ML052080204

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Request for a License Amendment to Modify Reactor Protective and Engineered Safety Features Actuation Systems Instrumentation Technical Specification Tables
ML052080204
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 07/09/2005
From: Mauldin D
Arizona Public Service Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
102-05306-CDM/TNW/RAB
Download: ML052080204 (27)
v • d • e


Text

10 CFR 50.90 LAMS David Mauldin Vice President Mail Station 7605 Palo Verde Nuclear Nuclear Engineering Tel: 623-393-5553 PO Box 52034 Generating Station and Support Fax: 623-393-6077 Phoenix, Arizona 85072-2034 102-05306-CDM/TNW/RAB July 9,2005 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

1. Letter No.102-05116-CDMITNW/RAB, Dated July 9, 2004, from C. D.

Mauldin, APS, to U. S. Nuclear Regulatory Commission, "Request for a License Amendment to Support Replacement of Steam Generators and Uprated Power Operations in Units I and 3, and Associated Administrative Changes for Unit 2"

2. Letter dated March 31, 2005, from J. E. Lyons, USNRC to Mr. Alex Marion, NEI, "Instrumentation, Systems, and Automation Society S67.04 Methods for Determining Trip Setpoints and Allowable Values for Safety-Related Instrumentation"

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3, Docket Nos. STN 50-528/5291530 Request for a License Amendment to Modify Reactor Protective and Engineered Safety Features Actuation Systems Instrumentation Technical Specification Tables In Reference 1, Arizona Public Service Company (APS) submitted a license amendment request to support steam generator replacement and uprated power operations for PVNGS Units 1, 2 and 3. Several of the requested changes modified safety-related instrumentation setpoints. During the NRC staff review of the request, the staff developed a request for additional information concerning the methodology used for determining setpoints and uncertainties. In Reference 2, the staff prescribed a footnote to be added to the technical specifications for those safety-related setpoints being changed.

The proposed amendment would add a footnote requiring that the as-left instrument settings be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit. The proposed amendment would apply to the safety-related setpoint changes requested in Reference 1.

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

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

e .1 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Request for a License Amendment to Modify Reactor Protective and Engineered Safety Features Actuation Systems Instrumentation Technical Specification Tables Page 2 Based on the responses to the three criteria provided for determining whether a significant hazard consideration exists as stated in 10CFR 50.92, APS has concluded that the proposed amendment involves no significant hazard considerations.

APS requests approval of this amendment concurrent with the approval of the amendment requested in Reference 1. Once approved, the amendment will be implemented within 120 days.

In accordance with the PVNGS Quality Assurance Program, the Plant Review Board and the 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).

The following Commitment is being made to the NRC in this letter:

The TS bases and procedure changes required to support this amendment request will be completed prior to implementation of the approved technical specification change.

Should you have any questions, please call Mr. Thomas N. Weber at (623) 393-5764.

Sincerely, CDM/TNW/RAB/ca

Enclosures:

1. Notarized Affidavit
2. Arizona Public Service Company's Evaluation of the Proposed Change Attachments:
1. Proposed Technical Specification Change (mark-up)
2. Proposed Technical Specification Change (re-typed )
3. Changes to TS Bases Pages (for information only) cc: B. S. Mallett NRC Region IV Regional Administrator M. B. Fields NRC NRR Project Manager G. G. Wamick NRC Senior Resident Inspector A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)

ENCLOSURE 1 NOTARIZED AFFIDAVIT STATE OF ARIZONA

) ss.

COUNTY OF MARICOPA 1, David Mauldin, represent that I am Vice President Nuclear Engineering and Support, 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.

David Mauldin Sworn To Before Me This Day Of. Ndci .1P 2005.

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Notla-ry)kPlic (9 S*USIE LYN EIHe giNotary Public - Arzona

. 3, Madkopa County MyComm. Expires 4ul 14, 2007 Notary Commission Stamp

ENCLOSURE 2 ARIZONA PUBLIC SERVICE COMPANY'S EVALUATION OF THE PROPOSED CHANGE Proposed Change to Technical Specifications 3.3.1, 3.3.2, 3.3.5 and 3.7.1 1.0 Description 2.0 Proposed Change

3.0 Background

4.0 Technical Analysis 5.0 Regulatory Safety Analysis 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements 6.0 Environmental Consideration 7.0 Precedent

1.0 DESCRIPTION

This letter is a request to amend Operating Licenses NPF-41, NPF-51 and NPF-74 for the Palo Verde Nuclear Generating Station Units 1, 2 and 3.

The proposed changes supplement the changes requested in the letter from APS to USNRC dated July 9, 2004. The changes requested in this letter would add a footnote in Tables 3.3.1-1 (Before CPC Upgrade), 3.3.1-1 (After CPC Upgrade), 3.3.2-1, 3.3.5-1 and 3.7.1-1 specifying action to protect the safety limit. These supplemental changes are requested in accordance with the letter dated March 31, 2005, from the USNRC to Mr. Alex Marion, NEI.

2.0 PROPOSED CHANGE

The proposed amendment would make the following changes.

A. Revise Table 3.3.1-1 to add a footnote to function 6, Steam generator #1 Pressure - Low and function 7, Steam Generator #2 Pressure - Low. The new footnote states:

The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

B. Revise Table 3.3.2-1 to add a footnote to function 2, Steam Generator #1 Pressure - Low and function 3, Steam Generator #2 Pressure - low. The new footnote states:

The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

C. Revise Table 3.3.5-1 to add a footnote to function 4a, Steam Generator #1 Pressure - Low and function 4b, Steam Generator #2 Pressure - Low. The new footnote states:

The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

D. Revise Table 3.7.1-1 to add a footnote to the Maximum Allowable Variable Overpower Trip Setpoint values for units licensed to operate at 3990 MWt. The new footnote states:

The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

3.0 BACKGROUND

On July 9, 2004, Arizona Public Service Company (APS) submitted an amendment request to support replacement of steam generators and uprated power operation in Units 1 and 3. During the review of the requested amendment, the NRC staff requested additional information concerning calculation of uncertainties for the reactor protection and engineered safety features actuation system setpoints that would change as a result of the requested amendment. On March 31, 2005 the NRC staff, in a letter to Mr.

Alex Marion, NEI, established a process that utilities could use to respond to RAls that have been issued for similar licensing action requests (LARs). This amendment is requested to establish a requirement in the Technical Specifications to return as-left instrument settings to within the tolerance band established to protect the safety limit. A footnote should be added to the technical specifications for the Limiting Safety System Settings (LSSS) to be changed by the request made on July 9, 2004.

3.1 System Description LCO 3.3.1, Reactor Protective System Instrumentation - Operating and Table 3.3.1-1, which it references, specify the required number of channels operable for each reactor trip function, the applicable modes for each function, the surveillance requirements and the allowable value for the setpoint to ensure that the purpose of the function is satisfied. The Steam Generator Pressure - Low trip function (items 6 and 7 in Table 3.3.1-1) provides protection against an excessive rate of heat extraction from the steam generators and the resulting rapid, uncontrolled cooldown of the Reactor Coolant System (RCS). This trip is needed to shut down the reactor and assist the Engineered Safety Features (ESF) system in the event of a Main Steam Line Break (MSLB) or Main Feedwater Line Break (MFWLB) accident. A Main Steam Isolation Signal (MSIS) is initiated simultaneously.1 LCO 3.3.2, Reactor Protective System Instrumentation - Shutdown and Table 3.3.2-1, which it references, specify the required number of channels operable for each reactor trip function, the applicable modes for each function, the surveillance requirements and the allowable value for the setpoint to ensure that the purpose of the function is satisfied. The Steam Generator Pressure - Low trip function (items 2 and 3 in Table 3.3.2-1) provides shutdown margin to prevent or minimize the return to power following a large MSLB in Mode 3.2 LCO 3.3.5, Engineered Safety Features Actuation System Instrumentation and Table 3.3.5-1, which it references specify the required number of channels operable for each reactor trip function, the applicable modes for each function, and the allowable value for the setpoint to ensure that the purpose of the function is satisfied. The Steam Generator Pressure - Low signal actuates a MSIS to prevent an excessive rate of heat extraction and subsequent cooldown of the RCS in the event of a MSLB or MFWLB. 3 TS Bases B.3 3.1. Applicable Safety Analysis 2TS Bases 3.3.2, Applicable Safety Analysis TS Bases 3.3.5. Applicable Safety Analysis

Table 3.7.1-1, Variable Overpower Trip Setpoint versus Operable Main Steam Safety Valves, referenced in LCO 3.7.1, Main Steam Safety Valves (MSSVs), specifies maximum power levels and overpower reactor trip setpoints for specified numbers of OPERABLE MSSVs. An alternative to restoring inoperable MSSV(s) to OPERABLE status is to reduce power in accordance with Table 3.7.1-1. These reduced power levels, derived from the transient analysis, compensate for degraded relieving capacity and ensure that the results of the transient analysis are acceptable. 4 3.2 Need for the Proposed Change The proposed footnote will ensure that the as-left instrument setting will be returned to a setting within the tolerance band of the trip setpoint that has been established to protect the safety limit.

4.0 TECHNICAL ANALYSIS

The action of ensuring that the as-left instrument setting is within the tolerance band of the field installed trip setpoint is a technical requirement established in the associated Design Instrumentation & Controls Uncertainty and Setpoint Calculation. In order to keep the results of these calculations associated with establishing trip setpoints valid, as-left instrument setting tolerances have been developed in the calculations. The as-left instrument setting tolerances are currently documented in the Plant Protective System (PPS) Bistable Trip Units Functional Test used to fulfill the surveillance requirements associated with the Steam Generator Low Pressure trip setpoint and others listed in Technical Specification Tables 3.3.1-1 and 3.3.5-1.

The requirement to ensure the as-left instrument setting is within the tolerance band of the trip setpoint already exists at Palo Verde and is procedurally controlled. In accordance with the direction in a letter dated March 31, 2005, from the NRC to Mr.

Alex Marion, NEI, this footnote is being added to the Technical Specifications for the LSSS being changed by the July 9, 2004 LAR in order for the staff to complete its review.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration APS 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:

TS Bases 3.7.1, Actions

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change does not result in any change to safety analysis methods or results, and the proposed change is not the result of a new or changed analysis. The changes to add footnotes in Technical Specification (TS) Tables 3.3.1-1, 3.3.2-1, 3.3.5-1, and 3.7.1-1 ensure that the low steam generator pressure setpoints and the variable overpower trip setpoints, under specified conditions, associated with the Plant Protective System (PPS) are set to protect the safety limit.

The proposed change only ensures that as left setpoints are returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

Adding footnotes to TS Tables 3.3.1-1, 3.3.2-1, 3.3.5-1 and 3.7.1-1 is not a change to the setpoints, operation or accident response of the Palo Verde Nuclear Generating Station (PVNGS) Units 1,2 and 3 structures, systems, and components. The changes ensure that certain setpoints associated with the PPS are set to protect the safety limit.

The only changes being proposed will ensure that PPS as left set points for low steam generator pressure and variable overpower trip, under specified conditions, are set to protect safety limits. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change does not result in any change to safety analysis methods or results. Therefore, by adding the footnotes to TS Tables 3.3.1-1, 3.3.2-1, 3.3.5-1 and 3.7.1-1 the margins as established in the PVNGS Units 1,2 and 3 Technical Specifications and Updated Final Safety Analysis Report (UFSAR) are unchanged.

The proposed change only involves the addition of a footnote to ensure that as left setpoints for low steam generator pressure and variable overpower trip, under specified conditions, are set to protect safety limits. Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel and fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. No actual plant equipment or accident analysis will be affected by the proposed changes.

Additionally, the proposed changes will not relax any criteria used to establish safety limits, will not relax any safety system settings, or will not relax the bases for any limiting conditions for operation.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above, APS concludes that the proposed amendments present 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.

5.2 Applicable Regulatory Requirements/Criteria The footnote ensures compliance with 10 CFR 50.36, Technical Specifications, by requiring that the instrument be returned to the trip set point established to protect the analytical limit (and, therefore, protect the safety limit) at the completion of testing or calibration.

6.0 ENVIRONMENTAL CONSIDERATION

Arizona Public Service Company has evaluated the proposed changes and has determined that the changes do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

7.0 PRECEDENT This licensing action request is being submitted in accordance with a letter, dated March 31, 2005 from J. A. Lyons, USNRC, to Mr. Alex Marion, NEI, "Instrumentation, Systems, and Automation Society S67.04 Methods for Determining Trip Setpoints and Allowable Values for Safety-Related Instrumentation."

ATTACHMENT I PROPOSED TECHNICAL SPECIFICATION CHANGE (mark-up)

RPS Instrumentation - Operating (Before CPC Upgrade) I 3.3.1 Table 3.3.1-1 (page 1 of 3)

Reactor Protective System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED SURVEILLANCE FUNCTION CONDITIONS REQUIREMENTS ALLOWABLE VALUE

1. Variable Over Power 1.2 SR 3.3.1.1 Ceiling s 111.0 RTP SR 3.3.1.4 Band s 9.9X RTP SR 3.3.1.6 Incr. Rate s 11.02/min RTP SR 3.3.1.7 Decr. Rate > 5S/sec RTP SR 3.3.1.8 SR 3.3.1.9 SR 3.3.1.13
2. Logarithmic Power Level - High(a) 2 SR 3.3.1.1 S 0.011X NRTP SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.12 SR 3.3.1.13
3. Pressurizer Pressure - High 1.2 SR 3.3.1.1 s 2388 psia SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.13
4. Pressurizer Pressure - Low 1.2 SR 3.3.1.1 2 1821 psla SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.12 SR 3.3.1.13 S. Containment Pressure - High 1.2 SR 3.3.1.1 S 3.2 psig SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.13
6. Steam Generator #1 Pressure - Low 1.2 SR 3.3.1.1 Ulatc I aPA i E.

SR SR 3.3.1.7 3.3.1.9 Unit J 90-ps-2:0 SR 3.3.1.13 UFA t 2 K i.5FC. ps

7. Steam Generator 12 Pressure - Low 1.2 SR 3.3.1.1 SR 3.3.1.7 SR 3.3.1.9 pbsi SR 3.3.1.13 (continued)

(a) Ti axbmsarithmic power is > 1E-4X NRTP. removed.U b ar~~whe loarith ifipowr 1s ts

~~~isTUArFM~ FNRL aSAL w AD 74rv#b A 5Y'O*,Ovr~ 4 sX; m4&-c lb ID-CA4,09 8 BIM D of-7N# TR-'P ssrao-,r A"&Lts~ rzr P 7v A~~ er PALO VERDE UNITS I AND 3 -AMENDMENT NO. 449, 450 PALO VERDE UNIT 2 3.3.1-8 AMENDMENT NO. 149. 1b0

RPS Instrumentation - Operating (After CPC Upgrade) 3.3.1 Table 3.3.1-1 (page 1 of 3)

Reactor Protective System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED SURVEILLANCE FUNCTION CONDITIONS REQUIREMENTS ALLOWABLE VALUE

1. Variable Over Power 1.2 SR 3.3.1.1 Ceiling S 111.0 RTP SR 3.3.1.4 Band s 9.9S RTP SR 3.3.1.6 Incr. Rate S 11.0S/min RTP SR 3.3.1.7 Decr. Rate > 5/sec RTP SR 3.3.1.8 SR 3.3.1.9 SR 3.3.1.13
2. Logarithmic Power Level - High(a) 2 SR 3.3.1.1 S 0.011S NRTP SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.12 SR 3.3.1.13
3. Pressurizer Pressure - High 1.2 SR 3.3.1.1 S 2388 psia SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.13
4. Pressurizer Pressure - Low 1.2 SR 3.3.1.1 2 1821 psla SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.12 SR 3.3.1.13
5. Contarinment Pressure - High 1.2 SR 3.3.1.1 S 3.2 psig SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.13
6. Steam Generator #1 Pressure - Low 1.2 SR 3.3.1.1 SR 3.3.1.7 z 890 p!

J10

7. Steam Generator #2 Pressure - Low 1.2 SR 3.3.1.1 SR 3.3.1.7 SR 3.3.1.9 2 890 pse5 SR 3.3.1.13 UA t2 -§Rj! 2: 2 e (continued) rya lse s is4 >NRTP.RP -3 oe 7

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PALO ED4EUI 1A.23 o3 MP .x 3.-17r7 AMENDMENT N.J $A L PALO VERDE UNITS 1.2.3 3.3.1-17 AMENDMENT NO. 64-

RPS Instrumentation - Shutdown 3.3.2 Table 3.3.2-1 (pa.ae i oa A)

Reactor Protective System Instrumentation - Shutdown APPLICABLE MODES OR OTHER SPECIFIED SURVEILLANCE FUNCTION CONDITIONS REQUIREMENTS ALLOWABLE VALVE

1. Logarithmic Power Level-High(d) 3(a) 4(a) 5(a) SR 3.3.2.1 S O.O11 NRTP(c)

SR 3.3.2.2 SR 3.3.2.3 SR 3.3.2.4 SR 3.3.2.5 3(a)

2. Steam Generator #1 Pressure-Low(b) SR 3.3.2.1 Uits I -and3 3876 ltWt l SR 3.3.2.2 RTP: .890 Bsi SR 3.3.2.4 Unit 23990 HWt-RT:e),r SR 3.3.2.5 2 955 pstaA*

Asset r

3. Steam Generator #2 Pressure-Low(b) 3(a) SR 3.3.2.1 Units 1 and 3 3876 KWt /

SR 3.3.2.2 RTP: 2 890 p I SR 3.3.2.4 "nit 395 ps SR 3.3.2.5 2 9SPsla~

(a) With any Reactor Trip Circuit Breakers (RTCBs) closed and any control element assembly capable of being withdrawn.

(b) The setpoint may be decreased as steam pressure is reduced, provided the margin between steam pressure and the setpoint ismaintained

  • 200 psig. The setpoint shall be automatically increased to the normal setpoint as steam pressure is increased.

(c) The setpoint must be reduced to S 1E-4% NRTP when less than 4 RCPs are running.

(d) Trip may be bypassed when logarithmic power is > 1E-4% NRTP. Bypass shall be automatically removed

( e) fe 4s-Llfr /ASTrm.,9 *; r SAW4S eft xeIvzvAJI:D b A SV.m p J5£t vilrd/ 7Wa r7oce 4,AeK. t34AJD Of r l 7VMP se5r7 otA SC*rLS~D 7 P r7 rH( 5,$4ry Z../1h4/7 PALO VERDE UNITS 1 AND 3 AMENDMENT NO. 444. 149 PALO VERDE UNIT 2 3.3.2-5 AMENDMENT NO. .149 4-49

ESFAS Instrumentation 3.3.5 Table 3.3.5-1 (page 1 of 1)

Engineered Safety Features Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED FUNCTION CONDITIONS ALLOWABLE VALUE

1. Safety Injection Actuation Signal
a. Containment Pressure - High 1,2,3 S 3.2 psig
b. Pressurizer Pressure - Low(a) 2 1821 psia
2. Containment Spray Actuation Signal
a. Containment Pressure - High High 1.2.3
  • 8.9 psig
3. Containment Isolation Actuation Signal
a. Containment Pressure - Higb 1,23 S 3.2 psig
b. Pressurizer Pressure - Lowa) 2 1821 psia
4. Main Steam Isolation Signal(C)
a. Steam Generator #1 Pressure-Low(b) 1.2.3 3876 MWt RTP: 2 890 p12'PIA 3990 MWt RTP: 2 955 psI &brf
b. Steam Generator #2 Pressure-Low(b) 3876 K~t RTP: 2 890 p=a 3990 MWt RTP: 2 955 psi Q9
c. Steam Generator #1 Level-High s 91.5:
d. Steam Generator #2 Level-High s 91.5%
e. Containment Pressure-High s 3.2 psig
5. Recirculation Actuation Signal
a. Refueling Water Storage Tank Level-Low 1,2.3 2 6.9 and s 7.9%
6. Auxiliary Feedwater Actuation Signal SG #1 (AFAS-1)
a. Steam Generator #1 Level-Low 1.2.3 2 25.3%
b. SG Pressure Difference-High s 192 psid
7. Auxiliary Feedwater Actuation Signal SG #2 (AFAS-2)
a. Steam Generator #2 Level-Low 1.2.3 2 25.3X
b. SG Pressure Difference-High s 192 psid (a) The setpoint may be decreased to a minimum value of 100 psia. as pressurizer pressure is reduced.

provided the margin between pressurizer pressure and the setpoint is maintained s 400 psia or 2 140 psia greater than the saturation pressure of the RCS cold leg when the RCS cold leg temperature is 2 485 0F. Trips may be bypassed when pressurizer pressure is < 400 psia. Bypass shall be automatically removed when pressurizer pressure is 2 500 psia. The setpoint shall be automatically increased to the normal setpoint as pressurizer pressure is increased.

(b) The setpoint may be decreased as steam pressure is reduced. provided the margin between steam pressure and the setpoint is maintained S 200 psig. The setpoint shall be automatically increased to the normal setpoint as steam pressure is increased.

(c) The Main Steam Isolation Signal (MSIS) Function (Steam Generator Pressure - Low. Steam Generator Level-High and Containment Pressure - High signals) is not required to be OPERABLE when all associated valves 5 d)Tr e as-left instrument setting shall be returned to a setting within the tolerance band of the trip V setointestalishd toprotect the safety limit.

PALO VERDE UNITS 1 AND 3 AMENDMENT NO. 44-7 PALO VERDE UNIT 2 3.3.5-4 AMENDMENT NO. 4-9

MSSVs 3.7.1 Table 3.7.1-1 (page 1 of 1)

Variable Overpower Trip Setpoint versus OPERABLE Main Steam Safety Valves MAXIMUM ALLOWABLE MAXIMUM POWER VARIABLE OVERPOWER TRIP MINIMUM NUMBER OF (% RTP) SETPOINT MSSVs PER STEAM

(% RTP) -,,,5,r GENERATOR REQUIRED OPERABLE Units ..876 Unit 2 3990 Units-1 and-338876 MWt 1-and-33876 Unit R239 MWt-RTP- RTP.. HWt-RTP- MWt RTP 10 100.0 100.0 111.0 111.0 9 98.2 90.0 108.0 99.7 8 87.3 80.0 97.1 89.7 7 76.4 68.0 86.2 77.7 6 65.5 56.0 75.3 65.7 Co), 1w), As-,Lcr a5tRovmzjr Sf nAI&. 5S4ALh 13. AjCr7-4M*4 b 9 4ASAM,)6. WIr4Tb ITOLnPAAAcO GAA1z o&A R T$rfIZIP SxrPiAxr rcsr 6 Llrtb/D . PO J4dr 7>@/£ 24lCF77 J-/H177 PALO VERDE UNITS 1 AND 3 AMENDMENT NO. 7 PALO VERDE UNIT 2 3.7.1-3 AMENDMENT NO. .1.17 49

MSSVs 3.7.1 Table 3.7.1-1 (page 1 of 1)

Variable Overpower Trip Setpoint versus OPERABLE Main Steam Safety Valves MAXIMUM POWER MAXIMUM ALLOWABLE MINIMUM NUMBER NUMBER OF (% RTP) VARIABLE OVERPOWER TRIP OF MSSVs PER INOPERABLE or HIGHEST MODE SETPOINT'a' STEAM GENERATOR MSSVs PER (% RTP) -.^ Lari REQUIRED STEAM +

Units /pnit-a OPERABLE GENERATOR Units_

U4nit 23990 3876 H~ 1MWt 1 and_,3876 MWt. RTP - !1T

'-'TP'- RTP, 10 0 100.0 100.0 111.0 111.0 9 1 98.2 90.0 108.0 99.7 8 2 87.3 80.0 97.1 89.7 7 3 76.4 68.0 86.2 77.7 6 4 65.5 56.0 75.3 65.7 5 5 MODE 3 MODE 3 NA NA 4 6 MODE 3 MODE 3 NA NA 3 7 MODE 3 MODE 3 NA NA 2 8 MODE 3 MODE 3 NA NA INOTEVHMARKED-UP'.ON-PROPOSED'~MMSV 1AMENDMENT"-'THATiAWAS REQUESTED"~IN -LETTER_NOT7'7 PALO VERDE UNITS 1 AND 3 AMENDMENT NO. 447 PALO VERDE UNIT 2 3.7.1-4 AMENDMENT NO. 449

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGE (retyped)

RPS Instrumentation - Operating (Before CPC Upgrade) 3.3.1 Table 3.3.1-1 (page 1 of 3)

Reactor Protective System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED SURVEILLANCE FUNCTION CONDITIONS REQUIREMENTS ALLOWABLE VALUE

1. Variable Over Power 1.2 SR 3.3.1.1 Ceiling s 111.0% RTP SR 3.3.1.4 Band s 9.9% RTP SR 3.3.1.6 Incr. Rate S 11.0/min RTP SR 3.3.1.7 Decr. Rate > 5%/sec RTP SR 3.3.1.8 SR 3.3.1.9 SR 3.3.1.13
2. Logarithmic Power Level - High(a) 2 SR 3.3.1.1 s 0.011% NRTP SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.12 SR 3.3.1.13
3. Pressurizer Pressure - High 1.2 SR 3.3.1.1
4. Pressurizer Pressure - Low 1.2 SR 3.3.1.1 2 1821 psia SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.12 SR 3.3.1.13
5. Containment Pressure - High 1.2 SR 3.3.1.1
6. Steam Generator #1 Pressure - Low 1.2 SR 3.3.1.1 3876 MWt RTP: 2 890 psia SR SR 3.3.1.7 3.3.1.9 3990 MWt RTP: 2 955 psia<" M I

SR 3.3.1.13

7. Steam Generator #2 Pressure - Low 1.2 SR 3.3.1.1 3876 MWt RTP: 2 890 psia SR SR 3.3.1.7 3.3.1.9 3990 MWt RTP: 2 955 psia(") I SR 3.3.1.13 (continued)

(a) Trip may be bypassed when logarithmic power is > 1E-4% NRTP. Bypass shall be automatically removed when logarithmic power is S 1E-4% NRTP.

(aa) The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit. I PALO VERDE UNITS 1.2.3 3.3.1-8 AMENDMENT NO. 47il.

RPS Instrumentation - Operating (After CPC Upgrade) 3.3.1 Table 3.3.1-1 (page 1 of 3)

Reactor Protective System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED SURVEILLANCE FUNCTION CONDITIONS I REQUIREMENTS ALLOWABLE VALUE

1. Variable Over Power 1.2 SR 3.3.1.1 Ceiling s 111.Oz RTP SR 3.3.1.4 Band
2. Logarithmic Power Level - High(a) 2 SR 3.3.1.1 s 0.011% NRTP SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.12 SR 3.3.1.13
3. Pressurizer Pressure - High 1.2 SR 3.3.1.1
4. Pressurizer Pressure - Low 1.2 SR 3.3.1.1 2 1821 psia SR 3.3.1.7 SR 3.3.1.9 SR 3.3.1.12 SR 3.3.1.13
5. Containment Pressure - High 1.2 SR 3.3.1.1
6. Steam Generator #1 Pressure - Low 1.2 SR 3.3.1.1 3876 MWt RTP: 2 890 psia SR 3.3.1.7 3990 MWt RTP: 2 955 psia"')

SR 3.3.1.9 SR 3.3.1.13

7. Steam Generator #2 Pressure - Low 1.2 SR 3.3.1.1 3876 MWt RTP: 2 890 psia SR 3.3.1.7 3990 MWt RTP: 2 955 psia('

SR 3.3.1.9 SR 3.3.1.13 (continued)

(a) Trip may be bypassed when logarithmic power is > 1E-4% NRTP. Bypass shall be automatically removed when logarithmic power is s IE-4% NRTP.

(aa) The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

I PALO VERDE UNITS 1.2.3 3.3.1-17 AMENDMENT NO. Gil9

RPS Instrumentation - Shutdown 3.3.2 Table 3.3.2-1 Reactor Protective System Instrumentation - Shutdown APPLICABLE MODES OR OTHER SPECIFIED SURVEILLANCE FUNCTION CONDITIONS REQUIREMENTS ALLOWABLE VALVE

1. Logarithmic Power Level-Highed) 3 (a). 4 (a) 5(a) SR 3.3.2.1 S 0.011% NRTP(c)

SR 3.3.2.2 SR 3.3.2.3 SR 3.3.2.4 SR 3.3.2.5 3(a)

2. Steam Generator #1 Pressure-Low(b) SR 3.3.2.1 3876 MWt RTP: 2 890 psia SR SR 3.3.2.2 3.3.2.4 3990 MWt RTP: 2 955 psia"') I SR 3.3.2.5 3(a)
3. Steam Generator #2 Pressure-Low(b) SR 3.3.2.1 3876 MWt RTP: 2 890 psia SR SR 3.3.2.2 3.3.2.4 3990 MWt RTP: 2 955 psia") I SR 3.3.2.5 (a) With any Reactor Trip Circuit Breakers (RTCBs),closed and any control element assembly capable of being withdrawn.

(b) The setpoint may be decreased as steam pressure is reduced, provided the margin between steam pressure and the setpoint is maintained S 200 psig. The setpoint shall be automatically increased to the normal setpoint as steam pressure is increased.

(c) The setpoint must be reduced to s 1E-4% NRTP when less than 4 RCPs are running.

(d) Trip may be bypassed when logarithmic power is > 1E-4% NRTP. Bypass shall be automatically removed when logarithmic power is

(e) The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

I PALO VERDE UNITS 1 AND 3 AMENDMENT NO. 44-9.

PALO VERDE UNIT 2 3.3.2-5 AMENDMENT NO. 149

ESFAS Instrumentation 3.3.5 Table 3.3.5-1 (page 1 of 1)

Engineered Safety Features Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED FUNCTION CONDITIONS ALLOWABLE VALUE

1. Safety Injection Actuation Signal
a. Containment Pressure - High 1.2.3 5 3.2 psig
b. Pressurizer Pressure - Low a) 2 1821 psia
2. Containment Spray Actuation Signal
a. Containment Pressure - High High 1.2.3 < 8.9 psig
3. Containment Isolation Actuation Signal
a. Containment Pressure - High 1.2.3 s 3.2 psig
b. Pressurizer Pressure - Low a) 2 1821 psia
4. Main Steam Isolation Signal(c)
a. Steam Generator #1 Pressure-Low(b) 1.2.3 3876 MWt RTP: 2 890 psia 3990 MWt RTP: 2 955 psla(d)
b. Steam Generator #2 Pressure-Low(b) 3876 MWt RTP: 2 890 psia 3990 MWt RTP: 2 955 psia'
c. Steam Generator #1 Level-High s 91.5s
d. Steam Generator #2 Level-High S 91.5%
e. Containment Pressure-High s 3.2 psig
5. Recirculation Actuation Signal
a. Refueling Water Storage Tank Level-Low 1.2.3 2 6.9 and s 7.9%
6. Auxiliary Feedwater Actuation Signal SG #1 (AFAS-1)
a. Steam Generator #1 Level-Low 1.2.3 2 25.3%
b. SG Pressure Difference-High s 192 psid
7. Auxiliary Feedwater Actuation Signal SG #2 (AFAS-2)
a. Steam Generator #2 Level-Low 1.2.3 2 25.3%
b. SG Pressure Difference-High S 192 psid (a) The setpoint may be decreased to a minimum value of 100 psia, as pressurizer pressure is reduced.

provided the margin between pressurizer pressure and the setpoint is maintained S 400 psia or 2 140 psia greater than the saturation pressure of the RCS cold leg when the RCS cold leg temperature is 2 485 0F. Trips may be bypassed when pressurizer pressure is < 400 sia. Bypass shall be automatically removed when pressurizer pressure is 2 500 psia. The setpoint shall be automatically increased to the normal setpoint as pressurizer pressure is increased.

(b) The setpoint may be decreased as steam pressure is reduced, provided the margin between steam pressure and the setpoint is maintained s 200 psig. The setpoint shall be automatically increased to the normal setpoint as steam pressure is increased.

(c) The Main Steam Isolation Signal (MSIS) Function (Steam Generator Pressure - Low, Steam Generator Level-High and Containment Pressure - High signals) is not required to be OPERABLE when all associated valves isolated by the MSIS Function are closed.

(d) The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

PALO VERDE UNITS 1 AND 3 AMENDMENT NO. 4417 PALO VERDE UNIT 2 3.3.5-4 AMENDMENT NO. -49

MSSVs 3.7.1 Table 3.7.1-1 (page 1 of 1)

Variable Overpower Trip Setpoint versus OPERABLE Main Steam Safety Valves MAXIMUM ALLOWABLE MINIMUM NUMBER OF MAXIMUM POWER VARIABLE OVERPOWER TRIP MSSVs PER STEAM C%RTP) SETPOINT GENERATOR (% RTP)

REQUIRED OPERABLE 3876 3990 3876 3990 MWt RTP MWt RTP MWt RTP MWt RTP(a) 10 100.0 100.0 111.0 111.0 9 98.2 90.0 108.0 99.7 8 87.3 80.0 97.1 89.7 7 76.4 68.0 86.2 77.7 6 65.5 56.0 75.3 65.7 (a) The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

PALO VERDE UNITS 1 AND 3 AMENDMENT NO. 44A PALO VERDE UNIT 2 3.7.1-3 AMENDMENT NO. 449

ATTACHMENT 3 CHANGES TO TS BASES PAGES (for information only)

RPS Instrumentation - Operating B 3.3;1 4..;

BASES LCO - 5. Containment Pressure.- High (continued)

The LCO requires four channels of Containment Pressure - High to be OPERABLE in MODES 1 and 2.

The Allowable Value is set high enough to allow for small pressure increases in containment expected during normal operation (i.e., plant heatup) and is not indicative of an abnormal condition. t is set low enough to initiate a reactor trip when an abnormal condition is indicated.

6. 7. Steam Generator Pressure - Low This LCO requires four channels of Steam Generator #1 Pressure - Low and Steam Generator #2 Pressure - Low to be OPERABLE in MODES 1 and 2.

This Allowable Value issufficiently below the full load operating value for steam pressure so as not to interfere with normal plant operation, but still high enough to provide the required protection in the event of excessive steam demand; Since excessive steam demand causes the RCS to cool down, resulting in positive reactivity addition to the core. If the moderator temperature coefficient is negative a reactor trip is required to offset that effect.

The trip setpoint may be manually decreased as steam generator pressure isreduced during controlled plant cooldown, provided the margin between steam generator pressure and the setpoint ismaintained

  • 200 psia.

This allows for controlled depressurization of the secondary system while still maintaining an active ftrAo00 7Z(at() WILL A reactor trip setpoint and MSIS setpoint. until the I o8t-r-ner pasr time is reached when the setpoints are no longer C'M0. 6bA N needed to potect the plant. The setpoint increases 7

k5i7?A WMAJ '* automatically as steam generator pressure increases 1until the specified trip setpoint is reached.

Tka-.0449A 61MA of' -

fiefrPetNr nm'rpi 8. Steam Generator Level - Low

\Pfteirc 7Ai $4sqT LIPV This LCO requires four channels of Steam Generator #1 Level - Low and Steam Generator #2 Level - Low for each steam generator to be OPERABLE inMODES 1 and 2. The Allowable Value issufficiently below the normal operating level for the steam generators so as not to (continued)

PALO VERDE UNITS 1.2.3 B 3.3.1-28 REVISION 25

RPS Instrumentation - Shutdown B 3.3.2 BASES LCO that removes power from the CEDMs may be used. The CEAs are (continued) still capable of withdrawal if the CEDMCS Withdrawal circuits are disabled with power applied-to the CEDMs because failures in the CEDMCS could result in CEA withdrawal.

rjwe1 -(e)

(lIr rqfraS-L.Arr WILL f n

e his LCO requires all four channels of Steam Generator #1 ressure-Low, and Steam Generator #2 Pressure-Low, to be 5S77ALLP 4 A A PERABLE in MODE 3. when the RTCBs are closed and the CEA 74 A S*Q toI x WA rive System is capable of CEA withdrawal. These RPS TL P40 C a t*Ab "e functions are not required in MODES 4 and 5 because the Steam r1jp Sxrp*,Ar tH4r 41*5 Generator temperature is low. therefore the energy release (S#L#(45fl&L$'*P Jb and resulting cooldown following a large MSLB in MODES 4 and PA*,ht 77W '4fJY 5 is not significant.<

l.flir

  • The Allowable Values are high enough to provide an operating envelope that prevents unnecessary Logarithmic Power Level - High reactor trips during normal plant operations.

The Allowable Values are low enough for the system to maintain a safety margin for unacceptable fuel cladding damage should a CEA withdrawal or MSLB event occur.

The Logarithmic Power Level - High trip may be bypassed when logarithmic power is above IE-4% NRTP to allow the reactor to be brought to power during a reactor startup. This bypass is automatically removed when logarithmic power decreases below 1E-4% NRTP. Above 1E-4% NRTP. the Variable Over Power - High and Pressurizer Pressure - High trips provide protection for reactivity transients.

The automatic bypass removal channel is INOPERABLE when the associated Log power channel has failed. The bypass function is manually controlled via station operating procedures and the bypass removal circuitry itself is fully capable of responding to a change inthe associated input bistable.

Footnotes (a) and (b) in Table 3.3.1-1 and (d) in Table 3.3.2-1 clearly require an "automaticw removal of trip bypasses. A failed Log channel may prevent. depending on the failure mode, the associated input bistable from changing state as power transitions through the automatic bypass removal setpoint. Specifically. when the indicated Log power channel isfailed high (above 1E-4%). the automatic Hi-Log power trip bypass removal feature inthat channel cannot function. Similarly, when the indicated Log power channel is failed low (below 1E-4X). the automatic DNBR-ELPD trip bypass removal feature inthat channel cannot function. Although one bypass removal feature is applicable above 1E-4% NRTP and the other is applicable below lE-4X NRTP, both are affected by a failed Log power channel and should therefore be considered INOPERABLE.

(continued)

B 3.3.2-6 REVISION 15 PALO VERDE UNITS PALO VERDE UNITS 1.2.3 1,2.3 B 3.3.2-6 REVISION 15

-ESFAS Instrumentation B-3.3.5:

BASES -

V`* -

LC a. team Generator Pressure - Low (continued) po rTT (c9 ) 'wLL P 1he Steam Generator Pressure-Low trip setpoint 17f*r MAg 4r-L0U#r xnw UP J \Iiay be manually decreased as steam generator 6 _rJ!741-C JILL. 64 Rash440 r ppressure is reduced. This prevents an RPS trip A 9,mA'a.. a) 17NIAI W 771iTL 1ZI4A*~ Cir MSIS actuation during controlled plant GA4SP 7*4 a e7lp sf7ifatr Cooldown. The margin between actual steam flr4r HS86"ecA nW s &STMSLUM to generator pressure and the trip setpoint must be (tore7r Awe satreTv £Jer naintained less than or equal to the specified Inl value of 200 psia to ensure a reactor trip and SIS will occur when required.

b. CM
b. Containment Pressure-High This LCO requires four channels of Containment Pressure- High to be OPERABLE in MODES 1. 2 and
3. The Containment Pressure-High signal is shared among the SIAS. (Function 1). CIAS (Function 3). and MSIS (Function 4)..

The Allowable Value for this trip is set high enough to allow for small pressure increases in containment expected during normal operation (i.e.. plant heatup) and is not indicative of an * . :C abnormal condition. The setting is low enough to initiate the ESF Functions-when an abnormal condition is indicated. This allows the ESF systems to perform as expected in the accident analyses to mitigate the consequences of the analyzed accidents.

c. Steam Generator Level-Hlah This LCO requires four channels of Steam Generator Level-High to be OPERABLE in MODES 1. 2 and 3.

The allowable value for this trip is set high enough to ensure it does not interfere with normal plant operation. The setting is low enough to prevent moisture damage to secondary plant components in the case of a steam generator overfill event.

(continued)

PALO VERDE UNITS 1.2.3 B 3.3.5-16 REVISION 0

MSSVs B 3.7.1 BASES APPLICABLE SAFETY ANALYSES The limiting accident for peak RCS pressure is the full (continued) power feedwater line break (FWLB). inside containment, with the failure of the backflow check valve in the feedwater line from the affected steam generator. Water from the affected steam generator is assumed to be lost through the break with minimal additional heat transfer from the RCS.

With heat removal limited to the unaffected steam generator.

the reduced heat transfer causes an increase in RCS temperature, and the resulting RCS fluid expansion causes an increase in pressure. The RCS pressure increases to

< 2843 psia, with the pressurizer safety valves providing relief capacity. These results were found acceptable by the NRC based on the low probability of the event.

The MSSVs satisfy Criterion 3 of 10CFR 50.36 (c)(2)(ii).

his LCO requires all MSSVs to be OPERABLE in compliance

,- / D, s,.a Ewith Reference 2. even though this is not a requirement of T T1r, AC-a t t e DBA analysis. This is because operation with less than T S- R t e full number of MSSVs requires limitations on allowable FAVM, pHERMAL POWER (to meet Reference 2 requirements). and

$A. C AMP djustment to the Reactor Protection System trip setpoints.

mo As 1 hese limitations are according to those shown in Wl7W SIt j a ble 3.7.1-1 and Required Action A.2 in the accompanying SAW$ Of 7N MP CO. An MSSV is considered inoperable if it fails to open sf6/Ar 1wV4 in pon demand.

Ap7.reCr 1W The OPERABILITY of the MSSVs is defined as.the ability to s 7 zoer LUI-/r open within the setpoint tolerances, relieve steam generator overpressure, and reseat when pressure has been reduced.

The OPERABILITY of the MSSVs is determined by periodic surveillance testing in accordance with the Inservice Testing Program.

The lift settings, according to Table 3.7.1-2 in the accompanying LCO. correspond to ambient conditions of the valve at nominal operating temperature and pressure.

This LCO provides assurance that the MSSVs will perform their designed safety function to mitigate the consequences of accidents that could result in a challenge to the RCPB.

(continued)

PALO VERDE UNITS 1.2.3 B 3.7.1-2 REVISION 7

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