ML101310396

Application for Technical Specification Change TSTF-491, Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using the Consolidated Line Item Improvement Process

ML101310396
Person / Time
Site:	Palo Verde
Issue date:	04/29/2010
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06180-DCM/DLK
Download: ML101310396 (15)

Text

10 CFR 50.90 LA R S A subsidiaryof Pinnacle 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 102-061 80-DCM/DLK April 29, 2010 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 Application for Technical Specification Change TSTF-491, Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Arizona Public Service Company (APS) is submitting a request for an amendment to the Technical Specifications (TS) for PVNGS Units 1,2, and 3.

The proposed amendment would modify the TS by removing the specific isolation time for the Main Steam and Main Feedwater isolation valves from the associated PVNGS TS Surveillance Requirements.

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-491, Revision 2, "Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications." The availability of this TS improvement was announced in the Federal Register on December 29, 2006 (71 FR 78472) as part of the Consolidated Line Item Improvement Process (CLIIP). provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Enclosure 2 provides the existing TS pages marked up to show the proposed change. Enclosure 3 provides revised (clean)

TS pages. Enclosure 4 provides the existing TS Bases pages marked up to show the proposed change (for information only).

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway 0 Comanche Peak 0 Diablo Canyon 0 Palo Verde

• San Onofre 0 South Texas 0 Wolf Creek -

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Application for Technical Specification Change TSTF-491, Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using the Consolidated Line Item Improvement Process Page 2 APS requests approval of the proposed license amendment by December 31, 2010, with the amendment being implemented within 90 days.

No commitments are being made to the NRC by this letter.

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).

Should you need further information regarding this amendment 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 _______

(Date)

Sincerely, DMC/RAS/DLK

Enclosures:

1. Description and Assessment

2. Proposed Technical Specification Changes

3. Revised Technical Specification Pages

4. Marked up Existing TS Bases Changes cc: E. E. Collins Jr. NRC Region IV Regional Administrator J. R. Hall NRC NRR Project Manager L. K. Gibson NRC NRR Project Manager R. I. Treadway NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)

T. Morales Arizona Radiation Regulatory Agency (ARRA) 9

Enclosure 1 Description and Assessment

Subject:

Application for Technical Specification Change TSTF-491, Removal of the Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications Using the Consolidated Line Item Improvement Process

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of TSTF 491 and Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination 3.2 Verification and Commitments 4.0 ENVIRONMENTAL EVALUATION

5.0 REFERENCES

1

Enclosure 1 License Amendment Request for Adoption of TSTF-491, Revision 2

1.0 DESCRIPTION

The proposed amendment would modify Technical Specifications (TS) by removing the specific isolation time for the Main Steam and Main Feedwater isolation valves from the associated Standard Technical Specifications (STS) Surveillance Requirements (SRs).

The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) TSTF-491 Revision 2. The availability of this TS improvement was published in the Federal Register on December 29, 2006 (71 FR 78472) as part of the Consolidated Line Item Improvement Process (CLIIP).

2.0 ASSESSMENT 2.1 Applicability of TSTF-491 and Published Safety Evaluation Arizona Public Service Company (APS) has reviewed TSTF-491 (Reference 1),

and the NRC model Safety Evaluation (SE) (Reference 2) as part of the CLIIP.

APS has concluded that the information in TSTF-491, as well as 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.

2.2 Optional Changes and Variations APS is not proposing any deviations from the TS changes described in TSTF-491 or the NRC staff's model SE published in the Federal Register on October 5, 2006 (71 FR 58884).

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Determination APS has reviewed the proposed No Significant Hazards Consideration Determination (NSHCD) published in the Federal Register as part of the CLIIP.

APS has concluded that the proposed NSHCD presented in the Federal Register notice is applicable to PVNGS Units 1, 2, and 3 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

2

Enclosure 1 License Amendment Request for Adoption of TSTF-491, Revision 2 3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on December 29, 2006 for this TS improvement, plant-specific verifications were performed as follows:

A review was performed of the affected systems as described in the Updated Final Safety Analysis Report to verify that TSTF-491 was applicable to PVNGS Units 1,2, and 3.

In addition, APS has proposed TS Bases consistent with TSTF-491 which provide guidance and details on how to implement the new requirements.

Finally, APS has a Bases Control Program consistent with Section 5.5 of the STS.

4.0 ENVIRONMENTAL EVALUATION The amendment changes requirements with respect to the installation or use of-a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment adopting TSTF-491; Rev 2, involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that TSTF-491, Rev 2, involves no significant hazards considerations, and there has been no -public comment on the finding in Federal Register Notice 71 FR 58884, October 5, 2006. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 REFERENCES

1. TSTF-491, Revision 2, "Removal of Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications."

2. NRC Model Safety Evaluation Report published on October 5, 2006 (71 FR 58884).

3

Enclosure 2 Proposed Technical Specification Changes Markup of Pages:

3.7.2-3 3.7.3-2

MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 ----------------- NOTE---------------

Not required to be performed prior to entry into MODE 3.

Verify closure timej*f each MSIV is In accordance 5 4.6 secnd withjin limits with each with the actuator train on an actual or simulated Inservice actuation signal. Testing Program PALO VERDE UNITS 1,2,3 3.7.2-3 AMENDMENT NO. 4-63

MFIVs 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 /> associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the closure time of each MFIV is In accordance

!59.6 secd within imits on an actual or with the simulated actuation signal. Inservice Testing Program PALO VERDE UNITS 1,2,3 3.7.3-2 AMENDMENT NO. 11-7

Enclosure 3 Revised Technical Specification Pages Page:

3.7.2-3 3.7.3-2

MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 ----------------- NOTE---------------

Not required to be performed prior to entry into MODE 3.

Verify closure time of each MSIV is In accordance within limits with each actuator train on with the an actual or simulated actuation signal. Inservice Testing Program PALO VERDE UNITS 1,2,3 3.7.2-3 AMENDMENT NO. 44ý

MFIVs 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.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 /> associated Completion Time not met. AND C.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify the closure time of each MFIV is In accordance within limits on an actual or simulated actuation signal.

with the Inservice I

Testing Program PALO VERDE UNITS 1,2,3 3.7.3-2 AMENDMENT NO. 44-ý ,

Enclosure 4 Marked up Existing TS Bases Changes Pages:

B 3.7.2-8 B 3.7.2-9 B 3.7.3-5

MSIVs B 3.7.2 BASES (continued)

ACTIONS H.1 and H.2 (continued)

(continued)

The 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time is consistent with that allowed in Condition F.

Inoperable MSIVs that cannot be restored to OPERABLE status within the specified Completion Time, but are closed, must be verified on a periodic basis to be closed. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, MSIV status indications available in the control room, and other administrative controls, to ensure these valves are in the closed position.

1.1 and 1.2 If the MSIVs cannot be restored to OPERABLE status, or closed, within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and in MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.2.1 REQUIREMENTS This SR verifies that the closure time of each MSIV is 4.6 seeonds within the limi giv en inReference 5 with each actuator train on an actual or simulated actuation signal-The M..V closure time is ,and .*swithinthat assumed in the accident and containment analyses. This SR alsoverifies the valve clsr timne i~sin accordance with the I1nservi~ce Testing Program. This SR is normally performed upon returning the unit to operation following .a refueling outage. The MSIVs should not. be full stroke tested at power.

(continued)

PALO VERDE UNITS 1,2,3 B 3.7.2-8 REVISION 40

MSIVs B 3.7.2 BASES (continued)

SURVEILLANCE SR 3.7.2.1 (continued)

REQUIREMENTS (continued) The Frequency for this SR is in accordance with the Inservice Testing Program. This Frequency demonstrates the valve closure time at least once per refueling cycle.

This test is conducted in MODE 3, with the unit at operating temperature and pressure, as discussed in the Reference 5 6 exercising requirements. This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This allows a delay of testing until MODE 3, in order to establish conditions consistent with those under which the acceptance criterion was generated.

REFERENCES 1. UFSAR, Section 10.3.

2. CESSAR, Section 6.2.

3. UFSAR, Section 15.1.5.

4. 10 CFR 100.11.

5. ASME, Boiler and Pressure Vessel Code,Section X!,

Inservice Tnspectien, Article !W..r 3,00. UFSAR, Sd*i*on 5.1.5.~

PALO VERDE UNITS 1,2,3 B 3.7.2-9 REVISION 4G

MFIVs B 3.7.3 BASES (continued)

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS This SR ve~rifies that closure tim~e ensures the actuation of each MFIV is < 9.6 seco-mnds, Wihntelmtgvni Reference 2 on an actual or simulated actuation signal. --- The MFJV closure time is anid is with*f*that assumed in the accident and containment analyses. ThisSR alaso verifies th av louetm is in accordance~ wihteInev Testing Program. This Su e*illa SR is normally performed upon returning the unit to operation following a refueling outage. The MFIVs should not be full stroke tested at power.

The Frequency is in accordance with the Inservice Testing Program. The Frequency for valve closure time is based on the refueling cycle. Operating experience has shown that these components usually pass the SR when performed at the specified Frequency.

REFERENCES 1. UFSAR, Section 10.4.7.

2. Q2<JFSAR, Section" .1.5.i PALO VERDE UNITS 1,2,3 B 3.7.3-5 REVISION G