Letter Sequence Response to RAI |
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TAC:MF3143, Predicting END-OF-CYCLE Mtc and Deleting Need for END-OF-CYCLE Mtc Verifiation (NPSD-911-A), Revise Mtc Surveillance for Startup Test Activity Reduction (STAR) Program (WCAP-16011) (Approved, Closed) |
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MONTHYEARML13329A0382013-08-31031 August 2013
WCAP-17787-NP, Rev 0, Palo Verde Nuclear Generating Station STAR Program Implementation Report.
Project stage: Request
ML13365A2072013-09-25025 September 2013
Westinghouse Application for Withholding Proprietary Information from Public Disclosure for WCAP-17787-P
Project stage: Request
ML13329A7002013-11-20020 November 2013
Transmittal of Proprietary Documents for Startup Test Activity Reduction (STAR) Program License Amendment Request
Project stage: Request
ML13357A2492013-12-20020 December 2013
NRR E-mail Capture - Acceptance Review of Palo Verde Amendment Request Regarding Startup Test Activity Reduction (STAR) Program
Project stage: Acceptance Review
ML14027A7012014-01-16016 January 2014
Transmittal of Updated Affidavit from Westinghouse for Proprietary Document for Startup Test Activity Reduction (STAR) Program License Amendment Request (LAR)
Project stage: Request
ML14006A2242014-01-24024 January 2014
Request for Proprietary Withholding of Information - 9/25/13 Affidavit Executed by J. Gresham, Westinghouse WCAP-17787
Project stage: Other
ML14042A1822014-02-27027 February 2014
Request for Withholding Information from Public Disclosure - 1/10/14 Affidavit Executed by J. Gresham, Westinghouse WCAP-16011-P-A, Revision 0
Project stage: Withholding Request Acceptance
ML15005A0282014-12-19019 December 2014
Response to Request for Additional Information Regarding Application for Technical Specification Change Regarding Moderator Temperature Coefficient Surveillance for Startup Test Activity Reduction Program
Project stage: Response to RAI
ML15070A1242015-03-30030 March 2015
Issuance of Amendment Nos. 195, 195, and 195, Adopt TSTF-486, Revision 2, Revise Mtc Surveillance for Startup Test Activity Reduction (STAR) Program (WCAP-16011) and TSTF-406, Revision 2
Project stage: Approval
2014-01-16
[Table View] |
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Category:Letter
MONTHYEARML24019A2012024-01-19019 January 2024
Fourth 10-Year Interval, Second Period Owners Activity Report Number 1R24
ML24019A1362024-01-18018 January 2024
Inservice Inspection Request for Information
ML24012A2452024-01-12012 January 2024
Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line
ML24010A1532024-01-10010 January 2024
Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection
ML23341A0062023-12-21021 December 2023
Project Manager Assignment
IR 05000528/20230112023-12-18018 December 2023
License Renewal Inspection Report 05000528/2023011
ML23335A0782023-11-30030 November 2023
Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation
ML23325A1602023-11-17017 November 2023
Supplemental Submittal - Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle
IR 05000528/20234032023-11-13013 November 2023
NRC Security Inspection Report 05000528 2023403, 05000529 2023403, 05000530 2023403 (Full Report)
ML23311A2082023-11-0909 November 2023
Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV
ML23299A3052023-10-26026 October 2023
Response to Request for Additional Information Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle
IR 05000528/20230032023-10-17017 October 2023
Integrated Inspection Report 05000528 2023003 and 05000529 2023003 and 05000530 2023003
ML23270B9232023-09-28028 September 2023
Notification of Age-Related Degradation Inspection (05000528/2024012, 05000529/2024012, and 05000530/2024012) and Request for Information
ML23251A2332023-09-13013 September 2023
Notification of Post Approval Site Inspection for License Renewal and Request for Information Inspection (05000528/2023011)
ML23241B0182023-09-13013 September 2023
Use of Honeywell Mururoa V4F1 and MTH2 Supplied Air Suits within Respiratory Protection Program
IR 05000528/20243012023-09-0606 September 2023
Notification of NRC Initial Operator Licensing Examination 05000528/2024301; 05000529/2024301; 05000530/2024301
IR 05000528/20230102023-08-22022 August 2023
Biennial Problem Identification and Resolution Inspection Report 05000528/2023010, 05000529/2023010 and 05000530/2023010
IR 05000528/20230052023-08-21021 August 2023
Updated Inspection Plan for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Report 05000528/2023005 and 05000529/2023005 and 05000530/2023005)
ML23222A2762023-08-10010 August 2023
Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Transportable Storage Canister Identification Numbers AMZDFX175 and AMZDFX176 and Vertical Concrete Cask Identification Numbers AMZDNE175, and AMZDNE176
ML23199A2942023-08-0909 August 2023
Issuance of Amendment Nos. 221, 221, and 221, to Revise Technical Specifications to Adopt TSTF-107, Separate Control Rods That Are Untrippable Versus Inoperable
IR 05000528/20230022023-08-0808 August 2023
Integrated Inspection Report 05000528/2023002 and 05000529/2023002 and 05000530/2023002
ML23207A2482023-07-26026 July 2023
License Renewal Pressurizer Surge Line Inspection
ML23188A1872023-07-0707 July 2023
Fourth 10-Year Interval, Second Period Owners Activity Report Number 2R24
ML23166B0832023-07-0505 July 2023
Independence Spent Fuel Storage Installation - Issuance of Exemption
ML23181A1602023-06-30030 June 2023
2 to Updated Final Safety Analysis Report, and Revision 3 to Operations Quality Assurance Program Description
ML23180A2222023-06-29029 June 2023
Application to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) - Operating, TS 3.5.2, Safety Injection Tanks (Sits) - Shutdown, and TS 3.6.5, Containment Air Temperature
ML23181A0772023-06-29029 June 2023
Program Review - Simulator Testing Methodology
ML23157A1292023-06-0101 June 2023
Annual Report of Guarantee of Payment of Deferred Premium
ML23144A3722023-05-24024 May 2023
Response to Regulatory Issue Summary (RIS) 2023-01, Preparation and Scheduling of Operator Licensing Examinations
ML23143A3912023-05-23023 May 2023
Independent Spent Fuel Storage Installation - Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Batch 3 Design Requirements
ML23145A2772023-05-17017 May 2023
10-PV-2023-05 Post-Exam Comments
ML23132A3392023-05-12012 May 2023
Application to Revise Technical Specifications 3.3.11 to Adopt TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls
IR 05000528/20230012023-05-0808 May 2023
and Independent Spent Fuel Storage Installation - Integrated Inspection Report 05000528/2023001 and 05000529/2023001 and 05000530/2023001 and 07200044/2023001
ML23128A0692023-05-0808 May 2023
Notification of Biennial Problem Dentification and Resolution Inspection and Request for Information
ML23122A1822023-04-29029 April 2023
Transmittal of Technical Specification Bases Revision 76
ML23122A1912023-04-29029 April 2023
Unit 1 Core Operating Limits Report Revision 32, Unit 2 Core Operating Limits Report Revision 25, Unit 3 Core Operating Limits Report Revision 31
ML23116A2772023-04-26026 April 2023
Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report 2022
ML23115A4012023-04-26026 April 2023
Review of the 2022 Steam Generator Tube Inspections During Refueling Outage 23
ML23115A4982023-04-25025 April 2023
2022 Annual Environmental Operating Report
IR 05000528/20230122023-04-19019 April 2023
Notification of Commercial Grade Dedication Inspection (05000528/2023012, 05000529/2023012, and 05000530/2023012) and RFI
ML23108A0342023-04-18018 April 2023
NRC Initial Operator Licensing Examination Approval 05000528/2023301; 05000529/2023301; 05000530/2023301
ML23103A4642023-04-13013 April 2023
Annual Radiological Environmental Operating Report 2022
ML23103A4312023-04-13013 April 2023
Emergency Core Cooling System Performance Evaluation Models, 10 CFR 50.46(a)(3)(ii) Annual Report for 2022
IR 05000528/20224012023-04-13013 April 2023
Cyber Security Inspection Report 05000528/2022401 and 05000529/2022401 and 05000530/2022401
ML23102A3292023-04-12012 April 2023
Application for Authorized Use of Mururoa Single-Use, Supplied Air Suits, Models V4F1 and MTH2
ML23102A3242023-04-12012 April 2023
Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods That Are Untrippable Versus Inoperable
ML23089A4002023-03-30030 March 2023
Consolidated Decommissioning Funding Status Report - 2022
ML23088A4012023-03-30030 March 2023
Project Manager Assignment
IR 05000528/20234022023-03-29029 March 2023
and 3 - NRC Security Inspection Report 05000528-2023402, 05000529-2023402, and 05000530-2023402, (Cover Letter Only)
ML23080A3002023-03-21021 March 2023
Present Levels of Financial Protection
2024-01-19
[Table view] |
Text
I 10 CFR 50.90 DWIGHT C. MIMS Senior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 102-06973-DCM/TNW Tel 623 393 5403 December 19, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Response to Request for Additional Information Regarding Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) Program Using the Consolidated Line Item Improvement Process (CLIIP)
By letter number 102-06784, dated November 20, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13329A037), as supplemented by letter number 102-06819, dated January 16, 2014 (ADAMS Accession No. ML14027A701), Arizona Public Service Company (APS) requested an amendment to the Palo Verde Nuclear Generating Station (PVNGS) technical specifications relating to the moderator temperature coefficient surveillance requirements for Startup Test Activity Reduction Program.
The U.S. Nuclear Regulatory Commission (NRC) staff provided a request for additional information (RAI) by e-mail dated December 1, 2014, to complete its review of the license amendment request. A draft RAI was originally transmitted on November 13, 2014, and a clarification call relating to the draft RAI was held on November 24, 2014, with participants from NRC and APS. The NRC staff requested the APS response to the final RAI within 30 days of December 1, 2014.
The enclosure to this letter provides the APS response to the NRC RAI. The RAI response remains consistent with the conclusion of the no significant hazards consideration determination [10 CFR 50.91(a), Notice for public comment] provided in the original LAR.
By copy of this letter, this LAR update is being forwarded to the Arizona Radiation Regulatory Agency (ARRA) pursuant to 10 CFR 50.91(b)(1), State consultation.
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Ao Callaway
102-06973-DCM/TNW ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to Request for Additional Information Regarding Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC)
Surveillance for Startup Test Activity Reduction (STAR) Program Using the Consolidated Line Item Improvement Process (CLIIP)
Page 2 No new commitments are being made to the NRC by this letter. Should you need further information regarding this submittal, please contact Thomas N. Weber, Licensing Department Leader, at (623) 393-5764.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on (Date)
Sincerely, DCM/TNW
Enclosure:
Response to Request for Additional Information Regarding Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) Program Using the Consolidated Line Item Improvement Process (CLIIP) cc: M. L. Dapas NRC Region IV Regional Administrator B. K. Singal NRC NRR Project Manager for PVNGS M. M. Watford NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)
T. Morales Arizona Radiation Regulatory Agency (ARRA)
Enclosure Response to Request for Additional Information Regarding Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR) Program Using the Consolidated Line Item Improvement Process (CLIIP)
Response to Request for Additional Information Regarding Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR)
Program Using the Consolidated Line Item Improvement Process (CLIIP)
Introduction By letter number 102-06784, dated November 20, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13329A037), as supplemented by letter number 102-06819, dated January 16, 2014 (ADAMS Accession No. ML14027A701),
Arizona Public Service Company (APS) requested an amendment to the Palo Verde Nuclear Generating Station (PVNGS) technical specifications relating to the moderator temperature coefficient surveillance requirements for Startup Test Activity Reduction Program.
The U.S. Nuclear Regulatory Commission (NRC) staff provided a request for additional information (RAI) by e-mail dated December 1, 2014, to complete its review of the license amendment request. A draft RAI was originally transmitted on November 13, 2014, and a clarification call relating to the draft RAI was held on November 24, 2014, with participants from NRC and APS. The NRC staff requested the APS response to the final RAI within 30 days of December 1, 2014.
The NRC request is stated first followed by the APS response.
NRC Request 1(a)
- 1. Arizona Public Service (APS) has proposed a modification to the PVNGS Technical Specifications (TS) that would allow the plant to perform a calculation in lieu of a measurement to complete Surveillance Requirement (SR) 3.1.4.2, which supports the Limiting Condition for Operation (LCO) for most negative Moderator Temperature Coefficient (MTC) established in LCO 3.1.4.
- a. How would APS ensure that PVNGS remains within LCO 3.1.4 if the plant deviates from normal operation, up to the TS limits, after performance of the two-thirds cycle surveillance required by SR 3.1.4.2?
APS Response APS performs a reload analysis (reload core safety evaluation) each cycle that includes a conservative calculation of the most negative MTC possible during the planned operating cycle. The analysis includes the biases, uncertainties and operating allowances required to ensure margin is maintained to the limits of LCO 3.1.4. The as-built core MTC will remain within the limits of LCO 3.1.4 provided the plant operates within the bounds established by the TS, the Core Operating Limits Report (COLR), and the cycle length evaluated in the reload analysis. If plans were made to operate in a condition beyond that which was evaluated in the reload analysis, then an additional evaluation would be performed to validate that the limits of LCO 3.1.4 would not be challenged by the planned change.
For example, the cycle specific reload analysis evaluates MTC beyond the planned cycle duration for operating margin. If plans were made to extend the expected life of the core beyond the burnup limit established in the reload analysis, an evaluation would be performed to validate that MTC remained within the bounds of LCO 3.1.4.
1
Response to Request for Additional Information Regarding Application for Technical Specification Change Regarding Moderator Temperature Coefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR)
Program Using the Consolidated Line Item Improvement Process (CLIIP)
In addition,Section VIII, Deviation from Normal Operation, of topical report, CE NPSD-91 l-A, Analysis of Moderator Temperature Coefficients in Support of a Change in the Technical Specification End of Cycle Negative MTC Limit, dated September 15, 2000 (ADAMS Accession No. ML003752592), which is referenced in APS letter number 102-06784, dated November 20, 2013, uses PVNGS as an example for evaluations on the effects of off-normal plant operation on MTC. The topical report concludes that off normal plant operation has only minor effects on MTC.
NRC Request 1(b)
- b. If the answer to the previous question involves comparison of predicted values to the LCO limit, what criteria would APS use to determine whether or not a reanalysis of the MTC prediction would be required?
APS Response If plans were made to operate in a condition beyond that which was evaluated in the reload analysis, then an additional evaluation would be performed to validate that the limits of LCO 3.1.4 would not be challenged by the planned change. If the analysis performed for the off normal operation, including appropriate biases and uncertainties, predicted that MTC would exceed the LCO limit, then a revised operating plan would be needed to operate at less challenging conditions such that the predicted MTC will not challenge the LCO limits.
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