ML17312B373
| ML17312B373 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/10/1997 |
| From: | Thomas C NRC (Affiliation Not Assigned) |
| To: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| TAC-M96672, TAC-M96673, TAC-M96674, NUDOCS 9704160279 | |
| Download: ML17312B373 (44) | |
Text
Hr. James H. Levine Senior Vice President, Nuclear Arizona Public Service Company Post Office Box 53999
- Phoenix, Arizona 85072-3999 April 10, 1997
SUBJECT:
RE(VEST FOR ADDITIONAL INFORMATION SECTION 3.8 OF THE PROPOSED LICENSE AMENDMENT TO IMPLEMENT IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR PALO VERDE NUCLEAR GENERATING STATION (PVNGS),
UNIT NO.
1 (TAC NO. H96672),
UNIT NO.
2 (TAC NO. H96673),
AND UNIT NO.
3 (TAC NO. H96674)
Dear Hr. Levine:
By letter dated October 4,
- 1996, and supplemented by letter dated March 16, 1997, Arizona Public Service Company submitted a request to convert the current Technical Specifications (TSs) for PVNGS Units 1, 2, and 3, to make them consistent with NUREG-1432, Revision 1, "Standard Technical Specifications Combustion Engineering Plants,"
dated April 1995.
In order for the staff to complete its review, the additional information identified in the enclosure is required.
To assist the staff in meeting its review schedule, we request that you respond to the RAI in writing within 60 days of receipt of this letter.
If you have any questions, please contact me at (301) 415-1325.
Sincerely, Original Signed By Charles R.
- Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects - II.I/IV Office of Nuclear Reactor Regulation Docket Nos.
STN 50-528, STN 50-529 and STN 50-530
Enclosure:
Request for Additional Information cc w/encl:
See next page I
DOCUMENT NAME: PV38SEC.RAI DISTRIBUTION:
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'Thomas
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NRR:TSB NAME DATE CThomas 4/A)97 JCliffor 4/lo g7',
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,Nr. James H. Levine Apri 1 10, 1997 cc w/encl:
Hr. Steve Olea Arizona Corporation Commission 1200 M. Mashington Street Phoenix, Arizona 85007 Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O.
Box 800
- Rosemead, California 91770 Senior Resident Inspector USNRC P. 0.
Box 40 Buckeye, Arizona 85326 Regional Administrator, Region IV U. S. Nuclear Regulatory Commission Harris Tower 8 Pavi.llion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064
- Chairman, Board of Supervisors ATTN:
Chairman 301 M. Jefferson, 10th Floor Phoenix, Arizona 85003 Mr. Aubrey V. Godwin, 'Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, Arizona 85040 Hs. Angela K. Krainik, Hanager Nuclear Licensing Arizona Public Service Company P.O; Box 52034 Phoenix, Arizona 85072-2034 Nr. John C. Horne, Vice President Power Supply Palo Verde Services 2025 N. Third Street, Suite 220 Phoenix, Arizona 85004 Hr. Robert Burt Los Angeles Department of Mater 5 Power Southern California Public Power Authority 111 North Hope Street, Room 1255-B Los Angeles, California 90051 Nr. David Summers Public Service Company of New Mexico 414 Silver SW, 80604 Albuquerque, New Mexico 87102 Hr. Robert D. Bledsoe Southern California Edison Company 14300 Mesa Road, Drop D41-SONGS San Clemente, California 92672 Hr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251 Terry Bassham, Esq.
General Counsel El Paso Electric Company 123 W. Mills El Paso, Texas 79901
Enclosure RE UEST FOR ADDITIONAL INFORMATION REGARDING SECTION 3.8 OF THE PROPOSED ICENS ENDMENT TO IMPLEMENT IMPROVED ST NDARD TECHNICAL SPECIFIC T ONS FOR PALO VERD. NUCLEAR GENERATING STATION PVNGS Section 3.8. 1 ITS LCO 3.8. 1 Actions A.3 and B.4 and SR 3.8. 1.20 A2 This change is beyond the scope of ITS conversion.
If approved by the NRC staff prior to the ITS conversion safety evaluation (SE), it will be incorporated into the ITS.
TS LCO 3.8. 1 ction H
LAl The licensee's discussion in Change LAl is not applicable because it is not consistent with CTS or NUREG-1432.
The licensee needs to include in its discussion that if a diesel generator (DG) is inoperable and the cause of the inoperability has not been determined within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the redundant DG must be tested.
The justification in LA1 leads the staff to conclude the licensee believes that DG operability can be restored without first testing the root cause of the original inoperability.
This is not the case.
Even if a DG can be made to run and accept load, there is no assurance that this will continue for any time, unless the original root cause has been determined.
Therefore, the DG may not be considered operable while the root cause determination continues beyond the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> completion time.
The licensee needs to revise Change LA1 to be consistent with NUREG-1432.
TS LCO 3.8.1 Action E
There is no Action E.2 in the ITS.
The CTS markup is annotated with Action E.2.
LA6 Change LA6 is confusing and it is not clear that the CTS requirements are properly indicated in the proposed ITS; e.g.,
the Bases do not include specific values for proposed ITS Action G; and it is not clear how proposed Actions G.l.l and G.2.2 reflect CTS requirements regarding two and three startup transformers in service.
The licensee needs to provide further discussion for Change LA6.
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ITS SR 3.8.1.2 A4 Change A4 requires revisions as follows:
.(1) The SRs to be conducted from standby conditions should. include 3.8. 1.2, 3.8. 1.7 and 3.8.1.1.9, (2) The remaining SRs may be conducted from the as found condition provided the jacket water and lube oil temperatures are within the upper limits for DG operability.
These revisions are acceptable because the SRs involved are primarily intended to test system response, not the ability of DGs to start from standby conditions.
.Deleting this constraint from all but the above SRs will help to decrease unnecessary stress on the DG while also providing increased flexibilityfor scheduling tests.
As currently worded, this change is too vague and does not adequately support the proposed change.
ITS SR 3.8.1.5 M2 The proposed SR is not consistent with NUREG-1432 because the frequency is every 92 days as opposed to the ITS 31 days.
Change M2 needs to be revised to address this inconsistency and to justify the 92 days based on the basis of the arid climate at PVNGS.
CT ootnote 1
The CTS prohibits performance of this SR in Node 1-4.
The ITS restriction on performance of this SR is limited to Nodes 1 and 2.
The allowance to now conduct this SR in Nodes 3 and 4 has not been addressed.
The submittal should be revised to address this less restrictive change.
ITS SRs 3.8.1.7 and 3.8.1.15 The staff has accepted changes to voltage and frequency upper limits on EDG starts.
The licensee has not taken advantage of this relaxation.
LA2 Change LA2 states that this footnote may be moved to the Bases since it is not a TS requirement.
LA2 is correct with respect to this footnote not being a TS requirement, but is incorrect in stating that it can be moved to the Bases.
This footnote is a permissive; i.e.,
a modification to a TS requirement.
It is not mandatory that the footnote be used;
- however, the TS requirements cannot be modified without the permissive note in TS.
The licensee needs to revise LA2 to correct this statement.
LA3 Change LA3 needs to be revised.
The part of the footnote, that addresses engine warmup is also a permissive which cannot be implemented in the Bases.
I'i
1 Footnote 4
LA4 Change LA4 states that modifiers to TS requirements such as "Momentary transients etc." can be implemented via the Bases.
This is not correct, the Bases cannot impose or modify any TS requirement.
The licensee needs to revise Change LA4.
TS SR 3.8.1.19 ITS M4 TS The licensee needs to revise this SR to state that the SR will be conducted from standby (keep warm) conditions.
SR 3.8.1.13 The proposed ITS SR is very specific; i.e., test for bypass function only with combined LOOP/LOCA.
The CTS requires testing during emergency operation which, by design, includes
Therefore, the proposed SR does not include testing of the individual operational Modes.
This change is less restrictive," not more restrictive as indicated in Change M4, and has not been justified.
The licensee needs to provide the appropriate justification, or revise the SR to include the LOOP and LOCA, individually.
SR 3.8.1.14 LA5 The portion of footnote 4 which allows loading in accordance with manufacturer's recommendations is a permissive that can not be implemented via the Bases.
In this instance, the Bases for SR 3.8.1.14 are incorrect as stated in Change LA5; The submittal associated with Change LA5 should be revised to include the permissive (if it is desired) as a note in the SR, with the appropriate discussion in the Bases.(not a reference,to another SR/Bases).
icabilit Ml Change Ml needs further clarification.
However, it is suggested that the applicability be "during movement of irradiated fuel" without the qualifier "with the core off loaded."
As proposed, the ITS raises the question "what are the requirements relative to handling fuel when the core is not off loaded" ?
By being more generic, all aspects of fuel handling are addressed and potential misinterpretations are avoided.
Other licensees have added a statement that LCO 3.0.3 is not applicable to cover the condition of fuel handling/movement at any time, including power operation.
TS Required Action A.2.2 requires that movement of irradiated fuel assemblies be suspended.
This obviously means fuel movement of any kind, but the proposed applicability would only cover fuel-movement after the core is unloaded; i.e.,
movement of fuel in the process of off loading the core is not covered.
LCO 3.8.2 Actions LAl The CTS requirement addresses movement of any loads over the spent fuel pool, not just fuel assemblies. 't is not clear how changing the LCO applicability will provide assurance that the necessary systems/components required to cope with dropping any load onto stored fuel will be available.
The dropped load is not limited to a fuel assembly.
Deletion of this CTS requirement, as described in Change
- LA1, requires further justification.
ITS SR 3.8.2.1 A3 The staff agrees with proposed ITS SR 3.8.2. 1 with the following exceptions:
(1)
SR 3.8. 1. 19 should be deleted from the list of SRs not required to be performed and added to the list of SRs that are not applicable, and (2) Change A3 should be expanded to more thoroughly address the SRs that must be performed, the SRs that are applicable but not required to be performed, and the SRs that are not applicable.
5 i
3.8.3.
H2 Change H2 needs to be revised to provide further clarification.
CTS requires that stored 'fuel be checked for viscosity, water, and sediment every 92 days.
Change H2 could be interpreted to mean that these requirements are carried over to the ITS.
This is not the case.
The ITS only requires that new fuel be tested for, among other things, viscosity, water, and sediment prior to adding the new fuel to the storage tanks.
Stored fuel is to be tested only if the sample of new fuel fails to conform to ASTH requirements for 2D fuel.
Change H2 does not make this clear.
Change H2 needs to be revised to accurately reflect the ITS.
CTS 3.8.1.3.2 R1 Relocation of the fuel oil storage system cathodic protection may or may not be acceptable.
Change Rl"(split report) needs to include a
discussion of why the CTS was initially imposed or what has changed over time such that this requirement is no longer valid.
Change Rl makes an adequate case for relocation in terms of 50.36 criteria 1, 2,
and 3.
However, the discussion regarding criterion 4 is inadequate and needs to be addressed by the licensee.
0 I
Section 3.8.4 ITS LCO 3.8.4 The.CTS and the ITS both allow continued oper ation with no operable battery chargers provided the designated pilot cells are shown to meet category A limits within one hour and every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.
To assist the staff in its evaluation of this TS, the licensee needs to provide answers to the foll'owing questions:
(I) Are there enough pilot cells to provide a good indication of overall battery condition?
(2) The open circuit voltage of these battery cells is 2.14 volts/cell.
Assuming a 60 cell battery, and all cells at optimum voltage, the open circuit terminal voltage without a charge on float would be 128.4 volts.
Any weak cells would drop this value, any DC. load would cause a further voltage drop.
How long before the terminal voltage is decreased to an unacceptable value?
(3) Assuming the battery appears to be ok at time I hour; what is the confidence level that it will remain so for the next 8
- hours, considering the above comments?
S LCO 3.8.4 A2 The licensee needs to include additional justification for deleting "energized" from this LCO.
The reason that deletion of the term "energized" is acceptable is that in the ITS (NUREG-1432), operable is defined in the Bases, and the definition includes the DC subsystems being energized to their proper voltage.
In addition, there are surveillances associated with this LCO which require moni'toring of the parameters associated with DC subsystem operability.
ITS Actions A and C
A7 The licensee needs to revise Change A7 to make a clear distinction
'etween the battery chargers and the remainder of the DC systems; i.e.,
"One DC electrical power subsystem (exclusive of the battery charger) inoperable."
The Bases can describe what constitutes operability in better detail than proposed Condition A without the potential for misinterpretation of the proposed condition.
The licensee needs to revise Change A7 to make a clear distinction that either charger can satisfy the LCO; i.e.,
"Required DC electrical power subsystem battery charger inoperable" and "Restore battery charger to operable status in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />."
This would avoid the proposed TS which would allow a battery to be without a charger for an indefinite period of time.
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TS SR 3.8.4.6 Ll Change Ll needs to be revised by including the proposed generic change to 3.0 (SR 3.0.2).
This will allow any unplanned events to be credited as successful SRs as long as the acceptance criteria of the SRs is satisfied by the unplanned event.
By utilizing the generic
- approach, this and other notes like it can be deleted along with the associated Bases.
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..4.4 Is there a generic action to delete the "tightness" check from the SR?
The rational is that re-torquing is not recommended and probably not necessary if resistance measurements are within acceptable tolerances.
ITS SR 3.8.4.7 The licensee needs to revise note I to this'R.
This note applies only to modified performance test.
The modified performance discharge test can be substituted for a service test at any time as long as the parameters of the test envelope the service test.
Note I also needs to be revised by including the proposed generic change to 3.0 (SR 3.0.2).
This will allow any unplanned events to be credited as successful SRs as long as the acceptance criteria of the SRs is satisfied by the unplanned event.
By utilizing the generic
- approach, this and other notes like it can be deleted along with the associated Bases.
q Section 3.8.5 ITS LCO 3.8.5 A2 TS Change A2 only discusses deletion of "energized",
but the changes indicated as being associated with this change involve a complete
- change, to the LCO.
The licensee needs to revise discussion A2 to include these additional requirements.
icabilit Change NI addresses adding to the LCO applicability "Movement of irradiated fuel assemblies with the core off loaded."
This is acceptable as far as it goes.
- However, movement of irradiated fuel assemblies can take place at any time, the location of the core notwithstanding.
Therefore, the last part of the applicability should be deleted, leaving only "During movement of irradiated fuel."
There is a generic issue, that involves adding a note to this LCO to the effect that LCO 3.0.3 is not applicable.'he licensee should review this generic issue with a view towards incorporating it into the PVNGS submittal.
0 v
ITS Actions A and 8
Separating the battery and the battery charger into separate actions is confusing.
The licensee needs to revise these Actions to make a clear distinction between the battery chargers and the remainder of the DC systems; i.e.,
"One DC electrical power subsystem (exclusive of the battery charger) inoperable."
The Bases can describe what constitutes operability in better detail than proposed Condition A without the potential for misinterpretation of the proposed condition.
ITS Act'on A. I L3 TS The licensee's justification for Change L3 needs to be revised to address why allowing affected features to be declared inoperable as opposed to immediately ceasing all activities is desirable and acceptable from a safety perspective.
Change L3 for LCO 3.8.5 discusses inverters; this should be changed to DC electrical power subsystems, or something similar.
SR 3.8.5.1 Change Ll needs to be revised to state why certain SRs from LCO 3.8.4 are not applicable, and, therefore, why deletion of the requirements from LCO 3.8.5 is acceptable.
Section 3.8.6 ITS LCO 3.8.6 ITS Change Hl is confusing and needs to be revised.
Mhich LCO is accurate LCO 3.8.4 or LCO 3.8.67 The discussion includes two references to a DG DC source.
LCO 3.8.4 does not indicate that there is a separate (from the station battery)
The licensee needs to make the necessary changes to be consistent.
Condit'o L5 The licensee needs to provide additional discussion in Change L5 of why this less restrictive change is acceptable, i.e., there is still adequate battery capacity to perform the required safety function, and allowing time to restore the battery to full operability is more desirable from a safety perspective than requiring a plant to shutdown.
R 3.8.6.3 The licensee needs to address the following: (I) CTS requires verifying the electrolyte temperature of 6 connected, cells.
ITS SR 3.8.6.3 requires verifying the temperature 'of representative cells.
What is the difference between the two requirements?
(2) Hhat assurance is provided that the ITS requirements accurately reflect CTS requirements7
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ITS Table 3.8.6-1 L3 The licensee needs to state what version of IEEE-450 is referenced in Change L3?
The discussion needs to be revised to more clearly identify why allowing the electrolyte level to rise, i.e.,
an elevated electrolyte level has no safety impact (as long as it is not over.
flowing), and the absence of this explanation could impact an adequate battery recharging.
TS Table 3.8.6-1 LAl ITS The licensee needs to provide additional information on Change LAl on why the CTS Category B requirements regarding the average specific gravity (SG) of all connected cells has been deleted?
Specifically, why is this parameter not required in order to determine operability of the battery?
able 3.8.6-1 Ll The licensee needs to provide additional information on Change Ll on whether PVNGS has done any studies to verify that there is adequate battery capacity for the accident scenario, assuming the battery SG has dropped to around 1.280 average for all-connected cells?
If so, the studies should be referenced in Change Ll. If no studies have been performed what is the basis for stating that adequate battery capacity exists when battery parameters are at the lower end of Category C
allowable limits?
ITS Table 3.8.6-1 L4 The licensee needs to state what version of IEEE-450 is referenced in Change L4?
This discussion requires additional information regarding the battery manufacturer's recommendations to not correct float voltage for electrolyte temperature.
IEEE-450 (1995) does not specifically state the temperature correction is not recommended.
To the contrary, the inspections detailed in IEEE-450 (1995) include electrolyte temperature measurement (although use of the information is not discussed).
Section 3.8.7 ITS ction A
CTS requires that the AC vital bus be re-energized within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, or be'n Cold Shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The proposed ITS allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore an inoperable inverter and includes a reference to LCO 3.8.9 if an AC vital bus is de-energized.
This change from the CTS to ITS is not discussed.
A change addressing this issue needs to be provided.
The licensee has not provided an adequate justification for this change.
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ITS Action B
The licensee needs to provide a justification to address the difference between the CTS Action B and the proposed ITS Action B.
The licensee also needs to provide a discussion on how the inverters at PYNGS are configured?
Is it a standard UPS arrangement with a battery feeding an inverter which in turn feeds the vital AC bus, with a transfer capability to a regulated source downstream between the inverter and the vital busT Or is there an internal rectifier feeding the inverter with an auctioneering circuit to switch from the internal rectifier to the battery as a function of voltages The licensee needs to add a required action to Condition A which would require powering the AC vital bus from a regulated source within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and restore inverter to operable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; this would make LCO 3.8.7 consistent with LCO 3.8.9.
After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, an inverter must be connected to the bus, or a shutdown is required.
Therefore, after 24
Sec ion 3.8.8 ITS CO
.8.8 LI LA1 ITS A Change Ll only addresses changes made in converting from CTS to ITS.
Ll does not adequately address why the change is acceptable.
Change Ll requires additional clarification to explain why the proposed relaxations do not constitute a safety concern, or may even be a safety enhancement by allowing the flexibilityto power AC vital busses as required.
Change LAI needs to be revised to adequately discuss why the changes are acceptable; i.e., the details moved to the Bases are not necessary for adequately stating the requirements of the LCO.
1 icabi1 it The second part of the applicability should be limited to "During Movement of Irradiated Fuel."
Limiting this applicability to only when the core is off loaded raises the question "What are the requirements for AC vital busses when moving irradiated fuel and the core is not off loaded'"
In fact, given the proposed Applicability, is it permissible to move irradiated fuel when the core is not off loaded'he licensee needs to address these issues as it relates to applicability.
ITS Action A L2 The licensee needs to discuss why the option to declare affected required features inoperable is acceptable as opposed to stopping all work, i.e., allows the option to assess the impact of the combination of inoperable required features which may not require stopping all work, as opposed to the unilateral requirement to stop all work.
The licensee needs to provide additional discussion for Change L2.
Section 3.8.9 ITS LCO 3.8.9 LAl Ll The licensee needs to revise Change LAl by adding words such as "the material moved to the Bases is not necessary to adequately describe the LCO requirement that electrical distribution subsystems required to support plant safety functions must be operable."
The licensee needs to address why pow'ering the AC vital bus from a constant voltage source is acceptable from a safety perspective?
The justification does not adequately address this issue.
Contrary to the statements in Change Ll, the source (i.e., quality) of the power to the AC vital bus is a concern which is not addressed.
Moreover, the proposed LCO condition does not have a time constraint on how long it is acceptable to power the AC vital bus from this alternate source (although it can be inferred from LCO 3.8.7 to be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).
- Finally, the constant voltage source itself is not addressed in the Bases.
The licensee needs to provide considerable revision to Change Ll.
The licensee needs to address why it is acceptable to have a
DC bus without an operable battery for any period of time from a safety perspective7 The justification does not adequately address this issue.
Contrary to the statement in Change Ll, the source of the DC power to the DC bus is important, especially with respect to functions that require DC power in the event of a LOOP.
In addition, the proposed change does not place a limit on how long a
DC bus may be powered from a battery charger, only (although this can be inferred from LCO 3.8.4).
Finally, the proposed Bases does not include a discussion of what constitutes a operable DC bus.
The licensee needs to revise Change Ll.
ITS A tions A
B and C
L2 The proposed changes associated with Change L2 are the same as those proposed in TSTF-16.
The staff has not accepted TSTF-16.
ITS Action C
LA2 Change LA2 and its associated change is not consistent with the proposed Bases or with the changes proposed in Change Ll of this section.
The Bases do not contain an adequate description of what constitutes an operable DC bus, and the changes in Ll would allow powering the DC bus
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from a battery charger (at least for a period of time).
Change LA2 should be revised to address these inconsistencies.
I S
ction E
M2 Change M2 appears to be improperly classified.
CTS allows one each of the AC, DC, or AC vital buses to be inoperable for a specified period of time.
The CTS does not,
- however, allow two of any of the above distribution subsystems to be inoperable, and a plant condition involving this would invoke LCO 3.0.3.
As proposed, Action E would allow continued plant operation for an unspecified period of time with two or more subsystems inoperable unless the multiple inoperability resulted in a loss of function.
This is no different than CTS so long as the inoperabilities are in different subsystems; i.e.,
However, if, say, 2
DC busses were inoperable, CTS would take you to 3.0.3.
This appears to be a less restrictive change that is
~ not adequately justified.
The licensee needs to address why Change M2 is classified as a more restrictive change.
Sect'on 3.8.10 ITS LCO 3.8.10 Ll L2 The justification in Change LI does not adequately address this issue.
Contrary to the statements in the change, the source (i.e., quality) of the power to,the AC vital bus is a concern which is not addressed.
Moreover, the proposed LCO condition does not have a time constraint on how long it is acceptable to power the AC vital bus from this alternate source (although it can be inferred from LCO 3.8.7 to be 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />).
Finally, the constant voltage source itself is not addressed in the Bases.
The licensee needs to add a discussion in Change Ll to address why powering the AC vital bus from a constant voltage source is acceptable from a safety perspective.
The licensee also. needs to address why it is acceptable to have a
DC bus without an operable battery for. any period of time from a,safety perspective7 The justification does not adequately address this issue.
Contrary to the statement in Change Ll, the source of the DC power,to the DC bus is important, especially with respect to functions that require DC power in the event of a LOOP.
In addition, the proposed change does not place a limit on how long a DC bus may be powered from a battery charger, only (although this can be inferred from LCO 3.8.4).
Finally, the proposed Bases does not include a discussion of what constitutes a operable DC bus.
The licensee's discussion in Change L2 does not draw an adequate conclusion for why the change is necessary or desirable.
As an example, CTS requires specific busses to be energized without reference to safety systems required operable.
The proposed LCO requires electrical power distribution subsystems to be operable in support of the safety systems required operable.
The proposed LCO represents an enhancement in
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The licensee needs to provide additional justification for Change L2.
TS CO 3.8. 10 S
3.8.
- 0. 1 a d Pro osed ITS Action A LA1 The licensee needs to revise Change LA1 by adding words such as "the material moved to the Bases is not necessary to adequately describe the LCO requirement that electrical distribution subsystem's required to support plant safety functions must be operable."
~IT 11 1111t H2 Change M2 addresses adding to the LCO applicability "movement of irradiated fuel assemblies with the core off loaded."
This is acceptable as far as it goes.
- However, movement of irradiated fuel assemblies can take place at any time, the location of the core notwithstanding.
Therefore, the last part of the applicability should be deleted, leaving only "During movement of irradiated fuel."
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L3 Change L3 does not make an adequate case for declaring required features inoperable.
The required actions associated with those features may prescribe a course of action that is acceptable from a safety perspective but still does not require that all activities be stopped.
This provides added flexibilityrelative to shutdown activities without creating a safety concern.
The licensee needs to provide additional justification for Change L3 and address why this change is acceptable.
NUREG SECTION 3.8-1 Conditions A and B
Bases Actions A.3 and B.4 The proposed changes are beyond the scope of ITS conversion.
If they are accepted by the staff prior to the ITS conversion SE, they will be incorporated into the ITS.
Cond tion F and Bases ction F. 1 What is the status of. the Risk-Informed Basis for Load Sequencer Allowed Outage Times (AOT) (B-NS-C24)7 Has the NRC staff reviewed this study2 If a sequencer is an essential part of both an offsite circuit and a
DG, failure of a sequencer should be the same as one offsite and one DG inoperable, i.e.,
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AOT.
The licensee should provide more details of the above study for staff review.
Condit'on G
The staff requires more information regarding the PVNGS design before an evaluation of the proposed condition can be made.
The licensee needs to provide additional description as required.
13-Surve'1 ance Re uirement SR 3.8. 1.5 This SR is a more restrictive addition by the licensee.
The change from 31 days to 92 days has not been addressed.
The licensee needs to provide justification for this change.
7 and SR 3.8. 1.15 The staff has accepted changes to voltage and frequency upper limits on EDG starts.
The licensee has not taken advantage of this relaxation.
SR 3.8.1.12 Deletion of the 10 second start requirement is not acceptable.
While this is primarily a system test, it is applicable to the whole system, including the bypassing or deactivation of any features that may be used to implement modified starts.
Subpart e of the NUREG SR is modified to delete that part of the requirement with "auto-connecting loads through the load sequencer."
This change has not been justified.
- moreover, the change appears to be in conflict with earlier portions of this submittal which indicate that emergency loads are
~se uenced onto the offsite circuit.
This proposed change requires some additional discussion by the licensee.
S 3.8.1.20 The licensee should review generic changes to LCO 3.0.2 which have been found acceptable by the staff and which address credit for unplanned events.
The staff has also accepted changes to voltage and frequency upper limits on EDG starts.
The licensee has not taken advantage of this relaxation.
Bases Limitin Conditions of- 0 eration LCO No justification is provided for deletion of the Bases material regarding definition of "gualified offsite circuits."
The licensee should provide a
justification or retain the NUREG-1432 language.
ases ew Text The Background section indicates that each 4160 VAC Class IE bus has a normal and an alternate offsite power feed.
This is not discussed in the proposed new text - there is only a discussion of 1 feed to each bus.
The licensee needs to provide additional information in the "new text" in order to provide a complete discussion of the ~ua ified offsite circuits.
ases LCO The licensee has not provided an adequate justification for deletion of the last paragraph in this Bases section.
The licensee needs to provide
. additional justification.
S' t
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1 h
14-Bases Action
. 1 and B. 1 What is the reason for deleting the Reviewers note7 Is the PVNGS design such that the turbine-driven auxiliary feed pump need not be considered a redundant feature7 If so, why is this not stated in the justification'?
The licensee needs to provide a justification for deletion of this note.
ases SR New Text It is not clear if SR 3.8.1.2 is being conducted from normal keep warm conditions.
Also, the new test reference to SR 3.8. 1.20 being conducted from standby (normal keep warm) conditions is incorrect.
The reference should be SR 3.8. 1. 19, and possibly should include SR 3.8. 1.2.
The new text also includes a permissive (i.e.,
may be performed).
This is inappropriate for the Bases.
The 3" paragraph of the proposed new text is not consistent with the TS SR, and is not acceptable.
It also establishes acceptance criteria which is inappropriate for TS ~
What is meant by the paragraph dealing with surveillance load testing?
The licensee needs to revise this section accordingly.
Bases SR 3.8.1.2 Review this deletion in light of comments on new text,
- above, and likely SR 3.8.1.7 changes to the proposed new text.
Bases SR 3.8.1.3 The licensee has not provided a justification for the addition to the 1" paragraph or for the deletion in the 2
paragraph.
Appropriate justifications should be provided.
SR 3.8.1.9 Subpart a is not consistent with the new text at the bottom of the page.
The new text specifically excludes paralleling with offsite to conduct this SR and is the basis for deleting power factor from this SR.
The licensee needs to address these inconsistencies.
SR 3.8.1.14 ew Te t The licensee needs to provide additional discussion on transients for the Bases.
The present discussion is not sufficient for this SR.
l t
I SR 3.8.1.15 New Text The purpose of.the Bases is to explain the TS requirement or allowance, not to establish requirements or allowances.
The SR Notes do not mention special testing.
Therefore, the Bases should not contain anything about such testing even if it is to be conducted under direct monitoring of the manufacturer.
The licensee needs to revise the new text accordingly.
SRs 3.8.1.3 3.8.1.10 3.8.1.11 3.8.1.
4 3.8.15 3.8.1.16 3.8.1.17 3.8. 1. 18 and Bases SR New Text Regulatory Guide (RG) 1.9, Rev. 3, supersedes RG 1. 108, and a licensee cannot use both as the basis for ITS conversion.
The licensee should review the submittal to ensure that only the provisions of one of the RGs are
- used, make any necessary
- changes, and retain only the appropriate RG reference.
In SR 3.8. 1. 10 new text discusses the "intent" of RG 1.9, Rev. 3.
What does this meant SR 3.8.1.19 This SR must be conducted from normal standby conditions; i.e.,
engine at keep warm temperature.
UREG SECTION 3.8.2 LCO 3.8.2.a and Bases LCO Deletion of the term "qualified" is not acceptable, as is deletion of the Bases discussion of "qualified."
This discussion states that PVNGS does not have "qualified" offsite circuits, but does not elaborate on why this is so; i.e., the discussion does not state what a "qualified PVNGS offsite circuits" is, and the Bases discussion is proposed to be deleted.
The submittal should be revised to retain the NUREG language and Bases.
LCO 3.8.2 A licabilit and Bases A licabilit The proposed change is not acceptable.
Contrary to what this discussion indicates, the minimum AC requirements are applicable at all times that irradiated fuel is being moved, including Nodes 1-6.
Also, as proposed, the Applicability is contradictory.
If any fuel assembly is not ~T REST in the spent fuel pool, the core is not offloaded.
Therefore, movement of irradiated fuel; cannot occur "with the core offloaded."
The problem can be resolved by retaining the NUREG language without modification.
R 3.8.2.1 SR 3.8.1.6 should be added to the note.
Since the EDG is not required to be loaded for a minimum of one hour, the fuel oil transfer pump will not cycle on.
The licensee has deleted NUREG material without providing any PVNGS plant specific material.
The licensee, also replaced the word "ambient" with "keep warm."
The licensee needs to provide justifications for these changes.
Bases Next to last Para ra h
Deletion of "for DG OPERABILITY" is not justified and is, therefore, not acceptable.
The licensee needs to provide an adequate justification for this
. deletion, or the NUREG-1432 language should be retained.
ases SR 3.8.2.1 What is the purpose of the 2
paragraph of the proposed new texts It does not appear to relate to anything in SR 3.8.2. 1.
The licensee needs to provide an explanation.
SR 3.8.1.6 should be added to a note.
Since the EDG is not required to be loaded for a minimum of one hour, the fuel oil transfer pump will not cycle on.
The term "with the core offloaded" is not defined in the 3.8.2 Bases or anyplace else in this ITS proposal.
The licensee needs to provide an explanation.
NUREG SECTION 3.8.3 LCO 3.8.3 Condition E
The change to the NUREG with respect to adding "a required" ahead of "starting air receiver" is not justified by PVNGS discussion of exceptions No. 1.
The proposed change is also not understood.
Does this change mean that the PVNGS EDG starting air arrangement includes more than one starting air receiver and that all receivers are required for starting the EDG? If not, does it mean that only one of the multiple receivers is required7 The licensee needs to provide an additional discussion that addresses this change specifically and which supports the proposed values for receiver pressures.
CO 3.8.3 Condition The proposed change is not acceptable.
The language in Condition F
(NUREG) is consistent with the LCO proper as well as the SRs that are the basis for establishing the limits that are or are not met.
The tie to defined terms comes in the Applicability and in the Required Actions.
The proposal to substitute "inoperable" for "within limits" destroys this consistency for no apparent reason.
Note also that "inoperable" is no more of a defined term than "not within limits."
The licensee needs to retain the NUREG-1432 language.
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I I
Bases Action E. 1 New Text The proposed new text needs clarification.
As worded, it is not clear how many air receivers are required and at what pressure.
The text states (see Bases annotation) "If the one starting air receiver..."
The licensee need to be consistent with its description of air receivers.
The second paragraph of the proposed new text is not necessary and does not relate to anything in TS.
What is the purpose of this paragraph, and can it be deleted'ases SR 3.8.3.2 New Text The proposed new text does not make it clear how it can be verified that there is 168 gallons of lube oil available.
The new text addresses an assumption regarding minimum usable oil level, but does not address what oil level must be maintained.
Additional clarification is 'required.
I Also, if the lube oil inventory is to be determined based on level in the DG crankcase, the SR will have to be changed along with. the Bases (and possibly the associated condition).
The licensee needs to provide additional discussion on this issue.
ases SR 3.8.3.5 This discussion does not address the change from 31 days to 92 days.
The licensee needs to provide the appropriate discussion.
NUREG SECTION - 3.8.4 CO 3.8.4 Conditio s
A and C
The licensee needs to revise Conditions A and C to make a clear distinction between the battery chargers and the remainder of the DC systems, i.e.,
"One DC electrical power subsystem (exclusive of the battery charger) inoperable."
The Bases can describe what constitutes operability in better detail than proposed Condition A without the potential for misinterpretation of the proposed condition.
S s 3.8.
.3 3.8.4.
SR 3.8.4.5 and Ba es Rs 3.8.4.3 3.8.4.4 and S
3.8.4.5 The licensee needs to provide adequate justification for changing
[12] months to 18 months.
An appropriate justification needs to be provided, or retain the NUREG-1432 language.
Also, for SR 3.8.4.4, is there a generic action to delete the "tightness" check from the SR?
The rational is that re-torquing is not recommended and probably not necessary if resistance measurements are within acceptable tolerances.
0
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I SR 3.8.4.6 and SR 3.8.4.7 These SRs needs to be revised to include the proposed generic change to 3.0 (SR 3.0.2).
This will allow any unplanned events to be credited as successful SRs as long as the acceptance criteria of the SRs is satisfied by the unplanned event.
By utilizing the generic approach, this and other notes like it can be deleted along with the associated Bases.
The licensee needs to revise note I to SR 3.8.4.7.
This note applies only to modified performance test.
The modified performance discharge test can be substituted for a service test at any time as long as the parameters of the test envelope the service test.
The licensee needs to provide a discussion on how the spare or swing battery chargers are tested for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> at ~ 400 amps or ~ 300 amps without impacting safety systems.
ases Back round Second and orth ara ra h
The discussion does not provide an adequate justification for the deletion.
The licensee needs to provide a better justification.
Insert 3 addresses "load groups" whereas the rest of the Bases and the LCO use the term subsystem(s).
What is the reason for the change in Insert 3P Bases Actions B. I and B.2 The proposed addition "(i.e., inoperable battery)" should be deleted.
As
- proposed, the implication is that only the battery can be a cause of subsystem inoperability.
This is inconsistent with the LCO and the previous Bases discussions.
Hence, it should be deleted.
nsert 4
The licensee needs to revise this section to make a clear distinction that either charger can satisfy the LCO, i.e.,
"Required DC electrical power subsystem battery charger inoperable" and "Restore battery charger to operable status in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />."
This would avoid the proposed TS which would allow a battery to be without a charger for an indefinite period of time.
SR 3.8.4.1 This discussion is confusing.
It states the "nominal design voltage" are used in the battery sizing calculations.
How does "nominal" voltage differ from the battery fully charged voltages If there is a difference, should this not be discussed in this Bases section7
I Bases SRs 3.8.4.3 3.8.4.4 and SR 3.8.4.5 The discussion of changes does not provide an adequate justification for the proposed changes.
These SRs can be performed at power and need not be tied to operating cycles.
Bases SR 3.8.4.7 What is the origin of the proposed addition re: "performance test rate"7 IEEE-4507 The licensee needs to provide a discussion which justifies this proposed addition.
Also, for the proposed deletion in this SR, the licensee's discussion does not provide an adequate justification.
A better justification needs to be provided, or retain the NUREG language.
ases SR 3.8.4.8 There is an inconsistency associated with the proposed Bases addition.
SR 3.8.4.7 (ITS) Note 1
~onl allows substitution of.the modified performance discharge test for the service test.
Nothing is said about the performance discharge test, and the Bases cannot be used to add a permissive to the TS.
Delete the proposed addition, or change the LCO accordingly.
What is the basis for the statement that a performance discharge test can be substituted for a service test provided the "capacity discharge rate" envelopes the duty cycle of the service test7 efe ences Why is PVNGS referencing the 1980 version of IEEE-4502 This reference is not consistent with the proposed TS, e.g.,
the modified performance discharge test is not included in the 1980 version.
The licensee needs to check other references to be certain they are consistent with the proposed ITS.
P UREG SECTION - 3.8.5 CO 3.8.5 A l'cabilit ases A
licable Safet Anal ses a
d Bases Smllibi 1 i
'During movement of irradiated fuel assemblies,"
and adding "with the core offloaded." Limiting this applicability to only when the core is offloaded raises the question "What are the requirements for AC vital buses when moving irradiated fuel and the core is not offloaded'P In fact, given the proposed Applicability, is it permissible to move irradiated fuel when the core is not offloadedf The licensee needs to address these issues as it relates to applicability.
CO 3.8.5 Condi
'o Insert 1 and Bases Insert 1
The licensee needs to revise Condition A and Insert 1 to make a clear distinction that either charger can satisfy the LCO, i.e.,
"Required DC electrical power subsystem battery charger inoperable" and "Restore battery
I l'
'I charger to operable status in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />." This would avoid the proposed TS which would allow a battery to be without a charger for an indefinite period of time.
The licensee needs to revise Condition A and Insert 1 to make
- a. clear distinction between the battery chargers and the remainder of the DC systems; i.e.,
"One DC electrical. power subsystem (exclusive of the battery charger) inoperable."
The Bases can describe what constitutes operability in better detail than proposed Condition A without the potential for misinterpretation of the proposed condition.
This insert uses
- channels, the same insert in 3.8.4 uses "load groups" whereas the rest of the Bases and the LCO use the term subsystem(s).
This is inconsistent wording.
What is the reason for this change?
UREG SECTION 3.8.6 SR 3.8.6.2 and Bases SR 3.8.6.2 What is the basis for the frequency change to CTS SR 3.8.6.2 and Bases from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 7 days?
What is PVNGS's licensing basis?
The licensee needs to provide additional justification for this change.
The licensee needs to provide a discussion on the following:
The open circuit terminal voltage of the ATST batteries at PVNGS is 131 VDC.
The NUREG is based on a battery having 2.13 specific gravity (SG) per cell and a 125 VDC terminal voltage (open circuit).
NUREG-1432 considers a 125 VDC battery to be discharged when the voltage reaches 110 VDC.
What is unique about the PVNGS AT8T batteries that they are not considered discharged, until 105 VDC is
- reached, even though the initial voltage was 131 VDC?
This is a total of ll VDC difference (131-125 6 and 110-105=5 and 6+5-11).
Why is the overcharge value the same as NUREG-1432, i.e.,
150 VDC?
Table 3.8.6-1 Does IEEE-450 (1980)
(Ref. 3) address the base temperature for high acid concentration cells such as those at PVNGS?
(See 3'aragraph) eferences Why does PVNGS reference the 1980 version of IEEE-450?
NUREG SECTION - 3.8.7 Co dit'on A
See suggestion for revising the wording of Condition A in comments to CTS markup for LCO 3.8.7.
(The connection between this LCO and LCO 3.8.9 is not clear - revising Condition A would improve on that connection and make for a better TS)
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SR 3.8.7.1 and SR 3.8.8.1 Are the "in synchronous" alarms for the inverters subject to a periodic determination of OPERABILITY?
What constitutes that determination'P 3"
ara ra h
The licensee needs to provide an adequate justification for deleting that portion of the Bases that deals with inverters being connected/
powered to/from their respective batteries.
Retention of the NUREG language will make this portion of the Bases consistent with the remainder of the Bases in this section.
NUREG SECTION - 3.8.8 A licabilit A
licable Safet Anal ses and Bases A licab'1't During movement of irradiated fuel assemblies and adding "with the core offloaded'."
Limiting this applicability to only when the core is offloaded raises the question "What are the requirements for AC vital busses when moving irradiated fuel and the core is not offloaded"7 In fact,- given the proposed Applicability, is it permissible to move irradiated fuel when the core is not offloaded?
The licensee needs to address these issues as it relates to applicability.
SR 3.8.1.1 and SR 3.8.8.1 The deletion of "frequency" has not been adequately justified.
The licensee needs to provide an adequate justification of this deletion or retain the NUREG-1432 language.
UREG SECTION 3.8.10 licabilit A licable Safet Anal ses and Bases A l ca ilit During movement of irradiated fuel assemblies and adding "with the core offloaded." Limiting this applicability to only when the core is offloaded raises the question "What are the requirements for AC vital busses when moving irradiated fuel and the core is not offloadedf In fact, given the proposed Applicability, is it permissible to move irradiated fuel when the core is not offloadedP The licensee needs to address these issues as it relates to appl icabi1 ity.