ML15005A386

Commitment Schedule Changes Related to TSTF-493 and TSTF-523

ML15005A386
Person / Time
Site:	Palo Verde
Issue date:	12/30/2014
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06982-DCM/DCE
Download: ML15005A386 (3)

Text

10 CFR 50.90 gaps DWIGHT C. MIMS Senior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 Tel 623 393 5403 102-06982-DCM/DCE December 30, 2014 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

References:

1. Arizona Public Service (APS) Letter 102-05305, Response to Request for Additional Information Regarding Steam Generator Replacement and Power Uprate - Instrumentation and Controls Section, dated July 9, 2005, [Agencywide Documents Access And Management System (ADAMS) Accession No. ML052080046]

2. APS Letter 102-05910, Nine-Month Response to NRC Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and ContainmentSpray Systems, dated October 14, 2008, [ADAMS Accession No. ML082940032]

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Commitment Schedule Changes Related to TSTF-493 and TSTF-523 The purpose of this letter is to inform the NRC that Arizona Public Service Company (APS) has revised the scheduled completion dates related to regulatory commitments to submit license amendment requests (LARs) for technical specification (TS) revisions documented in references 1 and 2.

Reference 1 contained the following commitment regarding Technical Specification Task Force (TSTF)-493, Clarify Application of Setpoint Methodology for LSSS Functions:

"APS shall continue to work with the industry on the finalization of the pending Technical Specification Task Force (TSTF) technical specification change and adopt the applicable changes to come into conformance with the existing understanding of the requirements of 10 CFR 50.36."

Revision 4 of TSTF-493 was subsequently approved by the NRC (75 FR 26294) on May 11, 2010. Option A of TSTF-493 adds notes related to as-found and as-left channel setpoints for applicable surveillance requirements identified in the TSTF.

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102-06982-DCM/DCE ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Commitment Schedule Changes Related to TSTF-493 and TSTF-523 Page 2 The commitment identified in Reference 1 was revised as follows:

"APS shall submit a license amendment request based on Option A of TSTF-493, Clarify Application of Setpoint Methodology for Limiting Safety System Settings, by March 30, 2016. No changes to the allowable values or nominal trip setpoints will be requested in the submittal."

The commitment change specifies Option A of TSTF-493 traveler as the intended basis of the proposed license amendment and adds a date for submittal of the LAR.

Reference 2 contained the following commitment regarding TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation:

"APS is continuing to support the industry and NEI Gas Accumulation Management Team activities regarding the resolution of generic TS changes via the TSTF traveler process. APS will evaluate the resolution of TS issues with respect to the changes contained in the TSTF traveler and submit a LAR based on this evaluation within one year following NRC approval of the CLIIP Notice of Availability of the TSTF traveler. The basis changes associated with the TS changes will also be made."

Revision 2 of TSTF-523 was approved by the NRC on January 15, 2014 (79 FR 2700). TSTF-523 will add surveillance requirements to emergency core cooling system, containment spray system, and shutdown cooling system technical specifications to ensure the systems are sufficiently filled with water.

The commitment identified in Reference 2 was revised as follows:

"APS will evaluate the resolution of TS issues with respect to the changes contained in the TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, and submit a license amendment request based on this evaluation by June 30, 2016. The basis changes associated with the TS changes will also be made."

The commitment change specifies TSTF-523 as the intended basis of the proposed license amendment and extends the existing completion date.

Current station testing procedures adopt practices similar to the TS requirements that will be adopted by incorporation of both TSTFs into TSs. These current practices ensure the objectives of the commitments will continue to be met until the proposed license amendments are implemented.

The extension of the scheduled commitment completion dates are needed to permit completion of other station priorities, such as implementation of obligations to NRC requirements, including NRC orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, and EA-12-051, Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation. In addition, three LARs are currently being

102-06982-DCM/DCE ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Commitment Schedule Changes Related to TSTF-493 and TSTF-523 Page 3 processed since they have a higher priority. These additional LARs address the following:

• Implementation of risk-informed completion times per TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF 4b

• Resolution of the non-conservative TS for spent fuel pool criticality analyses

• Fulfillment of the commitment to develop a plant design change to shorten the existing degraded voltage relay time delay in TS surveillance requirement 3.3.7.3 (a), as described in APS Letter No. 102-06498, DegradedVoltage License Amendment Request Commitment, dated September 26, 2014, ADAMS Accession No. ML14276A032 Completion of these obligations and the three LARs currently being processed will improve the conservatism in plant design and enable the station to manage risk more effectively. In contrast, the LARs to implement TSTF-493 and TSTF-523 are more administrative in nature in that they will incorporate similar existing practices into TSs. Application of station resources toward implementation of the current obligations and the three LARs being processed coupled with the revised commitment dates provide a cumulatively greater safety benefit. Therefore, the revised commitment dates are necessary and warranted.

Should you need further information regarding this submittal, please contact Thomas N. Weber, Nuclear Regulatory Affairs Department Leader, at (623) 393-5606.

Sincerely, DCM/TNW 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