project
* Wolf Creek

Document Control Desk                                                 PG&E Letter DCL-11-038 March 28, 2011 Page 2 I state under penalty of perjury that the foregoing is true and correct.
Executed on March 28, 2011.
Site Vice President kjse/4328 SAPN 50366219/50341329 Enclosure cc:        Diablo Distribution celene: Gary W. Butner, Branch Chief, California Department of Public Health Elmo E. Collins, Regional Administrator, NRC Region IV Michael S. Peck, NRC, Senior Resident Inspector James T. Polickoski, Project Manager, Office of Nuclear Reactor Regulation Alan B. Wang, Project Manager, Office of Nuclear Reactor Regulation A  member  of  the   STARS    (Strategic  Teaming  and  Resource  Sharing) Alliance Callaway
* Comanche Peak
* Diablo Canyon
* Palo Verde. San Onofre
* South Texas Project
* Wolf Creek

Enclosure PG&E Letter DCL-11-038 Evaluation of the Proposed Change License Amendment Request 11-03 Revision to Technical Specification 3.8.1, "AC Sources - Operating"
: 1. 

==SUMMARY==
DESCRIPTION
: 2. DETAILED DESCRIPTION
: 3. TECHNICAL EVALUATION
: 4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions
: 5. ENVIRONMENTAL CONSIDERATION
: 6. REFERENCES ATTACHMENTS:
: 1. Technical Specification Pages Markups
: 2. Retyped Technical Specification Pages
: 3. Technical Specification Bases Pages Markups (For Information Only)
: 4. FSAR Update Markups

Enclosure PG&E Letter DCL-11-038 EVALUATION
: 1. 

==SUMMARY==
DESCRIPTION This letter is a request to amend Operating Licenses DPR-80 and DPR-82 for Units 1 and 2 of the Diablo Canyon Power Plant (DCPP), respectively.
The proposed changes would revise the Operating Licenses to revise Technical Specification (TS) 3.8.1, "AC Sources - Operating," to incorporate Technical Specification Task Force (TSTF) Traveler TSTF-163, Revision 2. The proposed changes would also revise the Final Safety Analysis Report (FSAR) Update to identify an exception to Regulatory Guide (RG) 1.9, Revision O.
The TS 3.8.1 Surveillance Requirements (SRs) are revised per TSTF Traveler TSTF-163, Revision 2, to verify minimum frequency and voltage, and steady state frequency and voltage within limits following diesel generator (DG) start.
The FSAR Update is revised to specify an exception to RG 1.9, Revision 0, Regulatory Position C.4, for frequency recovery for the Auxiliary Feedwater (AFW) pump loading for DGs 1-1, 1-3,2-2, and 2-3.
: 2. DETAILED DESCRIPTION Proposed Amendment The following changes are proposed to the TS 3.8.1 SRs:
SR 3.8.1.2 is revised from:
Verify each DG starts from standby conditions and achieves speed 2:: 900 rpm, steady state voltage 2:: 3785 V and s 4400 V, and frequency 2:: 58.8 Hz and s 61.2 Hz.
to:
Verify each DG starts from standby conditions and achieves steady state voltage 2:: 3785 V and s 4400 V, and frequency 2:: 58.8 Hz and s 61.2 Hz.
SR 3.8.1.7.a is revised from:
in  s 10 seconds, speed 2:: 900 rpm; and to:
1

Enclosure PG&E Letter DCL-11-038 In :::; 10 seconds, voltage  ~ 3785 V and frequency    ~ 58.8 Hz; and SR 3.8.1.7.b is revised from:
in :::; 13 seconds, voltage  ~ 3785 V and:::; 4400 V, and frequency   ~ 58.8 Hz and
:::;61.2 Hz.
to:
Steady state voltage    ~ 3785 V and:::; 4400 V, and frequency    ~ 58.8 Hz and
:::;61.2 Hz.
SR 3.8.1.12.a is revised from:
In :::; 13 seconds after auto-start and during tests, achieves voltage  ~ 3785 Vand
:::;4400 V; to:
In :::; 10 seconds after auto-start and during tests, achieves voltage ~ 3785 Vand frequency ~ 58.8 Hz; SR 3.8.1.12.b is revised from:
In :::; 13 seconds after auto-start and during tests, achieves frequency   ~ 58.8 Hz and:::; 61.2 Hz; to:
Achieves steady state voltage      ~ 3785 V and:::; 4400 V, and frequency  ~ 58.8 Hz and:::; 61.2 Hz; SR 3.8.1.15.a is revised from:
in :::; 10 seconds, speed  ~  900 rpm; and to:
In :::; 10 seconds, voltage  ~ 3785 V and frequency    ~ 58.8 Hz; and SR 3.8.1.15.b is revised from:
in :::; 13 seconds, voltage  ~ 3785 V, and:::; 4400 V and frequency   ~ 58.8 Hz and
:::; 61.2 Hz.
2

Enclosure PG&E Letter DCL-11-038 to:
Steady state voltage 2 3785 V and :s; 4400 V, and frequency 2 58.8 Hz and
:s; 61.2 Hz.
SR 3.8.1.20.a is revised from:
in :s; 10 seconds, speed 2 900 rpm; and to:
In :s; 10 seconds, voltage 2 3785 V and frequency 2 58.8 Hz; and SR 3.8.1.20.b is revised from:
in :s; 13 seconds, voltage 2 3785 V and :s; 4400 V, and frequency 2 58.8 Hz and
:s; 61.2 Hz.
to:
Steady state voltage 2 3785 V and :s; 4400 V, and frequency 258.8 Hz and
:s; 61.2 Hz.
The TS 3.8.1 Bases are revised to remove the reference to RG 1.9, Revision 2, to remove the information related to the current 13 second DG start requirements, to reflect the steady state voltage and frequency requirements, and to reflect the periodic monitoring of the governor and regulator that is performed.
FSAR Update Section 8.1.4.3 for RG 1.9 is revised to remove reference to RG 1.9, Revision 2, and RG 1.9, Revision 3, and to add that DCPP is committed to Safety Guide 9 (RG 1.9 Rev. 0) with the exception of Regulatory Position C.4.
FSAR Update Section 8.3.1.1.13.1 is revised to remove reference to RG 1.9, Revision 2, and to add an exception to RG 1.9, Revision 0, Regulatory Position C.4 for the AFW pump loading for DGs 1-1, 1-3, 2-2, and 2-3, for which the frequency is not restored to within 2 percent of nominal in less than 40 percent of the load sequence time interval.
The proposed TS changes are noted on the marked-up TS page provided in Attachment 1. The proposed retyped TS is provided in Attachment 2. The revised TS Bases is contained for information only in Attachment 3. The revised FSAR Update sections are contained in Attachment 4.
3

Enclosure PG&E Letter DCL-11-038 Reason for Proposed Amendment The current SRs 3.8.1.2,3.8.1.7,3.8.1.15, and 3.8.1.20 contain both DG minimum speed and DG minimum frequency requirements that are inconsistent with the SRs contained in NUREG-1431, Revision 3.1, "Standard Technical Specifications Westinghouse Plants," which only contains minimum frequency requirements. In addition, SRs 3.8.1.7,3.8.1.12, 3.8.1.15, and 3.8.1.20 are not consistent with NUREG-1431, Revision 3.1 surveillance voltage and frequency requirements, which are based on changes contained in TSTF Traveler TSTF-163, Revision 2. SRs 3.8.1.7, 3.8.1.12, 3.8.1.15, and 3.8.1.20 are revised to be consistent with the NUREG-1431, Revision 3.1, DG surveillance voltage and frequency requirements.
The frequency recovery time for the AFW pump loading for DGs 1-1, 1-3,2-2, and 2-3, does not meet RG 1.9, Revision 0, Regulatory Position C.4, which specifies that during the DG loading sequence the frequency should be restored to within 2 percent of nominal in less than 40 percent of each load sequence time interval. For DCPP, 40 percent of each load sequence time interval is equal to 1.6 seconds for the 4 seconds nominal load sequence time interval. Test data demonstrates that for AFW pump loading for DGs 1-1, 1-3, 2-2, and 2-3, the DG frequency stabilizes within a nominal 2.2 to 2.3 seconds and that the DGs are capable of starting and accelerating the subsequent engineered safety feature (ESF) loads. For the AFW pump loading for DGs 1-1, 1-3,2-2, and 2-3, the frequency is restored to within 2 percent of nominal in less than 60 percent of each load sequence time interval. The proposed changes to the FSAR Update identify this exception to RG 1.9, Revision 0, Regulatory Position C.4, which requires NRC approval.
The current FSAR Update Sections 8.1.4.3 and 8.3.1.1.13.1 discuss that the DG frequency recovery is met by the applicable criteria of RG 1.9, Revision 2. This exception to RG 1.9, Revision 0, based on RG 1.9, Revision 2, should have received prior NRC approval and was incorrectly included through a change made to the FSAR Update under 10 CFR 50.59. This was entered into the Corrective Action Program in SAP Notification 50341329. There have also been issues with the power factor (PF) values, load values, and DG day tank volume value contained in the TS 3.8.1 SRs (SAP Notifications 50232181,50368931, and 50378557), which will be handled separately.
: 3. TECHNICAL EVALUATION Description of Electrical Power Distribution System Alternating Current (AC)
Sources The DCPP Electrical Power Distribution System AC sources consist of offsite power sources (230 kV and 500 kV switchyards), and the onsite standby power 4

Enclosure PG&E Letter DCL-11-038 sources (three DGs for each unit). The design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the ESF systems.
The onsite Class 1E AC Distribution System for each unit is divided into three load groups so that the loss of anyone group does not prevent the minimum safety functions from being performed. Each load group has connections to two offsite power sources and a single onsite standby DG.
Offsite power is supplied to the 230 kV and 500 kV switchyards from the transmission network by two 230 kV transmission lines and three 500 kV transmission lines. Each unit has an offsite circuit supplied from the immediate access 230 kV switchyard and an offsite circuit supplied from the delayed access 500 kV switchyard. These two electrically and physically separated circuits provide AC power, through auxiliary (500 kV) and standby startup (230 kV) transformers, to the 4.16 kV ESF buses. A detailed description of the offsite power network and the circuits to the Class 1E buses is found in the FSAR Update Chapter 8.
The onsite standby power source for each 4.16 kV ESF bus is a dedicated DG.
For Unit 1, DGs 1-1, 1-2, and 1-3 are dedicated to ESF buses H, G, and F, respectively. For Unit 2, DGs 2-1,2-2, and 2-3 are dedicated to ESF buses G, H, and F, respectively. A DG starts automatically on a safety injection (SI) signal (e.g., low pressurizer pressure or high containment pressure signals),
undervoltage on the offsite standby startup source, or on an ESF bus degraded voltage or undervoltage signal. After the DG has started, it will automatically tie to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of or coincident with an SI signal.
The DGs will also start and operate in the standby mode without tying to the ESF bus on an SI signal alone. Following the trip of offsite power, an undervoltage signal strips nonpermanent loads from the ESF bus. When the DG is tied to the ESF bus, loads are then sequentially connected to their respective ESF bus by the load sequencing timers (ESF timers). The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading the DG.
Each ESF component is provided with its own load sequencing timer.
In the event of a loss of the preferred 230 kV offsite power source concurrent with a safety injection signal, the ESF electrical loads are automatically connected to the DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a loss-of-coolant accident (LOCA).
Certain large required ESF loads are returned to service in a predetermined sequence in order to prevent overloading the DG in the process. All loads needed to recover the unit or maintain it in a safe condition are returned to 5

Enclosure PG&E Letter DCL-11-038 service via the ESF timers (ESF timer settings specified in TS Bases Table B 3.8.1-1). Each individual timer connects a single ESF component.
Description of DG Design The six DGs for Units 1 and 2 are essentially identical, self-contained units housed in individual compartments at the 85 foot elevation in the turbine building.
Three are located in the northwest or Unit 1 portion, and three are located in the southwest or Unit 2 portion of the structure. Compartments separate each DG and its accessories from adjacent DGs.
The DGs have a net continuous electrical output rating of 2600 kW at 0.8 PF (continuous rating), and are rated for 2750 kW at 0.8 PF for up to 2000 hours of operation (2000-hour rating). Short-term ratings of the DGs are 2860 kW at 0.8 PF (2 hours per 24-hour rating), 3000 kW at 0.8 PF (2 hours per year rating),
3250 kW at 0.8 PF (30-minute per 24-hour rating). During the starting sequence for the safeguard loads, these machines can also carry short-time overloads.
Each DG unit consists of a self-contained diesel engine directly connected to an alternating current generator, and the separate accessories needed for proper operation, all mounted on a common structural steel skid-type base. Mechanical power is provided by an 18 cylinder, four-cycle, 3630 horsepower at 900 rpm, turbocharged and aftercooled, heavy-duty, stationary-type diesel engine.
The generator is rated at 3250 kVA, 0.8 PF, 4160 V, and 60 Hz. The exciter is a static series, boost-type exciter controlled by a static solid-state voltage regulator.
Five of the DG units were supplied by the ALCO Engine Division of White Industrial Power, Inc. The sixth DG, DG 2-3, was manufactured by General Electric Locomotives. In most respects, 2-3 is similar to the other five DGs.
DG Load Testing and Compliance With RG 1.9, Revision 0 The DGs were designed to Safety Guide 9, "Selection of Diesel Generator Set Capacity for Standby Power Supplies," dated March 10, 1971 (hereafter referred to as RG 1.9, Revision 0). Vendor facility shop tests were conducted by ALCO Engine Division of White Industrial Power, Inc., for the five original DGs (1-1, 1-2, 1-3, 2-1, and 2-2) to verify the unit design capabilities, their reliability, and their conformance to specification requirements as summarized in FSAR Update Table 8.3-8. Extensive onsite preoperational qualification testing was performed for the original five DGs during DCPP startup as summarized in FSAR Update Table 8.3-9. Separate testing was performed on DG 2-3 to support qualification.
Preoperational testing performed during July 1981 identified an exception to RG 1.9, Revision 0, Position C.4. The results of the July 1981 testing determined that the frequency dropped to as low as 56.3 Hz during the last load block. This 6

Enclosure PG&E Letter DCL-11-038 was less than the guideline value of 57 Hz (95 percent of the nominal frequency of 60 Hz) specified by RG 1.9, Revision 0, Position C.4 that at no time during the load sequence should the frequency decrease to less than 95 percent of nominal. PG&E submitted a letter to the NRC on July 31, 1981, summarizing the results of the testing. The NRC responded to the PG&E letter dated July 31, 1981, in an NRC Letter dated September 14,1981. The letter approved a frequency exception to RG 1.9, Revision 0, Position C.4, and stated:
{(We have reviewed your submittal dated July 31, 1981 in regard to diesel generator load tests and find that the tests demonstrate compliance with the guidelines delineated in Regulatory Guide 1.9 except for one minor frequency variation. The frequency variation was slightly below the 95% frequency lower recommended limit for less than one second; the Diesel Generator showed strong recovery capability demonstrated by return to within the frequency limit within less than 0.035 seconds; this meets the objective of Regulatory Guide 1.9, and is, therefore acceptable."
On March 29, 1985, PG&E submitted Letter DCL-85-132, "Diesel Generator Capability," that provided a summary of the DG capabilities and test results for manufacturer and DCPP testing.
During DG testing performed in the fifth refueling outage for Units 1 and 2 (1 R5 and 2R5) and the seventh refueling outage for Units 1 and 2 (1 R7 and 2R7) to support removal of the kilo-watt sensing (KWS) relay, it was identified that the DG frequency recovery did not meet the RG 1.9, Revision 0, Position C.4 guideline to restore frequency to within 2 percent within 40 percent of the load sequence time interval for the AFW pump loads. In addition in 1997, PG&E calculations for worst case DG load sequence timer tolerances, that are not required by RG 1.9, Revision 0, determined the frequency drop and frequency recovery did not meet RG 1.9, Revision 0, guidelines. To address the exceptions to RG 1.9, Revision 0, PG&E revised FSAR Update Section 8.3.1.1.13.1 under 10 CFR 50.59 to identify the exceptions to RG 1.9, Revision 0, based on RG 1.9, Revision 2, that allows frequency recovery within 60 percent of the load block interval and allows "a greater percentage of the time interval may be used if it can be justified by analysis." These exceptions to RG 1.9, Revision 0, based on RG 1.9, Revision 2, should have received prior NRC approval and were incorrectly included through a change made to the FSAR Update under 10 CFR 50.59.
DG Surveillance Testing The TS surveillance testing for the DGs was originally in accordance, in part, with RG 1.108, Revision 1, "Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," August 1977.
7

Enclosure PG&E Letter DCL-11-038 In the Commission's Safety Evaluation Report Supplement NO.9 for DCPP, dated June 1980, it was stated:
((Our review of the design, testing, surveillance, and maintenance provisions for the Diablo Canyon Units 1 and 2 onsile emergency diesels are described in Section 8.3. 1 of the SER and Section B.3 of SER Supplement 7. Our requirements include preoperational and periodic testing to assure the reliability of the installed diesel generators in accordance with the provisions of Regulatory Guide 1. 1DB."
The TS Bases for TS 3/4.8, "Electrical Power Systems," in NUREG-1151, "Technical Specifications for Diablo Canyon Nuclear Power Plant, Units 1 and 2,"
dated August 1985, stated:
({The Surveillance Requirements for demonstrating the Operability of the diesel generators are in accordance with the recommendations of Regulatory Guides 1.9, 'Selection of Diesel Generator Set Capacity for Standby Power Supplies,' March 10, 1971, 1.108, 'Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants,' Revision 1, August 1977, where applicable, and 1.137
        'Fuel Oil Systems for Standby Diesel Generators, ' Revision 1, October 1979, where applicable."
PG&E has obtained NRC approval of exceptions to RG 1.108, Revision 1, as part of previous amendments for DCPP Units 1 and 2. An exception to the testing frequency guidelines of Regulatory Position C.2.a was approved based on compliance with the Technical Specification 5.5.18 Surveillance Frequency Control Program approved by the NRC in License Amendment No. 200 to Facility Operating License No. DPR-80 and Amendment No. 201 to Facility Operating License No. DPR-82 for the Diablo Canyon Power Plant, Unit Nos. 1 and 2, respectively, dated October 30,2008. An exception to the DG hot restart testing guidelines of Regulatory Position C.2.a.(5) based on use of a modif1ed hot restart test was approved by the NRC in License Amendment No. 105 to Facility Operating License No. DPR-80 and Amendment No.1 04 to Facility Operating License No. DPR-82 for the Diablo Canyon Power Plant, Unit Nos. 1 and 2, respectively, dated June 26, 1995. Exceptions to RG 1.108, Revision 1, Regulatory Positions C.2.a.(9), C.2.d, C.2.e, and C.3 were approved based on compliance with NUMARC 93-01, Revision 2, "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," dated April 1996, as part of License Amendments No. 135 to Facility Operating Licenses No. DPR-80 and No. DPR-82 for the Diablo Canyon Power Plant, Unit Nos. 1 and 2, respectively, dated May 28, 1999.
8

Enclosure PG&E Letter DCL-11-038 Technical Specification Changes SR 3.8.1.2 Revision The nominal design speed of the DG is 900 revolutions per minute (rpm). The DG speed and frequency are directly proportional. A speed of 882 rpm will result in a frequency of 58.8 Hz, a speed of 900 rpm will result in a frequency of 60.0 Hz, and a speed of 918 rpm will result in a frequency of 61.2 Hz.
The current SR 3.8.1.2 for the DG start test contains a speed requirement of greater than or equal to 900 rpm and a frequency requirement of greater than or equal to 58.8 Hz and less than or equal to 61.2 Hz. The use of both a speed requirement and a frequency requirement in the current SR results in an inconsistent requirement and leads to unnecessary questions on whether the SR is met when the frequency is above 58.8 Hz but the speed is between 882 rpm and 900 rpm. The SR 3.8.1.2 contained in the NUREG-1431, Revision 3.1, "Standard Technical Specifications Westinghouse Plants," dated December 1, 2005, contains only a frequency requirement and is stated as: "Verify each DG starts from standby conditions and achieves steady state voltage ~ [3740] V and
~ [4580] V, and frequency ~ [58.8] Hz and ~ [61.2] Hz."
The current SR 3.8.1.2 is revised to remove the requirement to achieve a speed of 900 rpm. It is not necessary to include both a minimum speed requirement and a minimum frequency requirement in SR 3.8.1.2. The minimum frequency requirement of 58.8 Hz in SR 3.8.1.2 ensures the DG is operating at a minimum of 882 rpm, which is within 2 percent if the DG nominal design speed of 900 rpm.
The 2 percent tolerance of the 60 Hz nominal frequency is derived from the guideline given in RG 1.9, Revision 0, Regulatory Position C.4.
The proposed minimum steady state voltage value of 3785 V is consistent with the second level undervoltage relay allowable value contained in TS SR 3.3.5.3.b. This is the minimum steady state voltage needed on the 4160 V vital buses to ensure adequate 4160 V, 480 Vand 120 V levels. The proposed maximum steady state output voltage of 4400 V is equal to the maximum operating voltage for 4000 V motors specified in ANSI C84.1 and ensures that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating voltages. DG operation within the steady state voltage and frequency range reflects the point at which the DG is assumed to have reached stable operation and assures the ability of the power distribution system to undergo further transients. Proposed SR 3.8.1.7.a verifies that the DG is capable of reaching a minimum frequency of 58.8 Hz within 10 seconds. The proposed change is consistent with SR 3.8.1.2 contained in NUREG-1431, Revision 3.1.
9

Enclosure PG&E Letter DCL-11-038 SR 3.8.1.7, 3.8.1.12, 3.8.1.15, and 3.8.1.20 Revisions The current SRs 3.8.1.7.a, 3.8.1.15.a, and 3.8.1.20.a for the DG fast start test, hot restart test, and redundant unit test, respectively, contain a speed requirement of greater than or equal to 900 rpm. Current SRs 3.8.1.7.b, 3.8.10 15.b, and 3.8.1.20.b contain a frequency limits requirement for frequency to be greater than or equal to 58.8 Hz and less than or equal to 61.2 Hz within 13 seconds. The use of both a speed requirement and a frequency requirement in these current SRs results in an inconsistent requirement and leads to unnecessary questions on whether the SR is met when the frequency is above 58.8 Hz but the speed is between 882 rpm and 900 rpm. The SRs 3.8.1.7, 3.8.1.15, and 3.8.1.20 contained in the NUREG-1431, Revision 3.1, "Standard Technical Specifications Westinghouse Plants," dated December 1, 2005, contains only a frequency requirement and require in part:
        "a. In ~  [10] seconds, voltage  ~ [3740] V and frequency  ~ [58.8] Hz and
: b. Steady state voltage ~ [3740] V and    ~ [4580] V and frequency  ~ [58.8]
Hz and ~ [61.2] Hz."
Current SRs 3.8.1.7.b, 3.8.1.15.b, and 3.8.1.20.b contain a minimum 13 second requirement to obtain voltage and frequency within limits while the SRs 3.8.1.7, 3.8.1015, and 3.8.1.20 contained in the NUREG-1431, Revision 3.1, contain a requirement to reach "steady state" instead of a specified time requirement.
Current SR 3.8.1.12.a and b, for the safety injection actuation signal (SIAS) start test, contains a minimum 13-second requirement to obtain voltage and frequency within limits while the SR 3.8.1.12 contained in the NUREG-1431, Revision 3.1, contains separate requirements to recover minimum voltage and frequency within a specified time and to achieve "steady state" voltage and frequency.
SRs 3.8.1.12 contained in the NUREG-1431, Revision 3.1 requires in part:
        "a. In  ~ [10] seconds after auto-start and during tests, achieves voltage
             ~ [3740] V and frequency ~ [58.8] Hz,
: b. Achieves steady state voltage ~ [3740] V and     ~ [4580] Vand frequency ~ [58.8] Hz and ~ [61.2] Hz."
The current SRs 3.8.1.7.a, 3.8.1.15.a, and 3.8.1.20.a are revised to replace the minimum 900 rpm speed requirement with a minimum voltage of greater than or equal to 3785 V and minimum frequency greater than or equal to 58.8 Hz requirement.
10

Enclosure PG&E Letter DCL-11-038 The current SRs 3.8.1.7.b, 3.8.1.15.b, and 3.8.1.20.b are revised to replace the minimum 13-second requirement to obtain voltage and frequency within limits with a requirement to achieve steady state voltage greater than or equal to 3785 V and less than or equal to 4400 V and frequency greater than or equal to 58.8 Hz and less than or equal to 61.2 Hz.
The TS Bases for SRs 3.8.1.2 and 3.8.1.7 is revised to add the statement: "In addition to the SR requirements, the time for the DG to reach steady state operation is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance."
The current SR 3.8.1.12.a is revised to replace the minimum 13-second requirement to obtain voltage within limits with a 10 second requirement to achieve minimum voltage greater than or equal to 3785 V and frequency greater than or equal to 58.8 Hz. SR 3.8.12.b is revised to replace the minimum 13-second requirement to obtain voltage and frequency within limits with a requirement to achieve steady state voltage greater than or equal to 3785 Vand less than or equal to 4400 V and frequency greater than or equal to 58.8 Hz and less than or equal to 61.2 Hz.
The proposed change to SRs 3.8.1.7, 3.8.1.12, 3.8.1.15, and 3.8.1.20 is consistent with the SRs contained in NUREG-1431, Revision 3.1, which is based on approved TSTF Traveler TSTF-163, Revision 2. Traveler TSTF-163, Revision 2 (ADAMS Accession No. ML040500733) was submitted to the NRC on April 22, 1998. The TS changes in Traveler TSTF-163, Revision 2, were made to provide better agreement with the performance of a DG that is started without subsequent connection to an emergency bus (unloaded DG start).
SRs 3.8.1.7,3.8.1.12,3.8.1.15, and 3.8.1.20 are unloaded DG start tests that do not result in connecting the DG to the emergency bus. For unloaded DG starts, a momentary voltage or frequency overshoot (and/or a subsequent undershoot) can occur because no loads are being connected to the DG. A loaded DG start tends to minimize the overshoot, compared to an unloaded DG start where the overshoot might momentarily exceed the specified limits within the first 10 seconds of startup. This is a condition inherent in the design and physical capabilities of the DG governor as it seeks to control DG speed following fast starts when the DG is not connected to an emergency bus. The voltage and frequency excursions do not affect the permissive for closure of the DG output breaker (nominal 3500 V), because the permissive is primarily dependent on minimum conditions being achieved regardless of any overshoot or subsequent momentary undershoot. The requirement for verifying steady state voltage and frequency are within limits following DG connection to an emergency bus is met by the tests required by SR 3.8.1.11 and SR 3.8.1.19. These SRs are associated with simulation of loss-of-offsite power (LOOP) and an actual or simulated SI signal, and they verify the capability of the DGs to provide power at a voltage and frequency adequate to start and operate the ESF loads. The time 11

Enclosure PG&E Letter DCL-11-038 for the DG to reach steady state operation will be periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance, to meet the proposed revision to the TS Bases for SRs 3.8.1.2 and 3.8.1.7.
The proposed minimum frequency requirement in SRs 3.8.1.7, 3.8.1.12, 3.8.1.15, and SR 3.8.1.20 with the minimum frequency requirement of 58.8 Hz in SR 3.8.1.2 ensures the DG is operating at a minimum of 882 rpm, which is within 2 percent of the DG nominal design speed of 900 rpm. DG operation within the steady state voltage and frequency range reflects the point at which the DG is assumed to have reached stable operation and assures the ability of the power distribution system to undergo further transients.
The required DG auto-start time, the time from the start of DG to when the DG breaker is closed onto its associated bus, is 10 seconds. The 10-second DG autostart time is derived from the requirements of the design basis Large Break LOCA. FSAR Update Table 15.4.1-7A summarizes the input assumptions for the Large Break LOCA accident and specifies a SI delay time for offsite power availability and for LOOP. The difference in the delay time for offsite power available and for LOOP is 10 seconds and is the DG auto-start time. The 10-second requirement reflects the assumption of the accident analysis that the DG has reached the point in its acceleration where the DG is able to accept load.
The 13-second requirement to obtain voltage and frequency within limits contained in SRs 3.8.1.7, 3.8.1.12, and 3.8.1.15 is based on a nominal time for the recovery of the DG and the power distribution system following a start and load transient and is not an input value contained in the accident analyses. The proposed replacement of the 13-second requirement to obtain voltage within limits with a 10 second requirement to achieve minimum voltage greater than or equal to 3785 V and frequency greater than or equal to 58.8 Hz in SR 3.8.1.12.a will ensure the DG is able to accept load within 10 seconds consistent with the accident analysis.
TS Bases Changes The TS Bases changes are contained in Attachment 3 for information only.
The Surveillance Requirements Section of the TS 3.8.1 Bases is revised to replace the reference for the basis for the minimum and maximum frequency from RG 1.9, Revision 2, to RG 1.9, Revision 0, Position CA because DCPP has not committed to RG 1.9, Revision 2, on the docket, and has not requested NRC approval to use the guidelines of RG 1.9, Revision 2.
The Surveillance Requirements Section for SR 3.8.1.7 is updated to reflect the revised requirements based on Traveler TSTF-163, Revision 2, to verify minimum voltage and frequency, to verify steady state voltage and frequency are within limits, and that the time for the DG to reach steady state operation is 12

Enclosure PG&E Letter DCL-11-038 periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance. The information related to the 13-second start requirements contained in the current TS 3.8.1 SRs is removed since it is replaced by the new sentence added on verification of the steady state voltage and frequency within limits.
The Surveillance Requirements Section for SR 3.8.1.9 is revised to remove the sentence referencing RG 1.9, Revision 2, for the time, voltage, and frequency tolerances. RG 1.9, Revision 2, is not part of the staff approved design or licensing basis for DCPP.
The Surveillance Requirements Section for SR 3.8.1.12 is revised to replace the current 13-second time to reach voltage and frequency stability with a 10-second time to achieve required minimum voltage and frequency. The 10-second time is based on the requirements of the design basis LOCA analysis. The requirement for the Surveillance to verify the DG achieves steady state voltage and frequency is added.
The Surveillance Requirements Section for SR 3.8.1.15 is revised to replace the current 13-second time to reach voltage and frequency stability with a 10-second time to achieve required minimum voltage and frequency. The 10-second time is based on the requirements of the design basis LOCA analysis. The sentence on acceptance criteria is revised to be consistent with revised requirements based on Traveler TSTF-163, Revision 2, to verify steady state voltage and frequency are within limits. The requirement for the Surveillance to verify the DG achieves steady state voltage and frequency is added.
The Surveillance References Section is revised to remove the reference to RG 1.9, Revision 2. DCPP has not requested NRC approval to use the guidelines of RG 1.9, Revision 2.
FSAR Update Changes FSAR Update Section 8.1.4.3 FSAR Update Section 8.1.4.3 for RG 1.9, Revision 0, is updated to revise the text that states "DCPP is committed to Rev. 0 for EDG steady state loading capability; Rev. 2 for EDG frequency and voltage dip and recovery; and Rev. 3 for EDG test scope and test interval frequency" to state "DCPP is committed to RG 1.9 Rev. 0 with the exception of Regulatory Position C.4. See Section 8.3.1.1.13.1." PG&E is committed to RG 1.9, Revision 0 and the reference to RG 1.9, Revisions 2 and 3, were inappropriately incorporated into the FSAR Update by PG&E. The exception to RG 1.9, Revision 0, Regulatory Position C.4 is justified in the section providing justification for the FSAR Update Section 8.3.1.1.13.1 changes.
13

Enclosure PG&E Letter DCL-11-038 FSAR Update Section 8.3.1.1.13.1, RG 1.9, Revision 0 Exception The paragraph that discusses RG 1.9 compliance is revised to specify an exception to RG 1.9, Revision 0, Regulatory Position C.4, for the AFW pump loading for DGs 1-1, 1-3,2-2, and 2-3, and to remove reference to RG 1.9, Revision 2. The exception is that for AFW pump loading for DGs 1-1, 1-3,2-2, and 2-3, the frequency is restored within 2 percent of nominal in less than 60 percent of the load sequence time interval (2.4 seconds for the DCPP 4 seconds nominal load sequence time interval). RG 1.9, Revision 0, Regulatory Position C.4 specifies that during the DG loading sequence the frequency should be restored to within 2 percent of nominal in less than 40 percent of each load sequence time interval (1.6 seconds for the DCPP 4 seconds nominal load sequence time interval).
The RG 1.9, Revision 0, Regulatory Position C.4 guideline ensures that the diesel is capable of maintaining the 4 kV system conditions (voltage and frequency) necessary for starting and accelerating, to rated speed, all the needed ESF loads. This is accomplished by specifying the DGs be capable of restoring frequency and voltage within 40 percent of the timer interval to the subsequent load.
Surveillance Test Procedure (STP) M-15, "Integrated Test of Engineered Safeguards and Diesel Generators," is performed on a refueling outage frequency to test the DG load sequencing capability under several conditions which simulate a LOOP coincident with a design basis SI signal. The equipment continuous operating loads are dependent on plant configuration at the time of the test. Additional DG frequency and voltage response test data was obtained during the STP M-15 testing during Units 1 and 2 fifth and seventh refueling outages (1 R5, 2R5, 1R7, and 2R7) in order to evaluate the effect of the KWS relays on DG response. The KWS relays were a feature that provided 3 seconds of turboboost to maintain engine speed upon sensing a load step change (10 to 50 percent load step change per the original specification). PG&E was informed by the manufacturer of the KWS relays in 1992 that the minimum load step change setting that could be used for the relay was approximately 25 percent, a load step change that was greater than the largest ESF load for the DCPP DGs.
In 1R7 and 2R7, testing with the KWS relay blocked showed acceptable DG response and provided the basis for later removal of KWS relays from the circuit.
The DG frequency and voltage response test data that was obtained during the 1R5, 2R5, 1R7, and 2R7 outages is not normally captured during STP M-15 testing.
Based on the results of testing performed during 1R5, 2R5, 1R7, and 2R7, the AFW pump frequency recovery times for DGs 1-1, 1-3, 2-2, and 2-3 do not meet RG 1.9, Revision 0, Regulatory Position C.4. The actual frequency recovery times were in the range of 2.2 to 2.3 seconds versus the guideline of 1.6 seconds for a 4 second load sequence time interval. The test data from the 1R5, 2R5, 14

Enclosure PG&E Letter DCL-11-038 1R7, and 2R7 outages establish that there is adequate margin in the 4-second load timer interval to ensure there is no overlapping of loads and that the DG is capable of starting and accelerating subsequent loads.
For DGs 1-3 and 2-3 Bus F, the AFW pump load is the last load. Therefore, for these DGs there is no impact on a subsequent ESF load. For DGs 1-1 and 2-2 Bus H, the AFW pump load is followed by the containment spray (CS) pump load. Since the AFW pump motor is one of the largest loads sequenced on a bus (600 hp per FSAR Update Table 8.3-5) and it has one of the longest start (acceleration) times, it is expected that the frequency recovery would require a longer interval than other ESF loads. The frequency response for the AFW pump motors was compared to one another for available data from the 1R5, 2R5, 1R7, and 2R7 outages. The AFW pump response was consistent, indicating that the extended frequency recovery was not related to an unusual or degraded DG or AFW pump condition or DG overload. The test data demonstrates that the DG frequency consistently stabilizes within a nominal 2.2 to 2.3 seconds and that the DGs are capable of starting and accelerating the subsequent ESF loads.
In addition, preoperation startup DG testing supports concurrent starting and acceleration of an AFW pump and CS pump. In July of 1981, a startup test was performed to demonstrate that DG 1-1 can accept the loading of a AFW pump concurrent with a CS pump. During the test, the DG was run in isochronous mode with a base load of ESF equipment resulting in a bus load of approximately 1100 kW. Four seconds later, an AFW pump and a CS pump were started concurrently resulting in a final bus load of approximately 1850 kW. The successful performance of this test supports the capability of the DGs to start and accelerate an AFW pump concurrently with a CS pump.
The NRC previously approved a minor frequency exception to RG 1.9, Revision 0, for DCPP in the NRC letter dated September 14, 1981. The approved exception was for a frequency variation that was below the 95 percent frequency lower recommended limit for less than one second.
Therefore, it is concluded for AFW pump loading for DGs 1-1, 1-3,2-2, and 2-3 that it is acceptable for the frequency to be restored to within 2 percent of nominal in less than 60 percent of the load sequence time interval (2.4 seconds) and still meet the objectives of RG 1.9, Revision 0, Regulatory Position C.4.
Summary In summary, with the proposed removal of the minimum speed requirement in SR 3.8.1.2, the replacement of the minimum DG speed with a minimum voltage and minimum frequency requirement in SRs 3.8.1.7, 3.8.1.15, and 3.8.1.20, and the replacement of the 13-second voltage and frequency stabilization limit with a steady state voltage and frequency limit in SRs 3.8.1.7, 3.8.1.12, 3.8.1.15, and 3.8.1.20, the DG will continue to perform its function credited in the accident 15

Enclosure PG&E Letter OCL-11-038 analyses. With frequency being restored to within 2 percent of nominal in less than 60 percent of the load sequence time interval for AFW pump loading for OGs 1-1, 1~3, 2-2, and 2-3, the objectives of RG 1.9, Revision 0, Regulatory Position C.4, are still met.
: 4. REGULATORY EVALUATION 4.1    Applicable Regulatory Requirements/Criteria OCPP conforms to 10 CFR Part 50, Appendix A, General Design Criterion (GOC) 17, "Electric Power Systems," and GOC 18, "Inspection and Testing of Electric Power Systems" for the onsite emergency power source. FSAR Update Section 3.1.8.3 discusses the compliance with GOCs 17 and 18.
FSAR Update Section 8.1.4.3 states that OCPP is committed to RG 1.9, Revision O.
The OG TS Surveillance testing is performed in accordance with RG 1.108, Revision 1, with exceptions that have been approved as part of previous amendments for OCPP Units 1 and 2.
Paragraph 50.36(c)(2)(ii) of 10 CFR, "Technical specifications," requires that "[a] TS limiting condition for operation [LCO] of a nuclear reactor must be established for each item meeting one or more of the [criteria set forth in 10 CFR 50.36(c)(2)(ii)(A)-(O)]." Paragraph 50.36(c)(3) of 10 CFR, "Technical specifications," requires that TSs include SRs, which "are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."
Paragraph 50.65(a)(1) of 10 CFR, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," requires that power reactor licensees monitor the performance or condition of systems, structures, and components (SSCs) against licensee-established goals in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. Such goals are to be established commensurate with safety and, where practical, take into account industry-wide operating experience. When the performance or condition of an SSC does not meet established goals, appropriate corrective action must be taken. Paragraph 50.65(a)(3) of 10 CFR, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," requires that "Performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between 16

Enclosure PG&E Letter OCL-11-038 evaluations does not exceed 24 months. The evaluations shall be conducted taking into account, where practical, industry-wide operating-experience. "
With the proposed revisions to the OCPP TS, TS Bases, and FSAR Update, OCPP continues to meet the requirements of GOC 17, GOC 18, 10 CFR 50.36, and 10 CFR 50.65.
For the requested exception to RG 1.9, Revision 0, Regulatory Position C.4, to allow the frequency to be restored to within 2 percent of nominal in less than 60 percent of the load sequence time interval, the objectives of RG 1.9, Revision 0, Regulatory Position C.4, continue to be met.
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
4.2 Precedent The NRC previously approved similar changes to SRs 3.8.1.7,3.8.1.12, 3.8.1.15, and 3.8.1.20 consistent with Traveler TSTF-163, Revision 2, in Amendment No. 159 to Facility Operating License No. NPF-72 and Amendment No. 159 to Facility Operating License No. NPF-77 for the Braidwood Station, Units 1 and 2, and Amendment No. 164 to Facility Operating License No. NPF-37 and Amendment No. 164 to Facility Operating License No. NPF-66 for the Byron Station, Unit Nos. 1 and 2, respectively, on May 11, 2009, and Amendment No. 165 to Facility Operating License No. NPF-47 for the River Bend Station, Unit 1, dated August 11,2009.
The NRC previously approved a minor frequency exception to RG 1.9, Revision 0, for OCPP. The approved exception was for a frequency variation that was below the 95 percent frequency lower recommended limit for less than one second.
17

Enclosure PG&E Letter DCL-11-038 4.3 No Significant Hazards Consideration Determination PG&E has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change revises the acceptance criteria to be applied to an existing Technical Specification (TS) surveillance test of the facility diesel generators (DGs). The proposed changes also revise the Final Safety Analysis Report (FSAR) Update to identify an exception to Regulatory Guide (RG) 1.9, Revision 0, for DG frequency recovery time following loading. The performing of a surveillance test or identification of RG 1.9 exceptions is not an accident initiator and does not increase the probability of an accident occurring. The proposed new surveillance acceptance criteria will continue to assure that the DGs are capable of carrying the peak electrical loading assumed in the various existing safety analyses, which take credit for the operation of the DGs. The proposed RG 1.9 exception does not adversely impact the ability of the DGs to perform their safety function.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed change create the possibility of a new or different accident from any accident previously evaluated?
Response: No.
The proposed change revises the test acceptance criteria for a specific performance test conducted on the existing DGs and specify a RG 1.9 exception. The proposed change does not involve installation of new equipment or modification of existing equipment, so no new equipment failure modes are introduced. The proposed revision to the DG surveillance test acceptance criteria and the RG 1.9 exception are not a change to the way that the equipment or facility is operated and no new accident initiators are created.
Therefore, the proposed change does not create the possibility of a new or different accident from any accident previously evaluated.
18

Enclosure PG&E Letter DCL-11-038
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The conduct of performance tests on safety-related plant equipment is a means of assuring that the equipment is capable of maintaining the margin of safety established in the safety analyses for the facility. With the proposed change in the DG TS surveillance test acceptance criteria, the DG will continue to tested in a manner that assures it will perform as assumed in the existing safety analyses. The proposed RG 1.9 exception does not adversely impact the ability of the DGs to perform their safety function and does not impact the safety analyses for the facility.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above evaluation, PG&E concludes that the proposed change does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.
4.4    Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and securityor to the health and safety of the public.
: 5. ENVIRONMENTAL CONSIDERATION PG&E has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
19

Enclosure PG&E Letter DCL-11-038
: 6. REFERENCES
: 1. Safety Guide 9 (Regulatory Guide 1.9, Revision 0), "Selection of Diesel Generator Set Capacity for Standby Power Supplies," dated March 10, 1971.
: 2. Regulatory Guide 1.9, Revision 1, "Selection, Design, and Qualification of Diesel-Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," dated November, 1978.
: 3. Regulatory Guide 1.9, Revision 2, "Selection, Design, and Qualification of Diesel-Generator Units Used as Standby (Onsite) Electric Power Systems at Nuclear Power Plants," dated December, 1979.
: 4. Regulatory Guide 1.9, Revision 3, "Selection, Design, Qualification, and Testing of Diesel Generator Units Used as Class 1E Onsite Electric Power Systems at Nuclear Power Plants," dated July 1993.
: 5. Regulatory Guide 1.108, Revision 1, "Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants,"
dated August 1977.
: 6. NUREG-1431, Revision 3.1, "Standard Technical Specifications Westinghouse Plants," dated December 1, 2005.
: 7. Technical Specification Task Force traveler, TSTF-163, Revision 2, "Minimum vs. Steady State Voltage and Frequency," dated April 22, 1998.
: 8. PG&E Letter, Philip A. Crane, Jr. (PG&E) to Frank J. Miraglia, Jr. (NRC),
dated July 31, 1981.
: 9. NRC Letter, Robert L Tedesco (NRC) to Malcolm H. Furbush (PG&E), dated September 14, 1981.
: 10. PG&E Letter DCL-85-132, "Diesel Generator Capability," dated March 29, 1985.
: 11. Diablo Canyon Power Station, Units 1 and 2, Safety Evaluation Report Supplement No.9, dated June 1980.
: 12. Amendment No. 135 to Facility Operating License Nos. DPR-80 and DPR-82, "Conversion to Improved Technical Specifications for Diablo Canyon Power Plant, Units 1 and 2 - Amendment No. 135 to Facility Operating License Nos. DPR 80 and DPR-82 (TAC Nos. M98984 and M98985)," dated May 28, 1999.
: 13. Amendment No. 200 to Facility Operating License No. DPR-80 and Amendment No. 201 to Facility Operating License No. DPR-82, "Diablo Canyon Power Plant, Unit Nos. 1 and 2 - Issuance of Amendments RE:
Technical Specifications Change to Relocate Surveillance Test Intervals to a Licensee-Contro"ed Program (Risk-informed Initiative 5b) (TAC Nos.
MD8911 and MD8912)," dated October 30, 2008.
20

Enclosure PG&E Letter DCL-11-038
: 14. NUREG-1366, "Improvements to Technical Specifications Surveillance Requirements," dated December 1992.
: 15. Amendment No.1 05 to Facility Operating License No. DPR-80 and Amendment No.1 04 to Facility Operating License No. DPR-82, "Issuance of Amendments for Diablo Canyon Nuclear Power Plant, Unit No. 1 (TAC No.
M91996) and Unit No.2 (TAC No. M91997)," dated June 26, 1995.
: 16. NUMARC 93-01, Revision 2, "Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," dated April 1996.
: 17. Regulatory Guide 1.160, Revision 2, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," dated March 1997.
: 18. Amendment No. 159 to Facility Operating License No. NPF-72 and Amendment No. 159 to Facility Operating License No. NPF-77 for the Braidwood Station, Units 1 and 2, Amendment No. 164 to Facility Operating License No. NPF-37 and Amendment No. 164 to Facility Operating License No. NPF-66 for the Byron Station, Unit Nos. 1 and 2, respectively, "Braidwood Station, Units 1 and 2, and Byron Station, Unit Nos. 1 and 2 -
Issuance of Amendments RE: Emergency Diesel Generator Start Time Surveillance Requirements (TAC Nos. MD9021, MD9022, MD9023, AND MD9024)," dated May 11,2009.
: 19. Amendment No. 165 to Facility Operating License No. NPF-47 for the River Bend Station, Unit 1, "River Bend Station, Unit 1 - Issuance of Amendments RE: Adoption of Technical Specification Task Force Improved Standard Technical Specification Change Travelers TSTF-163, TSTF-222, TSTF-230, and TSTF-306 (TAC No. ME0406," dated August 11,2009.
21

Enclosure Attachment 1 PG&E Letter DCL-11-038 Technical Specification Pages Markups

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                   FREQUENCY SR 3.8.1.1     Verify correct breaker alignment and indicated power                    In accordance with availability for each required offsite circuit.                         the Surveillance Frequency Control Program SR 3.8.1.2     -----------------------------NOTES---------------------~---------
: 1. Performance of SR 3.8.1.7 satisfies this SR.
: 2. All DG starts may be preceded by an engine
(    prelube period and fonowed by a warmup period prior to loading.
I~
Verifye ch DG starts from standby conditions and                        In accordance with achieves seed> 900 rpm, teady state voltage                             the Surveillance
                ~ 3785 V and::; 4400 V, and frequency ~ 58.8 Hz and                     Frequency Control
::;61.2 Hz.                                                             Program
                             'I SR 3.8.1.3      -----------------------------NOTES------------------------~------
: 1. DG loadings may include gradual loading as recommended by the manufacturer.
: 2. Momentary transients outside the load range do not invalidate this test.
: 3. This Surveillance shall be conducted on only one DG at a time.
: 4. This SR shall be preceded by and immediately                           I follow without shutdown a successful performance
                     'of SR 3.8.1.2 or SR 3.8.1.7.
Verify each DG is synchronized and loaded and                           In accordance with operates for ~ 60 minutes at a load ~ 2340 kW and                       the Surveillance
::;2600 kW.                                                              Frequency Control Program SR 3.8.1.4     Verify each day tank contains ~ 250 gal of fuel oil.                    In accordance with the Surveillance Frequency Control Program SR 3.8.1.5      Check for and remove accumulated water from each                       In accordance with day tank.                                                              the Swrveillance Frequency Control Program SR 3.8.1.6      Verify 'the fuel oil transfer system operates to transfer               In accordance with fuel oil from storage tanks to the day tank.                           the Surveillance Frequency Control Program (continued)
DIABLO CANYON - UNITS 1 & 2                          3.8-4            Unit 1 - Amendment No. m, -2t16",
8S9IDN08.DOA - R8 4                                                   Unit 2 - Amendment No. m, 2841

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                            FREQUENCY SR 3.8.1.7      -----------~-----------------NOTE---------------------------------
All DG starts may be preceded by an engine pre'lube period.
If Verify each DG starts from standby condition and                    In accordance with achieves:                                                           the Surveillance I ~ 10 second;(speed ~ 900 rpri]; and                                   Frequency Control Program
                       .          S-:!6n :;; 13 seconc@;l voltage ~ 3785 V and                                             I 5 } e o.,Jf 5 f Ale:::;; 4400 V, andTrequency 258.8 Hz and
                                 .         :::;;61.2 Hz.
SR 3.8.1.8      -----------------------------NOTE---------------------------------
This Surveillance shall not normally be performed for automatic transfers in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.
I...---='_~,~.                    Verify automatic and manual transfer of AC power                   In accordance with sources from the normal offsite circuit to the alternate          the Surveillance required offsite circuit and manual transfer from the             Frequency Control alternate offsite circuit to the delayed access circuit.          Program SR 3.8.1.9       -----------------------------NOTES-------------------------------
: 1.       This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment.
determines the safety of the plant is maintained or enhanced.
: 2.       If performed with the DG synchronized with offsite power, it shall be performed, at a power factor:::;; 0.9.
Verify each DG rejects a load greater than or equal to            In accordance with its associated single largest post-accident load"and:             the Surveillance
: a. Following load rejection, the frequency is :::;; 63 Hz;      ~~~ci~:~Cy Control
: b. Within 2.4 seconds following load rejection, the voltage is 2 3785 V and:::;; 4400 V; and
: c. Within 2.,4 seconds following load rejection, the frequency is 2 58.8 Hz and:::;; 61:2 Hz.
(continued)
DIABLO CANYON - UNITS 1 & 2                      3.8-5         Unit 1 - Amendment No. ~,4+4'~1 8S9IDN08.DOA - R8 5                                            Unit 2 - Amendment No. ~,m'~f

AC Sources - Operating 3.8.1
* I SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                             FREQUENCY SR 3.8.1.12       ------------------~----------NOTES-------------------------------
: 1. All DG starts may be preceded by an engine prelube period.
: 2.      This Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of tbe plant is maintained or enhanced.
Verify on an actual or simulated Safety Injection ,               In accordance with signal each DG auto-starts from standby condition                 the Surveillance and:       ~               ,                                      Frequency Control 10        a.      Iii ~ d3 seconds after auto-start and durin Program
                                                                                 ~~...-....
tests, achieves voltage;::: 3785 V and ::; 4400 \JJ, b.
H-~-=-
: c.       Operates fo'r;::: 5 minutes;
: d.       Permanently connected loads are energized from the alternate offsite power source; and
: e.      Emergency loads are auto-connected through the ESF load sequencing timers to the, alternate offsite power source.
SR 3.8.1.13    Verify each DG's automatic trips are bypassed when                   In accordance with the diesel engine trip cutout switch is in the cutout              the Surveillance position and the DG is aligned for automatic operation              Frequency Control except:                                                             Program
: a.      Engine overspeed;
: b.      Generato'r differential current; and
: c.       Low lube oil pressure; (continued)
DIABLO CANYON - UNITS 1 & 2                       3.8-7        Unit 1 - Amendment No. ~,4+4,2001 8S91 DN08. DOA - R8 7                                          Unit 2 - Amendment No. ~,m,~

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                               FREQUENCY SR 3.8.1.14        -----------------------------NOTES------------------------------
: 1. Momentary transients outside the load and power factor ranges do not invalidate this test.
t Verify each DG operating at a power factor ~0.87                       In accordance with operates for;;:: 24 hours:                                             the Surveillance Frequency Control
: a.       For;;:: 2 hours loaded;;::: 2600 kW and                       Program
                              ~ 2860 kW; and
: b.       For the remaining hours of the test loaded
                              ;;:: 2340 kW and ~ 2600 kW.
SR 3.8.1.15       -----------------------------NOTE S------------------------------.:.
: 1.       This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated;;::: 2 hours loaded;;::: 2340 kW and ~ 2600 kW.
Momentary transients outside of load range do not invalidate this test.
: 2.       All DG starts may be preceded by an engine,
   "//)(
r~ ~
prelube period.
Verify each DG starts and achieves:
10 seconds, speed::::: 900 rp . and
: b. ):fin::; 13 secoD@voltage;;::: 3785 v{and In accordance with the Surveillance Frequency Control I'
t 5+ t;;.-V\- 5tA. fe. ~ ~ 4400:~ and frequency;;::: 58.8 Hz and Program
                               ~   61.2 Hz.
SR 3.S.1.16-        -----------------------------:-NOTE ---------------------------------
This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.
Verify each DG:                                                        In accordance with the Surveillance
: a.        Synchronizes with offsite power source while Frequency Control loaded with emergency loads upon a simulated Program restoration of offsite power; (continued)
DIABLO CANYON - UNITS 1 & 2                         3.8-8         Unit 1 - Amendment No. ~,4+4,zee, 8S9IDN08.DOA - RS 8                                               Unit 2 - Amendment No. ~,m,Z84,

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                               FREQUENCY SR 3.8.1.19       Verify on an actual or simulated loss of offsite                        In accordance with (continued)       power signal in conjunction with an actual or                          the Surveillance simulated Safety Injection signal:                                     Frequency Control Program
: a.       De-energization of emergency buses;
: b.       Load shedding from emergency buses; and
: c.       DG auto-starts from standby condition and:
: 1.       energizes permanently connected loads in ::;; 10 sE?conds,
: 2.      .energizes auto-connected emergency loads through load sequencing timers,
: 3.       achieves steady state voltage;;::: 3785 V and ::;; 4400 V,
: 4.       achieves steady state frequency;;::: 58.8 Hz and ~ 61.2 Hz, and
: 5.       supplies permanently connected and auto-connected emergency loads for
                                      ;;::: 5 minutes.
SR 3.8.1.20       --------------:---------------NOT E---------------------------------
All DG starts may be preceded by an engine prelube period.
Verify when started simultaneously from standby                         In accordance with" condition, each DG achieves:                                           the Surveillance I ~ 10 seconds:                          -----e-ed-;;:::-9-00-r...,t; and Frequency Control Program "b.         in::;; 13 seconds, voltage;;::: 3785 V and 5+ eft)i    sfI{ fe           ::;; 4400 V, and frequency;;::: 58.8 Hz and
::; 61.2 Hz'.
DIABLO CANYON - UNITS 1 & 2                            3.8-10            Unit 1 - Amendment No. ~,414,Z8ej 8S91DN08.DOA - R8 10                                                     Unit 2 - Amendment No. ~,m,~

Technical Specification 3.8.1 Inserts Insert 1 voltage  ~ 3785 V and frequency ~ 58.8 Hz Insert 2 frequency   ~ 58.8 Hz Insert 3 Achieves steady state voltage ~ 3785 V and::;; 4400 V, and

Enclosure Attachment 2 PG&E Letter DCL-11-038 Retyped Technical Specification Pages Remove Page                                Insert Page 3.8-4                                      3.8-4 3.8-5                                      3.8-5 3.8-7                                      3.8-7 3.8-8                                      3.8-8 3.8-10                                     3.8-10

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                    FREQUENCY SR 3.8.1.1   Verify correct breaker alignment and indicated power                    In accordance with availability for each required offsite circuit.                         the Surveillance Frequency Control Program SR 3.8.1.2   -----------------------------NOTES-------------------------------
: 1. Performance of SR 3.8.1.7 satisfies this SR.
: 2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
Verify each DG starts from standby conditions and                       In accordance with achieves steady state voltage ~ 3785 V and                              the Surveillance s 4400 V, and frequency ~ 58.8 Hz and:::; 61.2 Hz.                      Frequency Control Program SR 3.8.1.3    -----------------------------NOTES-------------------------------
: 1. DG loadings may include gradual loading as recommended by the manufacturer.
: 2. Momentary transients outside the load range do not invalidate this test.
: 3. This Surveillance shall be conducted on only one DG at a time.
: 4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 orSR 3.8.1.7.
Verify each DG is synchronized and loaded and                           In accordance with operates for ~ 60 minutes at a load ~ 2340 kW and                       the Surveillance s 2600 kW.                                                               Frequency Control Program SR 3.8.1.4   Verify eath day tank contains ~ 250 gal of fuel oil.                     In accordance with the Surveillance Frequency Control Program SR 3.8.1.5    Check for and remove accumulated water from each                        In accordance with day tank.                                                                the Surveillance Frequency Control Program SR 3.8.1.6    Verify the fuel oil transfer system operates to transfer                In accordance with fuel oil from storage tanks to the day tank.                            the Surveillance Frequency Control Program (continued) 3.8-4            Unit 1 - Amendment No. -i3-&sect;, ~,
DIABLO CANYON - UNITS 1 & 2                                         Unit 2 - Amendment No. -i3-&sect;, ~,

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                             FREQUENCY SR 3.8.1.7    -----------------------------NOTE--~------------------------------
All DG starts may be preceded by an engine prelube period.
Verify each DG starts from standby condition and                    Inaccordance with achieves:                                                           the Surveillance Frequency Control
: a.        In :s; 10 seconds, voltage ~ 3785 Vand Program frequency ~ 58.8 Hz; and
: b.       Steady state voltage;::: 3785 V and :s; 4400 V, and frequency;::: 58.8 Hz and :s; 61.2 Hz.
SR 3.8.1.8    -----------------------------NOTE---------------------------------
This Surveillance shall not normally be performed for automatic transfers in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.
Verify automatic and manual transfer of AC power                   In accordance with sources from the normal offsite circuit to the alternate           the Surveillance required offsite circuit and manual transfer from the              Frequency Control alternate offsite circuit to the delayed access circuit.           Program SR 3.8.1.9    -----------------------------NOTES-------------------------------
: 1.       This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.
: 2.        If performed with the DG synchronized with offsite power, it shall be performed at a power factor:S; 0.9.
Verify each DG rejects a load greater than or equal to              In accordance with its associated single largest post-accident load, and:             the Surveillance Frequency Control
: a. Following load rejection, the frequency is :s; 63 Hz; Program
: b. Within 2.4 seconds following load rejection, the voltage is ;::: 3785 V and :s; 4400 V; and
: c. Within 2.4 seconds following load rejection, the frequency is ;::: 58.8 Hz and :s; 61.2 Hz.
(continued) 3.8-5          Unit 1 - Amendment No. 4aa,4+4,~,
DIABLO CANYON - UNITS 1 & 2                                  Unit 2 - Amendment No. 4aa,4+S,~,

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                           FREQUENCY SR 3.8.1.12   -----------------------------NOTES-------------------------------
: 1.      All DG starts may be preceded by an engine prelube period.
: 2.      This Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.
Verify on an actual or simulated Safety Injection                 In accordance with signal each DG auto-starts from standby condition                 the Surveillance and:                                                              Frequency Control Program
: a.       In :::; 10 seconds after auto-start and during tests, achieves voltage ~ 3785 V and frequency ~ 58.8 Hz;
: b.       Achieves steady state voltage 2 3785 V and s 4400 V, and frequency ~ 58.8 Hz and
:::; 61.2 Hz;
: c.       Operates for ~ 5 minutes;
: d.       Permanently connected loads are energized from the alternate offsite power source; and
: e.        Emergency loads are auto-connected through the ESF load sequencing timers to the alternate offsite power source.
SR 3.8.1.13  Verify each DG's automatic trips are bypassed when                  In accordance with the diesel engine trip cutout switch is in the cutout              the Surveillance position and the DG is aligned for automatic operation             Frequency Control except:                                                             Program
: a.       Engine overspeed;
: b.        Generator differential current; and
: c.        Low lube oil pressure; (continued) 3.8-7       Unit 1 - Amendment No. ~,.:t-+4,~,
DIABLO CANYON - UNITS 1 & 2                              Unit 2 - Amendment No. ~,4+@,~,

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE                                              FREQUENCY SR 3.8.1.14   -----------------------------NOTES------------------------------
: 1. Momentary transients outside the load and power factor ranges do not invalidate this test.
Verify each DG operating at a power factor SO.87                    In accordance with operates for ~ 24 hours:                                            the Surveillance Frequency Control
: a.      For ~ 2 hours loaded     ~ 2600 kWand Program S 2860 kW; and
: b.      For the remaining hours of the test loaded
                       ~ 2340 kW and S 2600 kW.
SR 3.8.1.15   -----------------------------NOTES-------------------------------
: 1.      This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated ~ 2 hours loaded ~ 2340 kW and S 2600 kW.
Momentary transients outside of load range do not invalidate this test.
: 2.      All DG starts may be preceded by an engine prelube period.
Verify each DG starts and achieves:                                In accordance with
: a.       In S 10 seconds, voltage ~ 3785 V and                     the Surveillance frequency ~ 58.8 Hz; and                                  Frequency Control Program
: b.       Steady state voltage ~ 3785 V and S 4400 V, and frequency ~ 58.8 Hz and S 61.2 Hz.
SR 3.8.1.16    -----------------------------NOTE---------------------------------
This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABI LlTY provided an assessment determines the safety of the plant is maintained or enhanced.
Verify each DG:                                                     In accordance with the Surveillance
: a.       Synchronizes with offsite power source while Frequency Control loaded with emergency loads upon a simulated Program restoration of offsite power; (continued) 3.8-8        Unit 1 - Amendment No. ~,474,~,
DIABLO CANYON - UNITS 1 & 2                               Unit 2 - Amendment No. ~,4+e,~,

AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                               FREQUENCY SR 3.8.1.19   Verify on an actual or simulated loss of offsite                    In accordance with (continued)  power signal in conjunction with an actual or                       the Surveillance simulated Safety Injection signal:                                  Frequency Control Program
: a.       De-energization of emergency buses;
: b.       Load shedding from emergency buses; and
: c.       DG auto-starts from standby condition and:
: 1. energizes permanently connected loads in s 10 seconds,
: 2. energizes auto-connected emergency loads through load sequencing timers,
: 3. achieves steady state voltage;::: 3785 V and s 4400 V,
: 4. achieves steady state frequency;::: 58.8 Hz and S 61.2 Hz, and
: 5. supplies permanently connected and auto-connected emergency loads for
                              ;::: 5 minutes.
SR 3.8.1.20   -----------------------------NOTE---------------------------------
All DG starts may be preceded by an engine prelube period.
Verify when started simultaneously from standby                     In accordance with condition, each DG achieves:                                       the Surveillance Frequency Control
: a.       In S 10 seconds, voltage;;::: 3785 Vand Program frequency;;::: 58.8 Hz; and
: b.      Steady state voltage;::: 3785 V and S 4400 V, and frequency;::: 58.8 Hz and S 61.2 Hz.
3.8-10        Unit 1 - Amendment No. 4-3-&sect;,4+4,2-00, DIABLO CANYON - UNITS 1 & 2                                Unit 2 - Amendment No. 4-3-&sect;,.:t+@,2-G-i,

Enclosure Attachment 3 PG&E Letter DCL-11-038 Technical Specification Bases Pages Markups (For information only)

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE     Where the SRs discussed herein specify voltage and frequency REQUIREMENTS     tolerances, the following is applicable. The minimum steady state (continued)     output voltage of 3785 V is consistent with the second level undervoltage relay allowable values. This is the minimum steady state voltage needed on the 4160 volt vital buses to ensure adequate 4160 volt, 480 volt and 120 volt revels. The specified maximum steady state output voltage of 4400 V is equal to the maximum operating voltage for 4000 V motors specified in ANSI C84.1. The maximum steady state output voltage of 4400 V ensures* that for a lightly loaded distribution system, the voltage at the terminals of 4000 V motors is no more than the maximum rated operating voltages. The specified minimum and maximum frequenci~s of the DG *are 58.8 Hz and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations given in f
Regulatory Guide 1.9 Rev. (Ref. 16).
SR 3.8.1.1 o         'L    PtJ 5 I' -I- ,. 0'4   C Lj J
This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution netWork and availability of offsite AC electrical power. The breaker alignment verifies that each breaker is in its correct position to ensure that distribution buses and loads are connected to their preferred power source, and that approprfate independence of offsite circuhs is maintained. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlfed under the Surveillance Frequency Control Progrnm.                                                           .
SR 3.8.1.2 and SR 3.8.1.7 These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and to maintain the unit in a safe shutdown condition.
To minimize the wear on moving part~ that do not get lubricated when the engine is not running, these SRs are modified by a Note (Note 2 for SR 3.8.1.2) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and, for SR 3.8.1.2, followed by a warmup period prior to loading.
For the purposes of SR 3.8.1.2 and SR 3.8.1.7 testing, the DGS are started from standby conditions. Standby conditions for a DG means that the diesel engine coolant and oil temperature is being maintained consistent with manufacturer recommendations of equal to or greater than gO&deg;F but less than 175&deg;F. For the purposes of this SR, the diesel generator start will be initiated using one of the following signals:
: 1) manual, 2) simulated loss of offsite power, and 3) safety injection actuation test signal.
(continued)
DIABLO CANYON - UNITS 1 & 2                                                            Revision 6a

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE     SR 3.8.1.2and SR 3.8.1.7 (continued)
REQUIREMENTS SR 3.8.1.7 requires that the DG starts from staQf!.by conditions and achieves reqt::liFed ~I?eed withl! I 1e sccoFlds QFlOrequired voltage and frequency within~econds. The 10 second start requirement reflects
       /0-        the point during the DG's acceleration at which the DGis assumed to be abf                  d. The 13 second start requirement reflects the point at whic!) the DG is assumed to have reached stable operation.
These stabil)ty points represent the recovery of the DG and the power distribution system following a transient. This assures the ability of the system to undergo further transients. Actual steady state operation is expecte 0 achieve a level of stability closer to the nominal 60 Hz value. The 10 -e~econ start requiremen . suppo                   e          ;J' ass      ptions of the desIgn basis LOCA analysis in the FSAR, Chapter 15 (Ref. 5).
Since SR 3.S.1.7 requires a timed start, it is more restrictive than SR 3.8 ..1.2, and it may be performed in lieu of SR 3.8.1.2. This is the intent of Note 1 of SR 3.8.1.2.
The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
SR 3.8.1.3 This Surveillance verifies that the DGs are capable of synchronizing with the offsite electrical system and accepting loads greater than or equal to the equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.
Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between 0.8 lagging and 1.0. The 0.8 value is the design rating of the machine, while the 1.0 is an operational limitation to ensure circulating currents are minimized.
The load band is provided to avoid routine overloading of the DG.
OPERATION within the load range of 90% to 100% of rated full load without anomalies will provide adequate assurance of the machine's ability to carry 100 % of rated full load if required.
The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
(continued)
DIABLO CANYON - UNITS 1 & 2                                                        Revision 6a SS9IEA06.DOA- R6a                        14

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE       SR 3.8.1.9 (continued)
REQUIREMENTS The'time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 Rev. 2 (Ref. 16) recommendations for res onse durin load se uence intervals. The 2 .. secon s specified is equal to 600/0 of a typical 4 second load sequence interval associated with sequencing of the largest load. The voltage and frequency specified are consistent with the design range of the equipment powered by the DG. SR 3.8.1.9.a corresponds to the maximum frequency excursion, while SR 3.8.1.9.b and SR 3.8.1.9.c are steady state voltage and frequency values to which the system must recover following load rejection. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
This SR is modified by two Notes. The reason for Note 1 is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge' continued steady state operation and, as a result, unit safety systems.
This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as th~ operator procedures available to cope, with these outcomes. These shall be measured againstthe avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.                                          -
Preplanned maintenance that would require the performance of this SR to demonstrate operability following the maintenance shall only be performed in Modes 3, 4, 5, or 6.
(continued)
DIABLO CANYON - UNITS 1 & 2                                                        Revision 6a 8S9IEA06.DOA - R6a                        18

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE       SR 3.8.1.11 (continued)
REQUIREMENTS This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGS during testing. For the purpose of this
                  , testing, the DGS, must be started from standby conditions, that is, with the engine coolant and oil temperature maintained consistent with manufacturer recommendations of equal to or greater than gO&deg;F but less than 175&deg;F. 'The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.
This restriction from normally performing the Surveillance in MODE 1 or' 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.
These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance ;3re performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this as~essment.
Preplanned maintenance that would require the performance of this SR to demonstrate operability following the maintenance shall only be performed in Modes 5 or 6.
SR 3.8.1.12                      rVVl'      '"    I VI, VV1 tit M This Surveillance demonstratef~~1"the DG automatically starts and
        )0           achieves stabili b reaching the required voltage and frequency within the specif.ie time       seconds) from the S'afety Injection actuation s' nal and operates for ;;:::5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.12.d and SR 3.8.1.12.e ensure that permanently connected loads and emergency loads are energized from the offsite electrical power system on a Safety Injection signal without loss of offsite power. The emergency loads are the ESF loads.
(continued)
DIABLO CANYON - UNITS 1 & 2                                                        Revision 6a

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE     SR 3.8.1.15 REQUIREMENTS This Surveillance demonstrates that the diesel engine can restart from (continued) a hot condition, such as subsequent to shutdown from normal Surveillances, and &sect;ghieve        ..          ..         e Ulre voltage       /0 10 -   and frequency within ~econds. The .;1ksecond time is derive from the requirements of the accident analysis to res ond to a desi n b 's accident. The acceptance criteria represents the recovery of the DG an     e power distribution system following a start and load transient.
This assures the ability of the s em to under 0 fu          transients.
Actual steady state operation is expected to achieve a level of stability closer to the nominal 60 Hz value. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control*Program.
This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to' maintain DG OPERABILITY. The requirement that the diesel has operated for at least 2 hours at full load conditions prior to performance of this Surveillance is based on test data and manufacturer recommendations for achieving hot conditions.
Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.
SR 3.8.1.16 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), this Surveillance ensures that the manual synchronization and load transfer from the DG to the offsite source can be made and the DG can be returned to ready to load status when offsite power is restored. It also ensures that the autostart logic is reset to allow the DG to reload if a subsequent loss of offsite power occurs. The DG is considered to be in ready to load status when the DG is at rated speed and voltage, the output breaker is open and can receive an auto close signal on bus undervoltage, and the load sequencing timers are reset.
The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
(continued)
DIABLO CANYON - UNITS 1 & 2                                                      Revision 6a

AC Sources - Operating B 3.8.1 BASES SURVEILLANCE       SR 3.8.1.20 REQUIREMENTS This Surveillance dem'onstrates*that the DG starting independence has (continued) not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously.
The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil temperature maintained consistent with manufacturer recommendations of equal to or greater than 90&deg;F but less than 175&deg;F.
REFERENCES         1.      10 CFR 50, Appendix A, GOC 17.
: 2.      FSAR, Chapter 8.
: 3.      Regulatory Guide 1.9, Rev. 0, March 10, 1971 (Safety Guide 9).
: 4.      FSAR, Chapter 6.
: 5.      FSAR, Chapter 15.
: 6.      Regulatory Guide 1.93, Rev. 0, December 1974.
: 7.      Generic Letter 84-15, "Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability," July 2, 1984.
: 8.      10 CFR 50, Appendix A, GDC 18.
: 9.      Regulatory Guide 1.108, Rev. 1, August 1977.
: 10. Regulatory Guide 1.137, Rev. 1, Oct 1979.
: 11. AsME, Boiler and Pressure Vessel Code, Section XI.
: 12. Generic Letter 94-01, "Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," May 31, 1994.
: 13. Diesel Generator Allowed Outage Time Study, LA 44/43, October 4, 1989
: 14. License Amendment 44/43, October 4, 1989.
: 15. Regulato     Guide 1.9 Rev. 3, Jul 1993.
: 16.         __        __.__
Regulatory Guide 1.9 Rev. 2, December 1979.
                           --~       ~~          ~=-__F         ~~
                                                                               !II0+   Vs e~~
: 17. License Amendment 166/167, April 20, 2004.18.          Calculation PRA 02-06, "Diesel Generator LAR for 14-day AOT."
: 19. License Amendment 174/176, September 28, 2004.
: 20. Operating Procedure OP J-2:VIII, "Guidelines for Reliable Transmission Service for OCPP."
DIABLO CANYON - UNITS 1 & 2                                                       Revision 6a 8S9IEA06.DOA - R6a                       30

Technical Specification 3.8.1 Bases Inserts Insert 1 SR 3.8.1.2 and SR 3.8.1.7 require the DG achieves steady state voltage and frequency within limits.
Actual steady state operation is expected to achieve a level of stability closer to the nominal 60 Hz value. In addition to the SR requirements, the time for the DG to reach steady state operation is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.
Insert 2 SR 3.8.1.15 requires the DG achieves steady state voltage and frequency within limits.

Enclosure Attachment 4 PG&E Letter DCL-11-038 FSAR Update Markups

DCPP UNITS 1 & 2 FSAR UPDATE Design criteria, as well as guides, codes, and applicable standards, are discussed in this section.
8.1.4.1 Design Bases The electrical systems are designed to ensure an adequate supply of electrical power to all essential auxiliary equipment during normal operation and under accident conditions.
Nonvital 4.16-kV auxiliary buses are provided with two power sources: offsite power and power from the main generator. Vital buses have an additional source: onsite diesel generators. The electrical systems are designed so that failure of anyone electrical device will not prevent operation of the minimum required ESF equipment.
The overall plant single line diagram is shown in Figure 8.1-1. The loads on the vital buses and the capabilities of the diesel generators are listed in Section 8.3.1.
8.1.4.2 General Design Criteria Compliance of electrical systems with the general design criteria, including seismic and environmental qualifications, is discussed in Chapter 3.
8.1.4.3 Regulatory Guides The following AEC and/or NRC Regulatory Guides (RGs) and Safety Guides (SGs) have been implemented:
Guide No.             Date                                       Title 1.6      March 10, 1971        Independence Between Redundant Standby (Onsite)
Power Sources and Between their Distribution Systems 1.9       March 10, 1971       Selection of Diesel-Generator Set Capacity for Standby Power Supplies. PG&E was originally licensed with respect to SG 9, which the NRC subsequently renamed RG 1.9. Hence, any reference to RG 1.9, Rev. 0, dated 1971, in ~ss . &#xa3;e r
                                                      &deg;   sins         G 9. DCPP is committed to Rev. for EDG steady state loading capability; Rev. 2 for EDG frequency and voltage dip and recovery; and Rev. 3 for EDG test scope and test interval frequency.
1.22       Feb. 17, 1972        Periodic Testing of Protection System Actuation Functions, as described in Section 7.2.3 8.1-3                Revision 18 October 2008

DCPP UNITS 1 & 2 FSAR UPDATE pumps would be stopped when most of the water in the refueling water storage tank has been pumped into the containment.
Loading of the diesel generators during the recirculation phase is under the control of the operator. To aid in loading these units, instruments are provided to indicate their load at all times.
8.3.1.1.13 Diesel Generator Units The six diesel generators for Units 1 and 2 are essentially identical, self-contained units housed in individual compartments at elevation +85 feet in the turbine-generator building. Three are located in the northwest or Unit 1 portion, and three are located in the southwest or Unit 2 portion of the structure. The compartments separate each diesel generator and its accessories from the adjacent units and conform to Design Class I requirements. The portion of each compartment that houses the diesel generator is provided with a thermally actuated total flooding CO2 gas system, in accordance with NFPA Standard No. 12 (Reference 6). Temperature-actuated, automatic closing, roll-down fire-rated doors close ventilation air openings to prevent CO 2 leakage. Additionally, two hose stations are provided adjacent to the compartment locations in each unit. The diesel generator installation is in accordance with NFPA Standard No. 37 (Reference 7).
8.3.1.1.13.1 Diesel Generator Unit Description The diesel generators have a net continuous electrical output rating of 2600 kW at 0.8 power factor (PF), and 2752 kW at 0.8 PF, for 2000 hours per year. Short-term ratings of the diesel generators are 3000 kW at 0.8 PF for 2 hours per year, 2860 kW at 0.8 PF for 2 hours per 24-hour period, and 3250 kW at 0.8 PF for 30 minutes per 24-hour period. During the starting sequence for the safeguard loads, these machines can also carry short-time overloads. EDG loading meets the applicable criteria of RG 1.9, Revision 0 (Reference 8).
During a design basis-loading scenario with nominal timer interval, these machines maintain the electric power frequency within 5 percent, hold voltages to a minimum of 5 percent, and recover successfull by complyin with SG          Reference 8) in all respec s except for frequency recovery criteria. The frequency recovery IS met by the applicable criteria of RG 1.9, Revision 2 (Reference 24).
In addition to testing and analysis to demonstrate performance for nominal timer intervals, preoperational tests and computer simulation were performed for a design basis-loading scenario with the worst case timer drift and tolerances. During this scenario, for the last load block, frequency dipped below 95 percent and recovery times in excess of 60 percent of the timer interval were observed. The frequency recovery times exceeding 60 percent of timer interval were justified by analysis following the guidelines of RG 1.9, Revision 2. The frequency dip below 95 percent was for a fraction 8.3-12                     Revision 19 May 2010

Final Safety Analysis Report Inserts Insert 1 PG&E is committed to RG 1.9, Rev. 0, with the exception of Regulatory Position C.4.      See Section 8.3.1.1.13.1.
Insert 2 with the exception of Regulatory Position CA. RG 1.9, Rev. 0, Regulatory Position C.4 specifies that during the EDG loading sequence the frequency should be restored to within 2 percent of nominal in less than 40 percent of each load sequence time interval. For AFW pump loading for EDGs 1-1, 1-3, 2-2, and 2-3, the frequency is restored to within 2 percent of nominal in less than 60 percent of the load sequence time interval. Based on test data, the EDGs 1-1, 1-3, 2-2, and 2-3 have adequate margin to prevent overlapping of loads and meets the objectives of RG 1.9, Rev. 0, Position C.4.
This exception to RG 1.9, Rev. 0, was approved in License Amendments [xxx/xxx] dated [Month],
[Day], [Year].}}