ML020780363
| ML020780363 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/01/2002 |
| From: | Ide W Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-04663-WEI/SAB/GAM/kg | |
| Download: ML020780363 (15) | |
Text
10 CFR 50.90 William E. Ide Mail Station 7602 Palo Verde Nuclear Vice President TEL (623) 393-6116 P.O. Box 52034 Generating Station Nuclear Production FAX (623) 393-6077 Phoenix, AZ 85072-2034 102-04663-WEI/SAB/GAM/kg March 1, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3 Docket Nos. STN 50-52815291530 Request for Amendment to Technical Specification Surveillance Requirement 3.0.3 Regarding Missed Surveillance Using the Consolidated Line Item Improvement Process (CLIIP)
Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) hereby requests an amendment to Technical Specifications (TS) Section 3.0 for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3. The proposed amendment would modify the TS requirements for missed surveillances in Surveillance Requirement (SR) 3.0.3 using the Consolidated Line Item Improvement Process (CLIIP). The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) change TSTF-358, Revision 6. The availability of this CLIIP TS improvement was published in the FederalRegister on September 28, 2001 (66 FR 49714).
APS is submitting this license amendment application in conjunction with an industry consortium of six plants as a result of a mutual agreement known as Strategic Teaming and Resource Sharing (STARS). The STARS group consists of the six plants operated by Wolf Creek Nuclear Operating Corporation, TXU Electric, AmerenUE, Pacific Gas and Electric, STP Nuclear Operating Company, and Arizona Public Service.
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Comanche Peak
- Diablo Canyon
- Palo Verde o South Texas Project
- Wolf Creek
-U. S. Nuclear Regulatory Commission Request for Amendment to Technical Specification Surveillance Requirement 3.0.3 Regarding Missed Surveillance Page 2 Attachment 1 provides a description and assessment of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed change. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides a summary of the regulatory commitments made in this submittal. Attachment 5 provides the existing TS Bases pages marked up to show the proposed change. Final TS Bases changes will be implemented pursuant to TS 5.5.14, Technical Specifications Bases Control Program.
Attachment 5 is provided for information only; however, APS will adopt these TS Bases changes upon implementation of the license amendment. This is the only commitment associated with this amendment application.
In accordance with the PVNGS Quality Assurance Program, the Plant Review Board and Offsite Safety Review Committee have reviewed and concurred with this proposed amendment. By copy of this letter, this submittal is being forwarded to the Arizona Radiation Regulatory Agency (ARRA) pursuant to 10 CFR 50.91 (b)(1)
Approval of this amendment application is requested by July 31, 2002. Once approved, this amendment will be implemented within 60 days.
Should you have any questions, please contact Thomas N. Weber at (623) 393-5764.
Sincerely, WEI/SAB/GAM/kg Attachments: 1. Description and Assessment
- 2. Proposed Technical Specification Changes (Mark-up)
- 3. Proposed Technical Specification Pages (Clean)
- 4. List of Regulatory Commitments
- 5. Proposed Technical Specification Bases Changes (Mark-up) cc: E. W. Merschoff [Region IV Administrator] (all w/Attachments)
J. N. Donohew [NRR Project Manager]
J. H. Moorman [Sr. Resident Inspector]
A. V. Godwin [ARRA]
STATE OF ARIZONA )
COUNTY OF MARICOPA )
I, William E. Ide, represent that I am Vice President Nuclear Production, Arizona Public Service Company (APS), that the foregoing document has been signed by me on behalf of APS with full authority to do so, and that to the best of my knowledge and belief, the statements made therein are true and correct.
William E. Ide Sworn To Before Me This /J Day Ofile.k. ,2002.
FVAL SEL" Nora E. ead 4yotary Public t" Pbm i Notary Commission Stamp
Attachment 1 Proposed Technical Specification Change Description and Assessment
Attachment 1 Page 1 of 2 Description and Assessment
1.0 DESCRIPTION
The proposed amendment would modify technical specifications (TS) requirements for missed surveillances in Surveillance Requirement (SR) 3.0.3.
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) change TSTF-358, Revision 6.
TSTF-358, Revision 6, incorporates the modifications made to TSTF-358, Revision 5, by Federal Register Notice 66 FR 32400 of June 14, 2001, and in response to public comments. The availability of this TS improvement was published in the Federal Registeron September 28, 2001 (66 FR 49714) as part of the consolidated line item improvement process (CLIIP).
2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation Arizona Public Service Company (APS) has reviewed the proposed safety evaluation dated June 14, 2001, as modified in response to the comments noticed on September 28, 2001, as part of the CLIIP. This review included a review of the NRC staff's evaluation, as well as the supporting information provided to support TSTF-358. APS has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Palo Verde Nuclear Generating Station (PVNGS) and justify this amendment for the incorporation of the changes to the PVNGS Plant TS.
2.2 Optional Changes and Variations APS is not proposing any variations or deviations from the TS changes described in TSTF-358, Revision 6, or the NRC staff's model safety evaluation dated June"14, 2001, as modified in response to the comments noticed on September 28, 2001.
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination APS has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the FederalRegisteras part of the CLIIP. The modifications to TSTF-358 and the proposed safety evaluation noticed on September 28, 2001, as part of the CLIIP, do not affect the NSHCD published in the Federal Register Notice of June 14, 2001. APS has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to PVNGS and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
Attachment 1 Page 2 of 2 3.2 Verification and Commitments As discussed in the notice of availability published in the FederalRegister on September 28, 2001, for this TS improvement, plant-specific verifications were performed as described below.
APS has established TS Bases for SR 3.0.3 which state that use of the delay period established by Surveillance Requirement 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend surveillance intervals, but only for the performance of missed surveillances. The modification will also include changes to the Bases for SR 3.0.3 that provide details on how to implement the new requirements.
The Bases changes provide guidance for surveillance frequencies that are not based on time intervals but are based on specified unit conditions, operating situations, or requirements of regulations. In addition, the Bases changes state that APS is expected to perform a missed surveillance test at the first reasonable opportunity, taking into account appropriate considerations, such as the impact on plant risk and accident analysis assumptions, consideration of unit conditions, planning, availability of personnel, and the time required to perform the surveillance. The Bases also state that the risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the missed surveillance should be treated as an emergent condition, as discussed in Regulatory Guide 1.182. In addition, the Bases state that the degree of depth and rigor of the evaluation should be commensurate with the importance of the component and that missed surveillances for important components should be analyzed quantitatively.
The Bases also state that the results of the risk evaluation determine the safest course of action. In addition, the Bases state that all missed surveillances will be placed in the licensee's Corrective Action Program. Finally, APS has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications.
4.0 ENVIRONMENTAL EVALUATION APS has reviewed the environmental evaluation included in the model safety evaluation dated June 14, 2001 as part of the CLIIP. The modifications to TSTF-358 and the proposed safety evaluation noticed on September 28, 2001, as part of the CLIIP, do not affect the environmental evaluation published in the Federal Register Notice of June 14, 2001. APS has concluded that the staff's findings presented in that evaluation are applicable to PVNGS and the evaluation is hereby incorporated by reference for this application.
Attachment 2 Proposed Technical Specification Changes (Mark-up)
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... " basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is 4-q-& greater. This delay period is permitted to allow performance of the
- risk evaiuati***' s"hall be performed for any Stirvpi 11 ance. A If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
(continued)
PALO VERDE UNITS 1,2,3 3.0-4 AMENDMENT NO. -4
Attachment 3 Proposed Technical Specification Pages (Clean)
SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.
Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.
SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.
For Frequencies specified as "once," the above interval extension does not apply.
If a Completion Time requires periodic performance on a "once per ... " basis, the above Frequency extension applies to each performance after the initial performance.
Exceptions to this Specification are stated in the individual Specifications.
SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
(continued)
PALO VERDE UNITS 1,2,3 3.0-4 AMENDMENT NO. 1-
Attachment 4 List of Regulatory Commitments Regulatory Commitments Due Date APS will establish the Technical To be implemented with Specification Bases for SR 3.0.3 as implementation of license amendment.
adopted with the applicable license amendment
Attachment 5 Proposed Technical Specification Bases Changes
SR Applicability B 3.0 BASES SR 3.0.2 The provisions of SR 3.0.2 are not intended to be used (continued) repeatedly merely as an operational convenience to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.
SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is Te!.s greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met. Reference Bases Section 3.0.2 for discussion and applicability of Frequency and 25% extension.
This delay period provides an adequate time to complete Surveillances that have been missed. This delay period permits the completion of a Surveillance before complying with Required Actions or other remedial measures that might preclude completion of the Surveillance.
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.
SR30.3IzoproVidcz a timc lim:it for complotioG o 1acc~that become app! kabl e as a consequonoc of Surci MOQPý changes imposed by Requi red Actions.,
(continued)
PALO VERDE UNITS 1,2,3 B 3.0-16 REVISION 0
SR Applicability B 3.0 BAS ES SR 3.0.3 (continued)
Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the PALO VERDE UNITS 1,2,3 B 3.0-17A REVISION
SR Applicability B 3.0 BASES If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.
Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.
SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified Condition in the Applicability.
This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit.
The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.
(continued)
PALO VERDE UNITS 1,2,3 B 3.0-17B REVISION