ML090350212

Amendment Request for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors Using the Consolidated Line Item Improvement Process

ML090350212
Person / Time
Site:	Palo Verde
Issue date:	01/15/2009
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-05949-DCM/DLK
Download: ML090350212 (37)

Text

10 CFR 50.90

ýA WA subsidiaryofPinnacle West CapitalCorporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Vice President Tel. 623-393-5403 P.O. Box 52034 Generating Station Regulatory Affairs and Plant Improvement Fax 623-393-6077 Phoenix, Arizona 85072-2034 102-05949-DCM/DLK January 15, 2009 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket Nos. STN 50-528/529/530 Amendment Request for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors using the Consolidated Line Item Improvement Process Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) hereby requests to amend PVNGS Operating License Nos. NPF-41, NPF-51, and NPF-74, by amending the PVNGS Technical Specifications (TS) that are incorporated as Appendix A to the Operating Licenses for PVNGS Units 1, 2, and 3. The proposed amendment will delete the TS requirements related to hydrogen recombiners and hydrogen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of the NRC-approved Industry/Technical Specification Task Force (TSTF)

Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

Attachment I provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. provides the existing TS pages marked up to show the.proposed changes. Attachment 3 provides revised (clean) TS pages. Attachment 4 provides A member of the STARS sitrategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak & Diablo Canyon 0 Palo Verde 0 San Onofre 0 South Texas 0 Wolf Creek /

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Amendment Request for Technical Specification Improvement using the Consolidated Line Item Improvement Process Page 2 existing TS Bases pages marked up to show the proposed changes.

APS requests approval of the proposed license amendment by June 30, 2009, with the amendment to be implemented within 90 days of approval. This requested approval date has been administratively selected to accommodate a normal NRC review time, and is not needed for continued plant operation.

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).

This letter contains commitments described in Attachment 1. Ifyou have any questions about this request, please contact Russell A. Stroud, Licensing Section Leader at (623) 393-5111.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on Al.- c, (Date)

Sincerely, DCM/RAS/DLKIgat Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes (mark-up)

3. Revised (clean) Technical Specification Pages

4. Proposed Technical Specification Bases Changes (for information only mark-up) cc: E. E. Collins Jr. NRC Region IV Regional Administrator B. K. Singal NRC NRR Project Manager R. I. Treadway NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA) agodwin(Dazrra.qov T. Morales Arizona Radiation Regulatory Agency (ARRA) tmorales(-azrra .. ov

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

Subject:

Amendment Request for Technical Specification Improvement to Eliminate Requirements for Hydrogen Recombiners and Hydrogen Monitors using the Consolidated Line Item Improvement Process

2.0 DESCRIPTION

OF PROPOSED CHANGES

3.0 BACKGROUND

4.0 REGULATORY REQUIREMENTS AND GUIDANCE

6.0 REGULATORY ANALYSIS

6.1 Verification and Commitments 7.0 NO SIGNIFICANT HAZARDS CONSIDERATION 8.0 ENVIRONMENTAL EVALUATION 9.0 PRECEDENT

10.0 REFERENCES

Attachment 1 Description and Assessment

1.0 INTRODUCTION

The proposed License amendment deletes Technical Specification (TS) 3.6.7, "Hydrogen Recombiners," and references to the hydrogen monitors in TS 3.3.10, "Post Accident Monitoring (PAM) Instrumentation." The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The deletion of the requirements for the hydrogen recombiner and references to hydrogen monitors resulted in numbering and formatting changes to other TS, which were otherwise unaffected by this proposed amendment.

The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003, as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED CHANGES Consistent with the NRC-approved Revision 1 of TSTF-447, the proposed TS changes include:

TS 3.3.10, Condition C Note referencing hydrogen Deleted monitor channels TS 3.3.10, Condition D Inoperable Hydrogen Monitors Deleted Table 3.3.10-1 Item 10, Containment Hydrogen Deleted Monitors TS 3.6.7 Hydrogen Recombiners Deleted Other TS changes included in this amendment request are limited to renumbering and formatting changes that resulted directly from the deletion of the above requirements related to hydrogen recombiners and hydrogen monitors.

As described in NRC-approved Revision 1 of TSTF-447, the changes to TS requirements and associated renumbering of other TSs results in changes to Various TS Bases sections. The TS Bases changes will be submitted with a future update in accordance with TS 5.5.11, "Technical Specifications (TS) Bases Control Program."

However, the proposed TS Bases changes are provided in Attachment 4 to this amendment request for information only.

1

Attachment 1 Description and Assessment

3.0 BACKGROUND

The background for this amendment request is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this amendment request are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

Arizona Public Service Company (APS) has reviewed the safety evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability. This verification included a review of the NRC staffs SE, as well as the supporting information provided to support TSTF-447, Revision 1. APS has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, and justify this amendment for the incorporation of the changes to the PVNGS TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416)9,for this TS improvement, APS is making the following - -

verifications and regulatory commitments:

1. APS has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at PVNGS and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Technical Requirements Manual (TRM). This regulatory commitment will be implemented within 90 days of issuance of the license amendment.

2. PVNGS does not have an inerted containment.

2

Attachment 1 Description and Assessment 7.0 NO SIGNIFICANT HAZARDS CONSIDERATION APS has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP. APS has concluded that the proposed determination pres6Wnted in the notice is applicable to PVNGS and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

8.0 ENVIRONMENTAL EVALUATION APS has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. APS has concluded that the staffs findings presented in that evaluation are applicable to PVNGS and the evaluation is hereby incorporated by reference for this amendment request.

9.0 PRECEDENT This amendment request is being made in accordance with the CLIIP. APS is not proposing variations or deviations from the TS changes described in TSTF-447 or the NRC staffs model SE published on September 25, 2003 (68 FR 55416).

10.0 REFERENCES

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

3

Attachment 2 Proposed Technical Specification Changes (mark-up)

Pages:

iii 3.3.10-1 3.3.10-2 3.3.10-4 3.6.7-1 3.6.7-2 5.6-6

PALO VERDE NUCLEAR GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS 3.6.1 Containment 3.6.2 Containment Air Locks 3.6.3 Containment Isolation Valves 3.6.4 Containment Pressure 3.6.5 Containment Air Temperature 3.6.6 Containment Spray System 3.6.7 Hydrogen Recombincrs 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs) 3.7.2 Main Steam Isolation Valves (MSIVs) 3.7.3 Main Feedwater Isolation Valves (MFIVs) 3.7.4 Atmospheric Dump Valves (ADVs) 3.7.5 Auxiliary Feedwater (AFW) System 3.7.6 Condensate Storage Tank (CST) 3.7.7 Essential Cooling Water (EW) System 3.7.8 Essential Spray Pond System (ESPS) 3.7.9 Ultimate Heat Sink (UHS) 3.7.10 Essential Chilled Water (EC) System 3.7.11 Control Room Essential Filtration (CREFS) System 3.7.12 Control Room Emergency Air Temperature Control System (CREATCS) 3.7.13 Engineered Safety Feature (ESF) Pump Room Exhaust Air Cleanup System (PREACS) 3.7.14 Fuel Storage Pool Water Level 3.7.15 Fuel Storage Pool Boron Concentration 3.7.16 Secondary Specific Activity 3.7.17 Spent Fuel Assembly Storage 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources -- Operating 3.8.2 AC Sources -- Shutdown 3.8.3 Diesel Fuel Oil, Lube Oil and Starting Air 3.8.4 DC Sources -- Operating 3.8.5 DC Sources -- Shutdown 3.8.6 Battery Cell Parameters 3.8.7 Inverters -- Operating 3.8.8 Inverters -- Shutdown 3.8.9 Distribution Systems -- Operating 3.8.10 Distribution Systems -- Shutdown PALO VERDE UNITS 1,2,3 ii i AMENDMENT NO. 117

PAM Instrumentation 3.3.10 3.3 INSTRUMENTATION 3.3.10 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.10 The PAM instrumentation for each Function in Table 3.3.10-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

---

NOTE-------------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable, status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6.

not met.

C. NOTE C.1 Restore one channel 7 days Not appli to OPERABLE status.

hydrogcn monitorp GhaARe]-s One or more Functions with two required channels inoperable.

(continued)

PALO VERDE UNITS 1,2,3 3.3.10-1 AMENDMENT NO. 4-14, 165

PAM Instrumentation 3.3.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two hydrogen monitor, D.1 Restore one hydrogen 72 he.n,.

c-hannel-s inoperable,.oio canlt OPERABLE status.

D E. Required Action and 6-.11 &.4 Enter the Condition Immediately associated Completion referenced in Time of Condition C Table 3.3.10-1 for er-Q not met. the'channel.

E F. As required by E.1 F-4 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Required Action D.1

&.4 and referencTe--in AND Table 3.3.10-1.

E.2, F--2 Be in MODE 4.

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

' G. As required by F.j-1 &4 Initiate action in Immediately Required Action [)1 accordance w.ith

&.4 and reference-Fin Specification 5.6.6.

Table 3.3.10-1.

PALO VERDE UNITS 1,2,3 3.3.10-2 AMENDMENT NO. 117

PAM Instrumentation 3.3.10 Table 3.3.10-.1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED FROM--

REQUIRED ACTION D.1 FUNCTION REQUIRED CHANNELS & -4

1. Logarithmic Neutron Flux 2 FE

2. Reactor Coolant System Hot Leg Temperature 2 per loop F

3. Reactor Coolant System Cold Leg Temperature 2 per loop FE

4. Reactor Coolant System Pressure (wide range) 2 FE S. Reactor Vessel Water Level 2(d) G

6. Containment Sump Water Level (wide range) 2 FE

7. Containment Pressure (wide range) 2 FE

8. Containment Isolation Valve Position 2 per pene~r in flow FE path a) (b

9. Containment Area Radiation (high range) 2 G

10. Containment Hydrpgen Monitors 2F 0 44. Pressurizer Level 2 F 1-114. Steam Generator Water Level (wide range) 2 per steam generator F-12, 43. Condensate Storage Tank Level 2 FE

-14. Core Exit Temperature - Quadrant 1 2(c) F

_144-. Core Exit Temperature - Quadrant 2 2(c) FE 4*546. Core Exit Temperature - Quadrant 3 2(c) FE 1 4. -6 Core Exit Temperature - Quadrant 4 2(c) F-

,17, 48. Steam Generator Pressure 2 per steam generator F-18 4.-9. Reactor Coolant System Subcooling Margin 2 FE Monitoring

,19 2-9. Reactor Coolant System Activity 2 G Z- 24. High Pressure Safety Injection Cold Leg Flow 2 per loop F-21124. High Pressure Safety Injection Hot Leg Flow 2 F (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.

(c) A channel consists of two or more core exit thermocouples.

(d) A channel is eight sensors in a probe. A channel is OPERABLE if four or more sensors, two or more in the upper four and two or more in the lower four, are OPERABLE.

PALO VERDE UNITS 1,2,3 3.3.10-4 AMENDMENT NO. 44-ý, 131

• *J~. ~ ~ .,t.I *J 32.6 CO-NMTATINMENT SYSTEMS 3.6.7 Hydrogen Recombiners

'I" L_.J ....... L L J J-L= *1 ..... .... --".L -- *L--11

• 3*'.~ '* J~'.** I ~~%iIIUJ** *t.* ~fl*I.AI~AW**.F* tfl *S.. t*

he 1 FRARb MODES 1 and 2.

ACTION kIr*Tr I!g I

• Al1 -1l-L,--. D\IlkIfl" mmL,, I " -I " l ii*;-- - ,,I.- i I Ll

--.- ce;*,k-fl* 'kIl t &ul sTTT CONDIITT REQUIRED ACTION' COMPLETION TIME Ar-.One hydrage XA4 Restore hydrogen 30 days recombiner inoperable recombhiner to O-PE-R-ABLE- status.

T-w heydraqe 9-4 Veriy-by I hourn i noper-abie-. that the hydrogen MND maonitro lqpfunctio ish--,-

94 Restore one hydrogen 7-days recombiner to O-PE-RABL-E status.

G-.- Required Action and r,. Be in MODE 3. hours associated Completion Time not met, PALO VERDE UNITS 1.2.3 3.. i"_1 AMENIIMENIT NI-. 1-1-7. 1

Hvdr~non RrAcnmbi nprg SURVEILL'ANCE REQUIREMENTIS ________

SURVSUREILLANC DF-REQTU-ENCY~

SR Visually examine each hydrogen r. . ,mbin,. ,.-.h-enclosuirc and verify there is no evidence of abnormal conditions.

SR .6.--7. Perform a fumn-tional test foro each hydrogen months SR 23-6."7-.* Perform a CHANNEI CAl IRDATION to inc.lue a 12 m,--h System Functional Test for each hydrogen PAI Q IIFP* IIWIT'r 1 2 E1 NO. 117

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.6 PAM Report When a report is required by Condition B or FjG of LCO 3.3.10, "Post Accident Monitoring (PAM) InstrumentatTon," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 Tendon Surveillance Report Any abnormal degradation of the containment structure detected during the tests required by the Pre-Stressed Concrete Containment Tendon Surveillance Program shall be reported to the NRC within 30 days. The report shall include a description of the tendon condition, the condition of the concrete (especially at tendon anchorages), the inspection procedures, the tolerances on cracking, and the corrective action taken.

5.6.8 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.9, Steam Generator (SG)

Program. The report shall include:

a. The scope of inspections performed on each SG.

b. Active degradation mechanisms found.

c. Nondestructive examination techniques utilized for each degradation mechanism.

d. Location, orientation (if linear), and measured sizes (if available) of service induced indications.

e. Number of tubes plugged during the inspection outage for each active degradation mechanism.

f. Total number and percentage of tubes plugged to date.

g. The results of condition monitoring, including the results of tube pulls and in-situ testing.

PALO VERDE UNITS 1,2,3 5.6-6 AMENDMENT NO. 4-,W, 161

Attachment 3 Revised (clean) Technical Specification Pages Pages iii 3.3.10-1 3.3.10-2 3.3.10-4 5.6-6

PALO VERDE NUCLEAR GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS TABLE OF CONTENTS 3.6 CONTAINMENT SYSTEMS 3.6.1 Containment 3.6.2 Containment Air Locks 3.6.3 Containment Isolation Valves 3.6.4 Containment Pressure 3.6.5 Containment Air Temperature 3.6.6 Containment Spray System 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs) 3.7.2 Main Steam Isolation Valves (MSIVs) 3.7.3 Main Feedwater Isolation Valves (MFIVs) 3.7.4 Atmospheric Dump Valves (ADVs) 3.7.5 Auxiliary Feedwater (AFW) System 3.7.6 Condensate Storage Tank (CST) 3.7.7 Essential Cooling Water (EW) System 3.7.8 Essential Spray Pond System (ESPS) 3.7.9 Ultimate Heat Sink (UHS) 3.7.10 Essential Chilled Water (EC) System 3.7.11 Control Room Essential Filtration (CREFS) System 3.7.12 Control Room Emergency Air Temperature Control System (CREATCS) 3.7.13 Engineered Safety Feature (ESF) Pump Room Exhaust Air Cleanup System (PREACS) 3.7.14 Fuel Storage Pool Water Level 3.7.15 Fuel Storage Pool Boron Concentration 3.7.16 Secondary Specific Activity 3.7.17 Spent Fuel Assembly Storage 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources -- Operating 3.8.2 AC Sources -- Shutdown 3.8.3 Diesel Fuel Oil, Lube Oil and Starting Air 3.8.4 DC Sources -- Operating 3.8.5 DC Sources -- Shutdown 3.8.6 Battery Cell Parameters 3.8.7 Inverters -- Operating 3.8.8 Inverters -- Shutdown 3.8.9 Distribution Systems -- Operating 3.8.10 Distribution Systems -- Shutdown PALO VERDE UNITS 1,2,3 ii i AMENDMENT NO. 44--ý

PAM Instrumentation 3.3.10 3.3 INSTRUMENTATION 3.3.10 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.10 The PAM instrumentation for each Function in Table 3.3.10-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

---

--------------------- NOTE ----------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Restore required 30 days with one required channel to OPERABLE channel inoperable, status.

B. Required Action and B.1 Initiate action in Immediately associated Completion accordance with Time of Condition A Specification 5.6.6.

not met.

C. One or more Functions C.1 Restore one channel 7 days with two required to OPERABLE status.

channels inoperable.

(continued)

PALO VERDE UNITS 1,2,3 3.3.10-1 AMENDMENT NO. 4-65,

PAM Instrumentation 3.3.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Time of Condition C Table 3.3.10-1 for not met. the channel.

E. As required by E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Required Action D.1 and referenced in AND Table 3.3.10-1.

E.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. As required by F.1 Initiate action in Immediately Required Action D.1 accordance with and referenced in Specification 5.6.6.

Table 3.3.10-1.

PALO VERDE UNITS 1,2,3 3.3,10-2 AMENDMENT NO. 44--ý

PAM Instrumentation 3.3.10 Table 3.3.10-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITIONS REFERENCED FROM FUNCTION REQUIRED CHANNELS REQUIRED ACTION D.1

1. Logarithmic Neutron Flux 2

2. Reactor Coolant System Hot Leg Temperature 2 per loop

3. Reactor Coolant System Cold Leg Temperature 2 per loop

4. Reactor Coolant System Pressure (wide range) 2

5. Reactor Vessel Water Level 2 (d)

6. Containment Sump Water Level (wide range) 2

7. Containment Pressure (wide range) 2

8. Containment Isolation Valve Position 2 per pene~rýMn flow 2

9. Containment Area Radiation (high range) 2

10. Pressurizer Level 2

11. Steam Generator Water Level (wide range) 2 per steam generator

12. Condensate Storage Tank Level 2

13. Core Exit Temperature - Quadrant 1 2(c)

14. Core Exit Temperature - Quadrant 2 2(c)

15. Core Exit Temperature - Quadrant 3 2(c)

16. Core Exit Temperature - Quadrant 4 2(c)

17. Steam Generator Pressure 2 per steam generator

18. Reactor Coolant System Subcooling Margin 2 Monitoring

19. Reactor Coolant System Activity 2

20. High Pressure Safety Injection Cold Leg Flow 2 per loop

21. High Pressure Safety Injection Hot Leg Flow 2 (a) Not required for isolation valves whose associated penetration is isolated by at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indication channel is required for penetration flow paths with only one installed control room indication channel.

(c) A channel consists of two or more core exit thermocouples.

(d) A channel is eight sensors in a probe. A channel is OPERABLE if four or more sensors, two or more in the upper four and two or more in the lower four, are OPERABLE.

PALO VERDE UNITS 1,2,3 3.3.10-4 AMENDMENT NO. 4,4,

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.6 PAM Report When a report is required by Condition B or F of LCO 3.3.10, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 Tendon Surveillance Report Any abnormal degradation of the containment structure detected during the tests required by the Pre-Stressed Concrete Containment Tendon Surveillance Program shall be reported to the NRC within 30 days. The report shall include a description of the tendon condition, the condition of the concrete (especially at tendon anchorages), the inspection procedures, the tolerances on cracking, and the corrective action taken.

5.6.8 Steam Generator Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.9, Steam Generator (SG)

Program. The report shall include:

a. The scope of inspections performed on each SG.

,b. Active degradation mechanisms found.

c. Nondestructive examination techniques utilized for each degradation mechanism.

d. Location, orientation (if linear), and measured sizes (if available) of service induced indications.

e. Number of tubes plugged during the inspection outage for each active degradation mechanism.

f. Total number and percentage of tubes plugged to date.

g. The results of condition monitoring, including the results of tube pulls and in-situ testing.

PALO VERDE UNITS 1,2,3 5.6-6 AMENDMENT NO. 14,

Attachment 4 Proposed Changes to Technical Specification Bases Pages (for information only mark-up)

Pages B 3.3.10-11 B 3.3.10-12 B 3.3.10-13 B 3.3.10-14 B 3.3.10-15 B 3.3.10-16 B 3.3.10-19 B 3.3.10-20 B 3.3.10-21 B 3.6.7-1 B 3.6.7-2 B 3.6.7-3 B 3.6.7-4 B 3.6.7-5 Intentionally Blank Page B 3.8.1-8

PAM Instrumentation B 3.3.10 BASES LOC 1Q. Conitainment. H'.'roacn Moqnitorrs (continued)

Cont-ainment Hydrogen Monitor-s -apeprovided- to detec-t high hydrogen; concentration coenditions that represen a-potentiAal :foPr con.tainen breac .Thi vaial is._

also import-ant in ver-if-ying the adequacy of mitigati-ng At PVNG9, Contlainment Hydrogen Ins"lumentati on consuists' of the foilloig HPA-AT-9 WPR- AT 40 ad, -u. Pressurizer Level Pressurizer Level is used to determine whether to terminate Safety Injection (SI), if still in progress, or to reinitiate SI if it has been stopped. Knowledge of pressurizer water level is also used to verify the plant conditions necessary to establish natural circulation in the RCS and to verify that the plant is maintained in a safe shutdown condition.

At PVNGS,. Pressurizer Level instrumentation consists.

of the following:

RCA-LT-11OX RCB-LT-110Y (conti nued)

PALO VERDE UNITS 1,2,3 B 3.3.10-11 REVISION 14

PAM Instrumentation B 3.3.10 BASES LCO ,117 1-. Steam Generator Water Level (continued)

Steam Generator Water Level is provided to monitor operation of decay heat removal via the steam generators. The Category I indication of steam generator level is the wide range level instrumentation. The wide range level covers a span of 143 inches above the lower tubesheet to 55.5 inches above the steam separator deck.

Wide Range Steam Generator Level is a Type A variable because the operator must manually control steam generator level during a Steam Generator Tube Rupture (STGR) event to ensure steam generator tube coverage.

At PVNGS wide range Steam Generator Level Instrumentation consists of:

SGA-LT-1113A SGB-LT-1113B SGC-LT-1113C SGD-LT-1113D SGA-LT-1123A SGB-LT-1123B SGC-LT-1123C SGD-LT-1123D

!_172 4.. Condensate Storage Tank (CST) Level CST Level is provided to ensure water supply for AFW.

The CST provides the ensured, safety grade water supply for the AFW System. Inventory is monitored by a 3 ft. to 50 ft. level indication. CST Level is displayed on a control room indicator.

At PVNGS CST Level Instrumentation consists of:

CTA-LT-35 CTB-LT-36 (continued)

PALO VERDE UNITS 1,2,3 B 3.3.10-12 REVISION 14

PAM Instrumentation B 3.3.10 BASES LCO (continued) 13.1 14, 15, 16, 4-7-.- Core Exit Temperature Core Exit Temperature is provided for verification and long term surveillance of core cooling.

An evaluation was made of the minimum number of valid core exit thermocouples necessary for inadequate core cooling detection. The evaluation determined the reduced complement of core exit thermocouples necessary to detect initial core recovery and trend the ensuing core heatup. The evaluations account for core nonuniformities including incore effects of the radial decay power distribution and excore effects of condensate runback in the hot legs and nonuniform inlet temperatures.

Based on these evaluations, adequate or inadequate core cooling detection is ensured with two valid core exit thermocouples per quadrant.

The design of the Incore Instrumentation System includes a Type K (chromel alumel) thermocouple within each of the 61 incore instrument detector assemblies.

The junction of each thermocouple is located a few inches above the fuel assembly, inside a structure that supports and shields the incore instrument detector assembly string from flow forces in the outlet plenum region. These core exit thermocouples monitor the temperature of the reactor coolant as it exits the fuel assemblies.

The core exit thermocouples have a usable temperature range from 320 F to 2300 0 F, although accuracy is reduced at temperatures above 1800 0 F.

(continued)

PALO VERDE UNITS 1,2,3 B 3.3.10-13 REVISION 14

PAM Instrumentation B 3.3.10 BASES LCO 17*48. Steam Generator Pressure (continued)

Steam Generator pressure indication is provided for Steam Generator pressure verification. At PVNGS Steam Generator Pressure Instrumentation consists of:

SGA-PT-1013A SGB-PT-1013B SGC-PT-1013C SGD-PT-1013D SGA-PT-1023A SGB-PT-1023B SGC-PT-1023C SGD-PT-1023D a_*4-9. Reactor Coolant System-Subcooling Margin Monitoring The RCS Subcooling Margin Monitor is a portion of the Inadequate Core Cooling (ICC) Instrumentation required by Item II.F.2 in NUREG-0737, the post-TMI Action Plan. The ICC instrumentation enhances the ability of the Operator to anticipate the approach to, and recovery from, ICC. At PVNGS RCS subcooling Margin Monitoring Instrumentation consists of:

QSPDS A QSPDS B Each channel of QSPDS processing equipment will calculate the following saturation margin parameters:

a) RCS Saturation Margin - temperature margin based on the difference between saturation temperature and the maximum RTD temperature taken from the hot and cold legs. This algorithm uses the hottest RCS temperature (Thot or Tcold) and pressurizer pressure (PT-102) to complete the calculation.

b) CET Saturation Margin - temperature margin based on the difference between the saturation temperature and the representative core exit temperature calculated from the CET's. A representative CET value is first calculated (and displayed on the B02 trend recorder) for the input temperature. This is compared to pressurizer pressure (PT-102) to complete the saturation (continued)

PALO VERDE UNITS 1,2,3 B 3.3.10-14 REVISION 32

PAM Instrumentation B 3.3.10 BASES LCO 118 4-9. Reactor Coolant System-Subcooling Margin Monitoring (continued) margin calculation. Minimum requirements for CET operability must be met before the CET Saturation Monitor can be considered operable.

c) Upper Head Saturation Margin - temperature margin based on the difference between the saturation temperature and the unheated junction thermocouples (UHJTC) temperature. This algorithm uses the hottest of the three upper unheated thermocouples from RVLMS along with pressurizer pressure (PT-102) to complete the margin calculation.

One OPERABLE Subcooling Margin Monitor Channel consists of one RCS Saturation Margin indicator and one CET Saturation margin indicator. These indicators shall be from the same channel. Additionally, for any CET Saturation monitor indicator to be considered OPERABLE, the CET's for that channel must also be operable.

'1*9, 2. Reactor Coolant System Activity The RCS Activity provides an indication of fuel cladding failure. This indicates degradation of the first of three barriers to fission product release to the environment. The three barriers to fission product release are (1) fuel cladding, (2) primary coolant pressure boundary, and (3) containment. At PVNGS the RCS Activity Instrumentation consists of:

SQA-RU-150 SQB-RU-151

20. 21, *2-2 HPSI System Flow HPSI System flow indication is provided for HPSI flow verification.

(continued)

PALO VERDE UNITS 1,2,3 B 3.3.10-15 REVISION 32

PAM Instrumentation B 3.3.10 BASES LCO 20. 21, 2 HPSI System Flow (continued)

HPSI System flow is a Type A variable because the operator must manually balance the HPSI flow between the hot and cold legs when switching from cold leg injection to a combined cold/hot leg injection in support of LOCA Long Term Cooling to prevent boron precipitation in stagnate core areas. Monitoring of these instruments is not required for initial operation of HPSI flow. At PVNGS, HPSI System Cold Leg Flow indication consists of:

J-SIB-FT-0311 J-SIB-FT-0321 J-SIA-FT-0331 J-SIA-FT-0341 At PVNGS, HPSI System Hot Leg Flow indication consists of:

J-SIA-FT-0390 J-SIB-FT-0391 Two channels are required to be OPERABLE for all but one Function. Two OPERABLE channels ensure that no single failure within the PAM instrumentation or its auxiliary supporting features or power sources, concurrent with failures that are a condition of or result from a specific accident, prevents the operators from being presented the information necessary for them to determine the safety status of the plant and to bring the plant to and maintain it in a safe condition following that accident.

In Table 3.3.10-1 the exception to the two channel requirement is Containment Isolation Valve Position.

Two OPERABLE channels of core exit thermocouples are required for each channel in each quadrant to provide indication of radial distribution of the coolant temperature rise across representative regions of the core. Power distribution symmetry was considered in determining the specific number and locations provided for diagnosis of local core problems. Plant specific evaluations in response to Item II.F.2 of NUREG-0737 (Ref. 3) have determined that any two thermocouple pairings per quadrant, satisfy these requirements. Two sets of two thermocouples in each quadrant ensure a single failure will not disable the ability to determine the radial temperature gradient.

(continued)

PALO VERDE UNITS 1,2,3 B 3.3.10-16 REVISION 32

PAM Instrumentation B 3.3.10 BASES ACTIONS C.1 (continued)

Therefore, requiring restoration of one inoperable channel of the Function limits the risk that the PAM Function will be in a degraded condition should an accident occur.

When two required hydrogen monito-. ch-annealls -are inoperable, Required Action 0.1 requires one channel to restored to hb OPE This status.

T-md Requird to Q ArImlfýn monitoring capability of ithe red 'e'rnng in A=*

hdoemnir. tere PhP***,It The Theaproriut PPR nh hl*

72phour Completion Time ibaed on thale latis 'ely low probability of an etet Requiring hydogen monitoring and the availability of al ternativ men t bti the required infocration Conetinuous operation with two required hannels inoperable ic s net acceproptable because alternate indications are net avdailtable.

This Required Action directs entry into the appropriate Condition referenced in Table 3.3.10-1. The applicable Condition referenced in the Table is Function dependent.

Each time Required dAe Action C.1 DI is not met, and the associated Completion Time has expired, Condition T, E is entered for that channel and provides for transfer-to the appropriate subsequent Condition.

'E.1 and Ej .2 an.~d-F-2 If the Required Action and associated Completion Time of Condition C are-not met and Table 3.3.10-1 directs entry into Condition E'F-,the plant must be brought to a MODE in which the LCO d-0es not apply. To achieve this status, the plant must be brought to 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 to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(conti nued)

PALO VERDE UNITS 1,2,3 B 3.3.10-19 REVISION 32

PAM Instrumentation B 3.3.10 BASES ACTIONS F.1 4 (continued)

Alternate means of monitoring Reactor Vessel Water Level, RCS Activity, and Containment Area Radiation have been developed and tested. These alternate means may be temporarily installed if the normal PAM channel cannot be restored to OPERABLE status within the allotted time. If these alternate means are used, the Required Action is not to shut down the plant, but rather to follow the directions of Specification 5.6.6. The report provided to the NRC should discuss whether the alternate means are equivalent to the installed PAM channels, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAM channels.

SURVEILLANCE A Note at the beginning of the SR table specifies that REQUIREMENTS the following SRs apply to each PAM instrumentation Function found in Table 3.3.10-1.

SR 3.3.10.1 Performance of the CHANNEL CHECK once every 31 days ensures that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is normally'a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.

(continued)

PALO VERDE UNITS 1,2,3 B 3.3.10-20 REVISION 32

PAM Instrumentation B 3.3.10 BASES SURVEILLANCE SR 3.3.10.1 (continued)

REQUIREMENTS If the channels are normally off scale during times when surveillance is required, the CHANNEL CHECK will only verify that they are off scale in the same direction.

Current loop channels are verified to be reading at the bottom of the range and not failed downscale.

The Frequency of 31 days is based upon plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 31 day interval is a rare event.

The CHANNEL CHECK supplements less formal, but more frequent, checks of channel during normal operational use of the displays associated with this LCO's required channels.

SR 3.3.10.2 A CHANNEL CALIBRATION is performed every 18 months or approximately every refueling. CHANNEL CALIBRATION is a complete check of the instrument channel including the sensor. The Surveillance verifies the channel responds to the measured parameter within the necessary range and accuracy. A Note excludes the neutron detectors from the CHANNEL CALIBRATION.

For the Containment Area Radiation instrumentation, a CHANNEL CALIBRATION as described in UFSAR Sections 18.II.F.1.3 and 11.5.2.1.6.2 will be performed.

The calibration of the Containment Isolation Valve (CIV) position indication channels will consist of verification that the position indication changes from not-closed to closed when the valve is actuated to its isolation position by SR 3.6.3.7. The position switch is the sensor for the CIV position indication channels.

The calibration of the containment hydroegen monitor will ue smlle gases containi*g a nAoGminal one volume percent hydrgen balncenitrogen, and- four volume percGent hydrgenbalance nitrogen.

The Frequency is based upon operating experience and consistency with the typical industry refueling cycle and is justified by the assumption of an 18 month calibration interval for the determination of the magnitude of equipment drift.

PALO VERDE UNITS 1,2,3 B 3.3.10-21 REVISION 33

Hydrogen Rcminr B 3.6 CONMTATINMENT SYSTEKM B 32.6.7 Hydrogen Recoembincr-s BACKGROUIND The funct-io*,n of the hydro"gen r.ecombinr* s is to el-iminate thc potential breach of ontainment d.ue. to -ahydrogen . . .gen reaction.+,r Per, 10%CFR 50.11 "SI'÷Atandards form Combustle--hl Gas-:

Coto SytesinLght-Water Cooled Reactors" (Ref. 1),

and 10 CFR 50, GDC 41, "Containment Atmosphere Cleanup" (Re. ),hydrogen reobnr r eurdto reedlucr-e the-hydrogn concntration in the copntainment following a Lo~ss O'%f Coo*'*lant Acc,,-,ident, (lOC*tA) or*vMain* Steam, in Breakv,*l, (MSLB).

The rec-m*b-nersppacmls this by recombiin*g hydrogen and o~'gn toform waterp vapor. The vapornrmisi containment, thus elim-inating anY discharge to the enin,,me,-nt. The hydrogen recombiners are manually initiated sne, flammability lim-it would noe" reached until several days after a De ign Basis Accident (9BA).

Tuo 100t capacity independent hydrogen r-ecombiners are shard aongthe three units. Eac-hcostsfcnrls a power supply, and a recombiner located inA the Auxiliar~y Building. ReDombination is acconm9plished by heating; a hydr-ogen air mixture abAov*11502F. The r-esulting water-vapor- and discarge gases are cooled prior to discharge from the recGmbine. Air flows through the unit. at 56 lcflm with a 5 hp centrifugal blower in the unit providing the motive force.P A sig eprembiner is capable of maintaining the hydrogen cocetato icotnment blwte .0 volume percent (We/) flammability 1i it. Two rcans are provided to meet the requirement for redundancy and independen*ce.- Ec reo-,-mbhiner red fro'm a separ'ate Engnere Safety F~eatures bu-s.

APPDITARIB " The hydrogen recombiners pr'ovide for -ontrolling the hblk SAEYANAL YSES hydrogen conc-entration in cnametto less than the lwe flammable concentr-ation of 4.0 v,' f-llowi*ng a OBA. This coentrol would prevent -a contamnmntwide hydrogen bur, thus ensuring the pressure and temperature a-ssumed- inth analysis are not ex÷eedved and minimizing damage to safety AE SgtA.-uedO PALO VERDE UNITS 1,2,3 9 3.6.7-1 REVISION 9

Hydrogen RDcombi ncrs 3*36.7 BASES APPFTCABALSE related equipment locmated in coAntainmcnt. The limiting DBA rel-ative to hydr-o-n gncration iS a LOCA Hydrogen may accUMUlatc Within conAtaRinment folIflowin a LOCA lasq-aresult of,

-A. A metal AtpAm reaction between the zicnu fucI roAd cla ddin n theP,, eaco -r- c,'rA ant

b. Radiolytic decomposition of iwater in the Reactr-Coolant S-stem (RCS) and the c-ont-ainment sump; G. Hydrogen in the RCS At the time of the LOCA (i.e.,

hydrogen dissol;e d in,thereactlo-,r co-olantI.-,**ln ndihydrFogeln gas inthe pressurizer vapor space); or

d. Corrosion of metals exposed to Containment Spray System and EmergencGy Core- CoAoling Systems solu--tion-s.

To evaluate the potenti-al forP hydr-ogen accu.mulationi contanmen followin a LOCA, the hydrogen generation as a function of time following the initi-ation of the acdn is c-alcul.1ated. Cosetive assumptions r-ecommended in Refrene are se to maximi~ze the amount of hydroGgen

{G- 42I-)i-m4 P n m *: 4 m :--lW%-;w* n,.m n rn4 -

The hydrogen recoembiners satisf-y Criterion 23of 1_0 CFR 50.36 L49 ~Two hydrogen recombiners shared among the- t-hreep units, must hb OpEDA.ILE This ensue-s oper-ation of at- le-ast on hydrogen recembiner in th t f A wors.t. c.ase singqe

-ac-tive faiure Operation with at least one hydrogen recombhiner ensurs tha the post LOCA hydrogen c-nrentration can be prevented from exceeding the fl ammaýb, - lmit.

"t APPLICA*BILITY In MODNE-S Iand 2, two hydrogen mbiners ar rco-- reuiedt coentrol the post LOCA hydroggen concentr-ation within conainentbeow its, flammability limit of .0 - 'o assuming a worst case single failure.

(Gentiniuedý

Hyclregcn Kecomr ner-s R 2 fi RAS F APPITCATIITTY In MODES 3 and 4, both the hydrogen produc-tion rate and the toalhdrogen ppdroducd after a LOCA wolib es hn tha cal*cuated for- the DB'A IOCA. Also, because of the limited time in thesge MODES, th rbbility of -an accpid-ent requiring thehydoge reombner islow Threfrethe hydrogen ecmbiners* armm s e not* requiredm inl mODE 3 or '1.

In MODES 5 and 6, the probability and consequences o aLOCA are low, due to the pressure and temper-ature limitations Therfore hyroge reombier -arenot required in the-se APTT/'*t, The required ACTION-S have been modified by a Note stating that all threep WINGS Unlits (Units 1, 2, and 3) shall simutanousl coplywith the REQUIRED ACTION(s) when the shardprntion of the hydrogen recombiner(s) is the c.au-se of aCONDITION. This is necessar-y since th the PVGSUnt share the two hydroegen recomIerWPS that araeurd by this LCO.It wllhe nec-essarty for- the Control Room'of the Palo Verd tatUntdscoersan inoperable shared portionm of the hydrogen eombiner(s) to notif-y the other two Palo Verde Unit'SCotoRom of the inoperability A-4 With one containment hydrogen r-ecoambhiner inoper-able, the inoprabl recmbinerp must be restored to OPFRARBL Fttu within 30 days.In hscniinvh eann OPERABLE hydroen recoembiner! is adequate to perform the hydrogen contol uncton.The30 day Completion Time is based on the avaiabiityof the other hydrogen recoMbiner, the small probablity f a LOCA or MSLB occurring (that would generate an Amount of hydroentht xced the flammability limit),

and the ' amount of time _av~ailable after- a LOC.A or- MSLB (should one occur) for operator actio to prevenAt hydr-ogen accuulaionfrom. exceeding the flammability limi-t, PALO VERDE UNITS 1,2,3 R 2 A 7-2 REVIS

• r*IO 4O

Hydrogen Recomi ner7 BASEP ACTIONS . 1 ,and-I9.

(GG~ti nued With two hydrogen recao-nmb-iner-s inopcrabe, the ability to perform the hydrogen ontr-]l function via altenmate capabilitie mu be verified by administrative means,within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />,. The ;a.ter -tehydrogen ,r-ntro] ,pbi-ies are provided by the Hydrogen Purge Cleanup System. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time allows a reasonable perio-d. of time to verif-y that a loss ofIhydgen contr-ol fu-nction does not exist. In adto,1- the,-Ialternate hydrogen control system capability must e veifie evey 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> teefe oesr t continued availability. Both the initial erifi-c-a*In and allsusequet. ver-ifications may be per-formed as an ad-ministrativechck by examining logs orn othe~r infor-mation to determine the _av~ailability of Ithe alternate hydroegen conrolsysem. It does not mean to perform the Surveillances needed to demonstrate OPERABTILITY of the

-al.tern-Aate hydroegen con.tro system. If the abi1ity t perform the hydrogen co-Antrol func-tion is maintained, cont inue d oprto s permitted-with two hydrogen recmbines inopernable for up to 7 days. Seven days6 reasonable time to-allow two hydro-gen re-co-mbiners, to b-e inoperable because the hydrogen conrtrol func-tion is mainaineandbecase f the low proebability of thee occur-ren~e_ of _a LOCA that woiuld generate hydrogen in amounts GazpabiIeI 9 CUI~ -ble f Ilammabilit I IL -iHil if the inoper-able hydrogen recombiner(s) cannot be restored to O-PERABLE tatu wit-hin t-he required Completion Time, the pl-ant must be brought to a MODE in whicmh the IC does, not, apply. To achieve thist , the plant mui÷st bee brought to at least MODE wIthin 6 ho,,ur. The a1lowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> israoale, based on operatin exerene, to reac'h MOE 3 from full. power-*oGnd.itions in an ord-,er-ly manner-and~~~ chlegn pln .ihu systems.

(Gantinue4}

D 1 7A D)E'I T QTt'ki n' PALO VERDE UNITS 1-,-2-,4 D*7 VRDEU.TS.,23 PAL DrIC TA£,7.;LI-A;

my.ageR- -R 2 rq7e RBAS FS SURVl NCE This SR egnsue that there are no physical problems that id affect. reome r oprt.ion. A visual inspection iS coul, suffiient to determine anra codtnsthat couAldcas fail.res. The 6 month Freque.'ncy for this SR ..ar developed consierintha the incd-encr-e- ohdrgn reco-mbiners fa'li*ng tIhe SRD -inthe past islw SRD 2 f 7, A functional test of each Hydrogen RecOMbiner System assure t'hat tlhe rc-m-nr- remain operational. The funct-iona tes shal rinld oprain he ~recombiner- inc-luding the air blas- heat echanger fan motor and encl,-ed blower motor contnuoslyfor at le-ast. 30- minute-s -at.a temprtueo approximaltl 8002oF reactio-n hamber temperature. The f .requenc*rommended for this surveillan-a in the Improved Standard Te,-hnic,4l Specification (NUREG-1*32, Rev. 1) is 18 months. The hasesp for NUREG 1132 was developed for-pamnently installed hydrogen mb'ners. The two potal hydrogen recombineS -atPWNGS a.e shared among the three units; -therefor, the 6 month frequency fom -- the in-itia-l li*'nsing basisis re f*or. reliability Performance of a CHANNh'EL CAl ITRATION to inc-lude a system functional test for eac,-h hydroge.n r,-ombner ensur that the e-eombiners are aperational and c-an attAinand sustain the temperatureý; neesayfo-ydoen-c--nain In par-ticular-, this SR requires 1) resistance checseof motors, thermocouples, and heater ytm,2 etigclbaino

-all flow elements, oswitcrhes, and temperature elements, -and-

3) operatMAn Of the recombiner to include a functional test atI129~0~0 0 F F) forit least* I hours. Operating experience has shonei that .÷ these components usually pass the Sumrvillance when rfoArmepd at the 12 month FrmequeGcy.

Teeoe, the Fr-equenqcy was cnlddto be acceptable froem

-areli-ability standpoint.

REFEEDEIS 1. 10 50.11.

'FR

2. 10 CFR 50, Appendix A, GDC 41.

3. Regulatory Guide 1.7, Revision 0.

4. U-F9AR, Section 6.2.5 PALO VERDE UNITS 1,2,3 REV!S!O 0

This page intentionally blank AC Sources - Operating B 3.8.1 BASES ACTIONS A.2 (continued) 3.6.3); containment hydrogen mo.nitr.*r (TJ9 3.3. hydrogen recombiners (TS 3.6.7); auxiliary feedwater system (TS 3.7.5); essential cooling water system (TS 3.7.7); essential spray pond system (JS3.7.8); essential chilled water system (TS 3.7.10); control room essential filtration system (TS 3.7.11) control room emergency air temperature control system (1S 3.7.12); ESF pump room air exhaust cleanup system (TS 3.7.13); shutdown cooling subsystems (TS 3.4.6, 3.4.7, 3.4.8, and 3.4.15); and fuel building ventilation. Mode applicability is as specified in each appropriate TS section.

The Completion Time for Required Action A.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. The train has no offsite power supplying its loads; and

b. A required feature on the other train is inoperable.

If at any time during the existence of Condition A (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours from the discovery of these events existing concurrently is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature.

(continued)

PALO VERDE UNITS 1,2,3 B 3.8.1-8 REVISION 42