Text

Proposed Tech Specs Supporting Cycle 3 Operation of Facility
	ML17304A996
Person / Time
Site:	Palo Verde
Issue date:	01/12/1989
From:	; ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	;
Shared Package
ML17304A995	List: ML17304A994; ML17304A996;
References
	NUDOCS 8901310223
	Download: ML17304A996 (50)
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....Number of. Q eratin Char in Pum s MODE 0 1 2. 3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months -R=S-hours 2'

~b. hour 5' OHA 4 not on SCS 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 2.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months hour 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months 5 nat on SCS 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 2.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .0.5 .hours

4 8 5 on SCS 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months ONA ONA Notes: SCS = Shutdown Cooling System ONA = Operation not allowed PALO VERDE " UNIT 1 3/4 1-17 AMENDMENT NO.

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.4 8 '5 on SCS 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .D.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months OHA NoCes':. SCS"= Shutdown Cooling System ONA = Operation not allowed PALO VERDE " UNIT 1 3j4 1-18 AHEHDHEHT HO. 23

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'4' 5 on SCS 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 0.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months I* ~ ~ I 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Note:- SCS = Shutdown Cooling System PALO VERDE - VHIT 1 3/4 1-20 AMEHDQEHT HO

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CEA INSERTION LIMITS A. DE RIPTION OF THE PR P ED HAN E This proposed amendment will revise Technical Specification Figures 3.1-3 and 3.1-4. These figures provide regulating group Control Element Assembly (CEA) insertion limits. Figure 3.1-3 provides CEA insertion limits when the Core Operating Limit Supervisory System (COLSS) is in service and Figure 3.1-4 provides the insertion limits when COLSS is out of service. The following two changes are proposed:

i) The revised Figure 3.1-3 (COLSS in service) will not permit insertion of regulating group 3 CEAs above 20% of rated thermal power. This is more restrictive than the current specification which does allow for regulating group 3 insertion above 20% of rated thermal power.

ii) The revised Figure 3.1-4 (COLSS out of service) will permit slightly increased insertion of regulating group 3 CEAs between 15% and 20% of rated thermal power.

B. PURPOSE OF THE TECHNICAL SPECIFICATION The proposed changes to Technical Specification Figures 3.1-3 and 3.1-4 only affect the transient insertion limit lines. There are two primary purposes for the transient insertion limits. The first purpose is to ensure that adequate shutdown margin is maintained for limiting Design Basis Events (DBEs). The second purpose is to limit the potential consequences of CEA ejection accidents to acceptable levels. For a further explanation of the reasons for these Technical Specification requirements, refer to bases section 3/4.1.3.

C. NEED FOR THE TECHNICAL SPECIFICATION AMENDMENT The proposed changes to the transient insertion limits are necessary to ensure that the Technical Specifications are consistent with the safety analyses performed for the Cycle 3 core design. A more restrictive transient insertion limit line is required when COLSS is in service and a slightly less restrictive limit is allowed when COLSS is out of service.

D. BASIS FOR NO SIGNIFICANT HAZARD CONSIDERATI N

1. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10CFR50.92. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment 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 evaluated; or (3) Involve a significant reduction in a margin of safety. A discussion of these standards as they relate to the amendment request follows:

ig ifi ti i tb p b bility q of an accident previously evaluated.

Technical Specification Figures 3.1-3 and 3.1-4 were updated to be consistent with the Cycle 3 safety analyses. The probability and/or consequences of an accident previously evaluated in the FSAR will not increase because the results of the Cycle 3 safety analyses, using the revised CEA insertion limits of Figures 3.1-3 and 3.1-4, assure that there is sufficient margin for the most limiting DBE. The analyses performed include an evaluation of all safety analyses for which the CEA insertion limit curves serve as an initial condition. Therefore, the proposed Technical Specification changes will not increase the probability or consequences of any accidents previously evaluated.

Raalzd2-G t tb p billy f dlf tti d f 'd any accident previously evaluated.

~B~I The proposed changes are required to make the Technical Specifications consistent with the Cycle 3 safety analyses. There have been no hardware changes involving equipment important to safety as a result of the proposed changes. Therefore, the possibility of an accident of a different type than any evaluated previously in the FSAR will not be created.

Q~nl~~r Involve a significant reduction in a margin of safety.

~BE The changes to the transient insertion limit lines of Figures 3.1-3 and 3.1-4 are required to make the Technical Specifications consistent with the Cycle 3 safety analyses. Operation of the reactor in accordance with the revised transient insertion limits will ensure that the Specified Acceptable Fuel Design Limits (SAFDLs) are not exceeded during the most limiting Anticipated Operational Occurrence (AOO). The Cycle 3 limits are based on the same design criteria as the Cycle 2 limits. Therefore, the margin of safety will not be reduced as a result of the proposed changes.

2. The Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (51FR7751) of amendments that are considered least likely to involve a significant hazards consideration. The proposed change matches the following example:

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(iii) For a nuclear power reactor, a change resulting from a nuclear reactor core reloading, if no fuel assemblies significantly different from those found previously acceptable to the NRC for a previous core at the facility in question are involved. This assumes that no significant changes are made to the acceptable criteria for the technical specifications, the analytical methods used to demonstrate conformance with the technical specifications and regulations are not significantly changed, and that the NRC has previously found such methods acceptable.

E. SAFETY EVALUATION FOR THE PROPOSED CHANGE The proposed revisions to Technical Specification Figures 3.1-3 and 3.1-4 will not increase the probability or consequences of any accidents previously evaluated in the FSAR. The transient insertion limits of Figure 3.1-3 will become more restrictive by not permitting regulating group 3 insertion above 20% power. The revised Figure 3.1-4 will permit slightly increased insertion of regulating group 3 between 15% and 20% power. These changes are consistent with the Cycle 3 safety analyses. The probability and/or consequences of an accident previously evaluated in the FSAR will not be increased because the results of the Cycle 3 safety analyses, using the revised CEA insertion limits of Figures 3.1-3 and 3.1-4, assure that there is sufficient margin for the most limiting DBE. The analyses performed included an. evaluation of all safety analysis events for which the CEA insertion limit curves serve as an initial condition. Therefore, the probability or consequences of an accident previously evaluated in the FSAR will not be increased.

J The changes to the, transient insertion limit lines of Figures 3.1-3 and 3.1-4 are required to make the Technical Specifications consistent with the Cycle 3 safety analyses. Operation of the reactor in accordance with the revised transient insertion limits will ensure that the Specified Acceptable Fuel Design Limits (SAFDLs) are not exceeded during the most limiting Anticipated Ope'rational Occurrence (AOO). Since the Cycle 3 limits are based on the same design criteria as the Cycle 2 limits, the possibility of an accident of a different type than any previously evaluated in the FSAR will not be created.

The proposed revisions to Figures 3.1-3 and 3.1-4 are required to make the Technical Specifications consistent with the Cycle 3 safety analyses. Bases section 3/4.1.3 states that transient insertion limits are provided to ensure that (1) the minimum shutdown margin is maintained, and (2) the potential effects of a CEA ejection accident are limited to acceptable levels. The Cycle 3 safety analyses verified that Cycle 3 operation, within the revised transient insertion limit lines, will be in conformance with these bases requirements. Therefore, the margin of safety as defined in the bases for the Technical Specification will not be reduced as a result of the proposed changes.

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F. ENVIRONMENTAL IMPA T NSIDERATION DETERMINATION The proposed Technical Specification change request does not involve an unreviewed environmental question because operation of PVNGS Unit 1 in accordance with this change would not:

1. Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by the staff's testimony to the Atomic Safety and Licensing Board (ASLB), Supplements to the FES, Environmental Impact appraisals, or in any decisions of the ASLB; or

2. Result is a significant change in effluents or power levels; or

3. Result in matters not previously reviewed in the licensing basis for PVNGS which may have a significant environmental impact.

G. MARKED-UP TECHNICAL SPECIFICATION CHANGE PAGES Enclosed are revised Figures 3.1-3 and 3.1-4 of the PVNGS Unit 1 Technical Specifications.

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AZIMUTHAL POWER TILT A. DESCRIPTI N F THE PROPO ED CHANGE This proposed amendment will revise Technical Specification Figure 3.2-1A. This figure provides azimuthal power tilt limits versus core power for COLSS in service.

The azimuthal power tilt limit will be increased for operation below 40% of rated thermal power.

This change has been previously approved for PVNGS Unit 2 (reference Amendment 25 to Facility Operating License No. NPF-51). In the previous request to modify this specification for Unit 2 (refer to letter 161-01059 dated May 27, 1988), ANPP stated that this change was unit and cycle specific and that supporting analysis would need to be conducted for each unit. Additionally, ANPP committed to submit the change requests for Units 1 and 3 as part of the next reload Technical Specification submittals. For Unit 1, the supporting analyses have been completed. This amendment request satisfies our previous commitment to modify the Unit 1 Technical Specifications.

B. PURPOSE OF THE TECHNICAL SPECIFICATION The limitations on the azimuthal power tilt are provided to ensure that the design safety margins are maintained. It is necessary to explicitly account for power asymmetries because the radial peaking factors used in the core power distribution calculations are based on an untilted power distribution.

C. NEED FOR THE TECHNICAL SPECIFICATION AMENDMENT Relaxation of the azimuthal power tilt limits with COLSS in service will allow the operators to better mitigate the consequences of xenon transients occurring below 40% of rated thermal power.

D. BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION

1. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10CFR50.92. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment 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 evaluated; or (3) Involve a significant reduction in a margin of safety. A discussion of these standards as they relate to the amendment request follows:

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of an accident Involve a significant increase evaluated.

in the probability or consequences previously

= The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated since the results of the Unit 1, Cycle 3 analyses incorporate the higher azimuthal tilt values at low power (with COLSS in service). This assures that there is sufficient margin in the safety analyses for the most limiting Design Basis Event (DBE).

Physics calculations were performed to verify that the results of the Cycle 3 analysis, using the azimuthal power tilt limits proposed in Figure 3.2-1A with COLSS in service, were bounded by the reference cycle analysis. In particular, all events which use an explicit value for azimuthal power tilt in the calculation (i.e., the CEA ejection, single full length CEA withdrawal, and single part length CEA drop events) were reanalyzed with the new higher azimuthal power tilt limits. For the remaining DBEs, there is sufficient conservatism in the assumptions made for the initial conditions (from which the events are started) to account for the increased azimuthal power tilt allowed by the proposed Technical Specification change below 40% power.

Above 40% power, the proposed figure is identical to the reference cycle and is therefore bounded by that analysis.

tsodanlk i' ii p iiiiiliity i diff ikiid i id any accident previously evaluated.

I~i = The proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed Technical Specification amendment only changes the azimuthal power tilt limits at low power levels (below 40% power), and does not modify any plant equipment or operating procedures. The relaxation of the azimuthal power tilt limit for Unit 1 allows the operators to better mitigate xenon transients below 40% power. Therefore, the possibility of a new or different kind of accident will not be created.

Q~~r Involve a significant reduction in a margin of safety.

~B~I = The proposed change will not involve a significant reduction in a margin of safety since the results of the analyses assuming the higher azimuthal tilt values assure that there is sufficient margin for the most limiting DBE. Therefore, the margin of safety will not be reduced.

2. The Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (51FR7751) of amendments that are considered least likely to involve a significant hazards consideration. The

proposed change matches the following example:

(iii) For a nuclear power reactor, a change resulting from a nuclear reactor core reloading, if no fuel assemblies significantly different from those found previously acceptable to the NRC for a previous core at the facility in question are involved. This assumes that no significant changes are made to the acceptable criteria for the technical specifications, the analytical methods used to demonstrate conformance with the technical specifications and regulations are not significantly changed, and that the NRC has previously found such methods acceptable.

E. SAFETY EVALUATION FOR THE PROPOSED CHANGE The proposed Technical Specification change will not increase the probability or consequences of any accidents previously evaluated in the FSAR. The results of the Cycle 3 analyses, using the azimuthal power tilt limits proposed in Figure 3.2-1A with COLSS in service, assure that there is sufficient margin for the most limiting DBE. The analyses performed include physics calculations for all reactivity insertion events in which the azimuthal power tilt is an explicit limit. These include the CEA ejection, single full length CEA withdrawl, and the single part length CEA drop events. For the remaining DBEs, there is sufficient conservatism in the assumptions made for the initial conditions (from which the events are started) to account for the increased azimuthal power tilt allowed by the proposed change below 40% power. Above 40% power, the proposed figure is identical to the existing figure for the reference cycle and is bounded by that analysis.

This proposed change will not create the possibility of an accident or malfunction of a different type than any evaluated previously in the FSAR. The proposed change does not modify any existing plant equipment or components. Additionally, the results of all DBEs affected by the proposed azimuthal power tilt limits are bounded by the reference cycle.

The revisions to Figure 3.2-1A will not reduce the margin of safety as defined in the basis for any Technical Specification. The results of the analyses for the revised azimuthal power tilt limits assure that there is sufficient margin for all DBEs affected by the proposed change.

F. ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION The proposed Technical Specification change request does not involve an unreviewed environmental question because operation of PVNGS Unit 1 in accordance with this change would not:

1. Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as

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modified by the staff's testimony to the Atomic Safety and Licensing Board (ASLB), Supplements to the FES, Environmental Impact appraisals, or in any decisions of the ASLB; or

2. Result is a significant change in effluents or power levels; or

3. Result in matters not previously reviewed in the licensing basis for PVNGS which may have a significant environmental impact.

G. MARKED-UP TECHNI AL PE IFICATION CHANGE PA E Enclosed is revised Figure 3.2-1A of the PVNGS Unit 1 Technical Specifications.

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PALO VERDE - UNIT 1 3j4 2-4a AMENDMENT NO. 38

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DN B R MARGIN A. DESCRIPTION OF THE PROPOSED CHANGE This proposed amendment will revise Technical Specification Figures 3.2-2 and 3.2-2A. These figures provide DNBR margin limits for various configurations of COLSS and CEACs inoperable. The changes are necessary to ensure that the Technical Specifications are consistent with the safety analyses performed for the Cycle 3 core design.

B. E E L E The DNBR limits of Figures 3.2-2 and 3.2-2A provide a conservative envelope of operating conditions consistent with the safety analysis assumptions. The limits have been analytically demonstrated to maintain an acceptable minimum DNBR throughout all Anticipated Operational Occurrences (AOOs).

C. NEED F R THE TECHNICAL SPECIFICATION AMENDMENT The proposed changes to the DNBR limit curves are necessary to ensure that the Technical Specifications are consistent with the safety analyses performed for the Cycle 3 core design.

D. BASIS FOR NO SIGNIFICANT HAZARD C N IDERATION

1. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10CFR50.92. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment 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 evaluated; or (3) Involve a significant reduction in a margin of safety. A discussion of these standards as they relate to the amendment request follows:

taalaai1 I I ig ifi I i th p b 1 ility q of an accident previously evaluated.

~Bjii. The proposed revisions to Technical Specification Figures 3.2-2 and 3.2-2A will not increase the probability or consequences of an accident previously evaluated. Figures 3.2-2 and 3.2-2A must be updated to be consistent with the Cycle 3 safety analyses.

a. The Cycle 3 safety analyses have shown that when COLSS is in service and at least one CEAC is operable, Technical Specification 3.2.4a

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provides adequate margin to DNB to accommodate the most limiting AOO without violating the SAFDLs.

b. The proposed revision to Figure 3.2-2 accounts for the situation where COLSS is out of service and at least one CEAC is operable. In this case the Cycle 3 safety analyses have shown that by maintaining the CPC calculated DNBR above the value shown in the revised figure, the limiting AOO will not result in a violation of the SAFDLs.

c. When COLSS and both CEACs are out of service, there must be additional margin in the initial CPC DNBR value to ensure that the limiting AOO will not result in exceeding a SAFDL. The evaluation of the Cycle 3 core design has shown that by maintaining the CPC calculated DNBR above the limits shown in Figure 3.2-2A, the SAFDLs will not be exceeded during the most limiting AOO.

dlffdtlffd I d I th p ihility I diff I hi d I id I ff any accident previously evaluated.

~BE The revisions to Technical Specification Figures 3.2-2 and 3.2-2A are required to make the Technical Specifications consistent with the Cycle 3 safety analyses. Therefore, the change will not create the possibility of a new or different kind of accident from any accident previously analyzed.

QfzldzU Involve a significant reduction in a margin of safety.

~B~i The changes in the content of Figures 3.2-2 and 3.2-2A are required to make the Technical Specifications consistent with the Cycle 3 safety analyses.

Operation of the reactor within the limits of the revised figures will ensure that the SAFDLs are not exceeded during the most limiting AOO. The Cycle 3 figures were based on the same design criteria as the Cycle 2 figures.

Therefore, the margin of safety will not be reduced as a result of the proposed changes.

2. The Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (51FR7751) of amendments that are considered least likely to involve a significant hazards consideration. The proposed change matches the following example:

(iii) For a nuclear power reactor, a change resulting from a nuclear reactor core reloading, if no fuel assemblies significantly different from those found previously acceptable to the NRC for a previous core at the facility in question are involved. This assumes that no significant changes are made to the acceptable criteria for the technical specifications, the analytical methods used to demonstrate

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conformance with the technical specifications and regulations are not significantly changed, and that the NRC has previously found such methods acceptable.

E. SAFETY EVALUATION FOR THE PROPOSED CHANGE The proposed Technical Specification change will not increase the probability or consequences of any accidents previously analyzed. Figures 3.2-2 and 3.2-2A must be updated to be consistent with the Cycle 3 safety analyses.

a. The Cycle 3 safety analyses have shown that when COLSS is in service and at least one CEAC is operable, Technical Specification 3.2.4a provides adequate margin to DNB to accommodate the most limiting AOO without violating the SAFDLs.

b. The proposed revision to Figure 3.2-2 accounts for the situation where COLSS is out of service and at least one CEAC is operable. In this case the Cycle 3 safety analyses have shown, that by maintaining the CPC calculated DNBR above the value shown in the revised figure, the limiting AOO will not result in a violation of the SAFDLs.

c. When COLSS and both CEACs are out of service, there must be additional margin in the initial CPC DNBR value to ensure that the limiting AOO will not result in exceeding a SAFDL. The evaluation of the Cycle 3 core design has shown that by maintaining the CPC calculated DNBR above the limits shown in Figure 3.2-2A, the SAFDLs will not be exceeded during the most limiting AOO.

The proposed Technical Specification change will not create the possibility of an accident or malfunctioning different than those already analyzed in the FSAR.

There have been no hardware changes to equipment important to safety as a result of this change.

The changes in the content of Technical Specification Figures 3.2-2 and 3.2-2A are required to make the Technical Specifications consistent with the Cycle 3 safety analyses. Operation of the reactor within the limits of the revised figures will ensure that the SAFDLs are not exceeded during the most limiting AOO. The Cycle 3 figures were based on the same design criteria as the Cycle 2 figures.

Therefore, there will be no reduction in the margin of safety as defined in the basis for any Technical Specification.

F. ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION The proposed Technical Specification change request does not involve an unreviewed environmental question because operation of PVNGS Unit 1 in accordance with this change would not:

1. Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by the staff's testimony to the Atomic Safety and Licensing Board (ASLB), Supplements to the FES, Environmental Impact appraisals, or in any decisions of the ASLB; or r

2. Result is a significant change in effluents or power levels; or

3. Result in matters not previously reviewed in the licensing basis for PVNGS which may have a significant environmental impact.

G. MARKED- P TECHNICAL PECIFICATION CHAN E PAGES Enclosed are revised Figures 3.2-2 and 3.2-2A of the PVNGS Unit 1 Technical Specifications.

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