ML16019A368

Supplemental Information for PVNGS License Amendment Request to Adopt TSTF-439-A

ML16019A368
Person / Time
Site:	Palo Verde
Issue date:	01/19/2016
From:	Lacal M Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-07177-MLL/TNW
Download: ML16019A368 (2)

Text

10 CFR 50.90 Maria L. Lacal Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 Tel 623 393 6491 102-07177-MLL/TNW January 19, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

Arizona Public Service Company (APS) letter 102-07002, License Amendment Request (LAR) for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-439-A, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, dated February 27, 2015, Agencywide Documents Access and Management System (ADAMS) Accession Number ML15065A031

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 License Nos. NPF-41, NPF-51 and NPF-74 Supplemental Information for PVNGS License Amendment Request to Adopt TSTF-439-A By the referenced letter, APS submitted a license amendment request (LAR) to revise the PVNGS Technical Specifications (TS) by adopting the NRC-approved TSTF traveler TSTF-439-A, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO.

In accordance with TSTF-439-A, the LAR provided justification that the removal of the second Completion Times in the TS was acceptable, in part, because the risk impact of inoperable risk-significant equipment is assessed and managed when performing preventive or corrective maintenance under 10 CFR 50.65(a)(4). The LAR noted these risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide (RG) 1.182, Revision 0, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. Regulatory Guide 1.182 endorsed the guidance in Section 11 of Nuclear Utility Management and Resource Council (NUMARC) 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, dated February 11, 2011, which at the time of the submittal was part of the PVNGS licensing basis. The above RG and NUMARC documents provided general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. The guidance recommended actions to determine that proposed maintenance and activities are acceptable and to plan and conduct them in a manner that controls overall risk by reducing the duration of the A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

102-07177-MLL/TNW ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Supplemental Information for PVNGS LAR to Adopt TSTF-439-A Page 2 conditions that increase risk and minimizing the magnitude of risk increases (establishment of backup success paths or compensatory measures). This comprehensive program provides greater assurance of safe plant operation than the second Completion Time in TS.

On November 27, 2012, the NRC published a Federal Register Notice (77 FR 70846) stating that RG 1.182 has been withdrawn and the subject matter has been incorporated into RG 1.160, Revision 3, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, dated May 2012. Regulatory Guide 1.160 endorses Revision 4A of NUMARC 93-01, dated April 2011. Section 11 of Revision 4A of NUMARC 93-01, continues to discuss assessment of risk resulting from performance of maintenance activities and provides additional considerations for external events and guidance for scoping, assessment, and management of fire risk during maintenance activities.

APS, by this supplement to the LAR, adopts Revision 3 of RG 1.160 and NUMARC 93-01 as part of the justification to approve removal of second Completion Times from PVNGS TS. Prior references to RG 1.182 in the LAR should be assumed to refer to RG 1.160, Revision 3, and NUMARC 93-01, Revision 4A.

APS will update PVNGS documents that refer to RG 1.182 as part of the implementation of the approved license amendment.

By copy of this letter, this supplemental information for the referenced LAR is being forwarded to the Arizona Radiation Regulatory Agency pursuant to 10 CFR 50.91(b)(1). No commitments are being made to the NRC by this letter.

Should you need further information regarding this submittal, please contact Thomas N. Weber, Nuclear Regulatory Affairs Department Leader, at (623) 393-5764.

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

Executed on January 19, 2016 Date Lacal, Maria Digitally signed by Lacal, Maria L(Z06149)

DN: cn=Lacal, Maria L(Z06149)

L(Z06149)

Reason: I am approving this document Date: 2016.01.19 07:58:34 -07'00' MLL/TNW cc: M. L. Dapas NRC Region IV Regional Administrator M. M. Watford NRC NRR Project Manager for PVNGS L. J. Klos NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency T. Morales Arizona Radiation Regulatory Agency

10 CFR 50.90 Maria L. Lacal Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 Tel 623 393 6491 102-07177-MLL/TNW January 19, 2016 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Reference:

Arizona Public Service Company (APS) letter 102-07002, License Amendment Request (LAR) for Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-439-A, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, dated February 27, 2015, Agencywide Documents Access and Management System (ADAMS) Accession Number ML15065A031

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 License Nos. NPF-41, NPF-51 and NPF-74 Supplemental Information for PVNGS License Amendment Request to Adopt TSTF-439-A By the referenced letter, APS submitted a license amendment request (LAR) to revise the PVNGS Technical Specifications (TS) by adopting the NRC-approved TSTF traveler TSTF-439-A, Revision 2, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO.

In accordance with TSTF-439-A, the LAR provided justification that the removal of the second Completion Times in the TS was acceptable, in part, because the risk impact of inoperable risk-significant equipment is assessed and managed when performing preventive or corrective maintenance under 10 CFR 50.65(a)(4). The LAR noted these risk assessments are conducted using the procedures and guidance endorsed by Regulatory Guide (RG) 1.182, Revision 0, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants. Regulatory Guide 1.182 endorsed the guidance in Section 11 of Nuclear Utility Management and Resource Council (NUMARC) 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, dated February 11, 2011, which at the time of the submittal was part of the PVNGS licensing basis. The above RG and NUMARC documents provided general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. The guidance recommended actions to determine that proposed maintenance and activities are acceptable and to plan and conduct them in a manner that controls overall risk by reducing the duration of the A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

102-07177-MLL/TNW ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Supplemental Information for PVNGS LAR to Adopt TSTF-439-A Page 2 conditions that increase risk and minimizing the magnitude of risk increases (establishment of backup success paths or compensatory measures). This comprehensive program provides greater assurance of safe plant operation than the second Completion Time in TS.

On November 27, 2012, the NRC published a Federal Register Notice (77 FR 70846) stating that RG 1.182 has been withdrawn and the subject matter has been incorporated into RG 1.160, Revision 3, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, dated May 2012. Regulatory Guide 1.160 endorses Revision 4A of NUMARC 93-01, dated April 2011. Section 11 of Revision 4A of NUMARC 93-01, continues to discuss assessment of risk resulting from performance of maintenance activities and provides additional considerations for external events and guidance for scoping, assessment, and management of fire risk during maintenance activities.

APS, by this supplement to the LAR, adopts Revision 3 of RG 1.160 and NUMARC 93-01 as part of the justification to approve removal of second Completion Times from PVNGS TS. Prior references to RG 1.182 in the LAR should be assumed to refer to RG 1.160, Revision 3, and NUMARC 93-01, Revision 4A.

APS will update PVNGS documents that refer to RG 1.182 as part of the implementation of the approved license amendment.

By copy of this letter, this supplemental information for the referenced LAR is being forwarded to the Arizona Radiation Regulatory Agency pursuant to 10 CFR 50.91(b)(1). No commitments are being made to the NRC by this letter.

Should you need further information regarding this submittal, please contact Thomas N. Weber, Nuclear Regulatory Affairs Department Leader, at (623) 393-5764.

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

Executed on January 19, 2016 Date Lacal, Maria Digitally signed by Lacal, Maria L(Z06149)

DN: cn=Lacal, Maria L(Z06149)

L(Z06149)

Reason: I am approving this document Date: 2016.01.19 07:58:34 -07'00' MLL/TNW cc: M. L. Dapas NRC Region IV Regional Administrator M. M. Watford NRC NRR Project Manager for PVNGS L. J. Klos NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency T. Morales Arizona Radiation Regulatory Agency