ML12076A045

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Request for Amendment to Eliminate the Use of the Term Core Alteration in the Technical Specifications
ML12076A045
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 03/08/2012
From: Mims D
Arizona Public Service Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06486-DCM/RAS/DFS
Download: ML12076A045 (72)


Text

10 CFR 50.90 A subsidiaryof PinnacleWest CapitalCorporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Senior Vice President Tel. 623-393-5403 P. 0. Box 52034 Generating Station Nuclear Regulatory and Oversight Fax 623-393-6077 Phoenix, Arizona 85072-2034 102-06486-DCM/RAS/DFS March 8, 2012 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Request for Amendment to Eliminate the Use of the Term CORE ALTERATION in the Technical Specifications Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) hereby requests an amendment to the Technical Specifications (TS) that are incorporated as Appendix A to Renewed Facility Operating License Nos. NPF-41, NPF-51, and NPF-74, for PVNGS Units 1, 2, and 3, respectively. The proposed license amendment request (LAR) will eliminate the use of the term CORE ALTERATIONS throughout the TSs. The proposed amendment incorporates changes reflected in Technical Specification Task Force (TSTF) Traveler 471-A, revision 1, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes." In addition, the proposed amendment implements changes related to TSTF-471 consistent with NUREG-1432, "Standard Technical Specifications -

Combustion Engineering Plants," revision 3.

Approval of the proposed LAR is requested within one year of the date of this letter, with the amendment to be implemented within 90 days after approval.

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 the proposed amendment. By copy of this letter, this LAR 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 LAR, please contact Russell A.

Stroud, Licensing Section Leader, at (623) 393-5111.

A member of the STaRS (Strategic Teaming and Resource Sharing) Alliance *W Callaway

  • Comanche Peak
  • Diablo Canyon
  • Palo Verde 0 San Onofre 0 South Texas a Wolf Creek k 10Z

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission

Subject:

Request for Amendment to Eliminate the Use of the Term CORE ALTERATION in the Technical Specifications Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on ,f/fWf C 2-(Date)

Sincerely,

,/7111-1

  • DCM/RAS/DFS/gat

Enclosure:

Evaluation of the Proposed Change cc: E. E. Collins Jr. NRC Region IV Regional Administrator B. K. Singal NRC NRR Project Manager for PVNGS L. K. Gibson NRC NRR Project Manager J. R. Hall NRC NRR Senior Project Manager M. A. Brown NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)

T. Morales Arizona Radiation Regulatory Agency (ARRA)

ENCLOSURE Evaluation of the Proposed Change

Subject:

Request for Amendment to Eliminate the Use of the Term CORE ALTERATION in the Technical Specifications 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

ATTACHMENTS:

1. Technical Specification Page Markups
2. Retyped Technical Specification Pages
3. Technical Specification Bases Page Markups

Enclosure Evaluation of the Proposed Change 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) hereby requests an amendment to the Technical Specifications (TS) that are incorporated as Appendix A to Renewed Facility Operating License Nos. NPF-41, NPF-51, and NPF-74, for PVNGS Units 1, 2, and 3, respectively. The proposed license amendment request (LAR) will eliminate the use of the term CORE ALTERATIONS throughout the TSs. The proposed amendment incorporates changes reflected in Technical Specification Task Force (TSTF) Traveler 471-A, revision 1, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes." In addition, the proposed amendment implements changes related to TSTF-471 consistent with NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants,"

revision 3 (Reference 6.2).

NUREG-1 432, revision 3, removed the use of the defined term CORE ALTERATIONS from all TS Applicability statements and use of the term in various TS Required Actions. TSTF-471-A Traveler removes the remaining instances where CORE ALTERATIONS was used in TS Required Actions and removes CORE ALTERATIONS from TS Section 1.1, Definitions.

Use of the term CORE ALTERATIONS throughout the TSs is restrictive and limits operational flexibility. The operator action of suspending core alterations has no effect on the initial conditions or mitigation of any design basis accident or transient. Therefore, the uses of the defined term CORE ALTERATIONS are proposed to be removed from the TSs.

2.0 DETAILED DESCRIPTION The proposed LAR revises the TSs as follows:

a) TS 1.1, Definitions - Delete the definition of CORE ALTERATION.

b) TS 3.3.8, Containment Purge Isolation Actuation Signal (CPIAS) - Remove the phrase "During CORE ALTERATIONS," from the Applicability statement, remove the words "CORE ALTERATIONS," from Condition C, remove the Required Action in Condition C to "Suspend CORE ALTERATIONS, remove the Completion Time for the associated Required Action, and renumber the remaining Required Action under Condition C.

c) TS 3.3.9, Control Room Essential Filtration Actuation Signal (CREFAS) - Remove the Required Action C.2.3 to "Suspend CORE ALTERATIONS," and remove the Completion Time for that Required Action.

d) TS 3.7.11, Control Room Essential Filtration System (CREFS) - Remove the Required Action F.1 to "Suspend CORE ALTERATIONS," remove the Completion Time for that Required Action, and renumber the remaining Required Action under Condition F.

e) TS 3.7.12, Control Room Emergency Air Temperature Control System (CREATCS) -

Remove the Required Action E.1 to "Suspend CORE ALTERATIONS," remove the Completion Time for that Required Action, and renumber the remaining Required Action under Condition E.

2

Enclosure Evaluation of the Proposed Change f) TS 3.8.2, AC Sources - Shutdown - Remove the Required Actions A.2.1 and B.1 to "Suspend CORE ALTERATIONS," remove the Completion Times for those Required Actions, renumber remaining Required Actions under Conditions A and B, and revise the Note which modifies the ACTIONS to address the renumbering.

g) TS 3.8.5, DC Sources - Shutdown - Remove the Required Action A.2.1 to "Suspend CORE ALTERATIONS," remove the Completion Time for that Required Action, renumber the remaining Required Actions under Condition A, and revise the Note which modifies the ACTIONS to address the renumbering.

h) TS 3.8.8, Inverters - Shutdown - Remove the Required Action A.2.1 to "Suspend CORE ALTERATIONS," remove the Completion Time for that Required Action, renumber remaining Required Actions under Condition A, and revise the Note which modifies the ACTIONS to address the renumbering.

i) TS 3.8.10, Distribution Systems - Shutdown - Remove the Required Action A.2.1 to "Suspend CORE ALTERATIONS," remove the Completion Time for that Required Action, renumber remaining Required Actions under Condition A, and revise the Note which modifies the ACTIONS to address the renumbering.

j) TS 3.9.1, Boron Concentration - Remove the Required Action A.1 to "Suspend CORE ALTERATIONS," remove the Completion Time for that Required Action, and renumber remaining Required Actions under Condition A.

k) TS 3.9.2, Nuclear Instrumentation - Remove the Required Action A.1 to "Suspend CORE ALTERATIONS," remove the Completion Time for that Required Action, and renumber remaining Required Action under Condition A.

I) TS 3.9.3, Containment Penetrations - Remove the phrase "During CORE ALTERATIONS," from the Applicability statement, remove the Required Action A.1 to "Suspend CORE ALTERATIONS, remove the Completion Time for that Required Action, and renumber the remaining Required Action under Condition A.

The term CORE ALTERATION is defined in the PVNGS TS as, "CORE ALTERATION shall be the movement or manipulation of any fuel, sources, or reactivity control components

[excluding control element assemblies (CEAs) withdrawn into the upper guide structure],

within the reactor vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position."

The proposed change will eliminate the defined term CORE ALTERATION from the TSs.

This is justified because suspension of CORE ALTERATIONS has no effect on the initial conditions or mitigation of any design basis accident or transient. Therefore, the definition of CORE ALTERATIONS provided in the TS 1.1, Definitions, and the various places where that defined term is used in the TS is not required and are proposed to be removed.

The current PVNGS procedures include precautions to ensure that no control rod drive shafts are still latched to avoid accidentally lifting a control rod and potentially violating a Required Action which prohibits CORE ALTERATIONS. However, these proceduralized actions have no safety benefit as the shutdown margin is determined assuming the worst configuration of the control rods.

3

Enclosure Evaluation of the Proposed Change

3.0 TECHNICAL EVALUATION

The term "core alteration" does not appear in the Standard Review Plan or in the Title 10 Code of Federal Regulations. Since CORE ALTERATIONS occur when the reactor vessel head is removed, it applies in Mode 6. There are two accidents considered during Mode 6 for pressurized water reactors: a fuel handling accident and a boron dilution accident.

According to the Standard Review Plan, a fuel handling accident is initiated by the dropping of an irradiated fuel assembly, either in the Containment or in the Fuel Handling Building.

For that accident there are no mitigation actions and suspension of CORE ALTERATIONS, except for suspension of movement of irradiated fuel, will not prevent or impair the mitigation of a fuel handling accident.

A second analyzed event is a boron dilution accident. A boron dilution accident is initiated by a dilution source that results in the boron concentration dropping below what is required to maintain the shutdown margin. As described in the Bases for TS 3.9.1, Boron Concentration, which applies in Mode 6, the refueling boron concentration limit is specified in the Core Operating Limits Report (COLR). Unit procedures ensure the specified boron concentration in order to maintain an overall core reactivity of keff< 0.95 during fuel handling, with control element assemblies and fuel assemblies assumed to be in the most adverse configuration (least negative reactivity) allowed by unit procedures. The accident is mitigated by stopping the dilution.

Likewise, the Bases for TS 3.9.2 state that source range monitors are needed to alert operators to unexpected changes in core reactivity caused by boron dilution or a misloaded fuel assembly. Suspension of CORE ALTERATIONS has no effect on the mitigation of a boron dilution accident as it is assumed that the control rods or fuel do not affect the initial conditions of a boron dilution accident, and it is assumed that the control rods and fuel are in the most adverse conditions as allowed by procedure with a large safety margin (keff<

0.95). To address the possibility of a misloaded fuel assembly in TS 3.9.2, the remaining Required Action suspends positive reactivity additions if nuclear instrumentation is not available. This precludes movement of fuel assemblies which could add reactivity to the core.

In summary, with the exception of suspending movement of irradiated fuel assemblies, there are no design basis accidents or transients that are initiated by, or mitigation affected by, suspension of CORE ALTERATIONS. Therefore, removing CORE ALTERATIONS from applicability of TS 3.3.8, Containment Purge Isolation Actuation Signal (CPIAS) and TS 3.9.3, Containment Penetrations, is justified. In addition, with the exception of two TSs discussed below, the TS Required Actions that currently require suspension of CORE ALTERATIONS also require suspension of movement of irradiated fuel. For these TSs, suspension of CORE ALTERATIONS provides no safety benefit and the removal of the suspension of CORE ALTERATIONS is justified.

There are two TSs with Required Actions that do not also require suspension of the movement of irradiated fuel assemblies, TS 3.9.1, Boron Concentration, and TS 3.9.2, Nuclear Instrumentation. These two TSs are based on boron dilution accidents, which do not rely on the suspension of CORE ALTERATIONS, including fuel movement, for mitigation. Therefore, suspension of CORE ALTERATIONS provides no safety benefit and removal is justified. Since there will be no uses of the defined term CORE ALTERATIONS 4

Enclosure Evaluation of the Proposed Change in the TS as a result of this proposed change, maintaining the definition in TS 1.1 is not required.

Additional Technical Specification Bases Changes As discussed above, the Bases for the listed TSs will be revised to reflect the proposed changes and a proposed markup is included "For Information Only" in Attachment 3.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria The NRC regulatory requirements related to the contents of TSs are set forth in Section 50.36 of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50.36), which assures the TS specified limiting conditions for operation (LCO) are consistent with assumed values of the initial conditions in the licensee's safety analyses. 10 CFR 50.36(c)(2)(ii)(B) requires an LCO in the TS for an operating restriction that is an initial condition of a design basis accident (DBA). In this regard, the LCOs specify the minimum requirements for ensuring safe operation. The TS LCOs also contain associated Actions that are prescribed to be taken should certain designated conditions exist such that the LCO requirements are not met.

The applicable General Design Criteria (GDC) are:

GDC 19, "Control room," of Appendix A to 10 CFR Part 50 provides requirements for maintaining a habitable control room and includes limitations on radiological dose that may be received by control room operators.

GDC 61, "Fuel storage and handling and radioactivity control," requires that the fuel storage and handling ... systems ... shall be designed to assure adequate safety under normal and postulated accident conditions. The systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety, (2) with suitable shielding for radiation protection, (3) with appropriate containment, confinement, and filtering systems.

GDC 62, "Prevention of criticality in fuel storage and handling," requires that criticality be prevented by physical systems and processes.

GDC 64, "Monitoring radioactivity releases," requires that the means shall be provided for monitoring the reactor containment atmosphere effluent discharge paths, and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences, and from postulated accidents.

The proposed changes do not affect PVNGS compliance with the applicable regulatory requirements and criteria.

4.2 Precedent In NUREG-1432, revision 3, the NRC approved deletion of the term CORE ALTERATIONS from any TS Applicability statement or TS Condition, and the requirement for the "Suspension of CORE ALTERATIONS," from most TS Required Actions On December 7, 2006, the NRC approved TSTF- 471-A, revision 1, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes" (Reference 6.1).

5

Enclosure Evaluation of the Proposed Change The NRC issued a license amendment approving the deletion of CORE ALTERATIONS from the TS in NRC letter titled "Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, Amendment RE: Deletion of Term Core Alterations," dated September 21, 2006 (ADAMS Accession No. ML062350447) (Reference 6.3).

The NRC issued a license amendment approving the deletion of CORE ALTERATIONS from the TS in NRC letter titled "Point Beach Nuclear Plant, Units 1 and 2 - Issuance of Amendment RE: Core Alterations," dated February 15, 2007 (ADAMS Accession No. ML063450073) (Reference 6.4).

4.3 No Significant Hazards Consideration Determination The proposed change would revise the Technical Specifications to eliminate the use of the term CORE ALTERATIONS. Arizona Public Service Company (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:

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

Response: No.

The proposed change eliminates the use of the defined term CORE ALTERATIONS from the Technical Specifications. CORE ALTERATIONS are not an initiator of any accident previously evaluated except a fuel handling accident. The revised Technical Specifications that protect the initial conditions of a fuel handling accident also require the suspension of movement of irradiated fuel assemblies. Suspending movement of irradiated fuel assemblies protects the initial condition of a fuel handling accident and, therefore, suspension of CORE ALTERATIONS is not required. Suspension of CORE ALTERATIONS does not provide mitigation of any accident previously evaluated. Therefore, CORE ALTERATIONS do not affect the initiators of the accidents previously evaluated and suspension of CORE ALTERATIONS does not affect the mitigation of the accidents previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No No new or different accidents result from utilizing the proposed change. The changes do not involve a physical modification of the plant (i.e., no new or different type of equipment will be installed) or a significant change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements. The changes do not alter assumptions made in the safety analysis.

The proposed changes are consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

6

Enclosure Evaluation of the Proposed Change

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

Response: No.

Only two accidents are postulated to occur during plant conditions where CORE ALTERATIONS may be made: a fuel handling accident and a boron dilution accident. Suspending movement of irradiated fuel assemblies prevents a fuel handling accident. Also requiring the suspension of CORE ALTERATIONS is a redundant requirement to suspending movement of irradiated fuel assemblies and does not increase the margin of safety. CORE ALTERATIONS have no effect on a boron dilution accident. Core components are not involved in the initiation or mitigation of a boron dilution accident and the SHUTDOWN MARGIN limit is based on assuming the worse-case configuration of the core components.

Therefore, CORE ALTERATIONS have no effect on the margin of safety related to a boron dilution accident.

Based on the above, APS concludes that the proposed amendment does not involve a 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.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment removes the definition of and reference to, CORE ALTERATIONS from the TSs. The remaining controls included in the affected TSs provide the same level of protection as previously provided in the affected TSs and ensures that the PVNGS Units 1, 2, and 3, design and licensing bases continue to be met. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7

Enclosure Evaluation of the Proposed Change

6.0 REFERENCES

6.1 TSTF- 471-A, revision 1, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes," December 7, 2006.

6.2 NUREG-1432, "Standard Technical Specifications - Combustion Engineering Plants," revision 3.

6.3 Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, Amendment RE: Deletion of Term Core Alterations, dated September 21, 2006 (ADAMS Accession No. ML062350447) 6.4 Point Beach Nuclear Plant, Units 1 and 2 - Issuance of Amendment RE: Core Alterations, dated February 15, 2007 (ADAMS Accession No. ML063450073) 8

Enclosure Evaluation of the Proposed Change ATTACHMENT I Technical Specification Page Markups Pages:

1.1-3 3.3.8-1 3.3.8-2 3.3.9-2 3.7.11-2 3.7.12-2 3.8.2-1 3.8.2-2 3.8.5-1 3.8.5-2 3.8.8-1 3.8.8-2 3.8.10-1 3.8.10-2 3.9.1-1 3.9.2-1 3.9.3-1

Defi ni ti ons 1.1 1.1 Definitions (continued)

CORE ALTERATION CORE ALTERATION shall be the movement or manipulatio99f any f ueI l,sources. or r-eacti*vity control com..ponents [vexcudiHng ontrol elemeRt asscmblies (C loithdrawn into the upper guide structure], within the rc.actor ve.s.sel wAith the vessel head removed and fiuel in vesse.*

Suspens9on of CORE AILTERIATTO-S shall not p*cluHde completion of moVement of a GcompnenA t to a Safe CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in ICRP 30, Supplement to Part 1, page 192-212, Table titled, "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity."

E - AVERAGE E shall be the average (weighted in proportion DISINTEGRATION ENERGY to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV)for isotopes, other than iodines, with half lives > 15 minutes, making up at least 95% of the total noniodine activity in the coolant.

(continued)

PALO VERDE UNITS 1,2,3 1.1-3 AMENDMENT NO. 4-14

CPIAS 3.3.8 3.3 INSTRUMENTATION 3.3.8 Containment Purge Isolation Actuation Signal (CPIAS)

LCO 3.3.8 One CPIAS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, During COR AILTiEATIOQIS During movement of irradiated fuel assemblies within containment.

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

Only required when the penetration is not isolated by at least one closed automatic valve, closed manual valve, or blind flange.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CPIAS Manual Trip, A.1 Place and maintain Immediately Actuation Logic, or containment purge and radiation monitor exhaust valves in inoperable in MODES 1, closed position.

2, 3, and 4.

B. Required Action and B.1 Enter applicable Immediately associated Completion Conditions and Time not met. Required Actions for affected valves of LCO 3.6.3 "Containment Isolation Valves" made inoperable by CPIAS instrumentation.

(conti nued)

PALO VERDE UNITS 1,2,3 3.3.8-1 AMENDMENT NO. 44--ý 1

CPIAS 3.3.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. CPIAS Manual Trip. C.1 Place and maintain Immediately Actuation Logic, or containment purge and radiation monitor exhaust valves in inoperable during C-G4 closed position.

ALTERATIONS or movement of irradiated OR fuel assemblies within containment. C.2,- Su... eRndy AI TE-ATT 9NSl A4P G.2.2 Suspend movement of Immediately irradiated fuel assemblies in containment.

SURVEILLANCE REQUIREMENTS SURVEI LLANCE FREQUENCY SR 3.3.8.1 Perform a CHANNEL CHECK on required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> radiation monitor channel.

SR 3.3.8.2 Perform a CHANNEL FUNCTIONAL TEST on each 92 days required radiation monitor channel, and Verify the setpoint _<2.5 mR/hr.

SR 3.3.8.3 ----------------- NOTE----------------

Surveillance of Actuation Logic shall include the verification of the proper operation of each actuation relay.

Perform a CHANNEL FUNCTIONAL TEST on 18 months required CPIAS Actuation Logic channel.

(continued)

PALO VERDE UNITS 1,2,3 3.3.8-2 AMENDMENT NO. ;4-ý

CREFAS 3.3.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. CREFAS Manual Trip, C.1 Place one CREFS train Immediately Actuation Logic, or in operation.

radi ati on monitor inoperable in MODE 5 OR or 6, or during movement of irradiated C.2.1 Suspend movement of Immediately fuel assemblies, irradiated fuel assemblies.

AND C.2.2 Suspend positive Immediately reactivity additions.

ANP C.2.3 suspeHd CORED 4e4I-e4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.9.1 Perform a CHANNEL CHECK on the required 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> control room radiation monitor channel.

(continued)

PALO VERDE UNITS 1,2,3 3.3.9-2 AMENDMENT NO. 44-ý

CREFS 3.7.11 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 /> associ ated Completion Time of Condition A or AND B not met in MODE 1, 2, 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 /> 3, or 4.

D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREFS train in Time of Condition A not operation.

met in MODE 5 or 6.

E. Required Action and E.1 Place OPERABLE Immediately associated Completion CREFS Train in Time of Condition A not operation.

met during movement of irradiated fuel OR assemblies.

E.2 Suspend movement of Immediately irradiated fuel assemblies.

F. Two CREFS trains F.1 sus.pe.R....d rTmmi4 ,,

inoperable in MODE 5 or ALTEATONS-.-

6, or during movement of irradiated fuel AND assemblies.

OR One or more CREFS trains F.2 Suspend movement of Immediately inoperable due to irradiated fuel inoperable CRE boundary assemblies.

in MODE 5 or 6, or during movement of irradiated fuel assemblies.

G. Two CREFS trains G.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4, for reasons other than Condition B.

(conti nued)

PALO VERDE UNITS 1.2.3 3.7.11-2 AMENDMENT NO. 117, 171

CREATCS 3.7.12 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CREATCS trains E.1 Su.e.R. rmmen! ately inoperable in MODE 5 ALTERAT4ONS7 or 6, or during movement of irradiated A4D fuel assemblies.

E.2 -Suspend movement of Immediately irradiated fuel assemblies.

F. Two CREATCS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Verify each CREATCS train has the 18 months capability to remove the assumed heat load.

PALO VERDE UNITS 1,2,3 3.7.12-2 AMENDMENT NO. 4-1-;

1

AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems Shutdown": and
b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS


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

In MODES 1, 2, 3, and 4, Required Actions A.2.3-2 and B.,-2 are not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite ------------NOTE----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected Immediately required feature(s) with no offsite power available inoperable.

OR A.2. 1 S..pe.d-. GQR-ALTERATIONS.

AND (continued)

PALO VERDE UNITS 1,2.3 3.8.2-1 AMENDMENT NO. 4-ý

AC Sources - Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.2 -Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.32 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND A.2.43 Initiate action to Immediately restore required offsite power circuit to OPERABLE status.

B. One required DG B.1 GPed G... e dnOR inoperable. AILTERAT !IiS.

A49 B. 2 Suspend movement of Immediately irradiated fuel assemblies.

AND B.32 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND B.43 Initiate action to Immediately restore required DG to OPERABLE status.

PALO VERDE UNITS 1,2,3 3.8.2-2 AMENDMENT NO. 44-7

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS


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

In MODES 1, 2, 3, and 4, Required Action A.2.3B-2 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately DC electrical power required feature(s) subsystems (exclusive inoperable.

of the battery charger) inoperable. OR A.2.1 4-E

.pe4.. lmr AND A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.,2 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

PALO VERDE UNITS 1,2,3 3.8.5-1 AMENDMENT NO. ;44

DC Sources - Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.43 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status.

B. Required DC electrical B.1 Verify battery cell 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> power subsystem parameters meet Table battery charger 3.8.6-1 category A AND inoperable. limits.

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> AND thereafter B.2 Restore DC electrical 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power subsystem battery charger to OPERABLE status.

C. Required Action and C.1 Declare associated Immediately associated Completion battery inoperable.

Time of Condition B not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 ----------------- NOTE---------------

The following SRs are not required to be performed: SR 3.8.4.6, SR 3.8.4.7, and SR 3.8.4.8.

For DC sources required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.4 SR 3.8.4.7 SR 3.8.4.2 SR 3.8.4.5 SR 3.8.4.8.

SR 3.8.4.3 SR 3.8.4.6 PALO VERDE UNITS 1,2,3 3.8.5-2 AMENDMENT NO. 4-1-;

Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown LCO 3.8.8 Required inverter(s) shall be OPERABLE to support the onsite Class HE AC vital instrument bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS


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

In MODES 1, 2, 3, and 4, Required Action A.2.3-2 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately inverters inoperable, required feature(s) inoperable.

OR A.2. 1 S.p.d..... lneiarte4

,AITERATTNS.

AND A-.-2. Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.42 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

PALO VERDE UNITS 1.2,3 3.8.8-1 AMENDMENT NO. 4-14

Inverters - Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.43 Initiate action to Immediately restore required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage, frequency, 7 days and alignments to required AC vital instrument buses.

PALO VERDE UNITS 1,2,3 3.8.8-2 AMENDMENT NO. 4-1;

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of AC, DC, and AC vital instrument bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS


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

In MODES 1, 2, 3, and 4, Required Action A.2.4-2 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare associated Immediately AC, DC, or AC vital supported required instrument bus feature(s) electrical power inoperable.

distribution subsystems inoperable. OR A.2.1 Suspend G94

,ALT ER,A,TI!ON~S. lmmed a-ten AN4 A.2.2 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.32 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

PALO VERDE UNITS 1,2,3 3.8.10-1 AMENDMENT NO. 444

Distribution Systems - Shutdown 3.8.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.43 Initiate actions to Immediately restore required AC, DC, and AC vital instrument bus electrical power distribution subsystems to OPERABLE status.

AND A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and 7 days voltage to required AC, DC, and AC vital instrument bus electrical power distribution subsystems.

PALO VERDE UNITS 1,2,3 3.8.10-2 AMENDMENT NO. 4-1; 1

Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System and the refueling canal shall be maintained within the limit specified in the COLR.

APPLICABILITY: MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A Boron concentration A.1 s. l an-r not within limit. ALTERATINS-.

AND A*2 Suspend positive Immediately reactivity additions.

AND A.32 Initiate action to Immediately restore boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Verify boron concentration is within the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> limit specified in the COLR.

PALO VERDE UNITS 1,2,3 3.9.1-1 AMENDMENT NO. 4-14

Nuclear Instrumentation 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Nuclear Instrumentation LCO 3.9.2 Two startup range monitors (SRMs) shall be OPERABLE.

APPLICABILITY: MODE 6.

ACTIONS


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

Enter applicable Conditions and Required Actions of LCO 3.3.12, "Boron Dilution Alarm System (BDAS)" for BDAS made inoperable by SRMs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required SRM A.1 su.p...9 lnmedi-ate!4.y inoperable. ALTERAT!4SN--.

AND A.2 Suspend positive Immediately reactivity additions.

B. Two required SRMs B.1 Initiate action to Immediately inoperable, restore one SRM to OPERABLE status.

PALO VERDE UNITS 1,2,3 3.9.2-1 AMENDMENT NO. 44-ý -1,39

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch closed and held in place by four bolts, or if open, capable of being closed:
b. One door in each air lock is capable of being closed; and
c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:
1. closed by a manual or automatic isolation valve, blind flange, or equivalent, or
2. capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System.

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

Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls.

APPLICABILITY: Dri-g CORE AI TDEATITJS, During movement of irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 HSPed rr 1mm4edi at-Cy containment ELTERAT ONS-.

penetrations not in required status. AND A.2 -Suspend movement of Immediately irradiated fuel assemblies within containment.

PALO VERDE UNITS 1,2,3 3.9.3-1 AMENDMENT NO. .4 4.44

Enclosure Evaluation of the Proposed Change ATTACHMENT 2 Retyped Technical Specification Pages Pages:

1.1-3 3.3.8-1 3.3.8-2 3.3.9-2 3.7.11-2 3.7.12-2 3.8.2-1 3.8.2-2 3.8.5-1 3.8.5-2 3.8.8-1 3.8.8-2 3.8.10-1 3.8.10-2 3.9.1-1 3.9.2-1 3.9.3-1

Defi ni ti ons 1.1 1.1 Definitions (continued)

CORE OPERATING LIMITS The COLR is the unit specific document that REPORT (COLR) provides cycle specific parameter limits for the current reload cycle. These cycle specific parameter limits shall be determined for each reload cycle in accordance with Specification 5.6.5. Plant operation within these limits is addressed in individual Specifications.

DOSE EQUIVALENT 1-131 DOSE EQUIVALENT 1-131 shall be that concentration of 1-131 (microcuries/gram) that alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134, and 1-135 actually present. The thyroid dose conversion factors used for this calculation shall be those listed in ICRP 30, Supplement to Part 1, page 192-212, Table titled, "Committed Dose Equivalent in Target Organs or Tissues per Intake of Unit Activity."

T - AVERAGE E shall be the average (weighted in proportion DISINTEGRATION ENERGY to the concentration of each radionuclide in the reactor coolant at the time of sampling) of the sum of the average beta and gamma energies per disintegration (in MeV) for isotopes, other than iodines, with half lives > 15 minutes, making up at least 95% of the total noniodine activity in the coolant.

(continued)

PALO VERDE UNITS 1,2,3 1.1-3 AMENDMENT NO. 44-ý,

CPIAS 3.3.8 3.3 INSTRUMENTATION 3.3.8 Containment Purge Isolation Actuation Signal (CPIAS)

LCO 3.3.8 One CPIAS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, During movement of irradiated fuel assemblies within containment.

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

Only required when the penetration is not isolated by at least one closed automatic valve, closed manual valve, or blind flange.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CPIAS Manual Trip, A.1 Place and maintain Immediately Actuation Logic, or containment purge and radiation monitor exhaust valves in inoperable in MODES 1, closed position.

2, 3, and 4.

B. Required Action and B.1 Enter applicable Immediately associated Completion Conditions and Time not met. Required Actions for affected valves of LCO 3.6.3 "Containment Isolation Valves" made inoperable by CPIAS instrumentation.

(continued)

PALO VERDE UNITS 1,2,3 3.3.8-1 AMENDMENT NO. 44-ý,

CPIAS 3.3.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. CPIAS Manual Trip, C.1 Place and maintain Immediately Actuation Logic, or containment purge and radiation monitor exhaust valves in inoperable during closed position.

movement of irradiated fuel assemblies within OR containment.

C.2 Suspend movement of Immediately irradiated fuel assemblies in containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform a CHANNEL CHECK on required In accordance radiation monitor channel, with the Surveillance Frequency Control Program SR 3.3.8.2 Perform a CHANNEL FUNCTIONAL TEST on each In accordance required radiation monitor channel, and with the Verify the setpoint

Surveillance of Actuation Logic shall include the verification of the proper operation of each actuation relay.

Perform a CHANNEL FUNCTIONAL TEST on In accordance required CPIAS Actuation Logic channel. with the Surveillance Frequency Control Program (continued)

PALO VERDE UNITS 1,2,3 3.3.8-2 AMENDMENT NO. 4-99,

CREFAS 3.3.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. CREFAS Manual Trip, C.1 Place one CREFS train Immediately Actuation Logic, or in operation.

radiation monitor OR inoperable in MODE 5 or 6, or during movement of irradiated C.2.1 Suspend movement of Immediately fuel assemblies, irradiated fuel assemblies.

AND C.2.2 Suspend positive Immediately reactivity additions.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.9.1 Perform a CHANNEL CHECK on the required In accordance control room radiation monitor channel. with the Surveillance Frequency Control Program (continued)

PALO VERDE UNITS 1,2,3 3.3.9-2 AMENDMENT NO. 4-99,

CREFS 3.7.11 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 of Condition A or AND B not met in MODE 1, 2, 3, or 4. 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 /> D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREFS train in Time of Condition A not operation.

met in MODE 5 or 6.

E. Required Action and E.1 Place OPERABLE Immediately associated Completion CREFS Train in Time of Condition A not operation.

met during movement of OR irradiated fuel assemblies. E.2 Suspend movement of Immediately irradiated fuel assemblies.

F. Two CREFS trains F.1 Suspend movement of Immediately inoperable in MODE 5 or irradiated fuel 6, or during movement of assemblies.

irradiated fuel assemblies.

OR One or more CREFS trains inoperable due to inoperable CRE boundary in MODE 5 or 6, or during movement of irradiated fuel assemblies.

G. Two CREFS trains G.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4, for reasons other than Condition B.

(continued)

PALO VERDE UNITS 1,2,3 3.7.11-2 AMENDMENT NO. 4;4,

CREATCS 3.7.12 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Two CREATCS trains E.1 Suspend movement of Immediately inoperable in MODE 5 irradiated fuel or 6, or during assemblies.

movement of irradiated fuel assemblies.

F. Two CREATCS trains F.1 Enter LCO 3.0.3. Immediately inoperable in MODE 1, 2, 3, or 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 Verify each CREATCS train has the In accordance capability to remove the assumed heat load. with the Surveillance Frequency Control Program PALO VERDE UNITS 1,2,3 3.7.12-2 AMENDMENT NO. 4-99,

AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems Shutdown"; and
b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS


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

In MODES 1, 2, 3, and 4, Required Actions A.2.2 and B.2 are not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite ----------- NOTE----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected Immediately required feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend movement of Immediately irradiated fuel assemblies.

AND (continued)

PALO VERDE UNITS 1,2,3 3.8.2-1 AMENDMENT NO. 4-14,

AC Sources - Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.2 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND A.2.3 Initiate action to Immediately restore required offsite power circuit to OPERABLE status.

B. One required DG B.1 Suspend movement of Immediately inoperable, irradiated fuel assemblies.

AND B.2 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND B.3 Initiate action to Immediately restore required DG to OPERABLE status.

PALO VERDE UNITS 1,2,3 3.8.2-2 AMENDMENT NO.

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources - Shutdown LCO 3.8.5 DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS


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

In MODES 1, 2, 3, and 4, Required Action A.2.2 is not applicable.

I CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately DC electrical power required feature(s) subsystems (exclusive inoperable.

of the battery charger) inoperable. OR A.2.1 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.2 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

PALO VERDE UNITS 1,2,3 3.8.5-1 AMENDMENT NO. 44--ý,

DC Sources - Shutdown 3.8.5 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately restore required DC electrical power subsystems to OPERABLE status.

B. Required DC electrical B.1 Verify battery cell 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> power subsystem parameters meet Table battery charger 3.8.6-1 category A AND inoperable. limits.

Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> AND thereafter B.2 Restore DC electrical 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> power subsystem battery charger to OPERABLE status.

C. Required Action and C.1 Declare associated Immediately associated Completion battery inoperable.

Time of Condition B not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.5.1 ---------------- NOTE----------------

The following SRs are not required to be performed: SR 3.8.4.6, SR 3.8.4.7, and SR 3.8.4.8.

For DC sources required to be OPERABLE, the In accordance following SRs are applicable: with applicable SRs SR 3.8.4.1 SR 3.8.4.4 SR 3.8.4.7 SR 3.8.4.2 SR 3.8.4.5 SR 3.8.4.8.

SR 3.8.4.3 SR 3.8.4.6 PALO VERDE UNITS 1,2,3 3.8.5-2 AMENDMENT NO. 444,

Inverters - Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters - Shutdown LCO 3.8.8 Required inverter(s) shall be OPERABLE to support the onsite Class 1E AC vital instrument bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS


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

In MODES 1, 2. 3, and 4, Required Action A.2.2 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately inverters inoperable, required feature(s) inoperable.

OR A.2.1 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.2 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

PALO VERDE UNITS 1,2,3 3.8.8-1 AMENDMENT NO. 14-7,

Inverters - Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate action to Immediately restore required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage, frequency, In accordance and alignments to required AC vital with the instrument buses. Surveillance Frequency Control Program PALO VERDE UNITS 1,2,3 3.8.8-2 AMENDMENT NO. 4-99,

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of AC, DC, and AC vital instrument bus electrical power distribution subsystems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

ACTIONS


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

In MODES 1, 2, 3, and 4, Required Action A.2.2 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare associated Immediately AC, DC, or AC vital supported required instrument bus feature(s) electrical power inoperable.

distribution OR subsystems inoperable. i A.2.1 Suspend movement of Immediately irradiated fuel assemblies.

AND A.2.2 Initiate action to Immediately suspend operations involving positive reactivity additions.

AND (continued)

PALO VERDE UNITS 1,2,3 3.8.10-1 AMENDMENT NO. 44-ý,

Distribution Systems - Shutdown 3.8.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.3 Initiate actions to Immediately restore required AC, DC, and AC vital instrument bus electrical power distribution subsystems to OPERABLE status.

AND A.2.4 Declare associated Immediately required shutdown cooling subsystem(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and In accordance voltage to required AC, DC, and AC vital with the instrument bus electrical power Surveillance distribution subsystems. Frequency Control Program PALO VERDE UNITS 1,2,3 3.8.10-2 AMENDMENT NO. 4-99,

Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System and the refueling canal shall be maintained within the limit specified in the COLR.

APPLICABILITY: MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Boron concentration A.1 Suspend positive Immediately not within limit, reactivity additions.

AND A.2 Initiate action to Immediately restore boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Verify boron concentration is within the In accordance limit specified in the COLR. with the Surveillance Frequency Control Program PALO VERDE UNITS 1,2,3 3.9.1-1 AMENDMENT NO. 4799,

Nuclear Instrumentation 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Nuclear Instrumentation LCO 3.9.2 Two startup range monitors (SRMs) shall be OPERABLE.

APPLICABILITY: MODE 6.

ACTIONS


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

Enter applicable Conditions and Required Actions of LCO 3.3.12, "Boron Dilution Alarm System (BDAS)" for BDAS made inoperable by SRMs.

CONDITION REQUIRED ACTION COMPLETION TIME A. One required SRM A.1 Suspend positive Immediately inoperable, reactivity additions.

B. Two required SRMs B.1 Initiate action to Immediately inoperable, restore one SRM to OPERABLE status.

PALO VERDE UNITS 1,2,3 3.9.2-1 AMENDMENT NO. 449,

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch closed and held in place by four bolts, or if open, capable of being closed:
b. One door in each air lock is capable of being closed; and
c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere either:

P. closed by a manual or automatic isolation valve, blind flange, or equivalent, or

2. capable of being closed by an OPERABLE Containment Purge and Exhaust Isolation System.

NOTE -----

Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls.

APPLICABILITY: During movement of irradiated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend movement of Immediately containment irradiated fuel penetrations not in assemblies within required status, containment.

PALO VERDE UNITS 1,2,3 3.9.3-1 AMENDMENT NO. 444,

ATTACHMENT 3 Technical Specification Bases Page Markups (For Information Only)

Pages:

B3.3.8-3 B3.3.8-4 B3.3.8-5 B3.3.9-4 B3.7.11-7 B3.7.12-3 B3.8.2-4 B3.8.2-5 B3.8.5-3 B3.8.5-4 B3.8.5-5 B3.8.8-3 B3.8.8-4 B3.8.10-3 B3.8.10-4 B3.9.1-3 B3.9.1-4 B3.9.2-1 B3.9.2-2 B3.9.2-3 B3.9.3-1 B3.9.3-2 B3.9.3-3 B3.9.3-4 B3.9.3-5

CPIAS B 3.3.8 BASES LCO LCO 3.3.8 requires one CPIAS channel to be OPERABLE. The required channel consists of an area radiation monitor; Actuation Logic; and Manual Trip. The specific trip setpoints for the CPIAS are listed in the SRs.

Each trip setpoint specified is more conservative than the analytical limit assumed in the transient and accident analysis in order to account for instrument uncertainties appropriate to the trip function.

The Bases for the LCO on CPIAS are discussed below for each Function:

a. Manual Trip The LCO on Manual Trip backs up the automatic trip and ensures operators have the capability to rapidly initiate the CPIAS Function if any parameter is trending toward its setpoint. One manual channel of CPIAS is required in MODES 1, 2, 3, and 4, since the CPIAS is redundant with the CIAS and there are additional means of closing the containment purge valves. Only one manual channel of CPIAS is required during CORE ALTERATIONS and movement of irradiated fuel assemblies, since there are additional means of closing the containment purge valves in the event of a channel failure.
b. Power Access and Refueling Purge Exhaust Duct Radiation One channel of radiation monitoring is required during in MODES 1, 2, 3, and 4 or during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment.

(continued)

PALO VERDE UNITS 1,2,3 B 3.3.8-3 REVISION -9

CPIAS B 3.3.8 BASES LCO c. Actuation Logic (continued)

One channel of Actuation Logic is required since the valves can be shut independently of the CPIAS signal either manually from the control room or using the CIAS pushbutton.

APPLICABILITY In MODES 1, 2, 3, and 4, the power access purge valves may be open. In these MODES, it is necessary to ensure the valves will shut in the event of a primary leak in containment whenever any of the containment purge valves are open.

With the purge valves open during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, there is the possibility of a fuel handling accident requiring CPIAS on high radiation in the power access purge and refueling purge exhaust ducts.

The Applicability is modified by a Note, which states that the CPIAS specification is only required when the penetration is not isolated by at least one closed automatic valve, closed manual valve, or blind flange.

ACTIONS A CPIAS channel is inoperable when it does not satisfy the OPERABILITY criteria for the channel's function. The most common cause of channel inoperability is outright failure.

A.1 Condition A applies to the failure of CPIAS Manual Trip, Actuation Logic, and area radiation monitor in MODES 1, 2, 3, and 4. The Required Action is to place and maintain containment purge and exhaust valves in closed position.

The Completion Time accounts for the condition that the capability to isolate containment on valid high radiation levels in the power access and refueling purge exhaust ducts or manual signals is degraded during power operation or shutdown modes.

(continued)

I PALO VERDE UNITS 1,2,3 B 3.3.8-4 REVISION 4 1

CPIAS B 3.3.8 BASES ACTIONS B.1 (conti nued) Condition B applies when the Required Action and associated Completion Time of Condition A are not met in MODES 1, 2, 3, or 4. If Required Action A cannot be met within the required Completion Time, entry into LCO 3.6.3 "Containment Isolation Valves" is required. The Completion Time accounts for the fact that the inability to close and maintain the purge and exhaust valves closed may affect the ability of the valves to automatically close on a Containment Isolation Actuation Signal (CIAS)

C.1, and C.2.1. and C.22.

Condition C applies to two channels of radiation monitor, Manual Trip, or Actuation Logic inoperable, the applicability is during CORE ,ALTERATIONS or during the movement of irradiated fuel assemblies within containment.

Required Action C.1 is to place the containment purge and exhaust isolation valves in the closed position. The Required Action immediately performs the isolation function of the CPIAS. Required Actions C.2.1 and C.2.2 may be performed in lieu of Required Action C.1. Required Action C.2-4 reqir*es the.usp..sion of CORE AL-TERATIONS aRnd R.qured Action C.2,2 requires suspension of movement of irradiated fuel in containment immediately. The Completion Time accounts for the fact that the automatic capability to isolate containment on valid power access and refueling purge exhaust duct high radiation signals is degraded during conditions in which a fuel handling accident is possible and CPIAS provides the only automatic mitigation of radiation release.

(continued)

PALO VERDE UNITS 1,2,3 B 3.3.8-5 REVISION P4

CREFAS B 3.3.9 BASES ACTIONS A.1, B.1, B.2, C.1, C.2.1, and C.2.2, and C.2.4 (continued)

Conditions A, B, and C are applicable to manual and automatic actuation of the CREFAS. Condition A applies to the failure of two channels of the CREFAS Manual Trip, Actuation Logic, and -radiation monitor channel in MODE 1, 2, 3, or 4. Entry into this Condition requires action to either restore the failed channel or manually perform the CREFS safety function (Required Action A.1). The Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is sufficient to complete the Required Actions and accounts for the fact that CREFAS supplements control room filtration by other Functions (e.g., SIAS) in MODES 1, 2, 3, and 4. If Required Action A.1 and the associated completion time are not met, the plant must be brought to a MODE in which the LCO does 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 /> (Required Action B.1) and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (Required Action B.2). The Completion Times of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for reaching MODES 3 and 5 from MODE I are reasonable, based on operating experience and normal cooldown rates, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant safety systems or operators.

Condition C applies to the failure of two channels of CREFAS Manual Trip, Actuation Logic, and radiation monitor channel in MODE 5 or 6, or when moving irradiated fuel assemblies.

The Required Actions are immediately taken to place one OPERABLE CREFS train in the emergency mode of operation (i.e., fan running, valves/dampers aligned to the post -

CREFAS mode, etc.) or to suspend CORE ALTERATIONS, positive reactivity additions, and movement of irradiated fuel assemblies. The Completion Time recognizes the fact that FBEVAS, or CPIAS are available to initiate control room filtration in the event of a fuel handling accident.

(continued)

PALO VERDE UNITS 1,2,3 B 3.3.9-4 REVISION 4--

CREFS B 3.7.11 BASES ACTIONS E.1 and E.2 (continued)

An alternative to Required Action E.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

F. 1 4i4 F-a,,dF.2 If two CREFS trains become inoperable for reasons other than an inoperable CRE boundary or one or more CREFS trains become inoperable due to an inoperable CRE boundary, during Mode 5 or 6, or during the movement of irradiated fuel assemblies, immediate action must be taken to suspend activities that could release radioactivity that might enter the CRE. The Required Actions place the unit in a condition that minimizes accident risk. These actions do not preclude movement of fuel assemblies to safe positions.

G.1 If both CREFS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e.,

Condition B), the CREFS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system.

Monthly operations for Ž 15 minutes to demonstrate the function of the system is required. The 31 day Frequency is based on the known reliability of the equipment, and the two train redundancy available.

(continued)

PALO VERDE UNITS 1,2,3 B 3.7.11-7 REVISION 5I

CREATCS B 3.7.12 BASES (continued)

ACTIONS B.1 and B.2 (continued)

In MODE 1, 2, 3, or 4, when Required Action A.1 cannot be completed within the required Completion Time, the unit must be placed in a MODE that minimizes the accident risk. 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 full power conditions in an orderly manner and without challenging unit systems.

C.1 In MODE 5 or 6, if Required Action A.1 cannot be completed within the required Completion Time, the OPERABLE CREATCS train must be placed in operation immediately. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure will be readily detected.

D.1 and D.2 During movement of irradiated fuel assemblies, if Required Action A.1 cannot be completed within the Required Completion Time, the OPERABLE CREATCS train must be placed in operation immediately or movement of irradiated fuel assemblies must be suspended immediately. The first action ensures that the remaining train is OPERABLE, that no undetected failures preventing system operation will occur, and that any active failure will be readily detected. If the system is not immediately placed in operation, this action requires suspension of the movement of irradiated fuel assemblies in order to minimize the risk of a release of radioactivity that might require isolation of the control room. This does not preclude the movement of fuel to a safe position.

E.and - E.2 In MODE 5 or 6, or during movement of irradiated fuel assemblies with two CREATCS trains inoperable, action must be taken immediately to suspend activities that could result in a release of radioactivity that might require isolation of the control room. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

(continued)

PALO VERDE UNITS 1,2,3 B 3.7.12-3 REVISION --

AC Sources - Shutdown B 3.8.2 BASES APPLICABILITY b. Systems needed to mitigate a fuel handling accident (continued) are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available: and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Movement of spent fuel casks containing irradiated fuel assemblies is. not within the scope of the Applicability of this technical specification. The movement of dry casks containing irradiated fuel assemblies will be done with a single-failure-proof handling system and with transport equipment that would prevent any credible accident that could result in a release of radioactivity.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS The ACTIONS are modified by a Note that identifies required Actions A.2.3-2 and B.3-2 are not applicable to the movement of irradiated fu-el assemblies in Modes 1 through 4.

A.1 An offsite circuit would be considered inoperable if it were not available to one required ESF train. Although two trains may be required by LCO 3.8.10, the remaining train with offsite power available may be capable of supporting sufficient required features to allow continuation of GOR ALTERATIONS and fuel movement. By the allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

A.2.1, A.2.2, A.2.3, A.2.-, B.1, B.2, and B.3-,-4d4B4 .4 With the offsite circuit not available to all required trains, the option would still exist to declare all required (continued)

PALO VERDE UNITS 1,2,3 B 3.8.2-4 REVISION 24

AC Sources - Shutdown B 3.8.2 BASES ACTIONS A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, and B.3, --andW.4 (continued) sufficiently conservative actions is made. With the required DG inoperable, the minimum required diversity of AC power sources is not available. It is, therefore, required to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions. The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SDM is maintained.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations.

Therefore, inability to immediately suspend movement of

  • irradiated fuel assemblies would not be sufficient reason to require a reactor shutdown. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System's ACTIONS are not entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when Condition A is entered with no AC power to any required ESF bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.10 provides the appropriate restrictions for the situation involving a de-energized train.

(continued)

PALO VERDE UNITS 1,2,3 B 3.8.2-5 REVISION -41

DC Sources - Shutdown B 3.8.5 BASES LCO required to be OPERABLE by LCO 3.8.10, the necessary (continued) DC buses of that additional DC distribution subsystem train shall be energized by a minimum of its associated battery charger or backup battery charger. Should the minimum battery charger requirements not be maintained for that additional.DC distribution subsystem train required by LCO 3.8.10, then LCO 3.8.10 (Condition 'A') would be applicable and not LCO 3.8.5. This is because the requirements of LCO 3.8.5 would still be met (i.e. one OPERABLE DC electrical power subsystem maintained).

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that:

a. Required features needed to mitigate a fuel handling accident are available;
b. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
c. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Movement of spent fuel casks containing irradiated fuel assemblies is not within the scope of the Applicability of this technical specification. The movement of dry casks containing irradiated fuel assemblies will be done with a single-failure-proof handling system and with transport equipment that would prevent any credible accident that could result in a release of radioactivity.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

ACTIONS The Actions are modified by a Note that identifies required Action A.2.3-2 is not applicable to the movement of irradiated fue-T assemblies in Modes 1 through 4.

A.1, A.2.1, A.2.2, and A.2.3, and A.2.A4 If two 125 VDC trains' buses are required to be energized per LCO 3.8.10, of the two required trains, the remaining (continued)

PALO VERDE UNITS 1,2,3 B 3.8.5-3 REVISION -24 1

DC Sources - Shutdown B 3.8.5 BASES ACTIONS A.1, A.2.1, A.2.2, and A.2.3, and A.2.4 (continued) buses with DC power available may be capable of supporting sufficient systems to allow continuation of CORE ALTERATIONS aF4-fuel movement. By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. For example, assume that the

'A' train 125 VDC sources are required to be OPERABLE per LCO 3.8.5. Also assume that two SDC trains are required to be OPERABLE and the corresponding 125VDC trains' buses energized (i.e. PK system buses 'A' and 'C' for train 'A' and buses 'B' and 'D' for train 'B') per LCO 3.8.10. Finally, assume that an electrical fault occurs on the PK system channel 'C' bus and the bus has been declared INOPERABLE. The action of LCO 3.8.5 would allow declaring the corresponding SDC suction valve J-SIC-UV-653 INOPERABLE. However the SDC system itself would not necessarily need to be declared INOPERABLE and this would allow CORE ALTERAT!ONSfuel movement to continue.

However, in many instances, this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS. movement of irradiated fuel assemblies, and operations involving positive reactivity additions). The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory, provided the required SDM is maintained.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations.

Therefore, inability to immediately suspend movement of irradiated fuel assemblies would not be sufficient reason to require a reactor shutdown. These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystem and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystem should be completed as quickly as possible in order to (continued)

PALO VERDE UNITS 1,2,3 B 3.8.5-4 REVISION 24

DC Sources - Shutdown B 3.8.5 BASES ACTIONS A.1, A.2.1, A.2.2, and A.2.3, aRd A.2.4 (continued) minimize the time during which the unit safety systems may be without sufficient power.

Entry into Condition A is not required with one of the required (in-service) battery chargers inoperable. When one of the required (in-service) battery chargers is inoperable, Condition B is appropriate to enter. The loss of two required (in-service) battery chargers on the same train would be a degradation of the train beyond the scope of Condition B, thus rendering the train inoperable and requiring entry into Condition A.

B.1 and B.2 Condition B represents the loss of one of the required (in-service) battery chargers and assumes that action will be taken immediately to restore charging capability to the battery with the alternate charger (i.e., normal or backup).

Under normal plant load conditions, the loss of the battery charger for

  • 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> has a negligible effect on the rated battery capacity and does not impact the DC electrical power subsystem's capability to perform its DBA safety function.

Immediately following the loss of the charging capability, battery cell parameters may not meet Category A limits because these limits assume that the battery is being charged at a minimum float voltage. 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 for re-establishing charging capability such that Category A parameters can be met. Operation with the DC electrical power subsystem battery charger inoperable is not allowed for an indefinite period of time even when the battery cell parameters have been verified to meet the category A limits of Table 3.8.6-1. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time provides a period of time to correct the problem commensurate with the importance of maintaining the DC electrical power subsystem battery charger in an OPERABLE status.

The loss of the two required (in-service) battery chargers on the same train would be a degradation of the train beyond the scope of Condition B, thus rendering the train inoperable and requiring entry into Condition A.

(continued)

PALO VERDE UNITS 1,2,3 B 3.8.5-5 REVISION 2- 1

Inverters - Shutdown B 3.8.8 BASES LCO equipment are required to be OPERABLE by LCO 3.8.10, the (continued) necessary AC vital instrument bus(es) associated with the additional train of inverters shall be energized by either the bus(es)' associated inverter or AC voltage regulator.

For those situations where an AC vital instrument bus associated with the additional train of inverters is energized by its inverter, the corresponding DC bus must be energized by.a minimum of its associated battery charger or backup battery charger per LCO 3.8.5.

APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6, and during movement of irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;
b. Systems needed to mitigate a fuel handling accident are available;
c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and
d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Movement of spent fuel casks containing irradiated fuel assemblies is not within the scope of the Applicability of this technical specification. The movement of dry casks containing irradiated fuel assemblies will be done with a single-failure-proof handling system and with transport equipment that would prevent any credible accident that could result in a release of radioactivity.

Inverter requirements for MODES 1, 2, 3. and 4 are covered in LCO 3.8.7.

ACTIONS The Actions are modified by a Note that identifies required Action A.2.4-2 is not applicable to the movement of irradiated fue-T assemblies in Modes 1 through 4.

A.1, A.2.1, A.2.2, and A.2.3, and A.2.4 If two trains of AC vital instrument buses are required by LCO 3.8.10, "Distribution Systems - Shutdown," of the two required trains, the remaining bus(es) with AC power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel (continued)

PALO VERDE UNITS 1,2,3 B 3.8.8-3 REVISION 24 1

Inverters - Shutdown B 3.8.8 BASES ACTIONS A.1, A.2.1, A.2.2, and A.2.3, and A.2.4 (continued) movement, operations with a potential for draining the reactor vessel, and operations with a potential for positive reactivity additions. By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required Actions. In many instances, this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movementl of irradiated fuel assemblies, and operations involving positive reactivity additions). The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory, provided the required SDM is maintained.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations.

Therefore, inability to immediately suspend movement of irradiated fuel assemblies would not be sufficient reason to require a reactor shutdown. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverters and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without sufficient power.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital instrument buses energized from the inverter. The verification of proper voltage and frequency output ensures that the required power is readily available for the instrumentation connected to the AC vital instrument buses. The 7 day Frequency takes into account the redundant (continued)

PALO VERDE UNITS 1,2,3 B 3.8.8-4 REVISION 24 1

Distribution Systems - Shutdown B 3.8.10 BASES (continued)

ACTIONS The Actions are modified by a Note that identifies required Action A.2.3-2 is not applicable to the movement of irradiated fue-T assemblies in Modes 1 through 4.

A.1, A.2.1, A.2.2, A.2.3, and A.2.4. and A.2.5 Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution subsystem train may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected required features LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, movement of irradiated fuel assemblies, and operations involving positive reactivity additions).

The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory provided the required SDM is maintained.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations.

Therefore, inability to immediately suspend movement of irradiated fuel assemblies would not be sufficient reason to require a reactor shutdown. These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC, DC, and AC vital instrument bus electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

(continued)

PALO VERDE UNITS 1,2,3 B 3.8.10-3 REVISION 48

Distribution Systems - Shutdown B 3.8.10 BASES (continued)

ACTIONS A.1. A.2.1, A.2.2, A.2.3. and A.2.4 (continued)

Notwithstanding performance of the above conservative Required Actions, a required shutdown cooling (SDC) subsystem may be inoperable. In this case, Required Actions A.2.1 through A.2.34 do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the SDC ACTIONS would not be entered.

Therefore, Required Action A.2.4- is provided to direct declaring SDC inoperable, which-results in taking the appropriate SDC actions.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution subsystems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

SURVEILLANCE SR 3.8.10.1 REQUIREMENTS This Surveillance verifies that the AC, DC, and AC vital instrument bus electrical power distribution system is functioning properly, with all the required buses energized.

The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. The 7 day Frequency takes into account the redundant capability of the electrical power distribution subsystems, and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

PALO VERDE UNITS 1,2,3 B 3.8.10-4 REVISION 4 1

Boron Concentration B 3.9.1 BASES LCO The LCO requires that a minimum boron concentration be maintained in the RCS and the refueling canal to ensure a uniform boron concentration is maintained for reactivity control in the volumes having direct access to the reactor vessel while in MODE 6. The boron concentration limit specified in the COLR ensures a core keff of

  • 0.95 is maintained during fuel handling operations. Violation of the LCO could lead to an inadvertent criticality during MODE 6.

APPLICABILITY This LCO is applicable in MODE 6 to ensure that the fuel in the reactor vessel will remain subcritical. The required boron concentration ensures a keff

ACTIONS A.1-444dA.2 Continuation of CORE ALTERATIONS or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the unit in compliance with the LCO. If the boron concentration of any coolant volume in the RCS or the refueling canal is less than its limit, all operations involving CORE ALTERATIONS or positive reactivity additions must be suspended immediately.

Suspension of CORE ALTERATIONS and positive reactivity additions shall not preclude moving a component to a safe position.

A.42 In addition to immediately suspending CORE ALTERATIONS or positive reactivity additions, boration to restore the concentration must be initiated immediately.

(continued)

PALO VERDE UNITS 1,2,3 B 3.9.1-3 REVISION -0

Boron Concentration B 3.9.1 BASES ACTIONS A.4-2 (continued)

In determining the required combination of boration flow rate and concentration, there is no unique design basis event that must be satisfied. The only requirement is to restore the boron concentration to its required value as soon as possible at greater than or equal to 26 gpm of a solution containing greater than 4000 ppm boron. In order to raise the boron concentration as soon as possible, the operator should begin boration with the best source available for unit conditions.

Once boration is initiated, it must be continued until the boron concentration is restored. The restoration time depends on the amount of boron that must be injected to reach the required concentration.

SURVEILLANCE SR 3.9.1.1 REQUIREMENTS This SR ensures the coolant boron concentration in the RCS and the refueling canal is within the COLR limits. The boron concentration of the coolant in each volume is determined periodically by chemical analysis.

A minimum Frequency of once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is therefore a reasonable amount of time to verify the boron concentration of representative samples. The Frequency is based on operating experience, which has shown 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to be adequate.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 26.

2. UFSAR, Section 9.1.2.

PALO VERDE UNITS 1,2,3 B 3.9.1-4 REVISION 01

Nuclear Instrumentation B 3.9.2 B 3.9 REFUELING OPERATIONS B 3.9.2 Nuclear Instrumentation BASES BACKGROUND The Startup Channel Neutron Flux Monitors or Startup Range Monitors (SRMs) are used duHing core alterations or movement of irradiated fuel assemblies in containment to monitor the core reactivity condition. The installed SRMs are part of the Excore Nuclear Instrumentation System.

These detectors are located external to the reactor vessel and detect neutrons leaking from the core. The use of portable detectors is permitted, provided the LCO requirements are met.

The installed SRMs are BF3 detectors operating in the proportional region of the gas filled detector characteristic curve. The detectors monitor the neutron flux in counts per second. The instrument range covers five decades of neutron flux (1E+5 cps) with a 5% instrument accuracy. The detectors also provide continuous visual indication in the control room and an audible indication in the control room and containment. An audible BDAS alarm alerts operators to a possible dilution accident. The excore startup channels are designed in accordance with the criteria presented in Reference 1.

APPLICABLE Two OPERABLE SRMs and the associated BDAS are required to SAFETY ANALYSES provide a signal to alert the operator to unexpected changes in core reactivity from a boron dilution accident. The safety analysis of the uncontrolled boron dilution accident is described in Reference 2. The analysis of the uncontrolled boron dilution accident shows that normally available reactor subcriticality would be reduced, but there is sufficient time for the operator to take corrective actions.

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

LCO This LCO requires two SRMs OPERABLE to ensure that redundant monitoring capability is available to detect changes in core reactivity.

(continued)

PALO VERDE UNITS 1,2,3 B 3.9.2-1 REVISION 48

Nuclear Instrumentation B 3.9.2 BASES LCO (continued) The SRMs include detectors, preamps, amplifiers, power supplies, indicators, recorders, speakers, alarms, switches and other components necessary to complete the SRM functions. Specifically, each SRM must provide continuous visual indication in the Control Room and each SRM must have the capability to provide audible indication in both the Control Room and Containment via use of the Control Room switch.

APPLICABILITY In MODE 6, the SRMs must be OPERABLE to determine changes in core reactivity. There is no other direct means available to check core reactivity levels.

The requirements for the associated Boron Dilution Alarm System (BDAS) operability in MODE 6 are contained in LCO 3.3.12, "Boron Dilution Alarm System." LCO 3.3.12 also covers SRM and BDAS operability requirements for MODES 3, 4 and 5.

ACTIONS A.1_and__.

With only one SRM OPERABLE, redundancy has been lost. Since these instruments are the only direct means of monitoring core reactivity conditions, CORE ALTERATIONS and positive reactivity additions must be suspended immediately.

Performance of Required Action A.1 shall not preclude completion of movement of a component to a safe position.

With one required SRM channel inoperable, the associated BDAS is also inoperable. Action A.1 of LCO 3.3.12 requires the RCS boron concentration to be determined immediately and at the applicable monitoring frequency specified in the COLR Section 3.3.12 in order to satisfy the requirements of the inadvertent deboration safety analysis. The monitoring frequency specified in the COLR ensures that a decrease in the boron concentration during a boron dilution event will be detected with sufficient time for termination of the event before the reactor achieves criticality. The boron concentration measurement and the OPERABLE BDAS channel provide alternate methods of detection of boron dilution.

(continued)

PALO VERDE UNITS 1,2,3 B 3.9.2-2 REVISION -ý51

Nuclear Instrumentation B 3.9.2 BASES ACTIONS B.1 (continued)

With no SRM OPERABLE, action to restore a monitor to OPERABLE status shall be initiated immediately. Once initiated, action shall be continued until an SRM is restored to OPERABLE status.

With no SRM OPERABLE, there is no direct means of detecting changes in core reactivity. However, since C4R-ALTERATIONS and positive reactivity additions are not to be made, the core reactivity condition is stabilized until the SRMs are OPERABLE. This stabilized condition is verified by performing Action B.1 of LCO 3.3.12 which requires RCS boron concentration to be determined by redundant methods immediately and at the monitoring frequency specified in the COLR Section 3.3.12. This action satisfies the requirements of the inadvertent deboration safety analysis.

RCS boron concentration sampling by redundant methods ensures a boron dilution will be detected with sufficient time to terminate the event before the reactor achieves criticality.

SURVEILLANCE SR 3.9.2.1 REQUIREMENTS SR 3.9.2.1 is the performance of a CHANNEL CHECK, which is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that the two indication channels should be consistent with core conditions. Changes in fuel loading and core geometry can result in significant differences between source range channels, but each channel should be consistent with its local conditions.

The Frequency is based on operating experience that demonstrates the rarity of channel failure. Since the probability of two random failures in redundant channels in any 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period is extremely low, a CHANNEL CHECK minimizes the chance of loss of function due to failure of redundant channels.

(continued)

PALO VERDE UNITS 1,2,3 B 3.9.2-3 REVISION 4-5 1

Containment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of fue! assemblies within containment with irradiated fuel assemblies in containment, a release of fission product radioactivity within the containment will be restricted from escaping to the environment when the LCO requirements are met. In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LCO 3.6.1, "Containment." In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. The LCO requirements are referred to as "containment closure" rather than "containment OPERABILITY." Containment closure means that all potential escape paths are closed or capable of being closed.

Since there is no potential for containment pressurization, the Appendix J leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100. Additionally, the containment structure provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment. During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be capable of being closed and held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LCO be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 operation in accordance with LCO 3.6.2, "Containment Air Locks." Each air lock has doors at both ends.

The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of shutdown when containment (continued)

PALO VERDE UNITS 1,2,3 B 3.9.3-1 REVISION 18

Containment Penetrations B 3.9.3 BASES BACKGROUND closure is not required, the door interlock mechanism may be (continued) disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain capable of being closed.

The requirements on containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted to within regulatory limits.

The Containment Purge and Exhaust System includes two subsystems. The refueling purge subsystem includes a 42 inch supply penetration and a 42 inch exhaust penetration. The second subsystem, power access purge subsystem, includes an 8 inch supply penetration and an 8 inch exhaust penetration. During MODES 1, 2, 3, and 4, the two valves in each of the refueling purge supply and exhaust penetrations are secured in the closed position.

The two valves in each of the two power access purge penetrations can be opened intermittently, but are closed automatically by the Engineered Safety Features Actuation System (ESFAS). Neither of the subsystems is subject to a Specification in MODE 5.

In MODE 6, large air exchanges are necessary to conduct refueling operations. The refueling purge system is used for this purpose and the valves are closed by the ESFAS in accordance with LCO 3.3.8, "Containment Purge Isolation Actuation Signal (CPIAS)."

The Power Access Purge System remains operational in MODE 6 and the valves are also closed by the ESFAS.

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on at least one side. Isolation may be achieved by an OPERABLE automatic isolation valve, or by a manual isolation valve, blind flange, or equivalent.

(continued)

PALO VERDE UNITS 1,2,3 B 3.9.3-2 REVISION 4-91

Containment Penetrations B 3.9.3 BASES BACKGROUND Equivalent isolation methods must be approved and may (continued) include use of devices designed to allow eddy current testing and sludge lancing of the steam generators. Devices which present a substantial restriction to the release of containment atmosphere may be considered equivalent.

APPLICABLE During CORE ALTERATIONS or movement of irradiated fuel SAFETY ANALYSES assemblies within containment, the most severe radiological consequences result from a fuel handling accident. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 2). Fuel handling accidents, analyzed in Reference 2, include dropping a single irradiated fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.6, "Refueling Water Level-Fuel Assemblies," LCO 3.9.7, "Refueling Water Level-CEAs," and the minimum decay time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> prior to CORE ALTERAT!ONSmovement of irradiated fuel ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are well within the guideline values specified in 10 CFR 100. The acceptance limits for offsite radiation exposure are contained in Standard Review Plan Section 15.7.4, Rev. 1 (Ref. 3), which defines "well within" 10 CFR 100 to be 25% or less of the 10 CFR 100 values.

Containment penetrations satisfy Criterion 3 of 10 CFR 50.36 (c)(2)(ii).

LCO This LCO limits the consequences of a fuel handling accident in containment by limiting the potential escape paths for fission product radioactivity released within containment.

The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except for the OPERABLE containment purge supply exhaust penetrations, containment personnel airlocks, and equipment hatch. For the OPERABLE containment purge supply and exhaust penetrations, this LCO ensures that these penetrations are isolable by a valve in the Containment Purge Isolation System. The OPERABILITY requirements for this LCO ensure that the automatic purge valve closure times specified in the UFSAR can be achieved and therefore meet the assumptions used in the safety analysis to ensure releases through the valves are terminated, such that the radiological doses are within the acceptance limit. The (continued)

PALO VERDE UNITS 1,2,3 B 3.9.3-3 REVISION 21ý 1

Containment Penetrations B 3.9.3 BASES LCO equipment hatch is required to be kept free of obstructions (continued) that could impede its closure so it is capable of being closed with a minimum of four bolts should a fuel handling accident occur inside containment.

The containment personnel airlock doors may be open during movement of irradiated fuel in the containment and du4rig GO9E ALTERATIONS provided that one door is capable of being closed in the event of a fuel handling accident. Should a fuel handling accident occur inside containment, one personnel airlock door will be closed following an evacuation of containment.

The LCO is modified by a Note allowing penetration flow paths with direct access from the containment atmosphere to the outside atmosphere to be unisolated under administrative controls. Administrative controls ensure that 1) appropriate personnel are aware of the open status of the penetration flow path during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, and 2) specified individuals are designated and readily available to isolate the flow path in the event of a fuel handling accident.

APPLICABILITY The containment penetration requirements are applicable during CORE ALTERATIONS or movement of irradiated fuel assemblies within containment because this is when there is a potential for a fuel handling accident. In MODES 1, 2, 3, and 4, containment penetration requirements are addressed by LCO 3.6.1, "Containment." In MODES 5 and 6, when GGRI ALTERATIONS or movement of irradiated fuel assemblies within containment are not being conducted, the potential for a fuel handling accident does not exist. Therefore, under these conditions no requirements are placed on containment penetration status.

ACTIONS A.1 and A.2 With the containment equipment hatch, air locks, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere not in the required status, including the Containment Purge Isolation System not capable of automatic actuation when the purge (continued)

PALO VERDE UNITS 1,2,3 B 3.9.3-4 REVISION 479

Containment Penetrations B 3.9.3 BASES ACTIONS A.1 and A.2 (continued) valves are open, the unit must be placed in a condition in which the isolation function is not needed. This is accomplished by immediately suspending CORE ALTERATIONS and movement of irradiated fuel assemblies within containment.

Performance of these actions shall not preclude completion of movement of a component to a safe position.

SURVEILLANCE SR 3.9.3.1 REQUIREMENTS This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open purge and exhaust valves will demonstrate that the valves are not blocked from closing. Also, the Surveillance will demonstrate that each valve operator has motive power, which will ensure each valve is capable of being closed by an OPERABLE automatic containment purge isolation signal.

The Surveillance is performed every 7 days during G R ALTERATIONS or movement of irradiated fuel assemblies withini the containment. The Surveillance interval is selected to be commensurate with the normal duration of time to complete fuel handling operations. A surveillance before the start of refueling operations will provide two or three surveillance verifications during the applicable period for this LCO. As such, this Surveillance ensures that a postulated fuel handling accident that releases fission product radioactivity within the containment will not result in a release of fission product radioactivity to the environment in excess of those recommended by Standard Review Plan Section 15.7.4 (Reference 3).

SR 3.9.3.2 This Surveillance demonstrates that each containment purge valve actuates to its isolation position on manual initiation or on an actual or simulated high radiation signal. The 18 month Frequency maintains consistency with other similar ESFAS instrumentation and valve testing requirements. The CPIAS is tested in accordance with LCO 3.3.8, "Containment Purge Isolation Actuation Signal (CPIAS)." SR 3.6.3.5 demonstrates that the isolation time of each valve is in accordance with the Inservice Testing (continued)

PALO VERDE UNITS 1,2,3 B 3.9.3-5 REVISION 4-.1