DCL-24-119, License Amendment Request 24-08 Application to Revise Technical Specifications to Adopt TSTF-541: Difference between revisions

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{{Adams
#REDIRECT [[DCL-24-119, Diablo Canyon, Units 1 and 2 - License Amendment Request 24-08 Application to Revise Technical Specifications to Adopt TSTF-541]]
| number = ML24359A003
| issue date = 12/24/2024
| title = License Amendment Request 24-08 Application to Revise Technical Specifications to Adopt TSTF-541
| author name = Brass M
| author affiliation = Pacific Gas & Electric Co
| addressee name =
| addressee affiliation = NRC/NRR, NRC/Document Control Desk
| docket = 05000275, 05000323
| license number = DPR-080, DPR-082
| contact person =
| case reference number = DCL-24-119, TSTF-541
| document type = Letter type:DCL, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specification, Amendment, Technical Specification, Bases Change
| page count = 1
| project =
| stage = Request
}}
 
=Text=
{{#Wiki_filter:Michael J. Brass Director, Nuclear Maintenance Services Diablo Canyon Power Plant Mail code 104/5/508 P.O. Box 56 Avila Beach, CA 93424 805.545.6184 Michael.Brass@pge.com A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
* Diablo Canyon
* Palo Verde
* Wolf Creek PG&E Letter DCL-24-119 10 CFR 50.90 U.S. Nuclear Regulatory Commission 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 24-08 Application to Revise Technical Specifications to Adopt TSTF-541
 
==Dear Commissioners and Staff:==
Pursuant to 10 CFR 50.90, Pacific Gas and Electric Company (PG&E) hereby requests approval of the enclosed proposed amendment to the Diablo Canyon Power Plant (DCPP), Units 1 and 2 Technical Specifications (TS).
PG&E requests adoption of TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position, which is an approved change to the Standard Technical Specifications (STS), into the DCPP, Units 1 and 2 TS. The proposed amendment modifies certain TS Surveillance Requirements (SRs) by adding exceptions to consider the SR met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position, in order to consider the SR met. Securing the automatic valve or damper in the actuated position may affect the operability of the system or any supported systems.
The associated Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function).
The enclosure provides a description and assessment of the proposed changes. provides the existing TS pages marked up to show the proposed changes. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked up to show revised text associated with the proposed TS changes and is provided for information only.
PG&E requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within 180 days.
Pacific Gas and Electric Company*
 
Document Control Desk Page2 PG&E Letter DCL-24-119 PG&E makes no regulatory commitments (as defined by NEI 99-04) in this letter.
This letter includes no revisions to existing regulatory commitments.
The enclosure to this letter contains the evaluation of the proposed change.
In accordance with site administrative procedures and the Quality Assurance Program, the proposed amendment has been reviewed by the Plant Staff Review Committee.
Pursuant to 1 0 CFR 50.91, PG&E is notifying the State of California of this License Amendment Request by transmitting a copy of this letter and enclosure to the California Department of Public Health.
If you have any questions or require additional information, please contact James Morris, Manager, Nuclear Regulatory Services, at 805-545-4609.
I state under penalty of perjury that the foregoing is true and correct.
Sincerely, Michael J. Brass, Director, Nuclear Maintenance Services, delegate for Justin E. Rogers, Station Director mjrm/51264238 Enclosure cc:
Diablo Distribution cc/enc: Anthony Chu, Branch Chief, California Dept of Public Health Mahdi 0. Hayes,-NRC Senior Resident Inspector Samson S. Lee, NRR Project Manager John D. Monninger, NRC Region IV Administrator A
member of the STARS (Strategic Teami ng and Resource Shari ng)
Alliance Callaway
* Comanche Peak
* Diablo Canyon
* Palo Verde
* Wolf Creek
 
PG&E Letter DCL-24-119 Enclosure 1
Evaluation of the Proposed Change
 
==Subject:==
License Amendment Request (LAR) 24-08, Application to Revise Technical Specifications to Adopt TSTF-541, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position 1.
DESCRIPTION 2.
ASSESSMENT 2.1 Applicability of Safety Evaluation 2.2 Variations 2.3 Licensee Verifications 3.
REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Determination 3.2 Conclusion 4.
ENVIRONMENTAL CONSIDERATION ATTACHMENTS:
: 1. Proposed Technical Specification Changes (Mark-Up)
: 2. Revised Technical Specification Pages
: 3. Proposed Technical Specification Bases Changes (Mark-Up) - (For Information Only)
 
PG&E Letter DCL-24-119 Enclosure 2
EVALUATION
 
==1.0 DESCRIPTION==
Pacific Gas and Electric Company (PG&E) requests adoption of TSTF-541, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position," which is an approved change to the Standard Technical Specifications (STS), into the Diablo Canyon Power Plant (DCPP), Units 1 and 2 Technical Specifications (TS). The proposed amendment modifies the TS Surveillance Requirements (SRs) by adding exceptions to consider the SR met when automatic valves or dampers are locked, sealed, or otherwise secured in the actuated position, in order to consider the SR met. Securing the automatic valve or damper in the actuated position may affect the operability of the system or of any supported systems. The associated Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function). The following SRs are affected by the proposed change.
TS 3.7.10, "Control Room Ventilation System (CRVS),"
TS 3.7.12, "Auxiliary Building Ventilation System (ABVS),"
TS 3.7.13, "Fuel Handling Building Ventilation System (FHBVS),"
While the proposed exceptions permit automatic valves and dampers that are locked, sealed, or otherwise secured in the actuated position to be excluded from the SR in order to consider the SR met, the proposed changes will not permit a system that is made inoperable by locking, sealing, or otherwise securing an automatic valve or damper in the actuated position to be considered operable. As stated in the SR 3.0.1 Bases, "Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when: a. The systems or components are known to be inoperable, although still meeting the SRs."
 
==2.0 ASSESSMENT==
2.1 Applicability of Safety Evaluation PG&E has reviewed the safety evaluation for TSTF-541 provided to the Technical Specifications Task Force in a {{letter dated|date=December 10, 2019|text=letter dated December 10, 2019}}. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-541.
PG&E has concluded that the justifications presented in TSTF-541 and the safety evaluation prepared by the NRC staff are applicable to DCPP, Units 1 and 2 and justify this amendment for the incorporation of the changes to the DCPP, Units 1 and 2 TS.
PG&E acknowledges that under the proposed change, the affected valves and dampers may be excluded from the SR when locked, sealed or otherwise secured in the actuated position. However, if the safety analysis assumes movement from the actuated position following an event, or the system is rendered inoperable by locking, sealing, or otherwise securing the valve or damper in the actuated position, then the system cannot
 
PG&E Letter DCL-24-119 Enclosure 3
perform its specified safety function and is inoperable regardless of whether the SR is met.
PG&E acknowledges for components for which the SR allowance can be utilized, the SR must be verified to have been met within its required Frequency after removing the valve or damper from the locked, sealed or otherwise secured status. If the SR exception is utilized to not test the actuation of a valve or damper and the specified Frequency of the SR is exceeded without testing the component, the SR must be performed on the component when it is returned to service in order to meet the SR.
2.2 Variations The DCPP TS utilize different system titles than the STS on which TSTF-541 was based. The following table shows the differences:
DCPP TS Title DCPP TS TSTF-541-A TS Title TSTF-541-A TS Control Room Ventilation System (CRVS) 3.7.10 Control Room Emergency Filtration System (CREFS) 3.7.10 Auxiliary Building Ventilation System (ABVS) 3.7.12 Emergency Core Cooling System (ECCS) Pump Room Exhaust Air Cleanup System (PREACS) 3.7.12 Fuel Handling Building Ventilation System (FHBVS) 3.7.13 Fuel Building Air Cleanup System (FBACS) 3.7.13 Additionally, DCPP TS utilize different SR numbering and some differences in wording than the STS on which TSTF-541 was based. The following table shows the differences in SR numbering and proposed markup wording.
DCPP TS SR Markup DCPP TS SR TSTF-541-A TS SR Markup TSTF-541-A SR Verify each CRVS train automatically switches into the pressurization mode of operation on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
3.7.10.4 Verify each CREFS train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
3.7.10.3
 
PG&E Letter DCL-24-119 Enclosure 4
Verify each ABVS train actuates on an actual or simulated actuation signal and the system realigns to exhaust through the common HEPA filter and charcoal adsorber, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
3.7.12.3 Verify each ECCS PREACS train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
3.7.12.3 Verify each FHBVS train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
3.7.13.3 Verify each FBACS train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
3.7.13.3 Verify damper M-29 can be closed, except if the damper is locked, sealed, or otherwise secured in the closed position.
3.7.13.5 Verify each FBACS filter bypass damper can be closed, except for dampers that are locked, sealed, or otherwise secured in the closed position.
3.7.13.5 However, these differences are administrative and do not affect the applicability of TSTF-541 to the DCPP TS.
The DCPP Technical Specifications contain a Surveillance Frequency Control Program.
Therefore, the Frequency for the affected SRs is "In accordance with the Surveillance Frequency Control Program." This has no effect on the applicability of the proposed change.
2.3 Licensee Verifications PG&E confirms that existing administrative processes, such as the Corrective Action Program, Operability Determination process, the maintenance, design control, configuration control, and operating procedures, etc., will be used to assess the operability of the system or of any supported systems when utilizing the SR allowances, which includes consideration of whether movement of the affected valves or dampers following an event is assumed in the safety analysis.
 
==3.0 REGULATORY ANALYSIS==
3.1 No Significant Hazards Consideration Determination Pacific Gas and Electric Company (PG&E) requests adoption of TSTF-541, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position," which is an approved change to the Standard Technical Specifications (STS), into the DCPP, Unit 1 and 2 Technical Specifications (TS). The proposed amendment modifies the TS Surveillance Requirements (SRs) by adding exceptions to consider the SR met when automatic valves or dampers are locked,
 
PG&E Letter DCL-24-119 Enclosure 5
sealed, or otherwise secured in the actuated position, in order to consider the SR met.
Securing the automatic valve or damper in the actuated position may affect the operability of the system or of any supported systems. The associated Limiting Condition for Operation (LCO) is met if the subject structure, system or component (SSC) remains operable (i.e., capable of performing its specified safety function).
PG&E has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change revises SRs by adding exceptions excluding from actuation and isolation time testing those valves and dampers that are locked, sealed or otherwise secured in the actuated position. The performance or lack of performance of SRs is not an initiator of any accident previously evaluated. As a result, the proposed change has no effect on the probability of any accident previously evaluated. The proposed change excludes performance of portions of certain SRs, but the SSC must still be capable of performing the safety functions assumed in the accident analysis. Otherwise, the SSC is inoperable, and the associated TS Actions are followed. As a result, the SSCs continue to perform their mitigating functions and the consequences of any accident previously evaluated are not affected.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change revises SRs by adding exceptions excluding from actuation and isolation time testing those valves and dampers that are locked, sealed or otherwise secured in the actuated position. The proposed change will not change the design function or operability requirements of the affected SSCs.
The SSC must still be capable of performing the safety functions assumed in the accident analysis or the SSC is inoperable, and the associated TS Actions are followed. The proposed change does not create any credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases.
 
PG&E Letter DCL-24-119 Enclosure 6
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
: 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises SRs by adding exceptions excluding from actuation and isolation time testing those valves and dampers that are locked, sealed or otherwise secured in the actuated position. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis assumptions and acceptance criteria are not affected by this change.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, PG&E concludes that the proposed change presents no 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.
3.2 Conclusion 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 Commissions 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.
 
==4.0 ENVIRONMENTAL CONSIDERATION==
A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a 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.
 
PG&E Letter DCL-24-119 Enclosure Proposed Technical Specification Changes (Mark-Up)
 
CRVS 3.7.10 DIABLO CANYON - UNITS 1 & 2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRVS trains inoperable in MODE 5 OR 6, or during movement of recently irradiated fuel assemblies.
OR E.1 Suspend movement of recently irradiated fuel assemblies.
Immediately One or more CRVS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of recently irradiated fuel assemblies.
F.
Two CRVS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.
F.1 Enter LCO 3.0.3.
Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRVS train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.2 Verify that each CRVS redundant fan is aligned to receive electrical power from a separate OPERABLE vital bus.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.3 Perform required CRVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with VFTP SR 3.7.10.4 Verify each CRVS train automatically switches into the pressurization mode of operation on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.5 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Envelope Habitability Program 3.7-19 Unit 1 - Amendment No. 135,142,163,184,200,201, Unit 2 - Amendment No. 135,142,165,186,201,202,
 
ABVS 3.7.12 DIABLO CANYON - UNITS 1 & 2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 This surveillance shall verify that each ABVS train is aligned to receive electrical power from a separate OPERABLE vital bus.
Operate each ABVS train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.2 Perform required ABVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP
--------------------------NOTE-------------------------------
SR is not applicable to a specific ABVS train when that ABVS train is configured and performing its safety function.
SR 3.7.12.3 Verify each ABVS train actuates on an actual or simulated actuation signal and the system realigns to exhaust through the common HEPA filter and charcoal adsorber, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.4 Not Used.
SR 3.7.12.5 Not Used.
SR 3.7.12.6 Verifying that leakage through the ABVS Dampers M2A and M2B is less than or equal to 5 cfm when subjected to a Constant Pressure or Pressure Decay Leak Rate Test in accordance with ASME N510-1989. The test pressure for the leak rate test shall be based on a maximum operating pressure as defined in ASME N510-1989, of 8 inches water gauge.
In accordance with the Surveillance Frequency Control Program 3.7-22 Unit 1 - Amendment No. 135,163,200, 219, Unit 2 - Amendment No. 135,201,201, 221,
___ r' _
 
FHBVS 3.7.13 DIABLO CANYON - UNITS 1 & 2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Operate each FHBVS train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.13.2 Perform required FHBVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.13.3 Verify each FHBVS train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.13.4 Verify one FHBVS train can maintain a pressure
-0.125 inches water gauge with respect to atmospheric pressure during the post accident mode of operation.
In accordance with the Surveillance Frequency Control Program SR 3.7.13.5 Verify damper M-29 can be closed, except if the damper is locked, sealed, or otherwise secured in the closed position.
In accordance with the Surveillance Frequency Control Program 3.7-24 Unit 1 - Amendment No. 135 142 200 Unit 2 - Amendment No. 135 142 201 t
- - - - - + - - - - -
t
---- i
 
PG&E Letter DCL-24-119 Enclosure Revised Technical Specification Pages
 
CRVS 3.7.10 DIABLO CANYON - UNITS 1 & 2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. Two CRVS trains inoperable in MODE 5 OR 6, or during movement of recently irradiated fuel assemblies.
OR E.1 Suspend movement of recently irradiated fuel assemblies.
Immediately One or more CRVS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6, or during movement of recently irradiated fuel assemblies.
F.
Two CRVS trains inoperable in MODE 1, 2, 3, or 4 for reasons other than Condition B.
F.1 Enter LCO 3.0.3.
Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.10.1 Operate each CRVS train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.2 Verify that each CRVS redundant fan is aligned to receive electrical power from a separate OPERABLE vital bus.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.3 Perform required CRVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with VFTP SR 3.7.10.4 Verify each CRVS train automatically switches into the pressurization mode of operation on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.10.5 Perform required CRE unfiltered air inleakage testing in accordance with the Control Room Envelope Habitability Program.
In accordance with the Control Room Envelope Habitability Program 3.7-19 Unit 1 - Amendment No. 135,142,163,184,200,201, Unit 2 - Amendment No. 135,142,165,186,201,202,
 
ABVS 3.7.12 DIABLO CANYON - UNITS 1 & 2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 This surveillance shall verify that each ABVS train is aligned to receive electrical power from a separate OPERABLE vital bus.
Operate each ABVS train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.2 Perform required ABVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP
--------------------------NOTE-------------------------------
SR is not applicable to a specific ABVS train when that ABVS train is configured and performing its safety function.
SR 3.7.12.3 Verify each ABVS train actuates on an actual or simulated actuation signal and the system realigns to exhaust through the common HEPA filter and charcoal adsorber, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.12.4 Not Used.
SR 3.7.12.5 Not Used.
SR 3.7.12.6 Verifying that leakage through the ABVS Dampers M2A and M2B is less than or equal to 5 cfm when subjected to a Constant Pressure or Pressure Decay Leak Rate Test in accordance with ASME N510-1989. The test pressure for the leak rate test shall be based on a maximum operating pressure as defined in ASME N510-1989, of 8 inches water gauge.
In accordance with the Surveillance Frequency Control Program 3.7-22 Unit 1 - Amendment No. 135,163,200,219, Unit 2 - Amendment No. 135,201,201,221,
 
FHBVS 3.7.13 DIABLO CANYON - UNITS 1 & 2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Operate each FHBVS train for 15 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.7.13.2 Perform required FHBVS filter testing in accordance with the Ventilation Filter Testing Program (VFTP).
In accordance with the VFTP SR 3.7.13.3 Verify each FHBVS train actuates on an actual or simulated actuation signal, except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position.
In accordance with the Surveillance Frequency Control Program SR 3.7.13.4 Verify one FHBVS train can maintain a pressure
-0.125 inches water gauge with respect to atmospheric pressure during the post accident mode of operation.
In accordance with the Surveillance Frequency Control Program SR 3.7.13.5 Verify damper M-29 can be closed, except if the damper is locked, sealed, or otherwise secured in the closed position.
In accordance with the Surveillance Frequency Control Program 3.7-24 Unit 1 - Amendment No. 135 142 200 Unit 2 - Amendment No. 135 142 201
 
Proposed Technical Specification Bases Changes (Mark-Up)
(For Information Only)
 
CRVS B 3.7.10 DIABLO CANYON - UNITS 1 & 2 Rev 14C Page 65 of 96 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.7.10.3 This SR verifies that the required CRVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CRVS filter tests are in accordance with ANSI N510-1980 (Ref. 3). The VFTP includes testing the performance of the HEPA filter, charcoal adsorber efficiency, minimum flow rate, and the physical properties of the activated charcoal. Specific test Frequencies and additional information are discussed in detail in the VFTP.
SR 3.7.10.4 This SR verifies that each CRVS train automatically starts and operates in the pressurization mode on an actual or simulated actuation signal generated from a Phase "A" Isolation. The SR excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
SR 3.7.10.5 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program. Any changes to the most limiting configuration of the CRVS testing alignment for determining unfiltered air inleakage past the CRE boundary into the CRE must be made using a conservative decision making process (References 11-13).
The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. For DCPP, there is no CRVS automatic actuation for hazardous chemical releases or smoke and there are no CRVS Surveillance Requirements that verify operability in cases of hazardous chemicals or smoke. This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences.
When unfiltered air inleakage is greater than the assumed flow rate,
 
ABVS B 3.7.12 DIABLO CANYON - UNITS 1 & 2 Rev 14C Page 75 of 96 BASES (continued)
SURVEILLANCE REQUIREMENTS SR 3.7.12.1 Each ABVS train should be checked periodically to ensure that it functions properly. As the environment and normal operating conditions on this system are not severe, testing each train with flow through both the HEPA filter and charcoal adsorber bank once a month provides an adequate check on this system. Both ABVS trains shall be operated long enough ( 15 minutes) to verify all components are operating correctly. Monthly verification of the separate OPERABLE Class 1E power supplies for the exhaust fans assures system redundancy. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
SR 3.7.12.2 This SR verifies that the required ABVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The ABVS filter tests are in accordance with References 3 and 4. The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).
Specific test Frequencies and additional information are discussed in detail in the VFTP.
SR 3.7.12.3 The SR is modified by a Note, which limits the applicability of this SR when the ABVS is already in its safety function configuration and is verified to be capable of providing that function. The intent of this change is only to address this specific condition and the SR is considered applicable and must be met whenever the ABVS is not in that configuration.
This SR verifies that each ABVS train actuates on an actual or simulated actuation signal by verifying that the system aligns to exhaust through the common HEPA filter and charcoal adsorber and that flow is established through the HEPA and charcoal adsorber (Ref. 3 and 4).
The SR excludes automatic dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.
The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the
 
FHBVS B 3.7.13 DIABLO CANYON - UNITS 1 & 2 Rev 14C Page 81 of 96 BASES ACTIONS (continued)
C.1 When two trains of the FHBVS are inoperable during movement of recently irradiated fuel assemblies in the fuel handling building, suspend movement of recently irradiated fuel assemblies in the fuel handling building. This does not preclude the movement of fuel assemblies to a safe position.
SURVEILLANCE REQUIREMENTS Once actuated due to a fuel handling accident the FHBVS must be protected against a single failure coincident with a loss of offsite power.
Protection against a loss of power, although not required for immediate accident response, is assured by requiring that a backup power supply be provided as described above in the LCO section. This back up is assured via the performance of non-TS surveillances.
SR 3.7.13.1 Standby systems should be checked periodically to ensure that they function properly. As the environmental and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system. This testing requires establishing air flow through both the HEPA filters and charcoal adsorbers.
Systems without heaters need only be operated for 15 minutes to demonstrate the function of the system. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
SR 3.7.13.2 This SR verifies that the required FHBVS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The FHBVS filter tests are in accordance with References 5 and 6. The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of the activated charcoal (general use and following specific operations).
Specific test frequencies and additional information are discussed in detail in the VFTP.
SR 3.7.13.3 This SR verifies that each FHBVS train starts and operates on an actual or simulated actuation signal and directs its exhaust flow through the HEPA Filters and charcoal adsorber banks. The SR does not apply to dampers or valves that are locked, sealed, or otherwise secured in the actuated position since the affected dampers or valves were verified to be in the actuated position prior to being locked, sealed, or otherwise secured. Placing an automatic valve or damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the valve or damper to be repositioned to
 
FHBVS B 3.7.13 DIABLO CANYON - UNITS 1 & 2 Rev 14C Page 82 of 96 the non-actuated position to support the accident analysis. Restoration of an automatic valve or damper to the non-actuated position requires verification that the SR has been met within its required Frequency.
The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
(continued)
 
FHBVS B 3.7.13 DIABLO CANYON - UNITS 1 & 2 Rev 14C Page 83 of 96 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.7.13.4 This SR verifies the integrity of the fuel handling building enclosure.
The ability of the fuel handling building to maintain negative pressure with respect to potentially uncontaminated adjacent areas is periodically tested to verify proper function of the FHBVS. During the post accident mode of operation, the FHBVS is designed to maintain a slight negative pressure in the fuel handling building, to prevent unfiltered LEAKAGE. The FHBVS is designed to maintain the building pressure -0.125 inches water gauge with respect to atmospheric pressure. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
SR 3.7.13.5 Operation of damper M-29 is necessary to ensure that the system functions properly. The operability of damper M-29 is verified if it can be closed. The SR excludes automatic dampers that are locked, sealed, or otherwise secured in the closed position. The SR does not apply if the damper is locked, sealed, or otherwise secured in the closed position since the affected damper was verified to be in the closed position prior to being locked, sealed, or otherwise secured.
Placing an automatic damper in a locked, sealed, or otherwise secured position requires an assessment of the operability of the system or any supported systems, including whether it is necessary for the damper to be opened to support the accident analysis. Restoration of an automatic damper to the opened position requires verification that the SR has been met within its required Frequency. The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
REFERENCES
: 1.
UFSAR, Section 9.4.4.
: 2.
UFSAR, Section 15.5.
: 3.
Regulatory Guide 1.183, July 2000.
: 4.
10 CFR 50.67.
: 5.
ASTM D 3802-1989
: 6.
ANSI N510-1980.
: 7.
NUREG-0800, Section 6.5.1, Rev. 2, July 1981.
: 8.
DCM S-23D, "Fuel handling Building HVAC System."
: 9.
Regulatory Guide 1.183, July 2000.
: 10. License Amendment 184/186, January 3, 2006.
: 11. PG&E Letter DCL-05-124
: 12. License Amendment 163/165, February 27, 2004.}}

Revision as of 05:12, 11 February 2026

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