ML051880501

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License Amendments 155, 155 and 155 Main Steam Safety Valves
ML051880501
Person / Time
Site: Palo Verde  
Issue date: 07/07/2005
From: Fields M
NRC/NRR/DLPM/LPD4
To: Overbeck G
Arizona Public Service Co
Fields E N 301-415-1173
Shared Package
ML051880505 List:
References
TAC MC1933, TAC MC1934, TAC MC1935
Download: ML051880501 (16)


Text

July 7, 2005 Mr. Gregg R. Overbeck Senior Vice President, Nuclear Arizona Public Service Company P. O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -

ISSUANCE OF AMENDMENTS RE: MAIN STEAM SAFETY VALVES (TAC NOS. MC1933, MC1934, AND MC1935)

Dear Mr. Overbeck:

The Commission has issued the enclosed Amendment No. 155 to Facility Operating License No. NPF-41, Amendment No. 155 to Facility Operating License No. NPF-51, and Amendment No. 155 to Facility Operating License No. NPF-74 for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated February 4, 2004.

The amendments revise TS 3.7.1, "Main Steam Safety Valves (MSSVs)," to permit operation in Mode 3 with five to eight inoperable MSSVs (two to five operable MSSVs) per steam generator (SG), increase the Completion Time to reduce the variable overpower trip setpoint when one to four MSSVs per SG are inoperable, and make associated editorial changes.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Mel B. Fields, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosures:

1. Amendment No. 155 to NPF-41
2. Amendment No. 155 to NPF-51
3. Amendment No. 155 to NPF-74
4. Safety Evaluation cc w/encls: See next page

Palo Verde Generating Station, Units 1, 2, and 3 cc:

Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 40 Buckeye, AZ 85326 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040 Mr. Craig K. Seaman,, Director Regulatory Affairs/Nuclear Assurance Palo Verde Nuclear Generating Station Mail Station 7636 Phoenix, AZ 85072-2034 Mr. Hector R. Puente Vice President, Power Generation El Paso Electric Company 310 E. Palm Lane, Suite 310 Phoenix, AZ 85004 Mr. John Taylor Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224 Ms. Cheryl Adams Southern California Edison Company 5000 Pacific Coast Hwy Bldg DIN San Clemente, CA 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, AZ 85251 Mr. Jeffrey T. Weikert Assistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901 Mr. John Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326

July 7, 2005 Mr. Gregg R. Overbeck Senior Vice President, Nuclear Arizona Public Service Company P. O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -

ISSUANCE OF AMENDMENTS RE: MAIN STEAM SAFETY VALVES (TAC NOS. MC1933, MC1934, AND MC1935)

Dear Mr. Overbeck:

The Commission has issued the enclosed Amendment No.155 to Facility Operating License No. NPF-41, Amendment No. 155 to Facility Operating License No. NPF-51, and Amendment No. 155 to Facility Operating License No. NPF-74 for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated February 4, 2004.

The amendments revise TS 3.7.1, "Main Steam Safety Valves (MSSVs)," to permit operation in Mode 3 with five to eight inoperable MSSVs (two to five operable MSSVs) per steam generator (SG), increase the Completion Time to reduce the variable overpower trip setpoint when one to four MSSVs per SG are inoperable, and make associated editorial changes.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Mel B. Fields, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosures:

1. Amendment No. 155 to NPF-41
2. Amendment No. 155 to NPF-51
3. Amendment No. 155 to NPF-74
4. Safety Evaluation cc w/encls: See next page DISTRIBUTION PUBLIC RidsNrrDlpmDpr PDIV-2 r/f RidsNrrDlpmLpdiv (HBerkow)

RidsNrrDlpmLpiv2 (DCollins)

RidsNrrPMMFields RidsNrrLADBaxley RidsNrrDripIrob (TBoyce)

RidsOgcRp RidsAcrsAcnwMailCenter RidsRgn4MailCenter (TPruett)

GHill (6)

TS: ML051890237 NRR-100

  • PDIV-2/(A)SC NAME MFields DBaxley JNakoski TBoyce DReddick DCollins DATE 6--30-05 6/30/05 5/20/05 6/16/05 6/29/05 7/6/05 OFFICIAL RECORD COPY

ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-528 PALO VERDE NUCLEAR GENERATING STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 155 License No. NPF-41 1.

The Nuclear Regulatory Commission (Commission) has found that:

A.

The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated February 4, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-41 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 155, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3.

This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance including the incorporation of the changes to the Technical Specification Bases for Technical Specification 3.7.1 as described in the licensee's letter dated February 4, 2004.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Daniel S. Collins, Acting Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: July 7, 2005

ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-529 PALO VERDE NUCLEAR GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 155 License No. NPF-51 1.

The Nuclear Regulatory Commission (Commission) has found that:

A.

The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated February 4, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-51 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 155, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3.

This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance including the incorporation of the changes to the Technical Specification Bases for Technical Specification 3.7.1 as described in the licensee's letter dated February 4, 2004.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Daniel S. Collins, Acting Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: July 7, 2005

ARIZONA PUBLIC SERVICE COMPANY, ET AL.

DOCKET NO. STN 50-530 PALO VERDE NUCLEAR GENERATING STATION, UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 155 License No. NPF-74 1.

The Nuclear Regulatory Commission (Commission) has found that:

A.

The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority dated February 4, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-74 is hereby amended to read as follows:

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 155, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. APS shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan, except where otherwise stated in specific license conditions.

3.

This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance including the incorporation of the changes to the Technical Specification Bases for Technical Specification 3.7.1 as described in the licensee's letter dated February 4, 2004.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Daniel S. Collins, Acting Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: July 7, 2005

ATTACHMENT TO LICENSE AMENDMENT NOS. 155, 155, AND 155 FACILITY OPERATING LICENSE NOS. NPF-41, NPF-51, AND NPF-74 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.7.1-1 3.7.1-1 3.7.1-2 3.7.1-2 3.7.1-3 3.7.1-3 3.7.1-4 3.7.1-4 3.7.1-5

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 155 TO FACILITY OPERATING LICENSE NO.

NPF-41, AMENDMENT NO. 155 TO FACILITY OPERATING LICENSE NO. NPF-51, AND AMENDMENT NO. 155 TO FACILITY OPERATING LICENSE NO. NPF-74 ARIZONA PUBLIC SERVICE COMPANY, ET AL.

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530

1.0 INTRODUCTION

By letter to the Nuclear Regulatory Commission (NRC or Commission) dated February 4, 2004, Arizona Public Service Company (APS or the licensee) requested a license amendment for Palo Verde Nuclear Generating Station (Palo Verde) Units 1, 2, and 3. The proposed amendments would revise Technical Specification (TS) 3.7.1, "Main Steam Safety Valves (MSSVs)," to permit operation in Mode 3 with five to eight inoperable MSSVs per steam generator (SG), increase the Completion Time (CT) to reduce the variable overpower trip (VOPT) setpoint when one to four MSSVs per SG are inoperable, and make associated editorial changes.

2.0 REGULATORY EVALUATION

The requirement of General Design Criterion (GDC) 15 of Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 specifies that "[t]he reactor coolant system [(RCS)] and associated auxiliary, control, and protection systems shall be designed with sufficient margin to assure that the design conditions of the reactor coolant pressure boundary are not exceeded during any condition of normal operation, including anticipated operational occurrences." This regulatory requirement is used by the NRC staff to judge the acceptability of the licensee<s proposal to permit operation in Mode 3 with five to eight inoperable MSSVs per SG.

The Commissions regulatory requirements also relate to the content of TSs, as set forth in 10 CFR 50.36. Specifically, 10 CFR 50.36(c)(2)(ii) states, in part, that a TS Limiting Condition for Operation (LCO) must be established for each item meeting one or more of the specified criteria. These criteria are: (1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the RCS pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; and (4) a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The standard TSs were developed based on the criteria in 10 CFR 50.36(c)(2)(ii). Existing LCOs and related surveillance requirements included as TS requirements which satisfy any of the criteria specified in 10 CFR 50.36(c)(2)(ii) must be retained in the TSs. The Palo Verde TSs are based on the standard TSs developed for Combustion Engineering Plants, which are contained in NUREG-1432, Standard Technical Specifications - Combustion Engineering Plants.

As stated by the licensee, the proposed change to increase the VOPT setpoint CT is consistent with NRC-approved Industry/Technical Specification Task Force TSTF-235, Revision 1, incorporated in Revision 2 of NUREG-1432. Since the standard TSs were developed based on the criteria in 10 CFR 50.36(c)(2)(ii), the staff's review of the proposed increase in the VOPT setpoint CT will be based on consistency with the guidance provided in NUREG-1432.

3.0 TECHNICAL EVALUATION

3.1 Background

Five MSSVs are located on each of the four main steam lines (two main steam lines per SG),

outside containment, upstream of the main steam isolation valves. The MSSV rated capacity passes the full steam flow at 102 percent of rated thermal power (RTP) (100 percent plus 2 percent for instrument error) with the valves full open.

The primary purpose of the MSSVs is to provide overpressure protection for the SG secondary side and associated main steam lines. The MSSVs also provide protection against overpressurizing the reactor coolant pressure boundary by providing a heat sink for the removal of energy from the RCS if the preferred heat sink, provided by the condenser and circulating water system, is not available. The MSSVs limit secondary system pressure to less than or equal to 110 percent of design pressure when passing 100 percent of design steam flow.

When 10 MSSVs are operable per SG (none inoperable), thermal power is limited to 100 percent RTP, and the VOPT allowable trip setpoint is limited to 111.0 percent RTP. When one to four MSSVs per SG are inoperable in Modes 1 or 2, an alternative to restoring inoperable MSSV(s) to operable status is to reduce power so that the available MSSV relieving capacity meets the licensing basis requirements for the power level. Operation may continue in Modes 1 or 2 with one to four inoperable MSSVs per SG by reducing the ceiling on the VOPT to an amount over the allowable thermal power equal to the band given for this trip according to TS Table 3.7.1-1.

The proposed request would revise TS 3.7.1 to permit operation in Mode 3 with five to eight inoperable MSSVs (two to five operable MSSVs) per SG, increase the CT to reduce the VOPT setpoint when one to four MSSVs per SG are inoperable, and make associated editorial changes. Each request is evaluated separately below. Also evaluated are the specific TS changes associated with these proposed changes including the editorial changes proposed by the licensee.

For the request to permit operation in Mode 3 with five to eight inoperable MSSVs (two to five operable MSSVs) per SG, the staff<s review focused on confirming that the licensees supporting analysis is based on acceptable methods and the values of input parameters used in the calculations are conservative.

For the request to increase the CT to reduce the VTOP setpoint when one to four MSSVs per SG are inoperable, the staff's review focused on consistency with the criteria in 10 CFR 50.36(c)(2)(ii) as set forth in NUREG-1432.

3.2 Allowable Plant Operation in Mode 3 with Inoperable MSSVs Currently, TS 3.7.1 requires the unit to be placed in Mode 4 within a specified time when more than four required MSSVs per SG are inoperable. The licensee proposes to modify TS 3.7.1 to require the unit to be placed in Mode 4 within a specified time when more than eight required MSSVs per SG are inoperable. The proposed change to TS 3.7.1 would allow continued operation in Mode 3 when five to eight required MSSVs per SG are inoperable.

For this requested change, the difference between the current and proposed TS is that the unit will be allowed to stay in Mode 3 for an indefinite period of time when five to eight required MSSVs per SG are inoperable. To support this change, the licensee conducted a heat balance analysis to show that the remaining minimum number of required operable MSSVs (two per SG) would be sufficient to remove the maximum reactor decay heat plus other heat sources.

Reactor decay heat is a maximum of 6.6 percent of RTP immediately following a reactor trip when the plant would be in Mode 3. The RTP used in this analysis is 3990 megawatt thermal (MWt), which is the RTP associated with the recent power uprate approved for Unit 2 and under review for Units 1 and 3. Heat from non-reactor sources, primarily reactor coolant pump heat, is as high as 26 MWt, or about 0.65 percent of 3990 MWt. The combination of decay heat and pump heat immediately after a reactor trip would equal approximately 7.3 percent of 3990 MWt.

The total design steam flow at 100 percent of 3990 MWt RTP is 17.9E6 pounds per hour (lb/hr),

and 7.3 percent of that value is 1.31E6 lb/hr. The minimum rated relieving capacity of a single MSSV is 9.415E5 lb/hr, and two MSSVs would relieve 1.883E6 lb/hr. Therefore two MSSVs have sufficient relieving capacity to dissipate core decay heat and reactor coolant pump heat in Mode 3 to limit secondary system pressure to less than or equal to 110 percent of design pressure, as required by American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section III, Article NC-7000. For additional conservatism, a minimum of two MSSVs per SG (four total) will be required to be operable in Mode 3 in case of a single failure of one of the valves in either SG.

The staff has reviewed the above analysis and concludes that the licensees supporting analysis is based on acceptable methods and the values of input parameters used in the calculations are conservative. Therefore, the staff finds that the proposed change to TS 3.7.1 to allow continued operation in Mode 3 when five to eight required MSSVs per SG are inoperable is acceptable.

3.3 Completion Time for the Variable Overpower Trip Setpoint Change Currently, Required Action A.2 of TS 3.7.1 specifies a CT of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to reduce the VOPT high setpoint if one or more required MSSVs are inoperable. The proposed increase in the CT for Action A.2 from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is consistent with TSTF-235, Revision 1, incorporated in the current version (Revision 3) of NUREG-1432.

The revised TS 3.7.1 Bases associated with TSTF-235, Revision 1, states that the CT of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for Required Action A.2 is based on a reasonable time to correct the MSSV inoperability, the time required to perform the power reduction, operating experience in resetting all channels of a protective function, and on the low probability of the occurrence of a transient that could result in SG overpressure during this period. Based on the considerations discussed in TSTF-235, Revision 1, which was developed consistent with the criteria in 10 CFR 50.36(c)(2)(ii) as set forth in NUREG-1432, the staff concludes that the proposed CT increase to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> is reasonable, based on operating experience to accomplish the required actions without challenging unit systems.

3.4 Specific Technical Specifications Changes 3.4.1 Change TS 3.7.1 Condition A from one or more required MSSVs inoperable, to one to four required MSSVs per steam generator inoperable in MODES 1 or 2.

Currently, Condition A of TS 3.7.1 specifies that when one or more required MSSVs are inoperable, power and the VOPT setpoint must be reduced to the values listed in Table 3.7.1-1.

Table 3.7.1-1 currently only lists reduced power and VOPT setpoint values for six to nine operable MSSVs (one to four inoperable MSSVs) per SG. The reduced power levels and VOPT setpoints only apply in Modes 1 and 2 because in Mode 3 reactivity must be less than 0.99 Keff (reactor is subcritical) per TS Table 1.1-1, and the VOPT trip is not required to be operable in Mode 3, per TSs 3.3.1 and 3.3.2. Therefore, since the current TS 3.7.1 Condition A can only be applied when six to nine MSSVs are operable (one to four MSSVs inoperable) in Modes 1 or 2, this proposed change to specify one to four required MSSVs inoperable in MODES 1 or 2 in Condition A does not change the Condition A requirements from the current TS 3.7.1.

The staff determines that this proposed change is acceptable because it only clarifies the intent and does not change the meaning of the existing requirements.

3.4.2 Change the CT of TS 3.7.1 Required Action A.2 (to reduce the VOPT high setpoint) from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

This specific TS change implements the licensee<s request to increase the CT to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for reducing the VOPT high setpoint if one or more required MSSVs are inoperable. This proposed change was discussed and approved in Section 3.3 of this Safety Evaluation (SE), and is therefore acceptable.

3.4.3 Change TS 3.7.1 Condition B to specify that when the Required Actions and associated CTs of Condition A are not met, OR when five to eight required MSSVs per SG are inoperable in Modes 1 or 2, the Required Action is to be in Mode 3 in a CT of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

This specific TS change implements the licensee's request to allow the unit to stay in Mode 3 for an indefinite period of time when five to eight required MSSVs per SG are inoperable. This proposed change was discussed and approved in Section 3.2 of this SE, and is therefore acceptable.

The proposed CT of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in Mode 3 is consistent with that specified in TS 3.7.1 of NUREG-1432, and the staff considers that it is a reasonable CT to reach the required unit conditions in an orderly manner and without challenging unit systems, and is therefore acceptable.

3.4.4 Add a new Condition C to specify that when the Required Action and associated CT of Condition B is not met, the Required Action is to be in Mode 4 in a CT of six hours.

If the plant is not placed in Mode 3 within the associated CT for Required Action B.1, the unit must be placed in a Mode in which the LCO does not apply. To achieve this status, the unit must be placed in at least Mode 4 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The proposed CT of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to be in Mode 4 is considered by the staff to be a reasonable CT to reach the required unit conditions in an orderly manner and without challenging unit systems, and is therefore acceptable.

3.4.5 Add a new Condition D to specify that with more than eight required MSSVs per SG inoperable, the Required Action is to be in Mode 3 in a CT of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and to be in Mode 4 in a CT of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

If one or more SGs have more than eight MSSVs inoperable, the unit must be placed in a Mode in which the LCO does not apply. To achieve this status, the unit must be placed in at least Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The proposed CTs are consistent with that specified in TS 3.7.1 of NUREG-1432, and the staff considers that they are reasonable CTs to reach the required unit conditions in an orderly manner and without challenging unit systems, and are therefore acceptable.

3.4.6 Change Table 3.7.1-1 to specify the "highest mode" in addition to the maximum power, to add a footnote stating that the VOPT setpoint is not required to be reset in Mode 3, and to add a column listing the number of inoperable MSSVs per SG.

TS Table 3.7.1-1 will be expanded to include five through eight inoperable MSSVs per SG, with a corresponding highest allowed mode of Mode 3, to be consistent with the proposed change discussed in Section 3.2 of this SE. To be consistent with that proposed change, the heading in the column currently titled "Maximum Power (%RTP)" will be edited to also include "or HIGHEST MODE.

The footnote stating that the VOPT setpoint is not required to be reset in Mode 3 will ensure that Table 3.7.1-1 is consistent with TSs 3.3.1 and 3.3.2, which do not require the VOPT to be operable in Mode 3.

The proposed editorial change to Table 3.7.1-1 to add a column listing the number of inoperable MSSVs per SG will enhance human performance because the TS 3.7.1 conditions describe the actions to take when certain number of MSSVs are inoperable, and the additional column will allow the operators to directly note the number of inoperable MSSVs per SG allowed for a specific maximum power or highest Mode of operation.

The staff agrees that these proposed changes are editorial in nature and are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Arizona State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (69 FR 40671). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: M. Fields Date: July 7, 2005