ML17167A215

Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised ...

ML17167A215
Person / Time
Site:	Palo Verde
Issue date:	11/23/2016
From:	Lacal M Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-07384-MLL/MDD
Download: ML17167A215 (10)

Text

10 CFR 50.90 Oaps Maria L. Lacal Senior Vice President, Nuclear Regulatory & Oversight 102-07384-MLL/MDD November 23, 2016 Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 U. S. Nuclear Regulatory Commission Tel 623.393.6491 ATTN: Document Control Desk Washington, DC 20555-0001

References:

1. Arizona Public Service Company (APS) letter number 102-07149, License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated November 25, 2015, [Agencywide Documents Access and Management System (ADAMS) Accession Numbers ML15336A251 and ML15336A087]

2. NRC document Palo Verde 1, 2, and 3 - Official RAIs from SNPB for LAR that Requested Revision of TSs to Incorporate Updated Criticality Safety Analysis, dated July 14, 2016 (ADAMS Accession Number ML16197A006)

3. APS letter number 102-07342, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated October 6, 2016 (ADAMS Accession Number ML16286A240)

4. APS letter number 102-07360, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis -

Revised Technical Specifications and Bases and WCAP-18030, Revision 1, dated November 9, 2016 (ADAMS Accession Number ML16321A001)

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised Technical Specification Page In Reference 1, Arizona Public Service Company (APS) submitted a license amendment request (LAR) to revise the PVNGS Technical Specifications (TS) for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3. The proposed amendment would modify TS requirements to incorporate the results of an updated criticality safety analysis for both new and spent fuel storage. In Reference 2, the NRC staff requested additional information to support the review of the LAR. The APS response to the NRC staff request for additional information (RAI) was provided in Reference 3, which indicated that the affected TS and TS Bases pages, as well as the necessary revision to WCAP-18030, Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3, would be submitted separately, which were provided by Reference 4. The enclosure to this letter includes a TS markup and re-typed (clean) page (Attachments 1 and 2) that was inadvertently omitted in Reference 4.

A member of the STARS Alliance LLC Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

102-07384-MLL7MDD ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Anaiysis - Revised Technical Specification Page Page 2 The omission has been entered in the PVNGS corrective action program.

The APS response does not affect the conciusion of the no significant hazards consideration determination [10 CFR 50.91(a)] provided in the original LAR, as supplemented by APS letter 102-07181, dated January 29, 2016 (ADAMS Accession Number ML16043A361).

This submittai does not contain new reguiatory commitments as defined by NEI 99-04, Guidelines for Managing NRC Commitment Changes, Revision 0.

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).

Should you have any questions concerning the content of this letter, please contact Michael D. Dilorenzo, Licensing Section Leader, at (623) 393-3495.

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

Executed on: November 23. 2016 (Date)

Sincerely, Digitally signed by Lacal, Maria Lacal, Maria UZ06149)

DN: cn=Lacal, Maria UZ06149)

L(Z06149) Date: 2016.11.23 12:30*7

• 7'00' MLL/MDD/CJS/af

Enclosure:

Response to Request for Additional Information (RAI) Regarding License Amendment Request (LAR) to Revise Technical Specifications (TS) to Incorporate Updated Criticality Safety Analysis - Nuclear Performance and Code Review Branch (SNPB) - Revised Technical Specification Page cc: K. M. Kennedy NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS M. M. Watford NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS T. Morales Arizona Radiation Regulatory Agency (ARRA)

Enclosure Response to Request for Additional Information (RAI)

Regarding License Amendment Request (LAR) to Revise Technical Specifications (TS) to Incorporate Updated Criticality Safety Analysis - Nuclear Performance and Code Review Branch (SNPB)

Revised Technical Specification Page

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis - Nuclear Performance and Code Review Branch (SNPB)

Revised Technical Specification Page Table of Contents Enclosure - Response to Request for Additional Information (RAI) Regarding License Amendment Request (LAR) to Revise Technical Specifications (TS) to Incorporate Updated Criticality Safety Analysis - Nuclear Performance and Code Review Branch (SNPB) - Revised Technical Specification Page Attachment 1 - Technical Specification Markup Page Attachment 2 - Technical Specification Clean Page

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis - Nuclear Performance and Code Review Branch (SNPB)

Revised Technical Specification Page Introduction By letter dated November 25, 2015 [Agencywide Documents Access and Management System (ADAMS) Accession Number ML15336A087] (Reference 1), as supplemented by letters dated January 29 (Reference 2) and June 30, 2016 (Reference 3) (ADAMS Accession Numbers ML16043A361 and ML16182A519, respectively), Arizona Public Service Company (APS) submitted a license amendment request (LAR) to amend Facility Operating License Numbers NPF-41, NPF-51, and NPF-74, and revise the Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, Technical Specifications (TSs). The LAR proposes to install NETCO-SNAP-IN neutron absorbing rack inserts into some spent fuel pool (SFP) storage rack cells coupled with six classifications of fuel (i.e., regions) by initial enrichment, burnup, and decay time in six storage configurations (i.e., arrays) for criticality control.

Approval of the license amendment will establish the new licensing basis for how APS meets the effective neutron multiplication factor (keffective or keff) criticality control requirements.

The U.S. Nuclear Regulatory Commission (NRC) Nuclear Performance and Code Review Branch (SNPB) provided an official request for additional information (RAI) by Reference 4.

The APS response to each of the NRC staff information requests of Reference 4 was provided by APS letter number 102-07342, dated October 6, 2016 (Reference 5). The APS response to the NRC staff RAI indicated that the affected TS and TS Bases pages, as well as the necessary revision to WCAP-18030, Criticality Safety Analysis for Palo Verde Nuclear Generating Station Units 1, 2, and 3, would be submitted separately. By letter 102-07360, dated November 9, 2016 (Reference 6), APS transmitted the proposed changes to the PVNGS TS, TS Bases and provided Revision 1 of WCAP-18030.

On November 15, 2016, APS personnel identified that an affected TS page was inadvertently omitted in Reference 6. Attachment 1 of this enclosure provides the markup TS page and Attachment 2 provides the clean (re-typed) TS page that was previously inadvertently omitted.

Proposed Changes to the Technical Specifications The following additional TS change is proposed as part of the updated criticality safety analysis resulting from References 5 and 6. The remaining TS changes previously submitted in the LAR dated November 25, 2015 (Reference 1), as supplemented by APS letters dated January 29, 2016 (Reference 2) and November 9, 2016 (Reference 6), are not affected and remain applicable.

• TS 4.3.1, Criticality

• Updated subsection 4.3.1.1.c, to reflect the revised boron concentration of 1600 ppm to address the WCAP-18030, Revision 1, re-evaluation of the postulated multiple mislead event, described in the response to RAI-7 of Reference 5.

Need for Proposed Changes The NRC SNPB provided an RAI by Reference 4. The APS response to each of the NRC staff information requests of Reference 4 was provided by Reference 5. Attachments 1 and 2 of this enclosure provide the updated TS markup and clean page that was inadvertently omitted in Reference 6.

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis - Nuclear Performance and Code Review Branch (SNPB)

Revised Technical Specification Page Specifically, re-analyses performed to respond to NRC staff RAI-7, provided in Reference 5, updated the criticality analysis required minimum boron concentration for the postulated multiple mislead event. The TS 3.7.15 required minimum boron concentration was not affected (greater than or equal to 2150 ppm), but the minimum value in the analysis was updated from 1460 ppm to 1600 ppm. This change was reflected in the TS Bases markups provided in Reference 6, but the change to TS 4.3.1.1.c was inadvertently omitted in Reference 6. Attachment 1 provides the updated markup TS page and Attachment 2 of this enclosure provides the re-typed (clean) TS page.

No Significant Hazards Consideration The APS response does not affect the conclusion of the no significant hazards consideration determination [10 CFR 50.91(a)] provided in the original LAR (Reference 1), as supplemented by Reference 2.

Conciusion APS concludes that operation of the facility in accordance with the proposed amendment, as supplemented, does not involve a significant hazards consideration and, accordingly, a finding of "no significant hazards consideration" is justified. Based on the considerations discussed above and in the referenced APS supplemental responses, (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 the health and safety of the public.

References

1. APS letter number 102-07149, License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated November 25, 2015, (ADAMS Accession Numbers ML15336A251 and ML15336A087)

2. APS letter number 102-07181, Supplemental Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated January 29, 2016 (ADAMS Accession Number ML16043A361)

3. APS letter number 102-07275, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated June 30, 2016 (ADAMS Accession Number ML16182A519)

4. NRC document Palo Verde 1, 2, and 3 - Official RAIs from SNPB for LAR that Requested Revision of TSs to Incorporate Updated Criticality Safety Analysis, dated July 14, 2016 (ADAMS Accession Number ML16197A006)

5. APS letter number 102-07342, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis, dated October 6, 2016 (ADAMS Accession Number ML16286A240)

6. APS letter number 102-07360, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised Technical Specifications and Bases and WCAP-18030, Revision 1, dated November 9, 2016 (ADAMS Accession Number ML16321A001)

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis - Nuclear Performance and Code Review Branch (SNPB)

Revised Technical Specification Page Attachment 1 Technical Specifications Markup Page 4.0-2

After SFP transition Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum radially averaged U-235 enrichment of 4.65 weight percent:

b. keff < 1.0 if fully flooded with unborated water, which includes an allowance for biases and uncertainties as described in Section 9.1 of the UFSAR:

c. keff ^ 0.95 if fully flooded with water borated to 1600 \- ->4460 ppm. which includes an allowance for biases and uncertainties as described in Section 9.1 of the UFSAR.

d. A nominal 9.5 inch center-to-center distance between adjacent storage cell locations.

e. Fuel assemblies are classified in Fuel Regions 1-6 as shown in Tables 3.7.17-1 through 3.7.17-5.

(continued)

PALO VERDE UNITS 1,2.3 4.0-2 AMENDMENT NO. 406.

Enclosure Response to RAI Regarding LAR to Revise TS to Incorporate Updated Criticality Safety Analysis - Nuclear Performance and Code Review Branch (SNPB)

Revised Technical Specification Page Attachment 2 Technical Specifications Clean Page 4.0-2

After SFP transition 1 Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

a. Fuel assemblies having a maximum radially averaged U-235 enrichment of 4.65 weight percent;

b. keff < 1.0 if fully flooded with unborated water, which includes an allowance for biases and uncertainties as described in Section 9.1 of the UFSAR:

c. keff ^ 0.95 if fully flooded with water borated to 1600 ppm, which includes an allowance for biases and uncertainties as described in Section 9,1 of the UFSAR.

d. A nominal 9.5 inch center-to-center distance between adjacent storage cell locations.

e. Fuel assemblies are classified in Fuel Regions 1-6 as shown in Tables 3.7.17-1 through 3.7.17-5.

(continued)

PALO VERDE UNITS 1.2,3 4.0-2 AMENDMENT NO. 42§.