Pacific Gas and Electric Company; Diablo Canyon Power Plant, Units 1 and 2 Environmental Assessment and Finding of No Significant Impact

NUCLEAR REGULATORY COMMISSION

[Docket Nos. 50-275 and 50-323]

Pacific Gas and Electric Company; Diablo Canyon Power Plant,

Units 1 and 2 Environmental Assessment and Finding of No Significant

Impact

The U.S. Nuclear Regulatory Commission (the Commission) is

considering the issuance of amendments to Facility Operating Licenses

No. DPR-80 and No. DPR-82 that were issued to Pacific Gas and Electric

Company (the licensee) for operation of the Diablo Canyon Power Plant,

Units 1 and 2 (DCPP), located in San Luis Obispo County, California.

Environmental Assessment

Identification of the Proposed Action

The proposed amendments will revise the existing, or current,

Technical Specifications (CTS) for DCPP in their entirety based on the

guidance provided in NUREG-1431, ``Standard Technical Specifications,

Westinghouse Plants,'' Revision 1, dated April 1995, and in the

Commission's ``Final Policy Statement on Technical Specifications

Improvements for Nuclear Power Reactors,'' published on July 22, 1993

(58 FR 39132). The proposed amendments are in accordance with the

licensee's amendment request dated June 2, 1997, as supplemented by

letters in 1998 dated January 9, June 25, August 5, August 28,

September 25, October 16, October 23, November 25, December 4, December

17, and December 30, and in 1999 dated February 24, March 10, April 28,

May 11, and May 19.

The Need for the Proposed Action

It has been recognized that nuclear safety in all nuclear power

plants would benefit from an improvement and standardization of plant

Technical Specifications (TS). The ``NRC Interim Policy Statement on

Technical Specification Improvements for Nuclear Power Plants,'' (52 FR

3788) contained proposed criteria for defining the scope of TS. Later,

the Commission's ``Final Policy Statement on Technical Specifications

Improvements for Nuclear Power Reactors,'' published on July 22, 1993

(58 FR 39132), incorporated lessons learned since publication of the

interim policy statement and formed the basis for revisions to 10 CFR

50.36, ``Technical Specifications.'' The ``Final Rule'' (60 FR 36953)

codified criteria for determining the content of TS. To facilitate the

development of standard TS for nuclear power reactors, each power

reactor vendor owners' group (OG) and the NRC staff developed standard

TS. For DCPP, the Improved Standard Technical Specifications (ISTS) are

in NUREG-1431. This document formed part of the basis for the DCPP

Improved Technical Specifications (ITS) conversion. The NRC Committee

to Review Generic Requirements (CRGR) reviewed the ISTS, made note of

its safety merits, and indicated its support of the conversion by

operating plants to the ISTS.

Description of the Proposed Change

The proposed changes to the CTS are based on NUREG-1431 and on

guidance provided by the Commission in its Final Policy Statement. The

objective of the changes is to completely rewrite, reformat, and

streamline the CTS (i.e., to convert the CTS to the ITS). Emphasis is

placed on human factors principles to improve clarity and understanding

of the TS. The Bases section of the ITS has been significantly expanded

to clarify and better explain the purpose and foundation of each

specification. In addition to NUREG-1431, portions of the CTS were also

used as the basis for the development of the DCPP ITS. Plant-specific

issues (e.g., unique design features, requirements, and operating

practices) were discussed with the licensee, and generic matters were

discussed with Westinghouse and other OGs.

This conversion is a joint effort in concert with three other

utilities: TU Electric for Comanche Peak Steam Electric Station, Units

1 and 2 (Docket Nos. 50-445 and 50-446); Union Electric Company for

Callaway Plant (Docket No. 50-483); and Wolf Creek Nuclear Operating

Corporation for Wolf Creek Generating Station (Docket No. 50-482). It

was a goal of the four utilities to make the ITS for all the plants as

similar as possible. This joint effort includes a common methodology

for the licensees in marking-up the CTS and NUREG-1431 Specifications,

and the NUREG-1431 Bases, that has been accepted by the staff.

This common methodology is discussed at the end of Enclosure 2,

``Mark-Up of Current TS''; Enclosure 5a, ``Mark-Up of NUREG-1431

Specifications''; and Enclosure 5b, ``Mark-Up of NUREG-1431 Bases,''

for each of the 14 separate ITS sections that were submitted with the

licensee's application. For each of the ITS sections, there is also the

following enclosures:

Enclosure 1, ``Cross-Reference Tables,'' the cross-

reference table connecting each CTS specification (i.e., LCO, required

action, or SR) to the associated ITS specification, sorted by both CTS

and ITS specifications.

Enclosures 3A and 3B, ``Description of Changes to Current

TS'' and ``Conversion Comparison Table,'' the description of the

changes to the CTS section and the comparison table showing which

plants (of the four licensees in the joint effort) that each change to

the CTS applies to.

Enclosure 4, ``No Significant Hazards Considerations,''

the no significant hazards consideration (NSHC) of 10 CFR 50.91 for the

changes to the CTS with generic NSHCs for administrative, more

restrictive, relocation, and moving-out-of-CTS changes, and individual

NSHCs for less restrictive changes and with the organization of the

NSHC evaluation discussed in the beginning of the enclosure.

Enclosures 6A and 6B, ``Differences From NUREG-1431'' and

``Conversion Comparison Table,'' the descriptions of the differences

from NUREG-1431 Specifications and the comparison table showing which

plants (of the four licensees in the joint effort) that each difference

to the ISTS applies to.

[[Page 28533]]

The common methodology includes the convention that, if the words

in an CTS specification are not the same as the words in the ITS

specification, but the CTS words have the same meaning or have the same

requirements as the words in the ITS specification, then the licensees

do not have to indicate or describe a change to the CTS. In general,

only technical changes have been identified; however, some non-

technical changes have also been identified when the changes cannot

easily be determined. The portion of any specification which is being

deleted is struck through (i.e., the deletion is annotated using the

strike-out feature of the word processing computer program or crossed

out by hand). Any text being added to a specification is shown by

shading the text, placing a circle around the new text, or by writing

the text in by hand. The text being struck through or added is shown in

the marked-up CTS and ISTS pages in Enclosures 2 (CTS pages) and 5

(ISTS and ISTS Bases pages) for each ITS section attachment to the

application. Another convention of the common methodology is that the

technical justifications for the less restrictive changes are included

in the NSHCs.

The proposed changes can be grouped into the following four

categories: relocated requirements, administrative changes, less

restrictive changes involving deletion of requirements, and more

restrictive changes. These categories are as follows:

1. Relocated requirements (i.e., the licensee's LG or R changes)

are items which are in the CTS but do not meet the criteria set forth

in the Final Policy Statement. The Final Policy Statement establishes a

specific set of objective criteria for determining which regulatory

requirements and operating restrictions should be included in the TS.

Relocation of requirements to documents with an established control

program, controlled by the regulations or the TS, allows the TS to be

reserved only for those conditions or limitations upon reactor

operation which are necessary to obviate the possibility of an abnormal

situation or event giving rise to an immediate threat to the public

health and safety, thereby focusing the scope of the TS. In general,

the proposed relocation of items from the CTS to the Updated Safety

Analysis Report (USAR), appropriate plant-specific programs, plant

procedures, or ITS Bases follows the guidance of NUREG-1431. Once these

items have been relocated to other licensee-controlled documents, the

licensee may revise them under the provisions of 10 CFR 50.59 or other

NRC-approved control mechanisms, which provide appropriate procedural

means to control changes by the licensee.

2. Administrative changes (i.e., the licensee's A changes) involve

the reformatting and rewording of requirements, consistent with the

style of the ISTS in NUREG-1431, to make the TS more readily

understandable to plant operators and other users. These changes are

purely editorial in nature, or involve the movement or reformatting of

requirements without affecting the technical content. Application of a

standardized format and style will also help ensure consistency is

achieved among specifications in the TS. During this reformatting and

rewording process, no technical changes (either actual or

interpretational) to the TS will be made unless they are identified and

justified.

3. Less restrictive changes and the deletion of requirements

involves portions of the CTS (i.e., the licensee's LS and TR changes)

which (1) provide information that is descriptive in nature regarding

the equipment, systems, actions, or surveillances, (2) provide little

or no safety benefit, and (3) place an unnecessary burden on the

licensee. This information is proposed to be deleted from the CTS and,

in some instances, moved to the proposed Bases, USAR, or procedures.

The removal of descriptive information to the Bases of the TS, USAR, or

procedures is permissible because these documents will be controlled

through a process that utilizes 10 CFR 50.59 and other NRC-approved

control mechanisms. The relaxations of requirements were the result of

generic NRC actions or other analyses. They will be justified on a

case-by-case basis for the DCPP and described in the safety evaluation

to be issued with the license amendment.

4. More restrictive requirements (i.e., the licensee's M changes)

are proposed to be implemented in some areas to impose more stringent

requirements than are in the CTS. In some cases, these more restrictive

requirements are being imposed to be consistent with the ISTS. Such

changes have been made after ensuring the previously evaluated safety

analysis for the DCPP was not affected. Also, other more restrictive

technical changes have been made to achieve consistency, correct

discrepancies, and remove ambiguities from the TS. Examples of more

restrictive requirements include: placing a Limiting Condition for

Operation (LCO) on plant equipment which is not required by the CTS to

be operable; more restrictive requirements to restore inoperable

equipment; and more restrictive surveillance requirements.

There are other proposed changes to the CTS that may be included in

the proposed amendments to convert the CTS to the ITS. These are

beyond-scope issues (BSIs) in that they are changes to both the CTS and

the ISTS. For the DCPP, these are the following:

1. The proposed change to ITS 3.1.7 adds a new action for more than

one digital rod position indicator (DRPI) per group inoperable.

2. The proposed change to ITS Surveillance Requirements (SR)

3.2.1.1 and 3.2.1.1 would revise the frequency to within 24 hours for

verifying the axial heat flux hot channel factor is within limit after

achieving equilibrium conditions.

3. The proposed change to ITS SR 3.6.3.7 adds a note to not require

leak rate test of containment purge valves with resilient seals when

penetration flow path is isolated by test-tested blank flange.

4. The proposed change to ITS 3.1.3 and 5.6.5 adds moderator

temperature coefficient to the Core Operating Limits Report.

5. The proposed change to ITS 3.9.1 and 5.6.5 adds refueling boron

concentration to the Core Operating Limits Report.

6. The proposed change adds an allowance to CTS SR 6.8.4.i for the

reactor coolant pump flywheel inspection program (ITS 5.5.7) to permit

an exception to the examination requirements specified in the CTS SR

(i.e., regulatory position C.4.b of NRC Regulatory Guide (RG) 1.14,

Revision 1) that is consistent with WCAP-14535, ``Topical Report on

Reactor Coolant Pump Flywheel Inspection Elimination.

7. Quarterly channel operational tests (COTs) would be added to CTS

Table 4.3-1 for the power range neutron flux-low and intermediate range

neutron flux. The CTS only require a COT prior to startup for these

functions. A new Note 19 would be added to require that the new

quarterly COT be performed within 12 hours after reducing power below

P-10 for the power range and intermediate range instrumentation (P-10

is the dividing point marking the applicability for these trip

functions), if not performed within the previous 92 days. A new Note 20

would be added to state that the P-6 and P-10 interlocks are verified

to be in their required state during all COTs on the power range

neutron flux-low and intermediate range neutron flux trip functions.

8. The proposed change would revise requirements concerning

overtime by replacing CTS 6.2.2.f with a reference to administrative

procedures for the control of working hours.

[[Page 28534]]

9. The proposed change would revise CTS 6.2.4 to eliminate the

title of Shift Technical Advisor. The engineering expertise is

maintained on shift, but a separate individual would not be required as

allowed by a Commission Policy Statement.

10. The proposed change would revise the dose rate limits in the

Radioactive Effluent Controls Program for releases to areas beyond the

site boundary to reflect 10 CFR Part 20 requirements.

11. The proposed change would revise the Radioactive Effluents

Controls Program to include clarification statements denoting that the

provisions of CTS 4.0.2 and 4.0.3, which allow extensions to

surveillance frequencies, are applicable to these activities.

12. CTS provides alternative high radiation area access control

alternatives pursuant to 10 CFR 20.203(c)(2). The proposed change would

revise CTS 6.12 to meet the current requirements in 10 CFR Part 20 and

the guidance in NRC Regulatory Guide 8.38, ``Control of Access to High

and Very High Radiation Areas in Nuclear Power Plants'' for such access

controls.

13. The proposed change would delete the CTS 6.9.1.7 requirement to

provide documentation of all challenges to the power operated relief

valves (PORVs) and safety valves on the reactor coolant system. The

proposed change is based on Generic Letter 97-02, ``Revised Contents of

the Monthly Operating Report,'' which reduced the requirement for

submitting such information to the NRC. GL-97-02 did not include these

valves for information to be submitted.

14. The proposed change would limit the CTS SRs 4.4.4.1.a and

4.4.4.2 requirements to perform the 92-day surveillance of the

pressurizer PORV block valves and the 18-month surveillance of the

pressurizer PORVs (i.e., perform one complete cycle of each valve) to

only Modes 1 and 2.

15. The proposed change would limit the CTS 4.4.4.2 requirement to

perform the 92-day surveillance of the pressurizer PORV block valves in

that the SR would not be performed if the PORV block valve is closed to

meet Action a of CTS LCO 3.4.4. Action a is for a PORV being

inoperable, but capable of being cycled.

16. The proposed change would revise the frequency for performing

the trip actuating device operational test (TADOT) in CTS Table 4.3-1

for the turbine trip (functional units 17.a and 17.b) to be consistent

with the modes for which the surveillance is required. This would be

adding a footnote to the TADOT that states ``Prior to exceeding the P-9

interlock whenever the unit has been in Mode 3.''

17. The proposed change would revise the diesel generator (DG)

loading requirements for the load rejection test in CTS SR

4.8.1.1.2.b.4 to specify a range of acceptable loads in kW without

tripping instead of specifying only a single minimum acceptable kW

load. The CTS require that the minimum load for the load rejection test

in SR 4.8.1.1.2.b.4 is 2484 kW and the proposed range of loads is

2370 kW and 2610 kW.

18. The proposed change would increase the maximum allowable DG

voltage following load rejection in CTS SR 4.8.1.1.2.b.4 from 4580 to

6200 volts.

19. The proposed change would remove the wording ``during

shutdown'' from the frequency of CTS SR 4.8.1.1.1.b.1 for manual bus

transfers, SR 4.8.1.1.2b.4 for emergency diesel generator (EDG) full

load testing, and SR 4.8.1.1.2.b.8 for the EDG 24-hour load run

testing. The change will facilitate post maintenance testing of an EDG

without requiring a plant shutdown.

20. The proposed change incorporates WCAP-13632-P-A, ``Eliminate

Response Time Testing of Pressure Sensors,'' into CTS SR 4.3.1.2 and SR

4.3.2.2, to state that the function shall be ``verified'' rather than

``demonstrated.'' This changes the Bases for ITS SR 3.3.1.16 and SR

3.3.2.10 to allow the elimination of pressure sensor response time

testing.

Environmental Impacts of the Proposed Action

The Commission has completed its evaluation of the proposed

conversion of the CTS to the ITS for DCPP, including the beyond-scope

issues discussed above. Changes which are administrative in nature have

been found to have no effect on the technical content of the TS. The

increased clarity and understanding these changes bring to the TS are

expected to improve the operators control of DCPP in normal and

accident conditions.

Relocation of requirements from the CTS to other licensee-

controlled documents does not change the requirements themselves.

Future changes to these requirements may then be made by the licensee

under 10 CFR 50.59 and other NRC-approved control mechanisms which will

ensure continued maintenance of adequate requirements. All such

relocations have been found consistent with the guidelines of NUREG-

1431, the Commission's Final Policy Statement, and 10 CFR 50.36, as

amended.

Changes involving more restrictive requirements have been found to

enhance plant safety.

Changes involving less restrictive requirements have been reviewed

individually. When requirements have been shown to provide little or no

safety benefit, or to place an unnecessary burden on the licensee,

their removal from the TS was justified. In most cases, relaxations

previously granted to individual plants on a plant-specific basis were

the result of a generic action, or of agreements reached during

discussions with the OG, and found to be acceptable for the plant.

Generic relaxations contained in NUREG-1431 have been reviewed by the

NRC staff and found to be acceptable.

In summary, the proposed revisions to the TS were found to provide

control of plant operations such that reasonable assurance will be

provided that the health and safety of the public will be adequately

protected.

The proposed amendments will not increase the probability or

consequences of accidents, will not change the quantity or types of any

effluent that may be released offsite, and will not significantly

increase the occupational or public exposure. Also, these changes do

not increase the licensed power and allowable effluents for the plant.

The changes will not create any new or unreviewed environmental impacts

that were not considered in the Final Environmental Statement (FES)

related to the operation of DCPP, dated May 1973 and addendum dated May

1976. Therefore, there are no significant radiological impacts

associated with the proposed amendments.

With regard to potential non-radiological impacts, the proposed

amendments involve features located entirely within the restricted area

for the plant defined in 10 CFR Part 20. They do not affect non-

radiological plant effluents and have no other environmental impact.

They do not increase any discharge limit for the plant. Therefore,

there are no significant non-radiological environmental impacts

associated with the proposed amendments.

Accordingly, the Commission concludes that there are no significant

environmental impacts associated with the proposed amendments.

Alternatives to the Proposed Action

Since the Commission has concluded there is no significant

environmental impact associated with the proposed amendments, any

alternatives with equal or greater environmental impact need not be

evaluated. The principal alternative to the proposed amendments

[[Page 28535]]

would be to deny the amendments. Denial of the licensee's application

would not reduce the environmental impacts of DCPP operations, but it

would prevent the safety benefits to the plant from the conversion to

the ITS. The environmental impacts of the proposed action and the

alternative action are similar.

Alternative Use of Resources

This action does not involve the use of any resources not

previously considered in the FES for DCPP.

Agencies and Persons Consulted

In accordance with its stated policy, on April 2, 1999, the staff

consulted with the California State official, Mr. Steve Hsu of the

Radiologic Health Branch of the State Department of Health Services,

regarding the environmental impact of the proposed amendments. The

State official had no comments.

Finding of No Significant Impact

Based upon the environmental assessment, the Commission concludes

that the proposed amendments will not have a significant effect on the

quality of the human environment. Accordingly, the Commission has

determined not to prepare an environmental impact statement for the

proposed action.

For further details with respect to the proposed action, see the

licensee's application dated June 2, 1997, as supplemented by letters

in 1998 dated January 9, June 25, August 5, August 28, September 25,

October 16, October 23, November 25, December 4, December 17, and

December 30, and in 1999 dated February 24, March 10, April 28, May 11,

and May 19, which are available for public inspection at the

Commission's Public Document Room, The Gelman Building, 2120 L Street,

NW., Washington, DC, and at the local public document room located at

the California Polytechnic State University, Robert E. Kennedy Library,

Government Documents and Maps Department, San Luis Obispo, California

93407.

Dated at Rockville, Maryland, this 20th day of May 1999.

For the Nuclear Regulatory Commission.

Steven D. Bloom,

Project Manager, Section 2, Project Directorate IV & Decommissioning,

Division of Licensing Project Management, Office of Nuclear Reactor

Regulation.

[FR Doc. 99-13420 Filed 5-25-99; 8:45 am]

BILLING CODE 7590-01-P