ML17299B011
| ML17299B011 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde |
| Issue date: | 02/13/1986 |
| From: | ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | |
| Shared Package | |
| ML17299B010 | List: |
| References | |
| TAC-60706, NUDOCS 8602180063 | |
| Download: ML17299B011 (194) | |
Text
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INDEX 8608I800b3 8808I3 PDR ADOCK 05000529 P
- PDR, ADMINISTRATIVE CONTROLS SECTION PAGE
- 6. 14 OFFSITE DOSE CALCULATIONMANUAL.............................
6"24 6.15 MAJOR CHANGES TO RADIOACTIVE LI UID GASEOUS AND SOLID WASTE TREATMENT SYSTEMS...........................
6-24 6.16 PRE"PLANNED ALTERNATE SAMPLING PROGRAM......................
6-25 PALO VERDE " UNIT 2
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0 I
LAULL' AL LIUKE REhSON I.
3.3.3.1 3.3-6 Delete Section 1 and change sections 2 and 3 to 1 and 2 respectively.
Pre-planned Alternates to these monitors are found in EPIP's and are implemented at all+times.
II.
3.3.3..1 3.3-6 p3-39 28(1)
Delete Section 1 and change section 2 to follow the phrase "within 7 days".
Current Regulatory guidance does not require a backup system for a manual PASS.
p3-38 Instrument 3-Delete m in its entirety Any definition requirements not contained in Tech Specs can be found in the Station Phnual.
III. 3.3.3.9 3.3-13 37(a)
Delete "a." change to:
a.
Place movable air monitors in line.
b.
Take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Regardless of the deletion of, PASP, this should be changed as stated since existing "a" is not an appropriate alternative to "b" IV.
3.3.3.9 3.3-13 Delete "a" change "b" statement to follow the word or PASP will be implemented by Station manual Procedures.
V.
6.5.3.5 Delete item "1" from audit list.
If PASP is not a program it need not be audited by NSG.
Delete item "k" from list.
Redesignate remaining listings to follow in order beginning with k.
If PASP is not a Tech Spec Program its implementation should not be required by Tech Specs.
'III.
6.16 Delete in its entirety.
Deletion requested per this submittal.
I
(
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.1.2.2 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; and (B)
The proposed amendment is a
purely administrative change to technical specifications:
for
- example, a
change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.
Surveillance requirements should renumbered to maintain standard numbering sequence.
0 0
~l RE CTIVITY CONTROL S".STEMS Fl OW PATHS " OPERATING LIMITING CONDITION FOR OPERATION V
3.1.2.2 At least two of the following three boron injection flow paths shall be OPERABLE:
a.
A gravity feed flow path from either the refueling water tank or the spent fuel pool through CH-536 (RWT Gravity Feed Isolation Valve) and a charging pump to the Reactor Coolant System, b.
A gravity feed flow path from the refueling water tank through CH-327 (RWT Gravity Feed/Safety Injection System Isolation Valve) and a charging pump to the Reacto~ Coolant System, c.
A flow path from either the refueling water tank or the spent fuel pool through CH-164 (Boric Acid Filter Bypass Valve), utilizing gravity feed and a charging pump to the Reactor Coolant System.
APPLICABILITY:
MODES 1, 2, 3, and 4.
ACTION:
With only one of the above required boron injection flow paths to the Reactor Coolant System OPERABLE, restore at least two boron injection flow paths to the Reactor Coolant System to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY and borated to a SHUTDOWN MARGIN equivalent to at least 6X de'lta k/k at 2104F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two flow paths to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE RE UIREMENTS 4.1.2.2.IAt least two of the above required flow paths shall be demonstrated OPERABLE:
- a. 't least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked,.;,
- sealed, or otherwise secured in position, is in its correct positi~n."-
,I b.
At least once per 18 months when the Reacto~ Coolant System.is at normal operating pressure by verifying that the flow path required by Specification 3.1.2.2 delivers at least 26 gpm for 1 charging pump and 68 gpm for two charging pumps to the Reactor Coolant System.
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The provisions of Specification 4.0.4 are not applicable for entry into Mode 3 or Mode 4 to perform the surveillance testing of Specification-4.1.2.2.b provided the testing is performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving normal operating pressure in the reactor coolant system.
PALO VERDE - UNIT 2
0 Il ll
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.2.2 Table 3.3.-3 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specifications.
The last sentence discusses returning one channel to operable status which places the status in a one less than total channels condition.
This is the subject of action 13.
0
ACTION 14 ACTION 15-ACTION 16-ACTION 17-ACTION 18-TABLE 3.3-3 (Continued)
ACTION STATEMENTS (Continued)
With the number of channels OPERABLE one less than the Minimum Channels
- OPERABLE, STARTUP and/or POMER OPERATION may continue provided the following conditions are satisfied:
a.
Verify that one of the inoperable chanhels has been bypassed and place the other inoperable channel in the tripped condition within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
b.
All functional units affected by the bypassed/tripped channel shall also, be placed in the bypassed/tripped condition as listed below:
Process Measurement Circuit Functional Unit B assed/Tri 1.
Steam Generator Pressure-Low Mith the number of OPERABLE channels one less than the Minimum Number of Channels, operation may continue for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
After 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> operation
.may continue provided at least 1 train of essential filtration is in operation, otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOMN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
yp pped Steam Generator Pressure - Low Steam Generator Level 1 - Low (ESF)
Steam Generator Level 2 - j.ow (ESF) 2.
Steam Generator Level - Low Steam Generator Level - Low (RPS)
(Wide Range)
Steam Generator Level= 1 - Low (ESF)
Steam Generator Level 2 - Low (ESF)
STARTUP and/or POWER OPERATION may continue until the performance of the next required CHANNEL FUNCTIONAL'EST.
Subsequent STARTUP and/or POWER OPERATION may continue if one channel is restored to 'OPERABLE status and the provisions of ACTION~are satisfied.
/3 Mith the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48'ours or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Mith the number of OPERABLE channels one less than the Total Number of Channels, be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in at least HOT SHUTDOMN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />;
- however, one channel may be bypassed for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for surveillance testing provided the other channel. is OPERABLE.
Mith the number of OPERABLE channels one less than the Minimum Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within, the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
PALO VERDE - DRI+jQpppQL3/4@$ 24 pgIP U'/pe
e 0
NO SIGNIFICANT HAZA1KS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.3.1 Table 4.3.-1 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; F
(E)
The proposed amendment is a
purely administrative change to technical specifications.
Since specification 2.2.2 does not exist in these technical specifications, the reference to specification 2.2.2 in,table notation (9) should be deleted.
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TABLE 4.3-1 (Continued (2)
(3)
(4)-
(5)-
(6)-
(7)-
(8)
(e)-
(io)-
TABLE NOTATIONS With reactor trip breakers in the closed position and the CEA drive system capable of CEA withdrawal, and fuel in the reactor vessel.
Each STARTUP or when required with the reactor trip breakers closed and the CEA drive'ystem capable of rod withdrawal, if not performed in the previous 7 days.
Heat balance only (CHANNEL FUNCTIONAL TEST not included),
above 15K of RATED THERMAL POWER; adjust the linear power level, the CPC delta T
power and CPC nuclear power signals to agree with the calorimetric calculation if absolute difference is greater than 2X.
During PHYSICS
- TESTS, these daily calibrations may be suspended provided these calibrations are performed upon reaching each major test power platea'u and prior to proceeding to the next major test power plateau.
Above 15K of RATED THERMAL POWER, verify that the linear power sub-channel gains of the excore detectors are consistent with the values used to establish the shape annealing matrix elements in the Core Protection Calculators.
Neutron detectors may be excluded from CHANNEL CALIBRATION.
After each fuel loading and prior,to exceeding 70K of RATED THERMAL.--
POWER, the incore detectors shall be used to determine the shape annealing matrix elements and the Core Protection Calculators shall use these elements.
This CHANNEL FUNCTIONAL TEST shall include the injection of simulated process signals into the channel as close to the sensors as practicable to verify OPERABILITY including alarm and/or trip functions.
Above 70K of RATED THERMAL POWER, verify that the total steady-state RCS flow rate as indicated by each CPC is less than or equal to the actual RCS total flow rate determined by either using the reactor coolant pump differential pressure instrumentation or by calorimetric calculations and if necessary, adjust the CPC addressable constant flow coefficients such that each CPC indicated flow is less than or equal to the actual flow rate.
The flow measurement uncertainty may be included in the BERR1 term in the CPC and is equa'I to or greater than 4X.
Above 70K of RATED THERMAL POWER, verify that the total"steady-state RCS flow rate as indicated by each CPC is less than or equal to the actual RCS total flow rate determined-by either using the reactor coolant pump differentral pressure instrumentation and the ultrasonic flow meter adjusted pump curves or calorimetric calculations.
The monthly CHANNEL FUNCTIONAL TEST shall include verification that the correct (current) values of addressable constants are installed OPE BLE P.i~
At least once per 18 months and following maintenance or adjustment of the reactor trip breakers, the CHANNEL FUNCTIONAL TEST shall include independent verification of the undervoltage and shunt trips.
PALO VERDE - UNIT 2 3/4 3=16
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NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.3.2 Table 4.3-2 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specifications.
Table 4.3-2 must be changed to be consistent with table 3.3-3.
The Unit 2
Tech.
Specs'.
used Unit 1 Tech.
Specs.
as a model, and they will be changed by separate request.
The change as proposed by this letter agree with the Standard Technical Specifications.
TABLE 4.3-2 ENGINEEREO SAFETY FEATURES ACTUATION SYSTEH INSTRUMENTATION SURVEILLANCE RE UIREHENTS
(
m C7 fthm I
C:
M ESFA SYSTEM FUNCTIONAL UNIT I.
SAFETY INJECTION (SIAS)
CHANNEL CHANNEL CHANNEL FUNCTIONAL CHECK CALIBRATION TEST MODES FOR MHICH SURVEILLANCE IS RE UIREO A.
Sensor/Trip Units 1.
Containment Pressure - Nigh S
2.
Pressurizer Pressure - Low I, 2, 3, 4 1, 2, 3, 4 B.
ESFA System Logic 1.
Matrix Logic 2.
Initiation Logic 3.
Hanual SIAS C.
Automatic Actuation Logic II.
CONTAINMENT ISOLATION (CIAS)
NA NA NA 1, 2, 3, 4 1, 2, 3, 4 1, 2, 3, 4 H(1) (2) (3) 1, 2, 3, 4 A.
Sensor/Trip Units 1.
Containment Pressure - High S
2.
Pressurizer Pressure - Low S
B.
ESFA System Logic 1.
Hatr ix Logic 2.
Initiation Logic 3.
Manual CIAS 4.
Manual SIAS NA NA
- 123, 1, 2, 3
1, 2, 3, 4 1, 2, 3; 4 1, 2, 3, 4 1, 2, 3, 4
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TABLE 4.3-2 (Continued)
ENGINEEREO SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE RE UIREMENTS (fll C7 Cll I
e M
ESFA SYSTEM FUNCTIONAI UNIT CHANNEL CHANNEL CHANNEL FUNCTIONAL CHECK CALIBRATION TEST MOOES FOR WHICH SURVEILLANCE IS RE UIRED II.
CONTAINMENT ISOLATION (Continued)
C.
Automatic Actuation Logic NA M(1) (2) (3) 1, 2, 3, 4
~4 Q
III.
A.
Sensor/Trip Units 1.
Containment Pressure High - High B.
ESFA System Logic 1.
Matrix Logic 2.
Initiation Logic 3.
Manua1 CSAS S
NA NA NA 1
2 3
I.,E, S,g 1, 2, 3, 4 1, 2, 3, 4 C.
Automatic Actuation Logic M(1) (2) (3) 1, 2, 3, 4
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C)
I m
I ESi V.
SYSTEM FUNCTIONAL UNIT RECIRCULATION (RAS)
A.
Sensor/Trip Units CHANNEL CHANNEL CHANNEL FUNCTIONAL CHECK CALIBRATION TEST MODES FOR WHICH SURVEILLANCE IS RE UIRED TABLE 4.3-2 (Continued)
- ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE RE UIREMENTS G5 VI.
c Refueling Water Storage Tank - Low B.
ESFA System Logic 1.
Matrix Logic 2.
Initiation Logic 3.
Manual RAS C.
Automatic Acutation Logic AUXILIARYFEEDWATER (SG-1)(AFAS-1)
A.
Sensor/Trip Units 1.
Steam Generator 01 Level-Low 2.
Steam Generator 4 Pressure SG2 > SG1 NA 1, 2, 3
1, 2, 3, 4 1, 2, 3, 4 1, 2, 3, 4 M(l) (2) (3)
I, 2, 3, 4 1
2 3
1, 2, 3
IC)
Ic M
Qrà GP Ai~.
QM ESf
. SYSTEM FUNCTIONAL UNIT VI.
AUXILIARYFEEDWATER (SG-1) (AFAS-1)
B.
ESFA System Logic 1.
Matrix Logic 2.
Initiation Logic 3.
Hanual AFAS C.
Automatic Actuation Logic VIl AUXILIARYFEEDWATER (SG-2)(AFAS-2)
A.
Sensor/Trip Units 1.
Steam Gener'ator ¹2 Level-Low 2.
Steam Generator 6 Pressure SG1 SG2 B.
ESFA System L'ogic 1.
Matrix Logic 2.
Initiation Logic 3.
Manual AFAS C.'utomatic Actuation Logic VI '.
LOSS OF POWER (LOV)
A.
4.16 kV Emergency Bus Under-voltage (Loss of Voltage)
B.
4.16 kV Emergency Bus Under-voltage (Degraded Voltage)
CHANNEL CHANNEL CHANNEL FUNCTIONAL CHECK CALIBRATION TEST (Continued)
MODES FOR WHICH SURVEILLANCE IS RE UIRED NA NA NA NA NA NA NA NA M
1, 2, 3, 4 M
1, 2, 3, 4 H
1, 2, 3, 4 M(1) (2) (3) 1, 2, 3, 4 1
2 3
1, 2, 3
NA NA NA NA NA NA NA NA H
H 1, 2, 3, 4 H
1, 2, 3, 4 H(1) (2) (3) 1, 2, 3, 4 1, 2, 3, 4 1, 2, 3, 4 TABLE 4.3-2 (Continued)
- GINEERED SAFETY fEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE RE UIREMENTS
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NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.3.3 Table 3.3-6 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
l)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or I
(
3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specifications.
This change requires a manual action which is the same as the automatic action which would occur.
C n
TABLE 3.3-6 (Continued}
ACTION STATEMENTS ACTION 22-ACTION 23-ACTION 24-ACTION 25 "
ACTION 26 "
ACTION 27 "
ACTION 28-Mith the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Mith the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.5.1.
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.12 or operate the fuel build-ing essential ventilation system while handling irradiated fuel.
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9.
Mith the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of the control room emergency ventilation y
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p i,i iSE<A2ri~E. ~l~rZarieV Mith the number of OPERABLE Channels less than required by the Minimum Channels OPERABLE requirement, 'either restore the inoperable channel(s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or:
1.
For area monitors RU-139 A and B, RU-140 A and B, RU-148 and RU-149, initiate'a preplanned alternate program to monitor the appropriate parameters, 2.
For process monitors, place moveable air monitor in-line.
3.
Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.
.With the number of OPERABLE Channels one less than required by the Minimum Channels OPERABLE requirement, either restore the inoperable channel(s) to OPERABLE status within 7 days, or:
l.
Initiate the Preplanned Alternate Sampling Program of Spec-ification 6.16 to monitor the appropriate parameter(s).
2.
Prepare and submit a Special Report-to the Commission pursuant to Specification 6.9.2 within 30 days follow>~"
the event outlining the action(s) taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.
PAL0 vERDE - UNIT 2<<0P ITRC3(4; 3 3g9 IBy IL1g
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NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.3.3.1 Action 27 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specification.
The Pre-Planned Alternate Sampling Program is not required by the Standard Tech.
Spec.
Review Plan.
The design of our high range monitors is consistent with regulatory guidance, therefore, no special Tech.
Spec.
considerations are necessary.
~
Deletion of the Pre-Planned Alternate Sampling Program from Technical Specifications The need to maintain the Pre-Planned Alternate Sampling Program (PASP) as a
Technical Specification Program is unnecessary.
The PASP has no precedented counterpart in the Standard Technical Specifications.
Notification of deficiencies in the Operability status of High Range and Accident Analysis monitors and system may be achieved by the existing system of Special Report submittals.
Enforcement action may be initiated based on the submittals should efforts of the facility staff to correct these situations be found to be repeatedly inadequate.
The existing Pre-Planned Alternate Sampling Program and other preplanned contingencies should be maintained by the facility outside the scope of Technical Specification requirements.
Regardless of the deletion of PASP as a Technical Specification
- Program, items I and III on the following table are requested to be deleted for the reasons listed.
In addition, current regulatory guidance does not require a backup system for the Post Accident Sampling System.
0
I.
3.3.3.
3.3-6 27.(1)
Delete Section 1 and change sections 2 and 3 to 1 and 2 respectively.
Pre-planned Alternates to these monitors are found in EPIP's and are implemented at all times.
II.
3.3.3..1 3.3-6 p3-39 28(1)
Delete Section 1 and change section 2 to follow the phrase "within 7 days".
Current Regulatory guidance does not require a backup system for a manual PASS.
p3-38 Instrument 3-Delete Q'g in its entirety Any definition requirements not contained in Tech Specs can be found in the Station Planual.
III. 3.3.3.9 3.3-13
. 37(a)
Delete "a." change to:
a.
Place movable air monitors in line.
b.
Take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Regardless of the deletion of PASP, this should be changed as stated since existing "a" is not an appropriate alternative to "b".
IV.
3.3.3.9 3.3-13 42(a)
Delete vs~a change vba statement to follow the word 01
~
PASP will be implemented by Station Phnual Procedures.
V.
6.5.3.5 Delete item "1". from audit list.
If PASP is not a program it need not be audited by NSG.
VI.
6.8.1 Delete item "k" from list.
Redesignate remaining listings to follow in order beginning with k.
If PASP is not a Tech Spec Program its implementation should not be required by Tech Specs.
II
- VXI, 6.16 Delete in its entirety.
Deletion requested per this submittal.
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ACTION 22-ACTION 23-ACTION 24-ACTION 25-ACTION 26-ACTION 27-ACTION 28-TABLE 3.3-6 (Continued)
ACTION STATEMENTS
/
Mith the number of channels OPERABLE less than required by the Hinimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Mith the number of channels OPERABLE less than required by the Hinimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.5.1.
Mith the number of channels, OPERABLE less than required by the Hinimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.12 or operate the fuel build-ing essential ventilation system while handling irradiated fuel.
Mith the number of channels OPERABLE less than required by the Hinimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9.
Mith the number of channels OPERABLE less than required by the Hinimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of the control room emergency ventilation system in the recirculation mode of operation.
Mith the number of OPERABLE Channels less than required by the Minimum Channels OPERABLE requirement, either restore the inoperable channel(s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or:
1.
For area monitors RU-139 A and B, RU-140 A and B, RU-148 and RU-149, initiate a preplanned alternate program to monitor the appropriate parameters, For process monitors, place moveable air monitor in-line.
Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.
Mith the number of OPERABLE Channels one less than required by the Minimum Channels OPERABLE requirement, either restore the inoperable channel(s) to OPERABLE status within 7 days, or:
l.
Initiate the Preplanned Alternate Sampling Program of Spec-ification 6.16 to monitor the appropriate parameter(s).
2.
Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days folic'~in".
'he event outlining the action(s) taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status
0
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.3.3.1 Action 28 The proposed amendment
.request Consideration because:
1 does not involve a
Significant Hazards (A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specification.
The Pre-Planned Alternate Sampling Program is not required by the Standard Tech.
Spec.
Review Plan.
The design of our high range monitors is consistent with regulatory guidance, therefore, no special Tech.
Spec.
considerations are necessary.
Deletion of the Pre-Planned Alternate Sampling Program from Technical Specifications The need to maintain the Pre-Planned Alternate Sampling Program (PASP) as a
Technical Specification Program is unnecessary.
The PASP has no precedented counterpart in the Standard Technical Specifications.
Notification of deficiencies in the Operability status of High Range and Accident Analysis monitors and system may be achieved by the existing system of Special Report submittals.
Enforcement action may be initiated based on the submittals should efforts of the facility staff to correct these situations be found to be repeatedly inadequate.
The existing Pre-Planned Alternate Sampling Program and other pre-planned contingencies should be maintained by the facility outside the scope of Technical Specification requirements.
Regardless of the deletion of PASP as a Technical Specification
- Program, items I and III on the following table are requested to be deleted for the reasons listed.
In addition, current regulatory guidance does not require a backup system for the Post Accident Sampling System.
Nl
RL'ASOH I.
3.3.3.1 3.3-6 27.(1)
Delete Section 1 and change sections 2 and 3 to 1 and 2 respectively.
Pre-planned Alternates to these monitors are found in EPIP's and are implemented at all times.
II. 3.3.3,1 3.3-6 p3-39 28(1)
Delete Section 1 and change section 2 to follow the phrase "within 7 days".
Current Regulatory guidance does not require a backup system for a manual PASS.
p3-38 Instrument 3-Delete m in its entirety Any definition requirements not contained in Tech Specs can be found in the Station Nanual.
III. 3.3.3.9 3.3-13 37(a)
Delete "a." change to:
a.
Place movable air monitors in line.
b.
Take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Regardless of the deletion of PASP, this should be changed as stated since existing "a" is not an appropriate alternative to "b".
IV.
3.3.3.9 3.3-13
<2(a)
Delete "a" change "b" statement to follow the word "or" PASP vill be implemented by Station Planual Procedures.
V.
6.5.3.5 Delete item "1". from audit list.
If PASP is not a program it need not be audited by NSG.
VI.
6.8.1 Delete item "k" from list.
Redesignate remaining listings to follow in order beginning with k.
If PASP is not a Tech Spec Program its implementation should not be required by Tech Specs.
II VlI.
6.16 Delete in its entirety.
Deletion requested per this submit'tal.
TABLE 3. 3"6 (Continued)
ACTION STATEMENTS ACTION 22-ACTION 23-ACTION 24-ACTION 25 "
ACTION 26 "
ACTION 27-With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, perform area surveys of the monitored area with portable monitoring instrumentation at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.4.5. 1.
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9. 12 or operate the fuel build-ing essential ventilation system while handling irradiated fuel.
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, comply with the ACTION requirements of Specification 3.9.9.
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of the control room emergency ventilation system in the recirculation mode of operation.
With the number of OPERABLE Channels less than required by the Minimum Channels OPERABLE requirement, either restore the inoperable channel(s) to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or:
1.
For area monitors RU-139 A and B, RU-140 A and B, RU-148 and RU-149, initiate a preplanned alternate program to monitor the appropriate parameters, 2.
For process monitors, place moveable air monitor in-line.
3.
Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days following the event outlining the action taken, the cause of the inoperabH ity, and the plans and schedule for restoring the system to OPERABLE status.
ACTION 28-With the number of OPERABLE Channels one less than required by'he Minimum Channels OPERABLE requirement, either restore the inoperable channel(s) to OPERABI E status within 7 days, o l.
Initiate the Preplanned Alternate Sampling Program of Spec-ification 6.16 to monitor the appropriate parameter(s).
Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days follow'T~".
'he event outlining the action(s) taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.
PAL0 vERDE - UNIT 2~~) ITqcIP 3
P~g
~,
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.3.3.1 Action 37 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would
- not, 1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; and (B)
The proposed amendment is a
purely administrative change to technical specification.
The Pre-Planned Alternate Sampling Program is not required by the Standard Tech.
Spec.
Review Plan.
The design of our high range monitors is consistent with regulatory guidance, therefore, no special Tech.
Spec.
considerations are necessary.
0
Deletion of the Pre-Planned Alternate Sampling Program from Technical Specifications The need to maintain the Pre-Planned Alternate Sampling Program (PASP) as a
Technical Specification Program is unnecessary.
The PASP has no precedented counterpart in the Standard Technical Specifications.
Notification of deficiencies in the Operability status of High Range and Accident Analysis monitors and systems may be achieved by the existing system of Special Report submittals.
Enforcement action may be initiated based on the submittals should efforts of the facility staff to correct these situations be found to be repeatedly inadequate.
The existing Pre-Planned Alternate Sampling Program and other pre-planned contingencies should be maintained by the facility outside the scope of Technical Specification requirements.
Regardless of the deletion of PASP as a technical Specification
- Program, items I and III on the following table are requested to be deleted for the reasons listed.
0 0
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.3.3.1 Action 37 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; and (B)
The proposed amendment is a
purely administrative change to technical specification.
The Pre-Planned Alternate Sampling Program is not required by the Standard Tech.
Spec.
Review Plan.
The design of our high range monitors is consistent with regulatory guidance, therefore, no special Tech.
Spec.
considerations are necessary.
aeeesawawam~m
~ ~ ~w
- L ELOLL M,lluh e ki"iJfAi;iJ"(iihVOL'EhSOH I.
3.3.3.1 3.3-6 27 (1)
Delete Section 1 and change sections 2 and 3 to 1 and.2 respectively.
Pre-planned Alternates to these monitors are found in EPIP's and are implemented at all times.
II.
3.3.3..1 3.3-6 p3-39 28(1)
Delete Section 1 and change section 2 to follow the phrase "within 7 days".
Current Regulatory guidance does not require a backup system for a manual PASS.
p3-38 Instrument 3-'Delete Hg in its entirety Any definition requirements not contained in Tech Specs can be found in the Station lttanual.
III. 3.3.3.9 3.3-13 37(a)
Delete "aF change to:
a.
Place movable air monitors in line.
b.
Take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Regardless of the deletion of PASP, this should be changed as stated since existing "a" is not an appropriate alternative to "b".
IV.
3.3.3.9 3.3-13
<2(a)
Delete "a" change "b" statement to follow the word or PASP will be implemented by Station Phnual Procedures.
V.
6.5.3.5 Delete item "1". from audit list.
If PASP is not a program it need not be audited by NSG.
VI.
6.8.1 Delete item "k" from list.
Redesignate remaining listings to follow in order beginning with k.
If PASP is not a Tech Spec Program its implementation should not be required by Tech Specs.'/
VII.
6.16 Delete in its entirety.
Deletion requested per this submittal.
TABLE 3'-13 Continued TABLE NOTATION At all times.
"* During GASEOUS RADWASTE,SYSTEM operation.
¹ During waste gas release.
¹¹ In MODES 1, 2, 3, and 4 or when irradiated fuel is in the fuel storage pool.
ACTION 35 -
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, the contents of the tank(s) may be released to the environment provided that prior to initiating the release:
a.
At least two independent samples of the tank's contents are analyzed, and b.
At least two technically qualified members of the facility staff independently verify the release rate calculations and discharge valve lineup; Otherwise, suspend release of radioactive effluents via this'athway.
ACTION 36-ACTION 37 "
Qr, ACTION 38 "
ACTION 39-With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided the flow rate is estimated at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via this pathway may continue provided the actions of (a) or (b) are performed:
a.
Initiate the Pr'eplanned Alternate Sampling Program of Specification 6.16 to monitor the appropriate parameter(s).
J5.
Place moveab1e air monitors in-line ~take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, immediately suspend PURGING of radioactive effluents.via this pathway.
With the number of channnels OPERABLE one less than required by the Minimum Channels OPERABLE requirement, operation of the GASEOUS RADWASTE SYSTEM may continue provided grab samples are taken and analyzed daily.
With both channels inoperable operation may continue provided grab samples are taken and analyzed (1) every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during degassing operations, and (2) daily during other operations.
PALO VERDE - UNIT 2 3/4 '3-'75
( O~>)7ROLLED 8'f USEP
P
(
~
~
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecifica'tion 3/4.3.3.1 Action 42 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specification.
The Pre-Planned Alternate Sampling Program is not required by the Standard Tech.
Spec.
Review Plan.
The design of our high range monitors is consistent with regulatory guidance, therefore, no special Tech.
Spec.
considerations are necessary.
Deletion of the Pre-Planned Alternate Sampling Program from Technical Specifications The need to maintain the Pre-Planned Alternate Sampling Program (PASP) as a
Technical Specification Program is unnecessary.
The PASP has no precedented counterpart in the Standard Technical Specifications.
Notification of deficiencies in the Operability status of High Range and Accident Analysis monitors and systems may be achieved by the existing system of Special Report submittals.
Enforcement action may be initiated based on the submittals should efforts of the facility staff to correct these situations be found to be repeatedly inadequate.
The existing Pre-Planned Alternate Sampling Program and other pre-planned contingencies should be maintained by the facility outside the scope of Technical Specification requirements.
Regardless of the deletion of PASP as a Technical Specification
- Program, items I and III on the following table are requested to be deleted for the reasons listed.
In
- addition, the, Pre-Planned Alternate Sampling Program will be implemented by Station Manual procedures.
I 0
i'll bl'Lv v m.llUN e
~M~~CDT lAOLl el l~r%i.KClXtl'BSt RL UlkL~I)
' ( L EhSOH I.
3.3.3.1 3.3-6 Delete Section 1 and change sections 2 and 3 to 1 and 2 respectively.
Pre-planned Alternates to these monitors are found in EPIP's and are implemented at all times.
II.
3.3.3..1 3.3-6 p3-39 28(1)
Delete Section 1 and change section 2 to follow the phrase "within 7 days".
Current Regulatory guidance does not require a backup system for a manual PASS.
p3-38 Instrument 3-Dele(e gag in its entirety Any definition requirements not contained in Tech Specs can be found in the Station Nanual.
III. 3.3.3.9
\\
3.3-13 37(a)
Delete "aP change to:
a.
Place movable air monitors in line.
b.
Take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Regardless oF the deletion of PASP, this should be changed as stated since existing "a" is not an appropriate alternative to "b".
IV.
3.3.3.9 3%3 13 42(a)
Delete "a" change "b" statement to follow the word "or" PASP will be implemented by Station ttlanual Procedures.
V.
6.5.3.5 Delete item "1". from audit list.
If PASP is not a program it need not be audited by NSG.
VI.
6.8.1 Delete item "k" from list.
Redesignate remaining listings to follow in order beginning with k.
If PASP is not a Tech Spec Program its implementation should not be required by Tech Specs.
II VII.
6.16 Delete in its entirety.
Deletion requested per this submittal.
TABLE 3. 3-13 (Continued TABLE NOTATION ACTION 40-With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement, effluent releases via the effected pathway may continue provided samples are contin-uously collected with auxiliary sampling equipment as required in Table 4.11-2 within one hour after the channel has been declared inoperable.
ACTION 41 -
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirements, comply with the ACTION b of Specification 3.9. 12 or operate the fuel building essential
'entilation system while moving irradiated fuel.
ACTION 42 -
With the number of channels OPERABLE less than required by the Minimum Channels OPERABLE requirement restore the channel to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> o~
a.
Initiate the Preplanned Alternate Sampling Program of Specification 6.16 to monitor the appropriate parameter(s) when it is needed.
b.
Prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days following the event outlining the action(s) taken, the cause of the inoperability, and the plans and schedule for restoring the system to OPERABLE status.
GMTRGLLE8 BY USER
~,
0
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.3.3.1 Table 3.3-6 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specification.
The Pre-Planned Alternate Sampling Program is not required by the Standard Technical Specification Review Plan.
The design of our high range monitors is consistent with regulatory
- guidance, therefore, no special tech.
spec.
considerations are necessary.
0
Deletion of the Pre-Planned Alternate Sampling Program from Technical Specifications The need to maintain the Pre-Planned Alternate Sampling Program (PASP) as a
Technical Specification Program is unnecessary.
The PASP has no precedented counterpart in the Standard Technical Specifications.
Notification of deficiencies in the Operability status of High Range and Accident Analysis monitors and systems may be achieved by the existing system of Special Report submittals.
Enforcement action may be initiated based on the submittals should efforts of the facility staff to correct these situations be found to be repeatedly inadequate.
The existing Pre-Planned Alternate Sampling Program and other pre-planned contingencies should be maintained by the facility outside the scope of Technical Specification requirements.
Regardless of the deletion of PASP,as a Technical Specification
- Program, items I and III on the following table are requested to be deleted for the reasons listed.
Station Manual procedures will define the minimum channels required if not listed elsewhere in the Technical Specifications.
lI 0,
ir.alt 61'r.v rs ihuLL 8
Ri; Ui:Rf;iihllABUE REASON
,I.
3.3.3.1 3.3-6 27.(1)
Delete Section 1 and change sections 2 and 3 to 1 and 2 respectively.
Pre-planned Alternates to these monitors are found in EPIP's and are implemented at all times.
II.
3.3.3,1 3.3-6 p3-39 28(1)
Delete Section 1 and change section 2 to follow the phrase "within 7 days" ~
Current Regulatory guidance does not require a backup system for a manual PASS.
p3-38 Instrument 3-Delete gg in its entirety Any definition requirements not contained in Tech Specs can be found in the Station Nanual.
III. 3.3.3.9 3.3-13 37(a)
Delete "a." change to:
a.
Place movable air monitors in line.
b.
Take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Regardless of the deletion of PASP, this should be changed as stated since existing "a" is not an appropriate alternative to "b" ~
IV.
3.3.3.9 3.3-13
~2(a)
Delete "a" change "b" statement to follow the word "or" PASP will be implemented by Station Phnual Procedures.
V.
6.5.3.5 Delete item "1". from audit list.
If PASP is not a program it need not be audited by HSG.
VI.
6.8.1 Delete item "k" from list.
Redesignate remaining listings to follow in order beginning with k.
If PASP is not a Tech Spec Program its implementation should not be required by Tech Specs.
V1I.
6.16 Delete in its entirety.
Deletion requested per this submittal.
j
'I 0'
h
TABLE 3.3-6 RADIATION MONITORING INSTRUMENTATION INSTRUMENT Area Honitors A.
Fuel Pool Area RU-31 B.
New Fuel Area RU-19 C.
Containment RU-148 8 RU-149 D.
Containment Power Access Purge Exhaust RU-37 8 RU-38 MINIMUM CHANNELS APPLICABLE ALARM/TRIP OPERABLE MODES SETPOINT MEASUREMENT RANGE ACTION 1,2,3,4
<15mR/hr
<15mR/hr
<10R/hr 10-i to 104mR/hr 22 8I 24 10-~ to 10~mR/hr 22 1R/hr to 107R/hr.
27
<2.5mR/hr 10-~ to 10-4mR/hr 25 E.
Hain Steam 1)
RU-139 A8B 2)
RU-140 A8B 2.
Process Monitors A.
Containment Building Atmosphere RU-1 1)
Particulate 2)
Gaseous 1,2,3,4 1,2,3,4 1,2,3,4 10-3 to 104R/hr 27 10-s to lO~R/hr 27 23 8I 27
<2.3xl0- pCi/cc 10-to 10- pC1/cc Cs-137
<6.6xl0- jjCi/cc 10-to 10-'pCi/cc Xe-133 Noble Gas Monitors Control Room Ventilation Intake RU-29 8 RU-30 B.
1 3.
Post Accident Sampling System
¹¹ 1,2,3 N.A.
N.A.
28 ALL MODES
<2xlO-yCi/cc 10-to 10- pCi/cc 26
((ith fuel in the storage pool or building.
- lith irradiated fuel in the storage pool.
.. (hen purge is being used.
/'ree 3 t mes back round in Rem/hour.
he Minimum Channels Operable w>
1 be defined in the Preplanned Alternate Sampling Program
)f Specification
- 6. 16.
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Techn1cal S ecification '3/4.3.3.5 The proposed amendment request does not 1nvolve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
l)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a s1gnificant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specifications.
This change corrects typos and makes corrections to equipment designators.
This change will help to insure that surveillance procedures contain the correct 1nformation.
This change has no impact on plant operat1on.
1
~
0
DISCONNECT SWITCHES SMITCH LOCATION I.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
. 12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
SG 1 line 2 Atmospheric Dump Valve Solenoid Air Isolation Valves SGB"HY-178A and SGB-HY-178R SG 2 line 1 Atmospheric Dump Valve Solenoid Air Isolation Valves SGB-HY-185A and SGB-HY-185R Auxiliary Spray Valve CHB"HV-203 Letdown to Regenerative Heat Exchanger Isolation, CHB-UV-515 Reactor Coolant Pump Controlled Bleedoff, CHB-P(V-505 Auxiliary Feedwater Pump B to SG 1 Control Valve, AFB-HV-30 Auxiliary Feedwater Pump B to SG 2 Control Valve, AFB-HV-31 Auxiliary Feedwater Pump 8 to SG 1 Block Valve, AFB"UV-34 Auxiliary Feedwater Pump B to SG 2 Block Valve, AFB-UV-35 Pressurizer Backup Heaters Banks
- 810, B18, A05 Control Safety Injection Tank 2A Vent Control SIB-HV-613 Safety Injection Tank 2B Vent Control SIB-HV-623 Safety Injection Tank-1A Vent Control SIB-HV-633 Safety Injection Tank 1B Vent Control SIB-HV-643 Safety Injection Tank Vent Valves Power Supply SIB-HS-18A SG 1 line 2 Atmospheric Dump Valve Solenoid Air Isolation Valves SGD-HY-1788 and SGD-HY-178S SG 2 line 1 Atmospheric Dump Valve Solenoid Air Isolation Valves SGD-HY"185B and SGD-HY-185S Control BLDG Battery Room D
Essential Exhaust Fan
'HJB-J01A'ontrol BLDG Battery Room 8 Essential Exhaust Fan
'HJB-J018'attery Charger D Control Room Circuits PKD-H14 ESF Switchgear Room Essential AHU HJB-Z03 LPSI Pump SIB-P01 Breaker Control Diesel Generator B Breaker Control Essential Spray Pond Pump SPB-POl Breaker Control RSP RSP RSP RSP RSP RSP RSP RSP RSP RSP RSP RSP RSP RSP RSP RSP RSP PHB-H3205 PHB-H3205 PHB-H3209 ANO PKD-H14 PHB-H3205 PBB-S04F PBB-S04B PBB-S04C
l
~
i
DISCONNECT SWITCHES
- 25. Essential Chiller ECB-EOl Breaker Control 26.
E-PBB-S04J 4.16KV Feeder Breaker to 480V Load Center PGB"L32 27.
E-PBB-SQ4H 4.16KV Feeder Breaker to 480V Load Center PGB-L34 28.
E-PBB-S04N 4. 16KV Feeder Breaker to 480V Load Center PGB-L36
- 29. Auxiliary Feedwater Pump AFB-P01 Breaker Control
- 30. Essential Cooling Water Pump EWB-P03. Breaker Control 31.
E-PGB-L32BZ 480V Main Supply Breaker to Load Center PGB-L32 32.
E-PGB-L34B2 480V Main Supply Breaker to Load Center PGB-L34 33.
E-PGB-L36B2 480V Main Supply Breaker to Load Center PGB-L36 34.
Charging Pump No.
2 CHB-POl Supply Breaker CHB-P01
- 35. Diesel Engine Control Switch HS-2A
- 36. Diesel Engine Control Switch HS-2B
- 37. Diesel Generator Control Switch HS-2
- 38. Diesel Generator Essential Exhaust Fan HDB"J01
- 39. Diesel Generator Fuel Oil Transfer Pump DFB-POl
- 40. Battery Charger BD Control Room Circuits PKB-H16
- 41. Battery Charger B
Control Room Circuits PKB-H12 42.
125 VDC Battery B Breaker Control Room Circuits 43.
125 VDC Battery D Breaker Control Room Circuits 44.
CS Pump B Discharge to SD HX B SIB-HV"689 45.
Shutdo Cooling LPSI Suction SIB-
"656 v
46.
LPSI-CS from SD HX B X-Tie SIB"HV-695 47.
Shutdown Cooling Warmup Bypass SIB-HV-690 48.
LPSI-CS to SD HX B Crossti e SIB-HV-694 49.
SD HX "B" to RC Loops 2A/2B SIB-HV-696 SWITCH LOCATION I
PBB"$04G PBB-S04J PBB-S04H PBB-S04N PBB-S04S PBB-S04M PGB-L32B2 PGB-L34B2 PGB-L36B2 PGB-L32CP'I DGB-COl DGB-Col DGB-C01 DGB-C01 DGB-C01 PHB"M3425 PHB"M3627 PKB-M4201 PKD-M4401 PHB-M3804 PHB-M3611 PHB-M3810 PHB-M3806 PHB-M3416 PHB-M3416
0
DISCONNECT SWITCHES 50.
LPSI-SD HX "B" Bypass, SIB"HV-307 51.
LPSI Pump "B" Recirc SIB-UV-668 52.
LPSI Pump "8" Suction from RWT SIB-HV-692 53.
SD Cooling LPSI Pump "8" Suction SIB-UV-652 54.
SD Cooling LPSI Pump "B" Suction SID-UV-654 55.
LPSI Header "B" to RC Loop 2A SIB"UY"615 56.
LPSI Header "B" to RC Loop 2B SIB-UV"625 57.
VCT Outlet Isolation CHN-UY-501 58.
RWT Gravity Feed CHE-HV-536 59.
Shutdown Cool Temperature Control SIB-Y-658 60.
Shutdown Cooling Heat Exchanger Bypass Valve SIB-HV-693
- 61. 4.16 KV Bus PBB-S04 Feeder from XFMR NBN-X04
- 62. 4. 16 KV Bus PBB-S04 Feeder from XFMR NBN-X03.
- 63. Electrical Penetration Room B
ACU HAB"Z06
O.S.A. Supply Damper HJB-M02 66.
O.S.A. Supply Damper HJB-MQ3 67.
R.C.S.
Sample Isolation Valve SSA-UV-203 68.
R.C.S.
Sample Isolation Valve SSB-UV-200 69.
125 VDC Battery A Breaker Control Room Circuits SWITCH LOCATION PHB-M3803 PHB"M3611 PHB-M3805 PHB"M3611
'KD-B44 PHB-M3611 PHB-M3640 NHN-M7208 NHN-M7209 PHB-M3416 PHB-M3416 PBB-S04K PBB"S04L
'HB-M3640 RSP RSP RSP SSA-J04 RSP PKA-M4101 PALO VERDE - UNIT 2 3/4 3"'52
0
~i/ ~I l l rX'~23ClMI&LB
.'3 I
2 AM~. IA4 CONTROL CIRCUITS
- 1. Auxiliary Feedwater Pump B to S/G 1 Isolation Valve AFB-UV-34
- 2. Auxiliary Feedwater Pump B to S/G 1 Control Valve AFB-HV-30 "
- 3. Auxiliary Feedwater Pump B to S/G 2 Isolation Valve AFB-UV-35
- 4. Auxiliary Feedwater Pump B to S/G 2
Control Yalve AFB-HV-31
- 5. Auxiliary Feedwater Pump AFB-Pol
- 6. Charging Pump No.
2 CHB-POl
- 7. Pressurizer Auxiliary Spray Valve CHB-HV-203
- 8. Pressurizer Backup Heater Bank 9.
Letdown to Regen HX Isolation Valve CHB-UV-515 10.
RCP Cont Bleedoff Valve CHB-UY-505 ll. Volume Control Tank Outlet Isolation Val ve CHN-UV-501 12.
RWT Gravity Feed Isolation Va1ve CHE-HV-536 13.
S/G 1 line 2 Atmospheric Dump Valve Controller SG8-HIC-178B 14.
S/G 1 line 2 Atmospheric Dump Valve Solenoid Air Isolation Valves SGB-HY-178A and SGB-HY-178R 15.
S/G 1 line 2 Atmospheric Dump Yalve Solenoid Air Isolation Valves SGD-HY-178B and SGD-HY-1785 16.
S/G 2 line 2 Atmospheric Dump Valve Controller SGB"HIC-185B 17.
S/G 2 line 1 Atmospheric Dump Valve Solenoid Air Isolation Valves SGB-HY-185A and SGB-HY-185R 18.
S/G 2 line 1 Atmospheric Dump Valve Solenoid Air Isolation Valves SGD-HY-185B and SGD"HY-185S
- 19. Diesel Generator B Output Breaker
- 20. Diesel Generator Building Essential Exhaust Fan HDB-JOl
- 21. Diesel Generator B Fuel Oil Transfer Pump DFB-P01 22.
E-PBB-S04H 4.16 KV Feeder Breaker to 480V Load Center PGB-L34 23.
E-PBB-SOOJ 4.16KV Feeder Breaker to 480V Load Center PGB-L32 24.
E-PBB"S04N 4.16KY Feeder Breaker to 480V Load Center PGB-L36 25.
E"PGB-L32B2 480V Main Supply Breaker To Load Center PGB-L32 26.
E-PGB-L34B2 480V Main Supply Breaker To Load Center PGB-L34 SMITCH LOCATION
)
'SP RSP RSP PBB-S04S PGB-L32C4 RSP RSP RSP RSP NHN-M7208 NHN-M7209 RSP RSP RSP RSP RSP RSP PBB-S04B DGB-B01 DGB-B01 PBB"S04H PBB-S04J PBB-S04N PGB"L32B) l PQB-L34Bg (
0
CONTROL CIRCUITS 27.
E-PGB-L36 480V Supply Breaker To Load Center PGB-L36
- 28. Battery Charger PKB-H12 Supply Breaker
- 29. Battery Charger PKO-H14 Supply Breaker 30.
Backup Battery Charger PKB-H16 Supply Breaker
- 31. Essential Spray Pond Pump SPB-P01
- 32. Essential Cooling Mater Pump EMB-P01
- 33. Essential Chilled Mater Chiller ECB-EOl
- 34. Battery Room D Essential Exhaust Fan HJB-J01A
- 35. Battery Room B Essential Exhaust Fan HJB-JOlB 36.
ESF Switchgear Room B
Essential AHU HJB-Z03
- 37. Electrical Penetration Room B
ACU Fan HAB-Z06 38.
SIT Vent Valves Power Supply SIB-HS-18/ 8 39.
SIT 2A Vent Valve SIB-HV-613 40.
SIT 2B Vent Valve 5IB-HV-623 41.
SIT lA Vent Valve SIB-HV-633 42.
SIT 1B Vent Valve SIB-HV-643 43.
LPSI Pump B
SIB-P01 44.
Containment Spray Pump B
Discharger to SD HX "B" Valve SIB-HV-689 45.
LPSI Containment Spray from SD HX "B" X-tie Valve SIB-HV-695 46.
Shutdown Cooling LPSI Suction Valve SIB"UV-656 47.
Shutdown Cooling Marmup Bypass Valve SIB-HY-690 48.
LPSI Containment Spray to SD HX "B" X-tie,Valve SIB-HV-694 SMITCH LOCATION PGB-[36' PHB-M3627 PHB-M3209 PHB-M3425 PBB-S04C PBB-S04M PBB-S04G PHB-M3206 PHB-M3207 PHB-M3203 PHB-M3631 RSP RSP RSP RSP RSP PBB-S04F PHB-M3804 PHB-M3810 PHB-M3605 PHB-M3806 PHB"M3414 PALO VERDE - UNIT 2w w
':~i <=:->3/4 3 54,,
0
~
~
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION I
Unit 2 Technical S ecification 3.3.3.6 Table 3.3-10 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specifications.
This change will correctly associate the action statements to table 3.3-10.
l 0
0
ACTION 29-ACTION 30-ACTION 31-ACTION 32-
- 3. 3-/0 TABLE~~
ACTION STATEMENTS I
With the number of OPERABLE Channels one less than the Required Number of Channels in Table 3.3-10, either restore the Inoperable Channel(s) to OPERABLE status within 7 days, or be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
With the number of OPERABLE Channels one less than the Hinimum Channels OPERABLE in Table 3.3-10', either restore the Inoperable Channel(s) to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
With the number of OPERABLE Channels one less than the Required Number of Channels, either restore the system to OPERABLE status within 7 days if repairs are feasible without shutting down or prepare and submit a Special Report to the Commission pursuant to Specification 6.9.2 within 30 days following the event out-lining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.
With the number of OPERABLE Channels one less than the Minimum Channels OPERABLE in Table 3.3-10, either restore the inoperable channel(s) to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> if repairs are feasible without shutting down or:
l.
Initiate an alternate method of monitoring the reactor vessel inventory; 2.
Prepare and submit a Special Report to the Commission pur-suant to Specification 6.9.2 within 30 days following the event outlining the action taken, the cause of the inopera-bility and the plans and schedule for restoring the system to OPERABLE status; and 3.
Restore the system to OPERABLE status at the next scheduled.
refuel ing.
PALO VERDE - UNIT 2~~Myp~3$t 3 6$ py'jgpg
0
~
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.6.2.2 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a'ignificant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; and (B)
The proposed amendment is a
purely administrative change to technical specifications:
for
- example, a
change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.
This change will make this Specification consistent with Specification 3.6.2.1 which prescribes operability requirements for
- the containment spray system.
The containment spray system must be operable before the iodine removal system can perform its function.
0 1,
0
CONTAINMENT SYSTEMS IODINE REMOVAL SYSTEM LIMITING CONDITION FOR OPERATION
'.6.2.2 The iodine removal system shall be OPERABLE with:
a.
An spray chemical addition tank containing a level of between 90K and lOOX (816 and 896 gallons) of between 33X and 35K by weight N2H4
- solution, and ACTION:
r r
With the iodine removal system inoperable, i estore the system to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />;-
restore the iodine removal system to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
b.
Two spray chemical addition pumps each capable of adding N2H4 solution from the spray chemical addition tank to a containment spray system pump, flow.
APPLICABILITY:
MODES 1, 2, 3, and 4.
'l4 SURVEILLANCE RE UIREMENTS 4.6.2.2 The iodine removal system.shal,l be demonstrated OPERABLE:
a.
At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked,
- sealed, or otherwise secured in position, is in its correct position.
b.
At least once per 6 months by:
1.
Verifying the contained solution volume in the tank, and 2.
Verifying the concentration of the N2H4 solutiori by chemical analysis.
c.
By verifying that on recirculation flow, each "spray chemical addition pump develops a discharge pressure of 100 psig when tested pursuant to Specification 4.0.5.
d.
At least once per 18 months,,during
- shutdown, by l.
Verifying that each automatic valve in the flow path actuates
'o its correct position on a containment spray actuation (CSAS) test signal, and 2.
Verifying that each spray chemical addition pump starts automatically on a CSAS test signal.
NHF 4 78K t'.oA 74/N Pgf47 Is R F-Q J I Cf='0 7O 96
@Pl-'Rrf 60C.
PALO VERDE " UNIT 2
.3/4 6-17
If
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.7.9 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; and The proposed amendment is a
purely administrative change to technical specifications.
4.7.9.a This change corrects the title of this section.
The section clearly addresses snubber types rather than inspection types.
4.7.9.c This change corrects a typo in the word susceptible, and deletes a
sentence which does not apply since there are no such snubbers at PVNGS.
4.7.9.d 4.7.9.f.4 This change clarifies the sentence and improves the grammar.
This section should be deleted since there are no such snubbers at PVNGS.
n e
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b 4
PLANT SYSTEMS 3/4.7.9 SNUBBERS LIMITING CONDITION FOR OPERATION 3.7.9 All hydraulic and mechanical snubbers shall be OPERABLE.
The only snubbers excluded from this requirement are those installed on nonsafety-related systems and then only if their failure or failure of the system on which they are installed, would have no adverse effect on any safety-related system.
APPLICABILITY:
MODES 1, 2, 3, and 4.
MODES 5 and 6 for snubbers located on systems required OPERABLE in those MODES.
ACTION:
kith one or more snubbers inoperable on any system, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> replace or restore the inoperable snubber(s) to OPERABLE status and perform an engineering evaluation per Specification 4.7.9g.
on the attached component or declare the attached system inoperable and follow the appropriate ACTION statement for that system.
.SURVEILLANCE RE UIREMENTS 4.7.9 Each snubber shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 4.0.5.
RdUQQi Q a.
T es As used in this specification, type of snubber shall mean snubbers of the same design and manufacturer, irrespective of capacity.
b.
Visual Ins ections Snubbers are categorized as inaccessible or accessible during reactor operation.
Each of these groups (inaccessible and accessible) may be inspected independently according to the schedule below.
The first inservice visual inspection of each type of snubber shall be performed after 4 months but within 10 months of commencing POKER OPERATION and shall include all hydraulic and mechanical snubbers.
If all snubbers of each type are found OPERABLE during the first inservice visual inspection, the second inservice visual inspection of that type shall be performed at the first refueling outage.
Otherwise, subsequent visual inspections of a given type shall be performed in accordance with the following schedule:
PALO VERDE - 'UNIT 2 '14 7-2l CAW7PP)ll ll lFP AV I f%PP
PLANT SYSTEMS
<Ql>.JTR'Gk.l-D 3Y ~~<"
SURVEILLANCE RE UIREMENTS Continued)
No. of Inoperable Snubbers of Each Type er Ins ection Period Subsequent 'Visual Ins ection Period"¹ C.
0 1
2 3,4 5,6,7 8 or more Visual Ins ection Acce tance Criteria 18 months i 25K 12 months t 25K 6 months k 25K 124 days t 25K 62 days k 25K 31 days a 25K Visual inspections shall verify that:
(1) there are no visible indica-tions of damage or impaired OPERABILITY and (2) attachments to the foundation or supporting structure are secure, and (3) fasteners for attachment of the snubber to the component and to the snubber anchorage are secure.
Snubbers which appear inoperable as a result of visual inspections may be determined OPERABLE for the purpose of establishing the next visual inspection interval, provided that:
(1) the cause of.
the rejection is clearly established and remedied for that particular snubber and for other snubbers irrespective of type on that system a
may e genericall
. and (2) the affected snubber is functionally tested in the as-found condition and determined OPERABLE per Specifications 4.7m 9f.
When a fluid port of a hydraulic snubber is found to be uncovered, the snubber shall be declared inoperable and cannot be determined OPERABLE via functional testing unless the test is started with the piston in the as-found
'xtendin the iston rod in the tension mode direction.
All snubbers connected to an inoperable common h draulic flui reservoir shall be counted as o erable snubbers.
Snubbers which appear inoperable dur>ng an area post maintenance inspection, area walkdown, or Transient Event Inspec-tion shall not be considered inoperable for the purpose of establishing the Subsequent Visual Inspection Period provided that the cause of the inoperability is clearly established and remedied for that particular snubber and for the other snubbers, irrespective of type, that may be generally susceptible.
d.
Transient Event Ins ection An inspection shall be performed of all hydraulic. and mechanical snubbers attached to sections of systems that have experienced unexpected, potentially damaging>transients as determined from a review of operationaT detain~visual inspection of the systemsa
~non within 6 months following such an event.
In addition to satisfying P
"The inspection interval for each type of snubber on a given system shall not be lengthened more than one step at a time unless a generic problem has been identified and corrected; in that event the inspection'nterval may be lengthened one step the first time and two steps thereafter if no inoperable snubbers of that type are found on that system.'The provisions of Specification 4.0.2 are not applicable.
PALO VERDE - UNIT 2 '/4 7 22 P~~TPAII I @6 P>f (kc'PP.
I
~
'~
PLANT SYSTEMS SURVEILLANCE RE UIREMENTS Continued) as the snubber, is tested.
If the point plotted falls on or below the ".Accept" line, testing of that type of snubber may be terminated.
If the point plotted falls above the "Accept" line, testing must continue until the point falls, in the "Accept" region or all the snubbers of that type have been tested.
The representative sample selected for the functional'est sample plans shall be randomly selected from the snubbers of each type and reviewed before beginning the testing.
The review shall ensure as far as practical that they are representative of the various configur-
- ations, operating environments, range of size, and capacity of snubbers of each type.
Snubbers placed in the same locations as snubbers which failed the previous functional test shall be retested at the time of the next functional test but shall not be included in the sample plan. If during the functional testing, additional sampling is required due to failure of only one type of snubber, the functional testing results shall be reviewed at the time to determine if additional samples should be limited to the type of snubber which has failed the functional testing.
f.
Functional Test Acce tance Criteria The snubber functional test shall verify that:
1)
Activation (restraining action} is achieved within the specified range in both tensi6n and compression; 2)
Snubber bleed, or release rate where required, is present in both tension and compression, within the specified range; 3)
For mechanical
- snubbers, the force required to initiate or maintain motion of the snubber is w'ithin the specified range in both directions of travel; and 4)
For snubbers specifically required not to displace under continuous load, the ability of the snubber to withstand load without displacement.
Testing methods may be used to measure parameters indirectly or parameters other than those specified if those results can be correlated to the specified parameters through established methods.
g.
Functional Test Failure Anal sis 9/4 7"24 PALO VERDE - UNIT 2C@n@ALL~P~ICH8~6'.
SURVEILLANCE RE UIREMENTS 4.9. 11 The water level in the, storage pool shall be.determined to be at least its minimum required depth at least once per 7 days when irradiated fuel assemblies are in the fuel storage pool.
PALO VERDE - UNIT 2 3/4 9-13
P '>>
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~
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 6.2-1 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; and (B)
The proposed amendment is a
purely administrative change to technical specifications'for
- example, a
change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.
The revised organization charts reflect pending changes in the Arizona Nuclear Power Project organization.
~-
0 (I'
CEO s ~-i EXECUTIVE VJ'L I
G14 PROJECT COHTROL I
I IL MGL ADMIH. SERVICES PVHGS PLANT MANAGER OIR.
MGR. AHPP OIR. PROJECT SERVICES I
EMPLOYEE RELY,TIONS I
COMMUNICATIONS I
VP.
NUCLEAR PRODUCTION NGR.
NUCLEAR SAFETY ISED/NSG ASST. V,P.
HUCLEAR PRODUCTION I
~
I I
I I
I NGR.
I DIR.
TRANSITION
~
TECHNICAL SERVICES OIR.
CORPORATE OA ASST. NGR.
CORPORATE QA P NS ITIVE MGR.
OUAL1TY SYSTEM~/
EHGIHEERIHG
<~d MGL CONTRACTS I
4 PURCHASING I
I MGR.
PARTIGI AHT SERVICES I
I I
I I
I I
I I'
MGR OPERATIONS I
I MGL MAINTEHAHCE I
I I
MGR. OUTAGE NAHAGENENT I
I NGR PLANT SERVICES I
I MGR.
I TECHNICAL SUPPORT NGR.
HUCLEAR EHGIHEERIHO MGR.
NUCLEAR CONSTRUCTION MGL ENERGEHCY PLAHNLNO MGR. NUCLEAR FUELS NGRe RECORDS NGL PROCUREMEHT OUAL1TY-llGR.
QUALITYAUDITS NOHITORIHG OIISITE MGR.
OVALlTYCONTROLS ONSITE FIGURE 6.2"1 OFFSITE ORGANIZATION MGL LICEHSDIG L
0 0
I t
I II l
EXECUTIVE V.P.
V.P.
NUCLEAR PRODUCTION ASST.
V.P. NUCLEAR PRODUCTION PVNGS PLANT MANAGER MGR.
NUCLEAR SAFETY ISEG/NSG DIR.
TECHNICAL SERVICES DIR.
CORPORATE QA MGR.
EMERGENCY PLAN MGR.
OPERATIONS MGR.
TRANSITION MGR.
NUCLEAR ENGINEERIHG ASST. MGR.
CORPORATE QA MGR.
+
ADMINISTRATIVE SERVICES MGR.
MAINTEHANCE MGR.
NUCLEAR CONSTRUCTION MGR.
QUALITY SYSTEMS/
ENGINEERING MGR.
TRAINING MGR.
OUTAGE MANAGEMENT MGR.
NUCLEAR FUELS MGR.
PROCUREMENT QUALITY WRF SUPERINTENDENT MGR.
PLANT SERVICES MGR. RECORDS MGR.
QUALITY AUDITS/
MONITORING
+
MGR.
TECHNICAL SUPPORT MGR. LICEHSING MGR.
QUALITY CONTROL
+ LOCATED ONSITE FIGURE 6.2-1 OFFSITE ORGANIZATION 710-1112 I2-ll-IKOAK
PVHOS PLANT MANAGER foalal C7 Dl OUTAGE'ANAGEMENT MAHAGER TECHNICAL SUPPORT MANAGER OPERATIONS MAHAGER MAINTEHANCE MANAGER PLANT SERVICES MAHAGER MAHAGER OPS EHGIHEERIHG WRF SUPERIHTEHDENT SUPERVISOR, HRF MAINTEHAHCE MANAGER TRAIHIHG SUPERVISOR STA SUPERINTENDENT UHIT I SUPERIHTEHDEHT IEC MAIHTEHAHCE MANAGER OPERATIONS~
SECURITY ~
MAHAGER RAD. PROT. 4 CHEM.
SUPERINTEHOEHT UNIT 2 SUPERINTENDENT MCC SUPERVISOR&
FIRE PROTECTION PtdhJA C.4a SUPERVISOR COMPLIAHCE SUPERINTENDENT UNIT 3 SUPERINTEHDEHT ELEC. MAIHTEHAHCE SUPERINTEHDEHT OPS COMPUTER SYSTEM SUPERVISOR OPERATIONS SUPPORT SUPERINTEHDENT STATION SERVICES FIGURE 6.2-2 ONSITE UNIT ORGANIZATION SUPERIHTEHDEHT MECHAHICAL MAINTEHAHCE
r -i 0
PVNGS PLANT MANAGER OUTAGE MANAGEMENT MANAGER TECHNICAL SUPPORT MAHAGER OPERATIONS MANAGER MAINTEHANCE MANAGER PLANT SERVICES MANAGER MANAGER OPS ENGINEERING SUPERINTENDENT UNIT I SUPERIHTENDENT ITIC MAINTENANCE MANAGER OPERATIONS SECURITY SUPERVISOR STA SUPERINTENDENT UNIT 2 SUPERINTENDENT MCC SUPERVISOR FIRE PROTECTION MANAGER RAO. PROT. it CHEM.
SUPERINTENDENT UHIT 3 SUPERINTENDENT ELEC. MAINTEHANCE MANAGER COMPLIANCE SUPERVISOR OPERATIONS SUPPORT SUPERINTENDENT STATION SERVICES SUPERINTENDENT OPS COMPUTER SYSTEM SUPERINTENDENT MECHANICAL MAINTENANCE FIGURE 6.2-2 ONSITE UNIT ORGANIZATION TIO-MII/ 2-11-86
e'
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 6.2.2.2a The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; and (B)
The proposed amendment is a
purely administrative change to technical specifications:
for
- example, a
change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.
This change is in response to a
notice of violation and was committed to in our letter ANPP-33926 EEVB/FJH dated ll/5/85.
This letter stated that APS would seek an amendment identifying the specific job classifications to which the overtime limitations shall apply.
0 0
J
ADMINISTRATIVE CONTROLS
- 6. 1 RESPONSIBILITY
- 6. 1. 1 The PVNGS Plant Manager shall be responsible for overall unit'operation and shall delegate in writing'he succession to this responsibility during his absence.
- 6. 1.2 The Shift Supervisor, or during his absence from the Control
- Room, a
designated individual per Table 6.2-1, shall be responsible for the Control Room command function.
A management directive to this effect, signed by the Vice President-Nuclear Production shall be reissued to all station personnel on an annual basis.
- 6. 2 ORGANIZATION OFF SITE 6.2.1 The offsite organization for unit management and technical support shall be as shown in Figure 6.2-1.,
UNIT STAFF 6.2.2.1 a.
C.
d.
e.
The unit organization shall be as shown in Figure 6:2-2 and:
Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2-1.
I
~ At least one licensed Reactor Operator shall be in the Control Room when fuel is in the reactor.
In addition, while the reactor is in MODE 1, 2, 3, or 4, at least one licensed Senior Reactor Operator shall be in the Control Room.
A radiation protection technician" shall be onsite when fu'el, is in the reactor.
All CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concur rent responsibilities during this operation.
A site Fire Team of at least five members shall be. maintained onsite at all times*.
The Fire Team shall. not include the Shift Supervisor, the STA, nor the 3 other members of the minimum shift crew necessary for safe shutdown of the unit and any personnel required for other essential functions during a fire emergency.
6.2.2.2 The unit staff working hours shall be as follows:
a.
Administrative procedures shall be developed and implemented to limit the working hours of unit staff who per form safety-related functions; e.g.,
Senior Reactor Operators, Reactor Operators, radiation protec-tion technicians, auxiliary operators, and key maintenance personnel.
gF Pc.gz,r=
g) g>
I4$fC7
~The radiation protection technician and Fire Team composition may be less than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to accommodate unexpected
- absence, provided immediate action is taken to fill the required positions.
PALO VERDE - UNIT 2 6"1
I 0
Insert A Administrative procedures shall be developed and implemented to limit the working hours of unit staff in the following gob classifications:
1)
Shift Supervisors, Assistant Shift Supervisors, Nuclear Operator III, Nuclear Operator II; 2)
Electricians, I6C Technicians, Computer Technicians, Plant Mechanics, Refrigeration Technicians; 3)
Chemistry Technicians, Radiation Protection Technicians, Radwaste Technicians.
~ r l
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 6.5.3.5 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specification.
The Pre-Planned Alternate Sampling Program is not required by the Standard Tech.
Spec.
Review Plan.
The design of our high range monitors is consistent with regulatory guidance, therefore, no special Tech.
Spec.
considerations are necessary.
Li
Deletion of the Pre-Planned Alternate Sampling Program from Technical Specifications The need to maintain the Pre-Planned Alternate Sampling Program (PASP) as a
Technical Specification Program is unnecessary.
The PASP has no precedented counterpart in the Standard Technical Specifications.
Notification of deficiencies in the Operability status of High Range and Accident Analysis monitors and systems may be achieved by the existing
. system of Special Report submittals.
Enforcement action may be initiated based on the submittals should efforts of the facility staff to correct these situations be found to be repeatedly inadequate.
The existing Pre-Planned Alternate Sampling Program and other pre-planned contingencies should be maintained by the facility outside the scope of Technical Specification requirements.
Regardless of the deletion of PASP as a Technical Specification
- Program, items I and III on the following table are requested to be deleted for the reasons listed.
In addition, since the Pre-Planned Alternate Sampling Program is no longer a required program, it need not be audited by NSG.
P l
/
RL'hSON I.
3.3.3.
3.3-6 27.(1)
Delete Section 1 and change sections 2 and 3 to 1 and "2 respectively.
Pre-planned Alternates to these monitors are found in EPIP's and are implemented at all gimes.
II.
3.3.3,1 3.3-6 p3-39 28(l)
Delete Section 1 and change section 2 to follow the phrase swithin 7 daysv Current Regulatory guidance does not require a backup system for a manual PASS.
p3-38 Instrument 3-Delete ggg in its entirety Any definition requirements not contained in Tech Specs can be found in the Station Nanual.-
III. 3.3.3.9 3.3-13 37(a)
Delete "a." change to:
a.
Place movable air monitors in line.
b.
Take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Regardless oF the deletion of PASP, this should be changed as stated since existing "a" is not an appropriate alternative to "b" ~
IV.
3.3.3.9 3.3-13 42(a)
Delete "a" change "b" statement to follow the word or PASP will be implemented by Station Phnual Procedures.
V.
6.5.3.5 Delete item "1". from audit list.
If PASP is not a program, it need not be audited by NSG.
VI.
6.8.1 Delete item "k" from list.
Redesignate remaining listings to follow in order beginning with k.
If PASP is not a Tech Spec Program its implementation should not be required by Tech Specs.
I/
VlI.
6,16 Delete in its entirety.
Deletion requested per this submittal.
0
"~a+]- Qk.L~D FY U'~'- ~
ADMINISTRATIVE CONTROLS AUDITS Continued g.
The fire protection equipment and program implementation at least
. once per 12 months utilizing either a qualified offsite licensee fire protection engineer or an outside independent fire protection consultant.
An outside independent fire protection consultant shall be used at least every third year.
t h.
The radsological environmental monitoring program and the results thereof at least once per 12 months.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at least once per 24 months.
J.
The PROCESS CONTROL PROGRAM and impl ementing procedures for processing and packaging of radioactive wastes at least once per 24 months.
k.
The performance of activities required by the Operations guality Assurance Criteria Manual to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months.
1.
The Pre-planned Alternate Sampling Program and implementing procedures at least once per 24 months.
AUTHORITY 6.5.3.6 The NSG shall report to and advise the 'Manager of Nuclear Safety on those areas of responsibility specified in Specifications 6.5.3.4 and 6.5.3.5.
RECORDS 6.5.3.7 Records of NSG activities shall be prepared and maintained.
Report of reviews and audits shall be prepared monthly for the Manager of Nuclear Safety who will distribute it to the Vice President-Nuclear Production, PVHGS Plant
- Manager, and to the management positions responsible for the areas audited.
- 6. 6 REPORTABLE EVENT ACTION.
6.6.1 The following actions shall be taken for REPORTABLE EVENTS:
a.
The Commission shall be notified pursuant to the requirements of Section 50.72 to 10 CFR Part 50, and a report submitted pursuant to the requirements of Section 50.73 to 10 CFR Part 50, and b.
Each REPORTABL'E EVENT shall be reviewed by the
- PRB, and the results of this review shall be submitted to the Supervisor of Huclear Safety Group and the Vice President-Nuclear Production.
PALO VERDE - UNIT 2 6"12 p~P,ITPAI.>.%Q @Y UFKP
~,
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 6.8.1 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
purely administrative change to technical specification.
The Pre-Planned Alternate Sampling Program is not required by the Standard Tech.
Spec.
Review Plan.
The design of our high range monitors is consistent with regulatory guidance, therefore, no special Tech.
Spec.
considerations are necessary.
0 t
0
Deletion of the Pre-Planned Alternate Sampling Program from Technical Specifications The need to maintain the Pre-Planned Alternate Sampling Program (PASP) as a
Technical Specification Program is unnecessary.
The PASP has no precedented counterpart in the Standard Technical Specifications.
Notification of deficiencies in the Operability status of High Range and Accident Analysis monitors and systems may be achieved by the existing system of Special Report submittals.
Enforcement action may be initiated based on the submittals should efforts of the facility staff to correct these situations be found to be repeatedly inadequate.
The existing Pre-Planned Alternate Sampling Program and other pre-planned contingencies should be maintained by the facility outside the scope of Technical Specification requirements.
Regardless of the deletion of PASP as a Technical Specification
- Program, it'ems I and III on the following table are requested to be deleted for the reasons listed.
In addition, if the Pre-Planned Alternate Sampling
- Program, is not a
Tech.
Spec.
program, its implementation should not be required by the tech.
specs.
':Wl eO'IS i
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@44 i@.L7l ht'Lv
.~
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4'Ã I Wt EMIT
~
41
~
lhULb 8 AL llUN 8 kL UIRL'I) 4L'L'hSOH M'
I.
3.3.3.
3.3-6 27.(1)
Delete Section 1 and change sections 2 and 3 to 1 and 2 respectively.
Pre-planned Alternates to these monitors are found in EPIP's and are implemented at all times.
II. 3.3.3,l 3.3-6 p3-39 28(l)
Delete Section 1 and change section 2 to follow the phrase vuithin 7 days".
Current Regulatory guidance does not require a backup system for a manual PASS.
p3-38 Instrument 3-Delete gag in its entirety Any definition requirements not contained in Tech Specs can be found in the Station Planual.
III. 3.3.3.9
- 3.3-13 37(a)
Delete "a." change to:
a.
Place movable air monitors in line.
b.
Take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Regardless of the deletion of PASP, this should be changed as stated since existing "a" is not an appropriate alternative to "b".
IV.
3.3.3.9 3'-13 42(a)
Delete va'r change vbv statement to follm the word "or" PASP Millbe iaplemented by Station Phnual Procedures, V.
6.5.3.5 Delete i.tern "1v from audit list.
If PASP is not.a program it need not be audited by NSG.
VI.
6.8.1 Delete item "k" from list.
Redesignate remaining listings to follou in order beginning Mith k.
If PASP is not a Tech Spec Program its implementation should not be required by Tech Specs.
4 I
C VII.
6.16 Delete in its entirety.
Deletion requested per this submittal~
I
1
~
i 0
- 6. 7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:
a.
The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The Vice President-'Nuclear Production, PVNGS Plant Manager and Supervisor of Nuclear Safety Group shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
b.
A Safety Limit Violation Report shall be prepared.
The report shall be reviewed by the PRB.
This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components,
- systems, or structures, and (3) corrective action taken to prevent recurrence.
c.
The Safety Limit Violation Report shall be submitted to the Commission, the Supervisor of the NSG and the Vice President-Nuclear Production within 30 days of the violation.
d.
Critical operation of the unit shall not be resumed until authorized by the Commission.
- 6. 8 PROCEDURES AND PROGRAMS 6.8.1 Mritten procedures shall be established, implemented, and maintained
~
~
~
~
~
~
covering the activities referenced below:
a.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, and those required for implementing the requirements of NUREG-0737.
b.
Refueling operations.
c.
Surveillance and test activities of safety"related equipment.
d.
Security Plan implementation.
e.
Emergency Plan implementation.
f.
Fire Protection Program implementation.
g.
Modification of Core Protection Calculator (CPC) Addressable Constants.
NOTE:
Modification to the CPC Addressable Constants based on information obtained through the Plant Computer -
CPC data link shall not be made without prior approval of the PRB.
h.
PROCESS CONTROL PROGRAM implementation.
i.
OFFSITE DOSE CALCULATION MANUAL implementation.
j.
guality Assurance Program for effluent and environmental monitoring, using the guidance in Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4. 1, Revision 1, April 1975.
k.
Pre-planned Alternate Sampling Program implementation k, g.
Secondary water chemistry program implementation.
PALO VERDE " UNIT 2 6-13
I Il
~
I
iQ:i~I7~0iLiL'~<2 '~ f~:"~
ADMINISTRATIVE CONTROLS NOTE:
The licensee shall perform a secondary water chemistry monitoring and control program that is in conformance with the program discussed in Sec-tion 10.3.4. 1 of the CESSAR FSAR or another HRC approved program.
) y(.
Post-Accident Sampling System implementation.*
~.p'.
Settlement Monitoring Program implementation.
NOTE:
The licensee shall maintain a settlement monitoring program throughout the life of the p'Pant in accordance with the program presented in Table 2.5-18 of the PVHGS FSAR or another NRC approved program.
~.p'.
CEA Symmetry Test Program implementation NOTE:
The licensee shall perform a
CEA symmetry test program in conformance with the program discussed in Section 4.2.2 of the PVNGS SER dated November ll, 1981.
- o. p'.
Fuel Assembly Surveillance Program Implementation NOTE:
The licensee shall perform a fuel assembly surveillance program in con-formance with the program discussed in Section 4.2.4 of the PVHGS SER dated November ll, 1981.
6.8.2 Each program or procedure of Specification 6.8. 1, and changes
- thereto, shall be reviewed as specified in Specification 6.5 and approved prior to implementation.
- Programs, administrative control procedures and implementing procedures shall be approved by the-PVHGS Plant Manager, or designated alternate who is at supervisory level or above.
Programs and procedures of Specifica-tion 6.8.1 shall be reviewed periodically as set forth in administrative procedures.
6.8.3 Temporary changes to procedures
'of Specification 6.8.1 above may be made provided:
a.
The intent of the origirral procedure is not altered.
b.
The change is approved by two members of the plant supervisory staff, at least one of whom is a Shift Supervisor or Assistant Shift Supervisor with an SRO on the affected unit.
c.
The change i's documented; reviewed in accordance with Specification 6.5.2 and approved by the PYNGS plant manager or cognizant department
- head, as designated by the PVNGS plant manager, within 14 days of implementation.
6.8.4 The following programs shall be established, implemented, maintained, and shall be audited under the cognizance of the NSG at least once per 24 months:
a ~
Primar Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a
serious transient or accident to as low as practical levels.
The systems include the recirculation portion of the high pressure safety injection system, the shutdown cooling portion of. the low pressure safety injection system, the post-accident sampling subsystem of the "Hot required until prior to exceeding 5X of RATED THERMAL POWER.
PALO VERDE - UNIT 2 6-14 P~MVPA)<<a PY 'lI~FP
0
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 6.16 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
,The operation of PVNGS Unit 2 in accordance with this change would
- not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; and (B)
The proposed amendment is a
purely administrative change to technical specification.
The Pre-Planned Alternate Sampling Program is not required by the Standard Technical Specification Review Plan.
The design of our high range monitors is consistent with regulatory
- guidance, therefore, no special tech.
spec.
considerations are necessary.
f
Deletion of the Pre-Planned Alternate Sampling Program from Technical Specifications The need to maintain the Pre-Planned Alternate Sampling Program (PASP) as a
Technical Specification Program is unnecessary.
The PASP has no precedented counterpart in the Standard Technical Specifications.
Notification of deficiencies in the Operability status of High Range and Accident Analysis monitors and systems may be achieved by the existing system of Special Report submittals.
Enforcement action may be initiated based on the submittals should efforts of the facility staff to correct these situations be found to be repeatedly inadequate.
The existing Pre-Planned Alternate Sampling Program and other pre-planned contingencies should be maintained by the facility outside the scope of Technical Specification requirements.
The following table is a listing of items to be deleted from Unit I Technical Specifications as reference to pre-planned alternatives.
Regardless of the deletion of PASP as a Technical Specification
- Program, items I and III on the following table are requested to be deleted for the reasons listed.
ichil bl'r4 g LAULl :
-d ":-il'L'it'll REASON I.
3.3.3.1 3.3-6 27.(1)
Delete Section 1 and change sections 2 and 3 to 1 and 2 respectively.
Pre-planned Alternates to these monitors are found in EPIP's and are implemented at all times.
II.
3.3.3..1 3.3-6 p3-39 28(1)
Delete Section 1 and change section 2 to follow the phrase "within 7 days".
Current Regulatory guidance does not requ're a backup system for a manual PASS.
p3-38 Instrument 3-Delete m in its entirety Any definition requirements not contained in Tech Specs can be found in the Station tqanual.
III. 3.3.3.9 3.3-13 37(a)
Delete "a." change to:
a.
Place movable air monitors in line.
bi Take grab samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Regardless of the deletion of PASP, this should be changed as stated since existing "a" is not an appropriate alternative to "b".
IV.
3.3.3.9 3.3-13 42(a)
Delete "a" change "b" statement to follow the word or
~
PASP will be implemented by Station Nanuai Procedures.
V.
6.5.3.5 Delete item "1". from audit list.
If PASP is not a program it need not be audited by NSG.
VI.
6.8.1 Delete item "k" from list.
Redesignate remaining listings to follow in order beginning with k.
If PASP is not a Tech Spec Program its implementation should not be required by Tech Specs.
VII.
6.16 Delete in its entirety.
Deletion requested per this submittal.
o, t
CQ~Pd!7RGLKEB SY USER ADMINISTRATIVE CONTROLS An evaluation of the change, which shows the expected maximum exposures to a MEMBER OF THE PUBLIC in the UNRESTRICTED AREA and to the general population that differ from those previously estimated in the license application and amendments thereto;
~ o A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the changes are to be made; and 6) 7)
An estimate of the exposure to plant operating personnel as a
result of the change.
MAJOR CHANGES TO RADIOACTIVE LI UID GASEOUS AND SOLID WASTE TREATMENT SYSTEMS (Continued) 5)
- 6. 16 PRE-PLANNED ALTERNATE SAMPLING PROGRAM PASP
- 6. 16.1 The PASP shall be approved by the Regional Administrator, U.S.
NRC Region V, prior to implementation.
6.16.2 Licensee-initiated changes to the PASP:
Shall be submitted to the Commission in the Semiannual Radioactive Effluent Release Report for the period in which the change(s) was made.
This submittal shall contain:
1)
Sufficiently detailed information to totally support the rationale for the change without benefit of additional or supplemental information; and 2)
A determination that the change. did not reduce the overall effectiveness of the Gaseous Effluent Sampling Program.
3)
A determination that the change did not reduce the overall effectiveness of the Post Accident Sampling System.
4)
A determination that the change did not reduce the overall effectiveness of. the post-accident High Range Effluent Monitors.
PALO VERDE - UNIT 2 6"25
<AMVPAlI @9 IRY l~~~P
0
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i
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3.1.1.3 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety:
(B)
The proposed amendment is a
change that constitutes an additional limitation, restriction or control not presently included in the technical specifications.
The proposed change revises Technical Specification 3.1.1.3, Moderator Temperature Coefficient.
Technical Specification 3.1.1.3 establishes the range of allowable moderator temperature coefficient (MTC) values as a
function of average moderator temperature.
MFC expresses variation in moderator reactivity per unit change in moderator temperature.
Technical Specification 3.1.1.3 is values of MTC occurring during Unit the safety analyses.
The proposed MEC (appearing on Figure 3.1-1) lo~
Ap/ F.
required to assure that actual (measured) 2 Cycle -1 are bounded by values assumed in change revises the most negative value of from
-3.5 x
10 4 A p/'F to
-3.0 x
The proposed change" in the most negative allowable MTC reflects a change from the existing value; which is a
number selected to bound anticipated equilibrium cycle operation, to a
new value that bounds anticipated Cycle 1, but not necessarily equilibrium cycle, MTC values.
The change is required at this time to validate a Palo Verde FSAR steam line break analysis which uses a
less negative value of MTC than was used for the corresponding CESSAR analysis.
Operation of Palo Verde Unit 2 Cycle 1 in accordance with this proposed change constitutes no significant hazards consideration because the amended technical specification reflects a
more restrictive range of allowable values for the subject parameter.
I v
In response to the no significant hazards consideration, the proposed change will in fact reduce the consequences of accidents which are affected by values permitted by this technical specification, since the new allowable range will be more restrictive than the existing allowable range.
No change to operating procedures is involved; thus. no new path is created which may lea'd -to a new or different kind of accident.
Furthermore, although the proposed change will impose a
greater restriction on the range of allowable values for the subject parameter, no constraints on the operation of the associated, fuel cycle will be imposed because the allowable limits are still anticipated to bound those which will actually occur.
The proposed amendment will not impact any characteristics of the fuel cycle since only a reduction in conservatism applied to the subject parameter is being changed.
Thus there will be no impact in margins of safety during steady-state operation.
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NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3.3.3.7 Table 3.3-11 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety.'B)
The proposed amendment is a
change that is necessary to eliminate spurious actuation of the smoke detectors in fire zones 74A and 74B..
Table 3.3-11 lists 6
as the number of instruments in fire zones 74A and B
respectively at elevations 100', 120'nd 140'.
These smoke detectors actuate when steam passes through the detector chamber.
By changing the smoke detector to heat detectors, steam clouds 'would not affect the system.
This will not change the function of the system as
- designed, the original purpose remains the same.
The heat detectors will be an improvement over the performance of the smoke detectors, therefore, the safety of the plant will not be adversely affected.
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CQNYROLLED BY USER TABLE 3. 3-11 (Continued)
FIRE DETECTION INSTRUMENTS FIRE ELEVATION INSTRUMENT LOCATION ZONE TOTAL NUMBER OF INSTRUMENTS" HEAT FLAME SMOKE
~xy) 7x> y5
~xi'3A 63B 120'2O'o.
2 RCPs and SG Area 6/0 6/0 66A866B 67A867B 140'outhwest, Southeast, Northwest and Northeast Perimeters 1/0 63A 63B 70 71B 72 73 140'4O'4O'40'40 SO'O'o.
'efueling Pool and Canal Area North Preaccess Normal AFU Area South Preaccess Normal AFU Area MAIN STEAM SUPPORT STRUCTURE Turbine Driven Aux. Feedpump Rm.
Motor Driven Aux.
Feedpump Rm.
5/0 5/0 4/O 2/0 2/0 0/3 74A 100',120'ain Steam Isol.
8 Dump Valve 8 140'rea North 74B 100',120' 140'ain Steam Isol.
8 Area South.
OUTSIDE AREAS Dump Valve o ~
. S3 Condensate Storage Tank Pump House 2/0 CQNTRIDI.ILEI5 BY USEIR..
Oi 0
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.5.1 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a change which either may result in some increase to the probability or consequences of a
previously analyzed accident or may reduce in some way a safety
- margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan.
This change will increase the minimum boron concentration in the Safety Injection Tank, and it will increase the amount of level change allowed prior to requiring a verification of boron concentration in the tank.
The increase in minimum boron concentration from 2,000 to 2,400 PPM will adequately compensate for the increased dilution effect which results from the increased level change allowed prior to sampling.
In addition, the boron concentration will be verified at least every 31
- days, as is presently required.
0
3/4. 5 EMERGENCY CORE COOLING SYSTEMS ECCS
~
~
3/4.5. 1 SAFETY INJECTION TANKS LIMITING CONDITION FOR OPERATION With one safety injection tank inoperable, except as a result of a - -.-*
closed isolation valve, restore the inoperable tank to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and.in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
With one safety injection tank inoperable due to the isolation valve being closed, either immediately open the.isolation valve or be in at least HOT STANDBY within I hour and be in HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
b.
3.5.1 Each Reactor Coolant, System safety injection tank shall be OPERABLE with:
a.
The isolation valve key-locked open and power to the valve removed, b.
A contained borated water level of between 1802 cubic feet (28K narrow range indication) and 1914 cubic feet (72 X narrow range indication),
49dO c.
A boron concentration between4900-and 4400 ppm of boron, and d.
A nitrogen cover-pressure of between 600 and 625 psig.
e.
Nitrogen vent valves closed and power removed"".
f.
.Nitrogen vent valves capable of being operated upon restoration of power.
APPLICABILITY:
MODES 1", 2", 3,"f, and 4"f.
ACTION:
ao SURVEILLANCE RE UIREMENTS 4.5.1 Each safety injection tank shall be demonstrated OPERABLE:
a.
At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by:
1.
Verifying the contained borated water volume and nitrogen cover-pressure in the tanks is within the above limits, and I
tW>th pressurizer pressure greater than.or equal to 1837 psia.
When pressur-izer pressure is less than 1837 psia, at least three safety injection tanks must be OPERABLE, each with a minimum pressure of 254 psig and a maximum pressure of 625 psig, and a contained borated water volume of between 1415 cu-bic feet (60K wide range indication) and 1914 cubic feet (83K wide range indication).
With all four safety injection tanks OPERABLE, each tank shall have a minimum pressure of 254 psig and a maximum pressure of 625 psig, and a contained borated water volume of between 962 cubic feet (39K wide range indication) and 1914 cubic feet (83K wide range indication).
In MODE 4 with pressurize) pressure less than 430 psia, the safety injection tanks may be isolated.
"See Special Test Exceptions
- 3. 10.6 and 3. 10.8.
""Nitrogen vent valves may be cycled as necessary to maintain the required nitrogen cover pressure per Specification 3.5.1d.
PALO VERDE - UNIT 2
EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE RE UIREMENTS Continued 2.
Verifying that each safety injection tank isolation valve is open and the nitrogen vent valves are closed.
b.
At least once per 31 days and.wlthln 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution level increase of greater than or.equal to 7X of tank narrow range level by verifying the boron concentration of the safety injection tank solution is between 2000 and 4400 ppm.
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c.
At least once per 31 days when the RCS pressure is above 700 psig, by verifying that power to the isolation valve operator is removed.
d.
At least once per 18 months by verifying that each safety injection tank isolation valve opens automatically under each of the following conditions:
e.
1.
When an actual or simulated RCS pressure signal exceeds 515 psia, and 2.
Upon receipt of a safety injection actuation (SIAS) test signal.
At least once per 18 months by verifying OPERABILITY of RCS-SIT differential pressure alarm by simulating RCS pressure
> 715 psia with SIT pressure
< 600 psig.
I f.
At least once per 18 months, when SITs are isolated, by verifying the SIT nitrogen vent valves can be opened.
g.
At least once per 31 days, by verifying that power is removed from the nitrogen vent valves.
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3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)
BASES 3/4.5. 1 SAFETY INJECTION TANKS The OPERABILITY of each of the Safety Injection System (SIS) safety injection tanks ensures that' sufficient volume of borated water will be immediately forced, into the reactor core through each of the cold legs in the event the RCS pressure falls below the pressure of the safety injection tanks.
This initial surge of water into the RCS provides the initial cooling mechanism during large RCS pipe ruptures.
The limits on safety injection tank volume, boron concentration, and pressure ensure that the safety injection tanks will adequately perform their function in the event of a LOCA in MODE 1, 2, 3, or 4.
A minimum of 25K narrow range corresponding to 1790 cubic feet and a
maximum of 75K narrow range corresponding to 1927 cubic feet of borated water are used in the safety analysis as the volume in the SITs.
To allow for instrument accuracy, 28K narrow range corresponding to 1802 cubic feet and 72K narrow range corresponding to 1914 cubic feet, are specified in the Techni'cal Specification.
A minimum of 593 psig and a maximum pressure of 632 psig are used in the safety analysis.
To allow for instrument accuracy 600 psig minimum and 625 psig maximum are specified in the Technical Specification.
A boron concentration of 2000 ppm minimum and 4400 ppm maximum are used in the safety analysis.
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The SIT isolation valves are not single failure proof; therefore, whenever the valves are open power shall be removed from these valves and the switch keylocked open.
These precautions ensure that the SITs are available during a Limiting Fault.
The SIT nitrogen vent valves are not single failure proof against depressurizing the SITs by spurious opening.
Therefore, power to the valves is removed while they are closed to ensure the safety analysis assumption of four pressurized SITs.
All of the SIT nitrogen vent valves are required to be operable so that,.
given a single failure, all four SITs may still be vented during post-LOCA long-term cooling.
Venting the SITs provides for SIT depressurization capability which ensures the timely establishment of shutdown cooling entry conditions as assumed by the safety analysis for small break LOCAs.
The limits for operation with a safety injection tank inoperable for any reason except an isolation valve closed minimizes the time exposure of the plant to a LOCA event occurring concurrent with failure of an additional safety injection tank which may result in unacceptable peak cladding tempera-tures.
If a closed isolation valve cannot be immediately opened, the full capability of one safety injection tank is not available and prompt action is required to place the reactor in a MODE where this capability is not required.
l For MODES 3 and 4 operation with pressurizer pressure less than 1837 psia the Technical Specifications require a minimum of 57K wide range corresponding ud S /~4.7 (3
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NO SIGNIPICANT HAZARDS 'CONSIDERATION, DOCUMENTATION Unit 2 Technical S ecification 3/4.6.4.1 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different, kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a change which either may result in some increase to the probability or consequences of a
previously analyzed accident or may reduce in some way a safety
- margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan.
The installed containment hydrogen monitoring system is augmented by the hydrogen sampling capability of the Post Accident Sampling System (PASS).
This system, which meets the requirements of NUREG 0737, section II.B3., uses the same containment penetration as one of the installed hydrogen monitors.
The system has redundant sample pumps which deliver the sample to the chemistry lab.
The sample is then analyzed using a laboratory grade gas chromatograph.
Surveillance is performed on the sampling capability per specification 4.3.3.1 and the gas chromatograph is calibrated prior to each use and is analytically verified every 18 months.
This system provides a reliable and accurate backup to the installed hydrogen monitors.
- E 4,
0
~CDlt'RQI. '-6 SY 'JG'~k CONTAINMENT SYSTEMS 3/4.6.4 COMBUSTIBLE GAS CONTROL HYDROGEN MONITORS LIMITING CONDITION FOR OPERATION 3.6.4.1 Two independent containment hydrogen monitors shall be OPERABLE.
APPLICABILITY:
MODES 1 and 2.
ACT10N:
aO With one hydrogen monitor inoperable, restore the inoperable monitor to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
b.
With both hydrogen monitors inoperable; restore at least one monitor to OPERABLE status 'within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
I'.
lrv s r- % 7 SURVEILLANCE RE UIREMENTS 4.6.4.1 Each hydrogen monitor shall be demonstrated OPERABLE by the performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a
CHANNEL FUNCTIONAL TEST at least once per 31 days, and at least once per 92 days on a STAGGERED TEST BASIS by performing a
CHANNEL CALIBRATION using sample gases containing a nominal:
a.
One volume percent hydrogen, balance nitrogen.
b.
Four volume percent
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NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecificat1on 3/4.6.4.1 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
l)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a change which either may result in some increase to the probability or consequences of a
previously.-
analyzed accident or may reduce in some way a safety
- margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan.
The installed containment hydrogen mon1toring system is augmented by the hydrogen sampling capability of the Post Accident Sampling System (PASS).
Th1s system, which meets the requirements of NUREG 0737, section II.B.3., uses the same containment penetrat1on as one of the installed hydrogen monitors.
The system has redundant sample pumps which deliver the sample to the chemistry lab.
The sample is then analyzed using a laboratory grade gas chromatograph.
Surveillance is performed on the sampling capability per specification 4.3.3.1 and the gas chromatograph is calibrated prior to each use and is analytically verified every 18 months.
This system provides a rel1able and accurate backup to" the installed hydrogen monitors.
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CONTAINMENT SYSTEMS BASES 3/4. 6. 3 CONTAINMENT ISOLATION VALVES The OPERABILITY of the containment automatic isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of She containment and is consistent with the requirements of GDC 54 through GDC 57 of Appendix A to 10 CFR Part 50.
Containment isolation within the time limits specified for those isolation valves designed to close automatically ensures that the release of radioactive material to the environ-ment will be consistent with the assumptions used in the analyses for a LOCA.
The only valves in the Table 6.2.4-1 of the PVNGS FSAR that are not required to be listed in Table 3.6-1 are the following:
main steam safety valves and main steam atmospheric dump valves.
The main steam safety valves and the atmospheric dump valves have very high pressure setpoints to actuate and are covered by Specifications 3/4.7. l. 1 and 3/4.7. 1.6, respectively.
3/4.6.4 COMBUSTIBLE GAS CONTROL The OPERABILITY of the equipment and systems required for the detection and control of hydrogen gas ensures that this equipment will be available to maintain the hydrogen concentration within containment below its flammable limit during post-LOCA conditions.
Either recombiner unit (or the purge system) is capable of controlling the expected hydrogen generation associated with (1) zirconium-water reactions, (2) radiolytic decomposition of water and (3) corrosion of metals within containment.
These hydrogen control systems are consistent with the recommendations of Regulatory Guide 1.7, "Control of Combustible Gas Concentrations in Containment Following a LOCA," March 1971.-
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PALO VERGE " UNIT 2 B 3/4 6-4
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.7.1.1 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; and (B)
The proposed amendment is the deletion of MODE 3 in action statement a.
which reflects the fact that the reactor is subcritical in Mode 3 and the overpower protection at this time is provided by the High Logarithmic Power level trip at
.798X power.
The change from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to accomplish prescribed action a. provides a realistic time period in which to accomplish this action in a safe controlled manner.
T.S. 3/4.7.1.1 Changing the Variable Overpower Trip setpoints is the fastest method to accomplish the compensatory actions.
There are four channels which must be readjusted; each channel requires approximately 2
hours to readjust.
In
- addition, some amount of time must be allowed for the technicians
'to refamiliarize themselves with the procedure, time to process work control paperwork, and time to close out the job and declare the system OPERABLE.
The logic required for the Variable Overpower Trip is 2 out of 4; at least two channels would be readjusted in approximately the present 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> limit.
These two channels would be OPERABLE and capable of performing their trip function at the lower setpoint.
Stating that at least one reactor coolant loop and associated steam generator should be in operation will eliminate confusion which required a
phone conversation on January '0, 1986 between
- Messrs, Knighton, Crutchfield and Viagitio of the NRC staff and members of the ANPP staff.
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3/4. 7 PLANT SYSTEHS 3/4.7.1 TURBINE CYCLE SAFETY VALVES I
LIHITING CONDITION FOR OPERATION 3.7.1.1 All main steam safety valves shall be OPERABLE with liftsettings as specified in Table 3.7-1.
APPLICABILITY:
MODES 1, 2, 3, and 4".
ACTION:
ao b.
C, With both reactor coolant loops and associated steam generators in operation and with one or more"" main steam safety valves ino e able per steam generator operation in MODES~2
, an may proceed provided t a w>thin hours, either all the inoperable valves are restored to OPERABLE status or the Maximum Variable Overpower trip setpoint and the Maximum Allowable Steady State Power Level are reduced per Table 3.7-2; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLO SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
g gpss Operation in MODES 3 and 4" may proceed with~one reactor coolant loop and associated steam generator in operation, provided that there are no more than four inoperable main steam safety valves associated with the operating steam generator; otherwise, be in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
The provisions of Specification 3.0.4 are not applicable.
SURVEILLANCE RE UIREHENTS 4.7.1.1 No additional Surveillance Requirements other than those required by Specification 4.0.5.
Until the steam generators are no longer required for heat removal.
The maximum number of inoperable safety valves on any operating steam generator is four (4).
'ALO VERDE - UNIT 2 3/4 7"1 g@gTP~LLFD PV lKF@
0
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.8.1.1 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a
change that will allow surveillance testing of diesel generators from an additional location.
Section 4.8.1.1.2a.4.:
. Rev.
1, to which APS is committed per section 1.8 of the
- FSAR, states that "all diesel generator protective trips should be in force during diesel generator unit testing.
Re-stating this in the specification as a
requirement is an unnecessary regulation.
APS does not intend to start the diesel generator in the emergency mode for testing purposes except to prove that a diesel generator could perform its emergency functon in, the event of a test start failure.
The diesel generator would not have, to be unnecessarily declared inoperable while the test start circuit was being repaired.
4.8.1.1.2a.4.a):
The diesel generator may also be started manually from the local control panel.
The start circuit from the local control panel is in parallel with and duplicates the start circuit from the control room.
This change will allow a local start as well as a start from the control room to count as a valid test of the diesel generator.
I V
ELECTRICAL POWER SYSTEMS SURVEILLANCE RE UIREHENTS 4.8. l.l. 1 Each of the above required physically independent circuits between the offsite transmission network and the onsite Class 1E distribution system shall be:
a A b.
Determined OPERABLE at least once per 7 days by verifying correct breaker alignment indicating power availability Demonstrated OPERABLE at least once per 18 months during shutdown by manually transferring the onsite Class 1E power supply from the normal circuit to the alternate circuit.
4.8.1.1.2 Each diesel generator shall be demonstrated OPERABLE:
a ~
In accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST BASIS by.
1.
Verifying the fuel level in the day tank.
2.
Verifying the fuel level in the fuel storage tank.
3.
Verifying the fuel transfer pump can be started and transfers fuel from the storage system to the day tank.
4.
Verifying the diesel generator can start"" and accelerate to generator voltage and frequency at 4160 + 420 volts and 60 +
1.2 Hz in less than or equal to 10 seconds.
Subsequently, the generator shall be manually synchronized to its appropriate bus and gradually loaded~" to an indicated 5200-5400 kM~"" and operates for at least g ojnutes.
The diesel generator shall be started for this test f
f 11 I 1 IG I
STAGGERED TEST BASIS:
a) b)
c) d)
Manual @rem-cea@ral~oom; Simulated loss of offsite power by itself.
Simulated loss of offsite power in conjunction with an ESF actuation test signal.
An ESF actuation test signal by itself.
5.
Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.
This test shall be conducted in accordance with the manufacturer's recommen-dations regarding engine prelube and warmup procedures, and as applicable regarding loading recommendations.
"**This band is meant as guidance to avoid routine overloading of the engine.
Loads in excess of this band for special testing under direct monitoring of the manufacturer or momentary variations due to changing bus loads shall not invalidate the test.
"""*Untilthe first refueling outage, the diesel generator shall be test started IE.G
'GS IP PALO VERDE - UNIT 2 3/4 8"3 Qi+PP~I(
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NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.2.5 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a change which either may result in some increase to the probability or consequences of a
previously-.:
analyzed accident or may reduce in some way a safety
- margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan.
3 0
Basis For Change To Technical Specification 3/4.2.5 PNVGS Unit 1 Technical Specification 3/4.2.5 (RCS Flowrate) required a minimum actual flowrate of 164.0x10 ibm/hr.
Flowrate was measured during post-core hot functional testing with an ultrasonic flow meter (UFM).
The measured flowrate at zero power was 105.1% of the design flowrate.
This value must be adjusted by two factors before it can be compared with the technical specification flow requirement.
The first factor accounts for the fact that the primary coolant specific volume on the core exit side is higher during the full power operation than it is at zero power.
The currently projected value associated with the resulting flowrate reduction is 1.4X.
- Thus, the projected full power flowrate is 103.7X.
The second factor accounts for the uncertainty associated with the flow measurement.
The attached figure shows the flowrate measurement uncertainty associated with the mass flowrate indicated by COLSS, designated as NKTHFLOW.
The variation in the flow measurement uncertainty with time is the result of drift and radiation effects on the pump differential pressure transducer output.
As can be seen from the attached
- figure, the uncertainty associated with 4
months of operation is 3.4X.
Using this value for illustration
- purposes, the projected full power flowrate adjusted for measurement uncertainty is 100.3X.
The previously mentioned technical specification as presently written is unclear as to the meaning of actual flowrate which is to be compared to 164 x 10 ibm/hr (100X design flow).
Comparing indicated flowrate to 100X is bounded by the safety analysis.
C-E's original interpretation of this technical specification however required subtraction of the flowrate measurement uncertainty from the indicated flowrate before comparison with the 100X value.
Using a projected indicated full power 'flowrate of 103.7X and an uncertainty of 3.4X, this comparison results in a +0.3% "operational flowrate margin" at 4
months from initial calibration of the pump differential pressure transducers.
At the end of cycle 1 the operational flowrate margin for PVNGS Unit 1 could be near zero.
The operational flowrate margin may also be diminished by, other factors.
These are listed below.
1.
Core crudding:
1 psi of core crudding causes a flowrate reduction of 0.35X.
2.
Tube plugging:
Plugging 100 short steam generator tubes causes an estimated flowrate reduction of 0.18%.
3.
Random effects associated with each flow measurement can influence a
given measurement in the positive or negative direction.
According to the corresponding basis
- section, the flowrate requirement is provided to ensure that the safety analysis assumptions are maintained.
In the safety
- analyses, the effects of flowrate are evaluated over a
range of 95-116%.
Where flowrate impacted
.~ analysis
- results, the most adverse flowrate was used.
Where flowrate did not significantly affect analysis results a
nominal value of 100X (164x10 ibm/hr) was used in conjunction with a sensitivity analysis.
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- Thus, the safety analysis assumptions are preserved by a flow rate of 155.8x106 ibm/hr (95K of 164xl06 ibm/hr).
Since the operational flowrate margin is small, we are requesting that the specified value for RCS flowrate be changed to the 95X value.
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POWER DISTRIBUTION LIMITS 3/4.2.'5 RCS FLOW RATE LIMITING CONDITION FOR OPERATION 3.2.5 The actual Reactor Coolant System total flow rate shall be greater than or equal to 164M-x 10'bm/hr.
Is'Z.
F'PPLICABILITY:
MODE l.
ACTION:
With the actual Reactor Coolant System total flow rate determined to be less than the above limit, reduce THERMAL POWER to less than 5X of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
SURVEILIANCE RE UIREMENTS 4.2.5 The actual Reactor Coolant System total flow rate shall be determined.
to be greater than or equal to its limit at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
PALO VERDE - UNIT 2 3/4 2-8
f J
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3.6.4.2 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is an exception to a technical specification justified by existing limiting conditions for operation and action statements.
The present specification allows unlimited operation in MODES 1 and 2 with one H2 recombiner inoperable as long as the H2 purge system is OPERABLE per specification 3.6.4.3; 'therefore, an'xception to 3'.0.4 may be granted with no further risk to the public.
a
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CONTAINMENT SYSTEMS ELECTRIC HYDROGEN RECOMBINERS LIMITING CONDITION FOR OPERATION 3.6.4.2 Two portable independent containment hydrogen recombiner systems shared among the three units shall be OPERABLE.
APPLICABILITY:
MODES 1 and 2.
ACTION:
a With one hydrogen recombiner system inoperable, restore the inoperable system to OPERABLE status within 30 days or meet the requirements of Specification 3.6.4.3, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Ni~ O4/='P DAO'.<4 CI COHQ IhlR4 SYS7&hg lAIOP6/2RCC 8, 4<0 Th'I-HP'OROC-F'A PVg@R SY$7Et1 OPSY//he f Pr=C.
S PCC IFicepod 3.G, 0, 3 > fly PROV/ 5/04 S of SPrco-gcqpoz
'3 o.q dao ~or DPPI-icvaI-r SURVEILLANCE RE UIREMENTS 4.6.4.2 Each hydrogen recombiner system shall be demonstrated OPERABLE:
At leas4 once per 6 months by:
l.
Verifying through a visual examination that there is no evi-dence of abnormal conditions within the recombiner enclosure and control console.
2.
Operating the air blast heat exchanger fan motor and enclosed blower motor continuously for at least 30 minutes.
b.
At'east once per year by:
1.
Performing a
CHANNEL CALIBRATION of recombiner instrumentation.
2.
Performing a "Low-Level Test-Heater Power Off" and "Low-Level Test-Heater Power On" test and verifying that the recombiner temperature increases to and is maintained at 600 k 25 F for at least one hour.
Mith power off and a simulated input signal of 1280oF, verify the OPERABILITY of all control circuits.
When this test is conducted, the air blast heat exchanger fan motor
.and enclosed blower motor shall be operated continuously for at least 30 minutes.
At least once per 5 years by performing a Recombiner System "High-Level Test" and verifying that the recombiner temperature increases to and is maintained at 1200 a 50 F for at least one hour.
PALO VERDE - UNIT 2 3/4 6"37
e
NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.4.8.3 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; (B)
The proposed amendment is a change which either may result in some increase to the probability or consequences of a
previously=
analyzed accident or may reduce in some way a safety
- margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan.
This change will allow a plant heatup of 10'F/hour above 255'F with the low temperature overpressure protection out of service.
Re-examination of the pressure/temperature analysis shows that the isothermal to 100'F/hour cooldown curve (Fig.
3.
4-2) also encompasses the 10'F/hour heatup rate.
The curve intersects 255'F at the 2500 psia point.
Therefore, a heat up rate of 10'F/hour or less may be tolerated as low as 255'F with the low pressure overpressure protection out of service.
Since this change is within the present analysis for pressure/temperature relationship, there is no increase in risk to the public.
I This change should be reviewed concurrently with the change to specification 3/4.4.8.1.
I N
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REACTOR COOLANT SYSTEM OVERPRESSURE PROTECTION SYSTEMS LIMITING CONDITION FOR OPERATION r
3.4.8.3 Both shutdown cooling system (SCS) suction line relief valves with liftsettings of less than or equal to 467 psig shall be OPERABLE and aligned to provide overpressure protection for the Reactor Coolant System.
APPLICABILITY:
When the reactor vessel head is installed and the temperature
.of one or more of the RCS cold legs is less than or equal to:
a.
255 F during cooldown b.
295aF during haatup ACTION:
With one SCS relief valve inoperable, restore the inoperable valve to OPERABLE status within seven days or reduce T
ld to less than 200'F cold and, depressurize and vent the RCS through a greater than or equal to 16 square inch vent(s) within the next eight hours.
Do'ot start a
reactor coolant pump if the steam generator secondary water temperature is greater than 100 F above any RCS cold leg temperature.
b.
C.
With both SCS relief valves inoperable, reduce T
ld to less than 200 F
cold and, depressurize and vent the RCS through a greater than or equal to 16 square inch vent(s} within eight hours.
Do not start a reactor coolant pump if the steam generator secondary water temperature is greater than 1004F above any RCS cold leg temperature.
In the event either the SCS suction line relief valves or an RCS vent(s) are used to mitigate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 30 days.
The report shall describe the circumstances initiating the transient, the effect of the SCS suction line relief valves or RCS vent(s} on the transient and any corrective action necessary to prevent recurrence.
d.
The provisions of Specification 3.0.4 are not applicable.
SURVEILLANCE RE UIREMENTS 4.4.8.3.1 Each SCS suction line relief valve shall be verified to be aligned to provide overpressure protection for the RCS once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> during a.
Cooldown with the RCS temperature less than or equal to 255 F.
b.
Heatup with the RCS temperature less than or equal to 295 F.
4.4.8.3.2 The SCS suction line relief valves shall be verified OPERABLE with the required setpoint at least once per 18 months.
(~ +ad 4~CkCb P94 ra.
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PALO VERDE - UNIT 2 3/4 4-32 CAM7PAII II PP) AY tNPP.
255 F during heatup orovided the heatup rate is limited to 10'F/hr or less for RCS temperature greater than 255 F
and less than or equal to 295 F.
~,
II
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NO SIGNIFICANT HAZARDS CONSIDERATION DOCUMENTATION Unit 2 Technical S ecification 3/4.4.8.1 The proposed amendment request does not involve a
Significant Hazards Consideration because:
(A)
The operation of PVNGS Unit 2 in accordance 'with this change would not:
1)
Involve a
significant increase in the probability or consequences of an accident previously evaluated; or 2)
Create the possibility of a new or different kind of accident from any accident previously analyzed; or 3)
Involve a significant reduction in a margin of safety; The proposed amendment is a
change which either may result in some increase to the probability or consequences of a
previously analyzed accident or may reduce in some way a safety
- margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan.
This change is made in conjunction with the change to specification 3/4.4.8.3.
Re-examination of the pressure/temperature analysis shows that the isothermal to 100'F hr.
cooldown curve (Fig. 3.4-2) also encompasses the 10'F/hour heat up rate.
This change will allow the change to be made to specification 3/4.4.8.3 and both changes should be reviewed concurrently.
0 II
3000 2500 F IGUR E 3.4-2
~ ~~ jy~ ':RGS PRESS/TEMP LIMITS
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'J ZiM.o LPXRS
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-)1) 150oF, 1500 PSIA':-.
(2) 205oF, 1450 PSIA'"..,,:
3) 80oF 500 PSIA (4) 68OF',470PSIA i.:--
.)5) 157oF'500 PSIA
-'--(6) 194 F,500PSIA,,
~~ (7) 264oFP 500 PSIA
"- -'*(8) 353oF 500PSIA
.(9) 393 F,500 PSIA
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.,HEATUP 5 10o/HR COOLDOWN CJ
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~8 100 200 300 INDICATEDRCS TEMP'c (oF) 400
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FIGURE 3.4-2 RCS PRESS/TEMP LIMITS (0 " 10 YRS) FULL POMER OPERATION PALO VERDE - UNIT 2 3/4 4.-29
)). AMTPAILILEQRY Il I/) FR
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