ML17312B321
| ML17312B321 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/16/1997 |
| From: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17312B322 | List: |
| References | |
| 102-03890-JML-A, 102-3890-JML-A, NUDOCS 9703250024 | |
| Download: ML17312B321 (22) | |
Text
CATEGORY 1 REGULATO INFORMATION DISTRIBUTION STEM (RIDS)
ACCESSION NBR:9703250024 DOC.DATE: 97/03/16 NOTARIZED:
NO DOCKET,N FACIL;,STN-00-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 SgN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi, 05000530 AUTH.NAME AUTHOR AFFILIATION LEVINE,J.M.
Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Provides response to RAI re Section 3.5.2 of license amend to implement improved STS.
DISTRIBUTION CODE:
AOOID COPIES RECEIVED:LTR I
ENCL SIZE: j!
TITLE: OR Submittal:
General Distribution NOTES:STANDARDIZED PLANT Standardized plant.
Standardized plant.
RECIPIENT ID CODE/NAME PD4-2 LA CLIFFORD,J INTERNAL: ACRS NRR/DE/ECGB/A NRR/DRCH/HICB NRR/DSSA/SRXB OGC/HDS2 EXTERNAL: NOAC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1, 0
1 1
RECIPIENT ID CODE/NAME PD4-2 PD
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NRR/DSSA/SPLB NUDOCS-ABSTRACT NRC PDR "COPIES
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE!
CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-S(EXT. 415-2083)
TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 14 ENCL 13
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Palo Verde Nuclear Generating Station James M. Levine Senior Vice President Nuclear TEL (602)393-5300 FAX'(602)3934077 Mail Station 7602 P.O. Box 52034 Phoenix, AZ65072-2034 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, D.C. 20555 102-03890- JML/AKK/SAB March 16, 1997
Reference:
1) 2)
NRC Letter dated January 16,
- 1997, "Request for Additional Information Regarding Section 3.5.2 of the Proposed License Amendment to Implement Improved Standard Technical Specifications" Y
PVNGS Letter No. 102-03794, dated October 4, 1996, "License Amendment Request for Conversion to the Improved Standard Technical Specifications (ITS)"
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1,2, and 3 Docket No. STN 50-528/529/530 Improved Standard Technical Specifications This letter provides in Enclosure 1 the response to the request for additional information in Reference 1.
This letter also provides documentation that was inadvertently omitted from the attachments to Reference 2 in Enclosure 2.
PVNGS is compiling a matrix of Technical Specification (TS) requirements that are being relocated from the Current Technical Specifications (CTS) to Licensee Controlled Documents.
Licensee Controlled Documents include the Updated Final Safety Analysis Report, Technical Requirements Manual, TS Bases, and Program Documents for the programs identified in ITS Chapter 5.0.
The TS requirements being relocated from the CTS are identified in the ITS with the alpha-numeric designator "LA". This matrix will be transmitted to the NRC upon completion, estimated to be on or before May 30, 1997.
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Improved Standard Technical Specifications Page 2 Reference 1 requested a response within 30 days from receipt of the letter.
In a telephone conference call with the NRC Project Manager for PVNGS, Mr. Charles Thomas, an extension of that date was granted in order to include the documentation included as enclosure 2 of this letter.
Should you have any questions, please contact Scott A. Bauer at (602) 393-5978.
Sincerely, JML/AKK/SAB/TNW/mah cc:
J. E. Dyer K. E. Perkins J. W. Clifford C. R. Thomas K. E. Johnston A. V. Godwin (ARRA)
U.S Nuclear Regulatory Commission
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Improved Standard Technical Specifications Page 3 FOR INTERNALDISTRIBUTIONONLY bcc G. R. Overbeck 7602 W. E. Ide 7616 S. L. Hall 7663 P. Paramithos 7663 M. S. Burns 7546 J. D. Hughey 7561 M. F. Hodge 7561 M. E. Powell 7543 A. K. Krainik 7636 S. A. Bauer 7636 T. N. Weber 7636 R. A. Fongemie 7668 Source Document Library 7747 CONCURRENCES:
S. L. Hall P. Paramithos M. S. Burns J. D. Hughey M. F. Hodge M. E. Powell W. E. Ide R. L. Roehler T. N. Weber S. A. Bauer A. K. Krainik q(
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C S. L. Hall P. Paramithas M. S. Burns J. D. Hughey M. F. Hodge M. E. Powell W. E. Ide R. K. Roehler T. N. Weber S. A. Bauer A. K. Krainik
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U.S Nuclear Regulatory Commission Improved Standard Technical Specifications Page 3 FOR INTERNALDISTRIBUTIONONLY bcc G. R. Overbeck 7602 W. E. Ide 7616 S. L. Hall 7663 P. Paramithos 7663 M. S. Burns 7546 J. D. Hughey 7561 M. F. Hodge 7561 M. E. Powell 7543 A. K. Krainik 7636 S. A. Bauer 7636 T. N. Weber 7636 R. A. Fongemie 7668 Source Document Library 7747 CONCURRENCES:
S. L. Hall P. Paramithgs M. S. Burns J. D. Hughey M. F. Hodge M. E. Powell W. E. Ide R. L. Roehler T. N. Weber S. A. Bauer A. K. Krainik rr-
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U:S Nuclear Regulatory Commission Improved Standard Technical Specifications Page 4 FOR INTERNALDISTRIBUTIONONLY VERIFICATIONOF ACCURACY I.
Related to the Request for Additional Information:
1.
LDCR 96-004, Request for TS change for the Nitrogen Pressures in the SIT, dated 4/9/96 2.
50.59 Evaluation; Log No. 96-00057, Revision 1, dated 9/26/96 3.
Setpoint Calculation No.
13-J-SI-211, Revision 2, dated 6/14/96 "SIT Pressure (wide range) Loops P-311, P-321, P-331 Total Loop Uncertainty" 4.
CRDR 95-0962, Nitrogen Pressure in the SIT Related to the documentation missing from the ITS transmittal:
1.
LDCR 96-008, Request for TS change for the Pressure Drop Values thru the Hydrogen Purge Exhaust AHU, 5/10/96 2.
50.59 Evaluation; Log No. 96-00043, Revision 1, dated 4/30/96 3.
Mechanical Design Calculation 13-MC-HP-207, Revision 0 4.
CRDR 96-0096, Pressure Drop Values thru the Hydrogen Purge Exhaust AHU III.
General Reference 1.
PVNGS letter No. 102-03794, dated 10/4/96, Transmittal of the ITS to the NRC COMMITMENT/ACTIONPLAN Stated or Im lied 1.
Transmit Matrix of Relocated TS Requirements to the NRC.
Responsibility:
Department:
RCTS No.:
Due Date:
T. N. Weber 042365 Ma 30 1997 Concurrence:
CHANGES TO UFSAR 1.
SARCN 3633 regarding Pressure Drop Values thru the Hydrogen Purge Exhaust AHU
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ENCLOSURE't RESPQNSE TO REQUEST FQR ADDITIONALINFQRMATION INCREASE SIT MINIMUMNITRQGEN COVER PRESSURE
Enclosure 1
'esponse to Request for Additional Information Increase SIT MinimumNitrogen Cover Pressure INTRODUCTION:
In the PVNGS submittal of the Improved Technical Specifications (ITS), a change was included to revise the Safety Injection Tank (SIT) minimum nitrogen cover pressure from the Current Technical Specification (CTS) value of254 psig to the value in the ITS of260 psig. Justification for the change was provided in the ITS submittal.
A request for additional information was received from the NRC on January 16, 1997 to further justify and describe the calculations used for the increase in SIT minimum nitrogen cover pressure.
The request also asked for a discussion of the standards and methodologies used in the instrument uncertainty calculations and the applicability ofthe standards to PVNGS Units 1, 2, and 3.
RESPONSE
PVNGS CTS 3/4.5.1, "Safety Injection Tanks" (Note t) requires that a minimum nitrogen cover pressure of254 psig (indicated) be maintained in the Safety Injection Tanks when the plant is in Modes 3 and 4 with pressurizer pressure less than 1837 psia.
The Bases for this CTS identifies the corresponding analytical limit for minimum pressure under this condition as 235 psig, and 254 psig is chosen for the LCO to account for instrument inaccuracy.
Thus, up to 19 psig is credited for the total uncertainty associated with the instrument loop(s) to verify compliance with the LCO.
PVNGS surveillance procedures specify the use of pressure indicators J-SIA-PI-331 and J-SIB-PI-311 to verify minimum pressure in Modes 3 and 4. These indicators are termed "wide range,"
and have a span of 0-750 psig. The total uncertainties associated with the instrument loops that include these indicators are derived in PVNGS setpoint and uncertainty calculation 13-JC-SI-
- 211, Rev.
2.
The calculation summarizes the indicator loop uncertainties under various environmental conditions.
For normal conditions the uncertainties are +3.01/-3.36% of span, or
+22.6/-25.2 psig. For a decreasing process variable (i.e., approaching the minimum), the positive
(+) uncertainty is applied to the minimum analytical limitto derive the minimum indicated value.
Adding 22.6 psig to 235 psig results in a minimum indicated value of 257.6 psig.
The scale of the indicators is 10 psig per division.
Thus, PVNGS is changing the limiting indicated value from 254 psig to 260 psig, for both readability and conservatism.
The analytical limitof 235 psig remains unchanged.
PVNGS CTS 3/4.5.1 requires the nitrogen cover pressure (indicated) in the Safety Injection Tanks shall be maintained between 600 and 625 psig when the plant is in Modes 1 and 2, and Modes 3 and 4 with pressurizer pressure greater than or equal to 1837 psia.
These requirements are not changing.
The minimum and maximum analysis pressures for this requirement have changed from a minimum of 593 psig and a maximum of 632 (as specified in the CTS Bases) to a minimum of 588 psig and a maximum of 637 psig (as specified in the ITS Bases).
These Page 1
f I
Enclosure 1
Resp'onse to Request for Additional Information Increase SIT MinimumNitrogen Cover Pressure changes are not within the scope ofchange LB.1. The minimum and maximum analytical values for pressure are part of the ITS Bases and controlled in accordance with 10 CFR50.59 and the ITS TS Bases Control Program.
The calculations were completed as part of the PVNGS Setpoint Project. The standards and methodologies used to perform calculations within the scope of the Project were determined to be applicable and developed under the guidelines of the PVNGS "Design Guide for Instrument Uncertainty Determination,"
which is based on ISA S67.04-1988 and its associated "Recommended Practice,"
and NRC Regulatory Guide 1.105, Rev. 2.
The methodologies include the establishment or verification of applicable analytical limits for process variables.
They also include derivations of total instrument loop uncertainties, based on examination of individual uncertainties (e.g., accuracy, drift, temperature effects, radiation effects, etc.) for each instrument in a given loop, under various environmental conditions (e.g., normal, post-seismic, post-accident, etc.).
Individual random uncertainties are combined using the SRSS (Square-Root-Sum-Squares) method.
Bias uncertainties are combined algebraically.
The resulting total random and total bias uncertainties are then combined algebraically to arrive at the total loop uncertainties.
These are then applied to the applicable analytical limits, to derive instrument setpoint and alarm points, and operator decision points.
IMPACTTO ITS SVBMITTAL:
The nitrogen cover pressures for the SIT appear in two specifications in the PVNGS ITS.
The two specifications are:
~
Specification 3.5.1, "SITs - Operating", which is applicable while in MODES 1
and 2, and MODES 3 and 4 with pressurizer pressure greater than or equal to 1837 psia; and
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Specification 3.5.2, "SITs - Shutdown", which is applicable while in MODES 3 and 4 with pressurizer pressure less than 1837 psia.
The Discussion of Change (DOC) for the increase in the minimum nitrogen cover pressure ofthe SIT was identified as Change No. LB.1 of ITS Specification 3.5.2.
It has been rewritten to incorporate the applicable portions of the response to the request for additional information and is attached.
Changes to the ITS Bases ofSpecification 3.5.1 needed as a result ofthis response to the request for additional information are attached.
Page B 3.5.1-5 of Specification 3.5.1 was impacted'y this response.
Page 2
tI ol
Enclosure 1
'esponse to Request for Additional Information Increase SIT MinimumNitrogen Cover Pressure Changes to the NUREG Bases markup of Specification 3.5.1 needed as a result of this response to the request for additional information are attached.
Page B 3.5-5 of NUREG Specification 3.5.1 was impacted by this response.
The CTS markup for Specification 3.5.1, "SIT's - Operating" is attached in its entirety since some distributed copies of the ITS did not contain this CTS markup.
The CTS markup for Specification 3.5.2 was not impacted by this response.
QXZKR The NO SIGNIFICANT HAZARDS CONSIDERATION, the SMOOTH COPY of the ITS SPECIFICATION, the NUREG 1432 SPECIFICATION
- MARKUP, and the NUREG EXCEPTIONS for ITS Specifications 3.5.1 and 3.5.2 were not impacted by this response.
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PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES ITS 3.5.2 DISCUSSION OF CHANGE (DOC) (Revised per NRC Request for Additional Information)
LB.1 PVNGS CTS 3/4.5.1, "Safety Injection Tanks" (Note t) requires that a minimum nitrogen cover pressure of 254 psig (indicated) be maintained in the Safety Injection Tanks when the plant is in Modes 3 and 4 with pressurizer pressure less than 1837 psia.
The Bases for this CTS identifies the corresponding analytical limit for minimum pressure under this condition as 235 psig, and 254 psig is chosen for the LCO to account for instrument inaccuracy.
Thus, up to 19 psig is credited for the total uncertainty associated with the instrument loop(s) to verify compliance with the LCO.
PVNGS surveillance procedures specify the use of pressure indicators J-SIA-PI-331 and J-SIB-PI-311 to verify minimum pressure in Modes 3 and 4. These indicators are termed "wide range," and have a span of 0-750 psig.
The total uncertainties associated with the instrument loops that include these indicators are derived in PVNGS setpoint and uncertainty calculation 13-JC-SI-211, Rev. 2.
The calculation summarizes the indicator loop uncertainties under various environmental conditions.
For normal conditions the uncertainties are +3.01/-3.36% of span, or +22.6/-25.2 psig.
For a decreasing process variable (i.e., approaching the minimum), the positive (+) uncertainty is applied to the minimum analytical limit to derive the minimum indicated value.
Adding 22.6 psig to 235 psig results in a minimum indicated value of 257.6 psig. The scale ofthe indicators is 10 psig per division. Thus, PVNGS is changing the limiting indicated value from 254 psig to 260 psig, for both readability and conservatism.
The analytical limitof 235 psig remains unchanged.
PVNGS CTS 3/4.5.1 requires the nitrogen cover pressure (indicated) in the Safety Injection Tanks shall be maintained between 600 and 625 psig when the plant is in Modes 1 and 2, and Modes 3 and 4 with pressurizer pressure greater than or equal to 1837 psia.
These requirements are not changing.
The minimum and maximum analysis pressures for this requirement have changed from a minimum of 593 psig and a maximum of 632 (as specified in the CTS Bases) to a minimum of588 psig and a maximum of637 psig (as specified in the ITS Bases).
These changes are not within the scope ofchange LB.1. The minimum and maximum analytical values for pressure are part of the ITS Bases and controlled in accordance with 10 CFR50.59 and the ITS TS Bases Control Program.
PALO VERDE - UNITS 1, 2, AND 3 REV B Revised per NRC request for additional information
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