ML13280A264

Request to Amend Technical Specification 3.3.3, Control Element Assembly Calculators and TS 3.3.6, Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip

ML13280A264
Person / Time
Site:	Palo Verde
Issue date:	09/27/2013
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06775-DCM/RKR/JR
Download: ML13280A264 (17)

Text

10 CFR 50.90 Qaps DWIGHT C. MIMS Senior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 102-06775DCM/RKR/JR Tel 623 393 5403 September 27, 2013 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Request to Amend Technical Specification (TS) 3.3.3, Control Element Assembly Calculators(CEACs) and TS 3.3.6, EngineeredSafety FeaturesActuation System (ESFAS) Logic and Manual Trip As permitted by 10 CFR 50.90, Arizona Public Service Company (APS) hereby requests to amend Operating License Nos. NPF-41, NPF-51, and NPF-74, by amending the Technical Specifications (TS) that are incorporated as Appendix A to the Operating Licenses for PVNGS Units 1, 2, and 3. As detailed further in the enclosure to this letter, the proposed amendment will reinstate an inadvertently omitted 4-hour completion time within TS 3.3.3, CEACs, and revise a test frequency note within a Surveillance Requirement under TS 3.3.6, ESFAS Logic and Manual Trip.

The enclosure to this letter provides a detailed description of, and basis for, the proposed TS amendment, as well as technical and regulatory evaluations of the amendment. The enclosure includes the basis for a determination that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c). Proposed TS page markups and retyped TS pages are included as Attachments 1 and 2, respectively, to the enclosure of this letter. No TS Bases changes are necessary to support these TS changes.

As discussed further in the enclosure, the amendment proposed herein is to:

• Reinstate a 4-hour completion time that was inadvertently omitted in a 2003 APS submittal to the NRC which requested an amendment to TS 3.3.3.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Oo Callaway.Comanche Peak.Diablo Canyon.Palo Verde.San Onofre.South Texas.Wolf Creek

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Request to Amend Technical Specifications 3.3.3 and 3.3.6 Page 2 Revise a note within a Surveillance Requirement in TS 3.3.6 to refer to the Surveillance Frequency Control Program for the frequency of the specific testing being performed. This change should have been addressed in the license amendment request for TSTF-425, Relocate Surveillance Frequenciesto Licensee Control - Risk-Informed Technical Specification Task Force (RITSTF) Initiative 5b.

Approval of the proposed amendment is requested by July 31, 2014 to support implementation prior to the Fall 2014 Unit 1 Outage. Once approved, the amendment shall be implemented within 60 days.

In accordance with the PVNGS Quality Assurance Program, the Plant Review Board and the Offsite Safety Review Committee have reviewed and concurred with this proposed amendment. By copy of this letter, this submittal is being forwarded to the Arizona Radiation Regulatory Agency (ARRA) pursuant to 10 CFR 50.91(b)(1).

No commitments are being made by this letter. Should you need further information regarding this submittal, please contact Robert K. Roehler, Licensing Section Leader, at (623) 393-5241.

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

Executed on *-A7*'- 64 .?Y l (Date)

Sincerel DCM/RKR/JR

Enclosure:

Evaluation of the Proposed Change - Amendment to Technical Specifications 3.3.3 and 3.3.6 cc: S. A. Reynolds NRC Region IV Regional Administrator J. K. Rankin NRC NRR Project Manager for PVNGS (electronic and hard copy)

J. P. Reynoso NRC Senior Resident Inspector for PVNGS A. V. Godwin ARRA T. Morales ARRA

ENCLOSURE Evaluation of the Proposed Change Amendment to Technical Specifications 3.3.3 and 3.3.6

ENCLOSURE Evaluation of the Proposed Change

Subject:

Request to Amend Technical Specification (TS) 3.3.3, Control Element Assembly Calculators(CEACs) and TS 3.3.6, EngineeredSafety FeaturesActuation System (ESFAS) Logic and Manual Trip

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 Description of the Proposed Changes 2.2 Basis for Requesting the Proposed Changes

3. TECHNICAL EVALUATION 3.1 Description/Justification 3.2 Conclusion

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Commitments

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. Technical Specification Markup

2. Retyped Technical Specification I of 8

Enclosure Evaluation of the Proposed Change Amendment to TS 3.3.3 and 3.3.6

1.

SUMMARY

DESCRIPTION This evaluation supports an Arizona Public Service Company (APS) request to amend Operating License Nos. NPF-41, NPF-51, and NPF-74 for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3, respectively. The license amendment is requested specifically to amend the Technical Specifications (TS) that are incorporated as Appendix A to the Operating Licenses for PVNGS 1, 2, and 3. The proposed amendment will reinstate an inadvertently omitted 4-hour completion time within TS 3.3.3, Control Element Assembly Calculators (CEACs), and revise a test frequency note within a Surveillance Requirement (SR) under TS 3.3.6, Engineered Safety FeaturesActuation System (ESFAS) Logic and Manual Trip.

2. DETAILED DESCRIPTION 2.1 Description of the Proposed Changes The proposed amendment contains two separate changes. The first change will reinstate an inadvertently omitted 4-hour completion time within TS 3.3.3, CEACS. The second change will revise a test frequency note within an SR under TS 3.3.6, ESFAS Logic and Manual Trip. The specific changes to the PVNGS TS for Units 1, 2, and 3 are indicated in the proposed TS page markups and retyped TS pages that are included as Attachments 1 and 2, respectively, to this enclosure.

2.2 Basis for Requesting the Proposed Changes The first change within this APS proposed amendment to the PVNGS TS will reinstate a 4-hour Completion Time to TS 3.3.3, Required Action B.2.2. APS letter number 102-04999 to the NRC (Ref. 6.1) requested an amendment to TS 3.3.3 with the completion time inadvertently omitted. As a result, the completion time was not included in License Amendment No. 152 (Ref 6.2) issued to APS.

The second change within this APS proposed amendment will revise a test frequency note within an SR under TS 3.3.6, ESFAS Logic and Manual Trip.

The NRC issued License Amendment No. 188 (Ref 6.3) to APS in response to APS request for the adoption of Technical Specification Task Force Traveler (TSTF) 425 (Ref 6.4), which relocated periodic surveillance frequencies to a licensee controlled program. The APS request overlooked a note within the TS SR 3.3.6.2 that designates a relay testing frequency of 18 months. The APS proposed amendment to the PVNGS TS will revise this note to test the relays in accordance with the Surveillance Frequency Control Program (SFCP) consistent with the intent of TSTF-425 (Ref 6.4). Both of these changes are considered to be administrative changes.

2 of 8

Enclosure Evaluation of the Proposed Change Amendment to TS 3.3.3 and 3.3.6

3. TECHNICAL EVALUATION 3.1 Description/Justification The proposed changes to the TSs are administrative and do not affect how plant equipment is operated or maintained. No changes to the physical plant or analytical methods are proposed and there are no impacts to the PVNGS Updated Final Safety Analysis Report (UFSAR) accident analysis.

Proposed Administrative Changes Proposed Justification Technical Change Specification Sections Reinstate a Correct an administrative error in a 2003 3.3.3 4-hour APS license amendment request to the completion NRC (Ref 6.1) which inadvertently omitted time. a 4-hour completion time in TS 3.3.3, Required Action B.2.2. This change restores the 4-hour completion time that existed prior to being inadvertently omitted.

Revise a note This change should have been addressed 3.3.6 within a in the license amendment request for Surveillance TSTF-425, Relocate Surveillance Requirement Frequenciesto Licensee Control - RITSTF to refer to the Initiative 5b. Surveillance frequencies SFCP for the should have been relocated except frequency of frequencies that:

the specific

• Reference other approved programs testing being for the specific interval (such as the performed. In-Service Testing Program);

• Are purely event-driven;

" Are event-driven, but have a time component for performing the surveillance on a one-time basis once the event occurs;

" Are related to specific conditions (e.g., battery degradation, age and capacity) or conditions for the performance of a surveillance requirement (e.g., "drywell to suppression chamber differential pressure decrease").

APS reviewed the change to the note in this surveillance in accordance with the SFCP and concluded that PVNGS 3 of 8

Enclosure Evaluation of the Proposed Change Amendment to TS 3.3.3 and 3.3.6 Proposed Justification Technical Change Specification Sections continued to meet the regulatory requirement of 10 CFR 50.36 and, specifically, 10 CFR 50.36(c)(3),

surveillance requirements (Ref 6.3).

APS has entered the errors in the corrective action program and implemented administrative controls to ensure the 4-hour completion time is enforced in the intervening period until the approved license amendment is received.

The proposed changes do not adversely impact plant safety. The change to reinstate the 4-hour completion time in TS 3.3.3 is consistent with the intent of the 2003 license amendment request (Ref 6.1) and corrects an error of omission. The change to revise the note within surveillance requirement 3.3.6.2 is consistent with the criteria for relocation of surveillance frequencies specified in TSTF-425 (Ref 6.4). The proposed changes do not affect the types or amounts of any effluents or increase radiation exposure.

3.2 Conclusion Based on the above descriptions, APS concludes that the proposed changes are acceptable and operation in the proposed manner will not present undue risk to public health and safety or be adverse to the common defense and security.

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria APS has determined that the proposed amendment does not require any exemptions or relief from regulatory requirements, other than the TS, and does not affect conformance with any General Design Criteria differently than described in the PVNGS UFSAR.

4.1.1 Regulations 10 CFR 50.36(c), "Technical specifications," describes Limiting conditions for operation and Surveillance requirements as follows:

(i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any 4 of 8

Enclosure Evaluation of the Proposed Change Amendment to TS 3.3.3 and 3.3.6 remedial action permitted by the technical specifications until the condition can be met.

(iii)(3) Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

The proposed amendment has no impact on the continued conformance with the requirements of 10 CFR 50.36.

10 CFR 50.90, "Application for amendment of license or construction permit,"

addresses the requirements for a licensee desiring to amend its license and the TS incorporated therein. This request for amendment to PVNGS TS 3.3.3 and 3.3.6 has been prepared to meet the requirements of 10 CFR 50.90.

4.2 Precedent The NRC issued License Amendment No. 188 (Ref 6.3) to APS in response to the APS request for the adoption of TSTF-425 (Ref 6.4), which relocated periodic surveillance frequencies to a licensee controlled program. The note within TS SR 3.3.6.2, which specifies an 18 month relay test interval, should have been addressed in the license amendment request for TSTF-425 (Ref 6.4) to refer to the SFCP for the relay test interval.

4.3 No Significant Hazards Consideration Determination The proposed amendment includes the following changes that are considered to be administrative changes:

• The first change will reinstate an inadvertently omitted 4-hour completion time within TS 3.3.3, Control Element Assembly Calculators (CEACS).

" The second change will revise a test frequency note within an SR under TS 3.3.6, Engineered Safety FeaturesActuation System (ESFAS)

Logic and Manual Trip.

Arizona Public Service Company (APS) has determined that the proposed TS amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c). This determination is based on an evaluation with respect to the specific criteria of 10 CFR 50.92(c) as follows:

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

5 of 8

Enclosure Evaluation of the Proposed Change Amendment to TS 3.3.3 and 3.3.6 Response: No.

" The reinstatement of the 4-hour completion time within TS 3.3.3 does not alter existing controls on plant operation (i.e., safety limit values, LCOs, Surveillance Requirements or Design Features). Functions which are necessary to operate the facility safely and in accordance with the operating licenses remain in effect. The proposed change will not affect the operation of structures, systems, or components, and will not reduce programmatic controls such that the plant safety would be affected.

• The revision to the SR testing frequency note under TS 3.3.6 relocates the specified frequency to licensee control under the Surveillance Frequency Control Program (SFCP). Surveillance frequencies are not an initiator to any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The systems and components required by the technical specifications for which this frequency is being relocated are still required to be operable, meet the acceptance criteria for the surveillance requirement, and be capable of performing any mitigation function assumed in the accident analysis.

Based on the above, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

" The reinstatement of the 4-hour completion time within TS 3.3.3 is an administrative correction. It will not affect the operation of structures, systems, or components, and will not reduce programmatic controls such that plant safety would be affected.

• No new or different accidents result from the revision to the SR testing frequency note under TS 3.3.6. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, this change does not impose any new or different requirements.

This change does not alter assumptions made in the safety analysis. This change is consistent with the safety analysis assumptions and current plant operating practice.

6 of 8

Enclosure Evaluation of the Proposed Change Amendment to TS 3.3.3 and 3.3.6 Based on the above, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

• The reinstatement of the 4-hour completion time within TS 3.3.3 is administrative and will not diminish any administrative controls currently in place. The proposed change will not affect the operation of structures, systems, or components, and will not reduce programmatic controls such that plant safety would be affected.

• The design, operation, testing methods, and acceptance criteria for systems, structures, and components (SSCs), specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the plant licensing basis (including the Updated Final Safety Analysis Report and Bases to the TS), since these are not affected by the proposed change which will revise the SR testing frequency note under TS 3.3.6. Similarly, there is no impact to safety analysis acceptance criteria as described in the plant licensing basis.

Based on the above, the proposed amendment does not involve a significant reduction in the margin of safety.

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 Commitments There are no commitments being made by this license amendment request.

The license amendment statements provide information to support NRC action and are not considered to be regulatory commitments. Once the license amendment is approved, APS plans to implement the amendment within 60 days.

5. ENVIRONMENTAL CONSIDERATION A review has determined that the proposed amendment would change an inspection or surveillance requirement. However, as established above, the proposed amendment does not involve (i) a significant hazards consideration, 7 of 8

Enclosure Evaluation of the Proposed Change Amendment to TS 3.3.3 and 3.3.6 (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 of 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.

6. REFERENCES 6.1 APS letter number 102-04999 to the NRC [Agencywide Documents Access and Management System (ADAMS) Accession Number ML032670629], dated September 17, 2003 6.2 License Amendment No. 152 (ADAMS Accession Numbers ML040860573 and ML040850316), dated March 23, 2004 6.3 License Amendment No. 188 (ADAMS Accession Number ML112620293), dated December 15, 2011 6.4 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler TSTF-425-A, Revision 3 (ADAMS Accession Number ML090850642), dated March 18, 2009 8 of 8

ENCLOSURE, ATTACHMENT 1 Technical Specification Markup Page:

3.3.3-2 3.3.6-3

CEACs 3.3.3 ACTIONS (continued)

CONDITION ] REQUIRED ACTION 1COMPLETION TIME B (continued) B.2.1 Verify the departure 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from nucleate boiling ratio requirement of LCO 3.2.4, "Departure from Nucleate Boiling Ratio (DNBR)." is met.

AND B.2.2 Verify all full 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> strength and part strength control element assembly (CEA) groups are fully withdrawn and maintained fully withdrawn, except during Surveillance testing pursuant to SR 3.1.5.3 or for control, when CEA group #5 may be inserted to a maximum of 127.5 inches withdrawn.

AND B.2.3 Verify the "RSPT/CEAC 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Inoperable" addressable constant in each affected core protection calculator (CPC) is set to indicate that both CEACs are inoperable.

AND (continued)

PALO VERDE UNITS 1.2,3 3.3.3-2 AMENDMENT NO. 1-521,9- I

ESFAS Logic and Manual Trip 3.3.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and F.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 AND Time of Conditions for Safety Injection Actuation Signal. F.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 /> Containment Isolation Actuation Signal, or Reci rcul ation Actuation Signal not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.6.1 ----------------- NOTE----------------

Testing of Actuation Logic shall include the verification of the proper operation of each initiation relay.

Perform a CHANNEL FUNCTIONAL TEST on each In accordance ESFAS logic channel and Manual Trip with the channel. Surveillance Frequency Control Program SR 3.3.6.2 ----------------- NOTE---------------

Relays exempt from testing during operation shall be tested eaeh 18 mcnths.in accordance with the Surveillance Frequency Control Program.

Perform a subgroup relay test of each In accordance Actuation Logic channel, which includes the with the de-energization of each subgroup relay and Surveillance verification of the OPERABILITY of each Frequency subgroup relay. Control Program PALO VERDE UNITS 1,2.3 3.3.6-3 AMENDMENT NO. 4-4-7-,-i ENCLOSURE, ATTACHMENT 2 Retyped Technical Specification Page:

3.3.3-2 3.3.6-3

CEACs 3.3.3 ACTIONS (continued)

CONDITION R REQUIRED ACTION COMPLETION TIME B (continued) B.2.1 Verify the departure 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from nucleate boiling ratio requirement of LCO 3.2.4. "Departure from Nucleate Boiling Ratio (DNBR)." is met.

AND B.2.2 Verify all full 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> strength and part strength control element assembly (CEA) groups are fully withdrawn and maintained fully withdrawn, except during Surveillance testing pursuant to SR 3.1.5.3 or for control, when CEA group #5 may be inserted to a maximum of 127.5 inches withdrawn.

AND B.2.3 Verify the "RSPT/CEAC 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Inoperable" addressable constant in each affected core protection calculator (CPC) is set to indicate that both CEACs are inoperable.

AND (continued)

PALO VERDE UNITS 1.2.3 3.3.3-2 AMENDMENT NO. 17-9.

ESFAS Logic and Manual Trip 3.3.6 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and F.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 AND Time of Conditions for Safety Injection Actuation Signal, F.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 /> Containment Isolation Actuation Signal, or Recirculation Actuation Signal not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.6.1 ----------------- NOTE----------------

Testing of Actuation Logic shall include the verification of the proper operation of each initiation relay.

Perform a CHANNEL FUNCTIONAL TEST on each In accordance ESFAS logic channel and Manual Trip with the channel. Surveillance Frequency Control Program SR 3.3.6.2 -----------------NOTE---------------

Relays exempt from testing during operation shall be tested in accordance with the Surveillance Frequency Control Program.

Perform a subgroup relay test of each In accordance Actuation Logic channel, which includes the with the de-energization of each subgroup relay and Surveillance verification of the OPERABILITY of each Frequency subgroup relay. Control Program PALO VERDE UNITS 1,2.3 3.3.6-3 AMENDMENT NO. 4-89,