DCL-04-040, Supplement to Exigent Amendment Request 04-02 Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation

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Supplement to Exigent Amendment Request 04-02 Revision to Technical Specification 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation
ML041040599
Person / Time
Site: Diablo Canyon Pacific Gas & Electric icon.png
Issue date: 04/08/2004
From: Becker J
Pacific Gas & Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
DCL-04-040
Download: ML041040599 (19)


Text

Pacific Gas and Electric Company James R. Becker Diablo Canyon Power Plant Vice President -Diabto Canyon P.O.

Box 56 Operations and Station Director Avila Beach, CA 93424 April 8, 2004 a05.545.423462 Fax: B05.545A4234 PG&E Letter DCL-04-040 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Docket No. 50-275, OL-DPR-80 Diablo Canyon Unit 1 Supplement to Exigent License Amendment Request 04-02 Revision to Technical Specification 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation" Pacific Gas and Electric (PG&E) Letter DCL-04-037, dated April 2, 2004, submitted Exigent License Amendment Request (LAR) 04-02, "Revision to Technical Specification 3.3.5, 'Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation'." LAR 04-02 proposed revising Technical Specification (TS) 3.3.5 to increase the frequency of Surveillance Requirement (SR) 3.3.5.2 from 18 months to 24 months.

The purpose of LAR 04-02 is to allow a delay in the performance of SR 3.3.5.2 on DCPP Unit 1, which is currently in its 12th refueling outage (1R12). To better manage outage defense-in-depth, it is preferable to perform SR 3.3.5.2 later in 1 RI 2, as originally scheduled, when the desired redundancy of safety-related equipment (defense-in-depth) is available.

Based on discussions with the NRC staff, PG&E is submitting this supplement to LAR 04-02 to provide additional justification for the need for approval on an exigent basis and to limit the change to a one-time extension for Unit 1. This LAR submittal supersedes, in its entirety, the LAR submitted in PG&E Letter DCL-04-037. contains a description of the proposed change, the supporting technical analyses, and the no significant hazards consideration determination. Enclosures 2 and 3 contain marked-up and retyped (clean) TS pages, respectively. Enclosures 1, 2, and 3 have been updated to reflect the additional information, and replace the enclosures transmitted in PG&E Letter DCL-04-037. Changes made to Enclosure 1 (from that submitted in PG&E Letter DCL-04-037) are indicated by revision bars.

There are no TS Bases revisions required for this change.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance 0° Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde
  • Wolf Creek

Document Control Desk PG&E Letter DCL-04-040 April 8, 2004 Page 2 PG&E has determined that this LAR does not involve a significant hazards consideration as determined per 10 CFR 50.92. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

This LAR is not required to address an immediate safety concern. However, approval is requested on an exigent basis to allow performance of SR 3.3.5.2 later in 1R12, as originally planned. Approval is requested as soon as practical, but no later than April 19, 2004, to support planned maintenance on DG 1 -1. PG&E requests the license amendment be made effective upon NRC issuance, to be implemented within 10 days from the date of issuance.

If you have any questions or require additional information, please contact Stan Ketelsen at 805-5454720.

Sincerel James R. Becker Vice President - Diablo Canyon Operations and Station Director jerl/3664 Enclosures cc:

Edgar Bailey, DHS Bruce S. Mallett David L. ProuIx Diablo Distribution cc/enc: Girija S. Shukla A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway. Comanche Peak

  • Diablo Canyon
  • Palo Verde. South Texas Project
  • Wolf Creek

PG&E Letter DCL-04-040 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

)

PACIFIC GAS AND ELECTRIC COMPANY)

)

Diablo Canyon Power Plant

)

Unit1

)

)

Docket No. 50-275 Facility Operating License No. DPR-80 AFFIDAVIT James R. Becker, of lawful age, first being duly sworn upon oath says that he is Vice President - Diablo Canyon Operations and Station Director of Pacific Gas and Electric Company; that he has executed this supplement to License Amendment Request 04-02 on behalf of said company with full power and authority to do so; that he is familiar with the content thereof; and that the facts stated therein are true and correct to the best of his knowledge, information, and belief.

James R-ecker Vice President - Diablo Canyon Operations and Station Director Subscribed and sworn to before me this 8th day of April 2004.

Notary Public County of San Luis Obispo State of California SANDRA L. RECTOR 1

Commission # 1339380 Notary Public - california Z

San Luis Obispo Count My Commn. E,;ires Jan 12,2006 PG&E Letter DCL-04-040 EVALUATION

1.0 DESCRIPTION

This letter is a request to amend Operating License DPR-80 for Unit 1 of the Diablo Canyon Power Plant (DCPP).

The proposed change would provide a one-time extension for Unit 1 for the trip actuation device operational test (TADOT) required by Technical Specification (TS) Surveillance Requirement (SR) 3.3.5.2. This change is similar to TADOT frequency extensions approved for other systems by NRC Letter dated April 14, 1997, which issued DCPP License Amendments 118 (Unit 1) and 116 (Unit 2) (LAs 118/116).

2.0 PROPOSED CHANGE

The proposed change would revise TS 3.3.5, "Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation," by adding a note to the FREQUENCY column of SR 3.3.5.2 stating, "For Unit I Cycle 13, SR is due prior to first entry into MODE 4."

Enclosures 2 and 3 contain marked-up and retyped (clean) TS pages, respectively. There are no TS Bases revisions required for this change.

3.0 BACKGROUND

SR 3.3.5.2 requires performing a TADOT on an 18-month frequency on the LOP DG start instrumentation. This involves testing the sequencing of the first and second-level undervoltage (UV) relays that start the three DGs that supply the three 4-kV vital busses (F, G, and H). The TADOT does not verify the relay setpoints. Other SRs performed in Mode 1 are used to verify relay setpoints and characteristics that are subject to time-dependent changes.

System DescriPtion The DGs provide a source of emergency power when offsite power is either unavailable, or is degraded below a point that would allow safe unit operation.

UV protection will generate an LOP start if a loss of voltage, or degraded voltage condition, occurs on the 4.16-kV vital bus. There are three LOP start signals for each 4-kV vital bus.

First level UV relays are provided on each 4-kV Class 1 E vital bus for detecting sustained degraded voltage condition, or a loss of bus voltage. The DG start relay will generate an LOP signal if the voltage is below 61.5 percent for a short time. The DG start relays (one per bus) have an inverse time 1

PG&E Letter DCL-04-040 characteristic and will generate an LOP signal with a < 0.8-second time delay at 2 0 volts and at < 10 seconds for 22583 volts. In addition, the circuit breakers for all loads, except the 4160-480 volt load center transformers, are opened automatically by load shedding relays for first-level undervoltage.

Each of the vital 4160-volt buses has a separate pair of these relays. The relays have a two-out-of-two logic arrangement for each bus to prevent inadvertent tripping of operating loads during a loss of voltage, either from a single failure in the potential circuits, or from human error. One relay trips instantaneously at 2 2870 volts. The second of the two relays has an inverse time characteristic and delay of < 4 seconds at no voltage, and a

< 25-second delay with 2 2583 volts to prevent loss of operating loads during transient voltage dips, and to permit the offsite power sources to pick up the load.

Second level UV relays are provided on each 4160-volt vital bus for detecting a degraded voltage condition, where the voltage of the vital 4-kV buses remains at approximately 3785 volts or below, but above the setpoints of the first-level undervoltage relays. Each vital 4160-volt bus has two second-level undervoltage relays operating with two-out-of-two logic. Each vital 4160-volt bus also has two second-level undervoltage timers. One timer provides the DG starts and the other initiates load shedding.

The following second-level undervoltage actions occur automatically:

(1) After a < 10-second time delay, the respective diesel generators will start.

(2) After a < 20-second time delay, if the undervoltage condition persists, the circuit breakers for all loads to the respective vital 4-kV buses, except the 4160-480-volt load center transformer, are opened and sequentially loaded on the DG.

SR 3.3.5.2 This TADOT surveillance is satisfied for Bus F by performing surveillance test procedure (STP) M-13F, "4KV Bus F Non-SI Auto-Transfer Test," and M-13G and M-13H for buses G and H, respectively. These STPs are performed only in Modes 5, 6, or defueled. Each STP involves initiating a vital bus first-level and second-level UV condition, and then verifying that:

1. The first-level/second-level UV relay is actuated.
2. The associated DG is auto-started.
3. Load shed on the associated bus is initiated.
4. The DG output breaker is closed onto the bus when the DG reaches the required voltage.

2 PG&E Letter DCL-04-040

5. Auto-transfer load sequence is initiated with the required loads sequentially loaded back onto the vital bus.

The SR verifies in part that the UV relays operate (change state) when a UV condition occurs on a 4-kV vital bus. Other SRs are used to verify relay setpoints and characteristics that are subject to time-dependent changes.

SR 3.3.5.2 has a frequency of 18 months. With the interval of 1.25 times the frequency allowed by SR 3.0.2, the maximum interval for this surveillance is 687 days. The due date for SR 3.3.5.2 for the Unit 1 vital busses, including the allowed 1.25 extension, is as follows:

Bus F - April 6, 2004 Bus G - April 8, 2004 Bus H - April 5, 2004 SR 3.3.5.2 is required to be current only when one or more DGs are required to be operable. With Unit 1 fuel currently offloaded to the spent fuel pool, a DG is required only during movement of irradiated fuel assemblies in accordance with TS 3.8.2, "AC Sources - Shutdown."

If TS 3.8.2 is entered and SR 3.3.5.2 is not current, Unit 1 will be required to enter TS 3.3.5 Condition A. Its Required Action A.1 is to enter applicable condition(s) and required action(s) for the associated DG made inoperable by LOP DG instrumentation immediately. Since Unit I is shut down, the applicable TS condition is LCO 3.8.2, which requires at least one DG to be operable. With no DG operable, the required actions are to immediately:

B.1 Suspend core alterations, and B.2 Suspend movement of irradiated fuel assemblies, and B.3 Suspend operations involving positive reactivity additions that could result in loss of required shutdown margin or boron concentration, and B.4 Initiate action to restore required DG to operable status.

With Unit 1 in its shutdown condition, compliance with LCO 3.8.2 actions B.1, B.2, and B.3 is not an issue as it can be controlled. However, compliance with B.4 to restore the DG to operable status would mean performing the applicable M-13F, M-13G and M-13H STP(s) to meet SR 3.3.5.2. From an outage defense-in-depth standpoint, it is better to perform this SR at a time when desired redundancy of safety-related equipment is available. This will not occur until later in 1 R12, past the current due dates for SR 3.3.5.2.

.3 PG&E Letter DCL-04-040 4.0.

JUSTIFICATION AND BASIS FOR THE EXIGENT CIRCUMSTANCES Testing to satisfy SR 3.3.5.2 is normally performed at the end of each refueling outage, in conjunction with testing the load shed and auto sequencing functions for each DG and its associated vital bus. Performance of SR 3.3.5.2 requires de-energizing the vital bus for each DG. This testing is done prior to entering Mode 4 to assure that all components associated with the vital buses are available for testing.

The 18-month frequency for SR 3.3.5.2, and the interval of 1.25 times the frequency allowed by SR 3.0.2, normally provides sufficient time to schedule the tests that satisfy SR 3.3.5.2 at the end of each refueling outage without it becoming overdue. However, following the Unit I eleventh Refueling Outage (1 R1 1), Unit 1 experienced problems with the main generator, which resulted in a 52-day forced Mode 5 outage. This outage affected core burnup for the cycle, which subsequently moved the start date for the Unit 1 twelfth Refueling Outage (I R1 2) to a later date. The effect of this outage schedule change on SR 3.3.5.2 was not discovered until four days into the 1 R12 refueling outage.

This scheduling deficiency has been entered into the DCPP corrective action program for resolution.

Refueling outage schedules are developed months in advance, based on typical outage sequences. Outage maintenance and testing is scheduled using an outage safety schedule as a framework. Outage safety schedules are developed in accordance with Administrative Procedure AD8.DC55, "Outage Safety Scheduling," to minimize shutdown risk and optimize defense-in-depth. The outage safety schedule shows the availability of plant safety systems and vital electrical power supplies during the outage. In conjunction with the outage safety schedule, the Outage Risk Assessment Management (ORAM) program is a computerized program used to analyze outage safety based on maintaining appropriate defense-in-depth.

For Unit I in its present condition (core offloaded), SR 3.3.5.2 does not have to be current as long there is no movement of irradiated fuel assemblies.

However, to allow scheduled fuel reconstitution activities to proceed as planned, a performance of the TADOT for SR 3.3.5.2 for Bus H and DG 1-1 was conducted during the weekend of April 3-4, 2004. The TADOT test was written as a special test, with increased management oversight. Actual testing took approximately three hours. Performance of this test at this time was determined to be acceptable based on a component-based ORAM assessment. Completion of this test allowed making DG 1-1 operable so that fuel reconstitution activities could proceed.

SR 3.3.5.2 testing for Bus F prior to restoration of Bus G has been determined to be unacceptable based on ORAM results. In the case of Bus F testing, the 4

PG&E Letter DCL-04-040 only available auxiliary saltwater (ASW) pump would have to be tripped and restarted twice to complete the test. The other ASW pump is powered from 4-kV Bus G, which is cleared for maintenance at this time, per the outage safety schedule. The ASW system provides cooling to the spent fuel pool cooling system via the component cooling water system. With the core offloaded to the spent fuel pool, interrupting ASW flow at this time places the unit in an unacceptable ORAM condition. Currently 4-kV vital Bus G is out of service for maintenance, making its associated DG 1-2 unavailable for testing.

To provide a plant configuration with the desired redundancy of safety-related equipment (defense-in-depth) without further disruption of the outage plan, it is advisable to retain the existing schedule for performance of the SR 3.3.5.2 TADOTs for Buses F and G later in the outage. This will require extending the frequency of SR 3.3.5.2 as requested in this license amendment request (LAR).

Sufficient testing has been performed to maintain DG 1-1 operable in Modes 5 and 6, to allow continued fuel movement in the fuel handling building. The TADOT-only test for DG 1-1 was written as a special test, with increased management oversight. However, PG&E will not be able to load the core until the LAR is approved, or the test has been completed to support mode 6 activities. At least two DGs are required to provide emergency backup power for two source range channels for core reload.

Performance of the surveillance prior to the original test window in order to meet the existing surveillance frequency requirements will result in de-energizing a vital 4-kV bus when less redundant equipment is available.

This results in an undesirable interruption of ASW cooling for the fuel in the spent fuel pool. In addition, the existing surveillance test procedures used to satisfy SR 3.3.5.2 are written to test multiple bus functions, and cannot be performed as written in the current plant configuration. New procedures must be written to perform the TADOT-only surveillance in the existing plant configuration. This introduces an increased potential for operational error. In addition, performance of a special TADOT test now will not preclude the need to perform the other vital bus load shed and auto sequencing testing scheduled for the end of the outage when all required equipment has been returned to service. This will result in additional vital bus de-energizations, which are undesirable.

Approval is requested as soon as practical, but no later than April 19, 2004, to support planned maintenance on DG 1-1. DG 1-1 is the only Unit 1 DG that is in compliance with SR 3.3.5.2. Approval to extend SR 3.3.5.2 by April 19, 2004, will allow declaring DG 1-3 operable at that time to support planned maintenance, without first having to perform SR 3.3.5.2 testing.

In conclusion, this LAR is submitted on an exigent basis to allow a delay in the performance of the SR 3.3.5.2 testing, which has come due on Unit 1, which is 5

Enclosure I PG&E Letter DCL-04-040 currently in its 1 R12 outage. Early performance of the SR 3.3.5.2 test is not appropriate from an outage safety standpoint. From an outage defense-in-depth standpoint, it is better to perform SR 3.3.5.2 later in 1 RI 2 as originally planned, when the desired redundancy of safety-related equipment is available. Approval to extend the due date for SR 3.3.5.2 will allow performing SR 3.3.5.2 testing in conjunction with load shed and auto sequencing testing for each DG and its associated vital bus at the end of the outage, prior to entry into Mode 4, as currently planned.

5.0 TECHNICAL ANALYSIS

The TADOT required SR 3.3.5.2 is similar to other TADOTs that have been previously revised to change the surveillance frequency from 18 months to 24 months. PG&E Letter DCL-96-052, "License Amendment Request 96-04, Revision of Technical Specifications to Support Extended Fuel Cycles to 24 Months," dated February 14, 1996, and approved by NRC Letter dated April 14, 1997, which issued LAs 118/116, revised the surveillance frequency for the following TADOTs from 18 months to 24 months (the numbering reflects "Current Technical Specifications (CTS)" in use at the time prior to implementation of "Improved TS (ITS)"):

TS 3/4.3.1, "Reactor Trip System Instrumentation," TS 4.3.1.1, Table 4.3-1:

Functional Unit 1, Manual Reactor Trip Functional Unit 18, Safety Injection Input from ESF Functional Unit 19, Reactor Coolant Pump Breaker Position Trip Functional Unit 24, Reactor Trip Bypass Breaker TS 3/4.3.2, "Engineered Safety Features Actuation System Instrumentation," TS 4.3.2.1, Table 4.3-2:

Functional Unit 1.a, Safety Injection, Manual Initiation Functional Unit 3.a.1), Containment Isolation, Phase "A" Isolation, Manual Functional Unit 3.b.1), Containment Isolation, Phase "B" Isolation, Manual Functional Unit 4.a, Steam Line Isolation, Manual Functional Unit 8.c, ESFAS Interlocks, Reactor Trip, P4 The NRC Safety Evaluation issued in support of LAs 118/116 states for these changes:

Devices of functional units of item 3.5.1.1 through item 3.5.1.9 are either manual switches, auxiliary contacts of breakers, shunt-trip solenoids, relays and relay contacts, orsolid state logic states. These devices are tested only 6

PG&E Letter DCL-04-040 during a refueling outage. Testing includes operating of the device and verifying the operability of related alarms, interlocks and/or trips. The licensee stated that these devices do not experience time-dependent drift, and that a review of surveillance, maintenance and operational history of these devices indicated that there were no time-dependent failures or problems in meeting the TS test requirements. In addition, there were no recurring failures observed in historical data. The licensee concluded that the effect on safety of extending the surveillance intervals is small. The staff finds the licensee's conclusion for the proposed change acceptable.

In PG&E Letter DCL-00-056, "Supplement to License Amendment Request 00-01, Administrative Revisions to the Improved Technical Specifications," dated April 11, 2000, PG&E corrected an inadvertent change that had been made to both SR 3.3.5.2 (TADOT) and 3.3.5.3 (channel calibration) to change the frequencies from 18 months to 24 months as part of the ITS conversion. PG&E acknowledged that it had not provided justification for either of these changes and restored the frequency for both to the CTS value of 18 months. In retrospect, PG&E could have retained the 24-month surveillance interval for the SR 3.3.5.2 TADOT by providing a justification similar to the other TADOT revisions that had been made for 24-month fuel cycles.

Justification for a One-Time SR 3.3.5.2 Frequencv Extension for Unit 1 The SR 3.3.5.2 TADOT is performed on a refueling frequency. The frequency of surveillance is based on the potential for an unplanned transient if the surveillance were performed with the reactor at power, and the need to perform this test under conditions that apply during a plant outage.

Operating History A review of DCPP operating history was completed. No instances were found where the relays required to be tested in accordance with SR 3.3.5.2 failed to actuate when required to do so.

Surveillance History A review of the applicable surveillance history was completed. No instances were found where the relays required to be tested in accordance with SR 3.3.5.2 failed to meet their SR 3.3.5.2 surveillance test.

7 PG&E Letter DCL-04-040 Maintenance History A review of the maintenance history for the relays required to be tested in accordance with SR 3.3.5.2 was completed. Other than periodic preventive maintenance and inspection, no maintenance-related issues were identified.

Industry Experience A review of industry experience for the past ten years was completed. No events were identified where relays of the type required to be tested in accordance with SR 3.3.5.2 failed to perform as required.

Summary The surveillance, maintenance, and operating history of the first and second-level UV relays required to be tested in accordance with SR 3.3.5.2 support the conclusion that the effect on safety of extending the surveillance interval is small. No time-dependent failure history is evident for these relays. PG&E believes there is reasonable assurance that the health and safety of the public will not be adversely affected by the proposed TS change.

6.0 REGULATORY ANALYSIS

6.1 No Significant Hazards Consideration 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.

Extending the frequency of Surveillance Requirement (SR) 3.3.5.2 on a one-time basis for Unit I does not involve an accident initiator. The SR only verifies that undervoltage (UV) relays operate (change state) when a UV condition occurs on a 4-kV vital bus. Other SRs performed in Mode 1 are used to verify relay setpoints and characteristics that are subject to time-dependent changes. Therefore, the proposed change will not increase the probability of any accident previously evaluated.

Also, the proposed change has no affect on the radiological consequences of any accident previously evaluated because it will not 8

PG&E Letter DCL-04-040 delay or prevent any plant equipment from performing its design 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 does not involve or create an accident initiator. It only extends the surveillance interval for verifying operability of UV relay sequencing. Other SRs are used to verify relay setpoints and characteristics that are subject to time-dependent changes.

Therefore, the proposed change does not create the possibility of a new or different accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change only involves extending an SR frequency that, has no time-dependent characteristics. The SR itself is not changed.

Other SRs are used to verify relay setpoints and characteristics that are subject to time-dependent changes. Extension of this SR frequency has no effect on any margin of safety.

Based on the above evaluation, 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.

6.2 Applicable Reculatorv Requirements/Criteria 10 CFR 50, Appendix A, "General Design Criteria for Nuclear Power Plants," states in part:

Criterion 17--Electric power systems. An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide 9

PG&E Letter DCL-04-040 sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

Criterion 18--Inspection and testing of electric power systems.

Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system.

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.

7.0 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 effluent 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 10 PG&E Letter DCL-04-040 environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

8.0 REFERENCES

1. PG&E Letter DCL-96-052, 'License Amendment Request 96-04, Revision of Technical Specifications to Support Extended Fuel Cycles to 24 Months," dated February 14, 1996
2. NRC Letter dated April 14, 1997, License Amendments 118 (Unit 1) and 116 (Unit 2)
3. PG&E Letter DCL-00-056, "Supplement to License Amendment Request 00-01, Administrative Revisions to the Improved Technical Specifications," dated April 11, 2000 11 PG&E Letter DCL-04-040 Proposed Technical Specification Page (Mark-up)

Remove Page Insert Page 3.3-41 3.3-42 3.3-41 3.3-42

LOP DG Start Instrumentation 3.3.5 3.3 INSTRUMENTATION 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation LCO 3.3.5 APPLICABILITY:

One channel per bus of loss of voltage DG start Function; and two channels per bus of degraded voltage Function shall be OPERABLE.

MODES 1,2,3, and 4, When associated DG is required to be OPERABLE by LCO 3.8.2, 'AC Sources-Shutdown."

ACTIONS S r C i ey aw------NOTE------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Functions with A.1


NOTE------

one or more channels per One channel may be bus inoperable.

bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing.

Enter applicable Immediately Condition(s) and Requ1rar Action(s) for the Note---

associated DG made For Unit 1 Cycle 13, SR is inoperable by LOP DG due prior to first entry into start instrumentation.

MODE 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 Not used SR 3.3.5.2 Perform TADOT.

8 months SR 3.3.5.3 Perform CHANNEL CALIBRATION with Allowable Value setpoints as follows:

a. Loss of voltage Diesel Start Allowable Value 2 0 V with a time delay of
  • 0.8 seconds and Ž 2583 V with a < 10 second time delay.

Loss of voltage initiation of load shed with one relay Allowable Value Ž 0 V with a time delay of <

4 seconds and 2 2583 V with a time delay < 25 seconds and with one relay Allowable Value 2 2870 V, instantaneous.

18 months wed)

Unit 1 -Amendment No. 435 Unit 2 - Amendment No. 435 42 3.3-41 Diablo Canyon - Units 1 & 2 PG&E Letter DCL-04-040 Proposed Technical Specification Changes (Retyped)

LOP DG Start Instrumentation 3.3.5 3.3 INSTRUMENTATION 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation LCO 3.3.5 APPLICABILITY:

One channel per bus of loss of voltage DG start Function; and two channels per bus of degraded voltage Function shall be OPERABLE.

MODES 1, 2, 3, and 4, When associated DG is required to be OPERABLE by LCO 3.8.2, 'AC Sources-Shutdown."

ACTIONS Sn-----NOTE----a Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Functions with A.1 NOTE--------

one or more channels per One channel may be bus inoperable.

bypassed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing.

Enter applicable Immediately Condition(s) and Required Action(s) for the associated DG made inoperable by LOP DG start instrumentation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.5.1 Not used SR 3.3.5.2 Perform TADOT.


NOTE---

For Unit 1 Cycle 13, SR is due prior to first entry into MODE 4.

18 months (continued)

Diablo Canyon - Units 1 & 2 3.3-41 Unit 1 - Amendment No. 415 442 Unit 2 - Amendment No. 435 442

LOP DG Start Instrumentation 3.3.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.5.3 Perform CHANNEL CALIBRATION with Allowable 18 months Value setpoints as follows:

a. Loss of voltage Diesel Start Allowable Value 2 0 V with a time delay of
  • 0.8 seconds and 2 2583 V with a
  • 10 second time delay.

Loss of voltage initiation of load shed with one relay Allowable Value 2 0 V with a time delay of

  • 4 seconds and 2 2583 V with a time delay
  • 25 seconds and with one relay Allowable Value 2 2870 V, instantaneous.
b. Degraded voltage Diesel Start Allowable Value 2 3785 V with a time delay of
  • 10 seconds.

Degraded voltage initiation of Load Shed Allowable Value 2 3785 V with a time delay of

  • 20 seconds.

3.3-42 Unit 1 - Amendment No. 435 442 Unit 2 - Amendment No. 435 442 Diablo Canyon - Units 1 & 2