ML18361A845

Application to Revise Technical Specifications to Adopt TSTF- 529, Revision 4, Clarify Use and Application Rules, Using the Consolidated Line Item Improvement Process

ML18361A845
Person / Time
Site:	Palo Verde
Issue date:	12/27/2018
From:	Lacal M Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-07822-MLL/MDD
Download: ML18361A845 (27)

Text

10 CFR 50.90 Qaps MARIA L. LACAL Senior Vice President Nuclear Regulatory and Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mall Station 7605 Tel 623.393.6491 102-07822-MLI7MDD December 27, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Application to Revise Technical Specifications to Adopt TSTF-529, Revision 4, Clarify Use and Application Rules, using the Consolidated Line Item Improvement Process In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Arizona Public Service Company (APS) is submitting a License Amendment Request (LAR) to revise the Technical Specifications (TS) for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3.

The proposed amendment would modify TS requirements in Section 1.3 and Section 3.0 regarding Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) usage. These changes are consistent with NRC-approved Technical Specifications Task Force (TSTF) Traveler TSTF-529, Clarify Use and Application Rules.

The enclosure to this letter provides a description and assessment of the proposed changes including a regulatory evaluation, a no significant hazards consideration, and an environmental evaluation. Additionally, the enclosure contains three attachments. Attachment 1 provides the marked-up existing TS pages. Attachment 2 provides the revised (clean) TS pages. Attachment 3 provides, for information only, the marked-up TS Bases pages to show the conforming changes.

APS requests approval of the LAR within one year from the date of the submittal and will implement the TS amendment within 90 days following NRC approval.

No new commitments are being made to the NRC by this letter.

In accordance with the PVNGS Quality Assurance Program, the Plant Review Board has reviewed and approved the LAR. By copy of this letter, this LAR is being forwarded to the Arizona Department of Health Services - Bureau of Radiation Control in accordance with 10 CFR 50.91(b)(1).

A member of the STARS Alliance, LLC Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

102-07822-MLL/MDD ATTN: Document Control Desk Application to Revise Technical Specifications to Adopt TSTF-529 Page 2 Should you need further information regarding this letter, please contact Matthew S.

Cox, Licensing Section Leader, at (623) 393-5753.

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

Executed on: December 27. 2018 (Date)

Sincerely,

\JU

/Wctr'.a L, UaC^[

MLL/MDD/PJH/sma

Enclosure:

Description and Assessment of Proposed License Amendment cc: K. M. Kennedy NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS M. M. O'Banion NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS B. Goretzki Arizona Department of Health Services - Bureau of Radiation Control (ADHS)

ENCLOSURE Description and Assessment of Proposed License Amendment

Enclosure Description and Assessment of Proposed License Amendment Description and Assessment of Proposed License Amendment

Subject:

Application to Revise Technical Specifications to Adopt TSTF-529, Revision 4, Clarify Use and Application Rules

1. DESCRIPTION

2. ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Variations

3. REGULATORY ANALYSIS 3.1 No Significant Hazards Consideration Determination

4. ENVIRONMENTAL EVALUATION ATTACHMENTS:

1. Proposed Technical Specification Changes (Mark-Up)

2. Revised Technical Specification Pages (Clean)

3. Proposed Technical Specification Bases Changes (Mark-Up) -

Information Only

Enclosure Description and Assessment of Proposed License Amendment

1.0 DESCRIPTION

The proposed change revises Section 1.3, Completion Times, Section 3.0, Limiting Condition for Operation (LCO) Applicability, and Section 3.0, Surveillance Requirement (SR) Applicability of the Palo Verde Nuclear Generating Station (PVNGS) Technical Specifications (TS) to clarify the use and application of the TS usage rules, as described below:

• Section 1.3 is revised to clarify "discovery."

• Section 1.3 is revised to discuss exceptions to starting the Completion Time at condition entry.

• LCO 3.0.4.b is revised to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.C are independent options.

• SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed and to clarify the application of SR 3.0.3.

2.0 ASSESSMENT 2.1 AoDlicabilitv of Safety Evaluation Arizona Public Service (APS) has reviewed the safety evaluation provided to the Technical Specifications Task Force in a letter dated April 21, 2016 (NRC ADAMS Accession No. ML16060A455). This review included a review of the NRC staff's evaluation, as well as the information provided in TSTF-529. APS has concluded that the justifications presented in the TSTF-529 proposal and the safety evaluation prepared by the NRC staff are applicable to PVNGS Units 1, 2, and 3 and justify this amendment for the incorporation of the changes to the PVNGS TS.

2.2 Variations APS is not proposing any variations from the TS changes described in TSTF-529 or the applicable parts of the NRC staff's safety evaluation dated April 21, 2016.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis APS requests adoption of TSTF-529, Clarify Use and Application Rules, that is an approved change to the standard technical specifications (STS), into the PVNGS Units 1, 2, and 3 TS. The proposed change revises Section 1.3, Completion Times, and Section 3.0, Limiting Condition for Operation (LCO)

Applicability, and Section 3.0, Surveillance Requirement (SR) Applicability Page 1 of 3

Enclosure Description and Assessment of Proposed License Amendment of the TS to clarify the use and application of the TS usage rules and revise the application of SR 3.0.3.

Section 1.3 is modified to clarify the concept of "discovery" that a LCO is not met and to describe existing exceptions to the start of Completion Times in the TS. An editorial change is made to LCO 3.0.4.b to clarify that LCO 3.0.4.a, LCO 3.0.4.b, and LCO 3.0.4.C are independent options. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed.

APS has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes to Section 1.3 and LCO 3.0.4 have no effect on the requirement for systems to be Operable and have no effect on the application of TS actions. The proposed change to SR 3.0.3 states that the allowance may only be used when there is a reasonable expectation the surveillance will be met when performed. Since the proposed change does not significantly affect system Operability, the proposed change, will have no significant effect on the initiating events for accidents previously evaluated and will have no significant effect on the ability of the systems to mitigate accidents previously evaluated.

Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes to the TS usage rules do not affect the design or function of any plant systems. The proposed change does not change the Operability requirements for plant systems or the actions taken when plant systems are not operable.

Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page 2 of 3

Enclosure Description and Assessment of Proposed License Amendment

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change clarifies the application of Section 1.3 and LCO 3.0.4 and does not result in changes in plant operation. SR 3.0.3 is revised to allow application of SR 3.0.3 when an SR has not been previously performed and there is reasonable expectation that the SR will be met when performed. This expands the use of SR 3.0.3 while ensuring the affected system is capable of performing its safety function. As a result, plant safety is either improved or unaffected.

Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.

Based on the above, APS concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.0 ENVIRONMENTAL EVALUATION The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

Page 3 of 3

Enclosure Description and Assessment of Proposed License Amendment ATTACHMENT 1 Proposed Technical Specification Changes (Mark-Up)

Changed Pages 1.3-1 1.3-2 3.0-2 3.0-4

Completion Times 1.3 1.3 Completion Times 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated v\/ith an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met.

Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The othen/vise specified exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time.

For example. LCO 3.8.1, AC Sources - Operating. Reguired Action B.2, reguires declaring reguired feature(s) supported by an inoperable diesel generator, inoperable when the redundant reguired feature(s) are inoperable. The Completion Time states. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant reguired feature(s). In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

(continued)

PALO VERDE UNITS 1,2,3 1.3-1 AMENDMENT NO. 40?

Completion Times 1.3 1.3 Completion Times DESCRIPTION Required Actions must be completed prior to the expiration of the (continued) specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the time of-discovery of the situation that required entry into the Condition, unless othenA/ise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will n^ result in separate entry into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met.

The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and

b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

(continued)

PALO VERDE UNITS 1,2,3 1.3-2 AMENDMENT NO. 497

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing (continued) inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate j (exceptions to this Specification are stated in the individual Specifications);r or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

(continued)

PALO VERDE UNITS 1,2,3 3.0-2 AMENDMENT NO. 4§§,

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance wil be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

PALO VERDE UNITS 1,2,3 3.0-4 AMENDMENT NO. 444

Enclosure Description and Assessment of Proposed License Amendment ATTACHMENT 2 Revised Technical Specification Pages (Clean)

Changed Pages 1.3-1 1.3-2 3.0-2 3.0-4

Completion Times 1.3 1.3 Completion Times 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the unit. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met.

Specified with each stated Condition are Required Action(s) and Completion Time(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the unit is in a MODE or specified condition stated in the Applicability of the LCO.

Unless otherwise specified, the Completion Time begins when a senior licensed operator on the operating shift crew with responsibility for plant operations makes the determination that an LCO is not met and an ACTIONS Condition is entered. The otherwise specified exceptions are varied, such as a Required Action Note or Surveillance Requirement Note that provides an alternative time to perform specific tasks, such as testing, without starting the Completion Time. While utilizing the Note, should a Condition be applicable for any reason not addressed by the Note, the Completion Time begins. Should the time allowance in the Note be exceeded, the Completion Time begins at that point. The exceptions may also be incorporated into the Completion Time.

For example, LCO 3.8.1, AC Sources - Operating, Required Action B.2, requires declaring required featurefs) supported by an inoperable diesel generator, inoperable when tne redundant required feature(s) are inoperable. The Completion Time states, 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s). In this case the Completion Time does not begin until the conditions in the Completion Time are satisfied.

(continued)

PALO VERDE UNITS 1,2,3 1.3-1 AMENDMENT NO. 4©7

Completion Times 1.3 1.3 Completion Times DESCRIPTION Required Actions must be completed prior to the expiration of the (continued) specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the unit is not within the LCO Applicability.

If situations are discovered that require entry into more than one Condition at a time within a single LCO (multiple Conditions), the Required Actions for each Condition must be performed within the associated Completion Time. When in multiple Conditions, separate Completion Times are tracked for each Condition starting from the discovery of the situation that required entry into the Condition, unless otherwise specified.

Once a Condition has been entered, subsequent trains, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will Qpt result in separate entiy into the Condition, unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition, unless otherwise specified.

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met.

The subsequent inoperability:

a. Must exist concurrent with the first inoperability; and

b. Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a. The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; or

b. The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

(continued)

PALO VERDE UNITS 1,2,3 1.3-2 AMENDMENT NO. 4©7

LCO ApplicabNity 3.0 LCO APPLICABILITY LCO 3.0.4 b. After performance of a risk assessment addressing (continued) inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications): or

c. When an allow/ance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABIL TY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, an evaluation shall be performed in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

(continued)

PALO VERDE UNITS 1,2,3 3.0-2 AMENDMENT NO. 46S.

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Freq^uency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

(continued)

PALO VERDE UNITS 1,2,3 3.0-4 AMENDMENT NO. 444-

Enclosure Description and Assessment of Proposed License Amendment ATTACHMENT 3 Proposed Technical Specification Bases Changes (Mark-Up)

Information Only Changed Pages B 3.0-1 B 3.0-3 B 3.0-4 B 3.0-6 B 3.0-9 B 3.0-11 B 3.0-21 B 3.0-22 B 3.0-23

LCO Applicability B3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY BASES LCOs LCO 3.0.1 through LCO 3.0.8 establish the general requirements applicable to all Specifications and apply at all times unless othenA/ise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met. The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered, unless otherwise specified. The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Action specifies a time limit in which the LCO must be met. This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits. If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. (Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering (continued)

PALO VERDE UNITS 1,2,3 B 3.0-1 REVISION 40

LCO Applicability B3.0 BASES LCO 3.0.3 LCO 3.0.3 establishes the actions that must be implemented when an LCO is not met and:

a. An associated Required Action and Completion Time is not met and no other Condition applies; or

b. The condition of the unit is not specifically addressed by the associated ACTIONS. This means that no combination of Conditions stated in the ACTIONS can be made that exactly corresponds to the actual condition of the unit. Sometimes, Dossible combinations of Conditions are such that entering

-CO 3.0.3 is warranted; in such cases, the ACTIONS specifically state a Condition corresponding to such combinations and also that LCO 3.0.3 be entered immediately.

This Specification delineates the time limits for placing the unit in a safe MODE or other specified condition when operation cannot be maintained within the limits for safe operation as defined by the LCO and its ACTIONS. It is not intended to be used as an operational convenience that permits routine voluntary removal of redundant systems or components from service in lieu of other alternatives that would not result in redundant systems or components being inoperable.

Upon entering LCO 3.0.3, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is allowed to prepare for an orderly shutdown before initiating a change in unit operation. This includes time to permit the operator to coordinate the reduction in electrical generation with the load dispatcher to ensure the stability and availability of the electrical grid. The time limits specified to reach enter lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE.

This reduces thermal stresses on components of the Reactor Coolant System and the potential for a plant upset that could challenge safety systems under conditions to which this Specification applies. The use and interpretation of specified times to complete the actions of LCO 3.0.3 are consistent with the discussion of Section 1.3, Completion Times.

(continued)

PALO VERDE UNITS 1,2,3 B 3.0-3 REVISION 0

LCO Applicability B3.0 BASES LCO 3.0.3 A unit shutdown required in accordance with LCO 3.0.3 may be (continued) terminated and LCO 3.0.3 exited if any of the following occurs:

a. The LCO is now met.

b. The LCO is no longer applicable.

be. A Condition exists for which the Required Actions have now been performed.

ed. ACTIONS exist that do not have expired Completion Times.

These Completion Times are applicable from the point in time that the Condition is initially entered and not from the time LCO 3.0.3 is exited.

The time limits of Specification 3.0.3 allow 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> for the unit to be in MODE 5 when a shutdown is required during MODE 1 operation. If the unit is in a lower MODE of operation when a lower MODE applies. less time than allowed, however, the total allowable time to reach enter MODE 5, or other applicable MODE, is not reduced. For example, if MODE 3 is reached entered in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then the time allowed for reaching entering MODE 5 is the next 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />, because the total time for reaching entering MODE 5 is not reduced from the allowable limit of 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />. Therefore, if remedial measures are completed that would permit a return to MODE 1, a penalty is not incurred by having to feaeh-enter a lower MODE of operation in less than the total time allowed.

In MODES 1, 2, 3, and 4, LCO 3.0.3 provides actions for Conditions not covered in other Specifications. The requirements of LCO 3.0.3 do not apply in MODES 5 and 6 because the unit is already in the most restrictive Condition required by LCO 3.0.3.

The requirements of LCO 3.0.3 do not apply in other specified conditions of the Applicability (unless in MODE 1, 2, 3, or 4) because the ACTIONS of individual Specifications sufficiently define the remedial measures to be taken. Exceptions to LCO 3.0.3 are provided in instances where requiring a unit shutdown, in accordance with LCO 3.0.3, would not provide appropriate remedial measures for the associated condition of the unit. An example of this is in LCO 3.7.14, "Fuel Storage Pool Water Level." LCO 3.7.14 has an Applicability of "During movement of irradiated fuel assemblies in the fuel storage pool."

Therefore, this LCO can be applicable in any or all MODES. If the (continued)

PALO VERDE UNITS 1,2,3 B 3.0-4 REVISION m

LCO Applicability B3.0 BASES LCO 3.0.3 the unit in a shutdown condition. The Required Action of (continued) LCO 3.7.14 of "Suspend movement of irradiated fuel assemblies in fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when Umt-unit conditions are such that the requirements of the LCO would not be met in accordance with either LCO 3.0.4.a, LCO 3.0.4.b, or LCO 3.O.4.C.

LCO 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in following entry into the MODE or other specified condition in the Applicability will permit continued operation within the MODE or other specified condition for an unlimited period of time.

Compliance with Required ActionsACTIONS that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be madeTn-accordance with the provisions of the Required Actions and the Required Actions followed after entry into the Applicability.

For example LCO 3.0.4.a may be used when the Required Action to be entered states that an inoperable instrument channel must be placed in the trip condition within the Completion Time. Transition into a MODE or other specified condition in the Applicability may be made in accordance with LCO 3.0.4 and the channel is subsequently placed in the tripped condition within the Completion Time, which begins when the Applicability is entered. If the instrument channel cannot be placed in the tripped condition and the subsequent default ACTION (Required Action and associated Completion Time not met) allows the OPERABLE train to be placed in operation, use of LCO 3.0.4.a is acceptable because the subsequent ACTIONS to be entered following entry into the MODE include ACTIONS (place the OPERABLE train in operation) that permit safe plant operation for an unlimited period of time in the MODE or other specified condition to be entered.

(continued)

PALO VERDE UNITS 1,2,3 B 3.0-6 REVISION m

LCO Applicability B3.0 BASES LCO 3.0.4 The Technical Specifications allow continued operation with (continued) equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4.b allowance is prohibited. The LCOs governing these systems and components contain Notes prohibiting the use of LCO 3.0.4.b by stating that LCO 3.0.4.b is not applicable.

LCO 3.0.4.C allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4.C is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed.

This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4.b usually only consider systems and components. For this reason, LCO 3.0.4.C is typically applied to Specifications which describe values and parameters (e.q., RCS Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

(continued)

PALO VERDE UNITS 1,2,3 B 3.0-9 REVISION §§

LCO Applicability B3.0 BASES LCO 3.0.5 LCO 3.0.5 should not be used in lieu of other practicable (continued) alternatives that comply with Required Actions and that do not require changing the MODE or other specified conditions in the Applicability in order to demonstrate equipment is OPERABLE.

LCO 3.0.5 is not intended to be used repeatedly.

An example of demonstrating equipment is OPERABLE with the Required Actions not met is opening a manual valve that was closed to comply with Required Actions to isolate a flowpath with excessive Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage in order to perform testing to demonstrate that RCS PIV leakage is now within limit.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply v\/ith Required Actions and must be reopened to perform the required testing.

Examples of demonstrating equipment OPERABILITY include instances in which it is necessary to take an inoperable channel or trip system out of a tripped condition that was directed by a Required Action, if there is no Required Action Note for this purpose. An example of verifying OPERABILITY of equipment removed from service is taking a tripped channel out of the tripped condition to permit the logic to function and indicate the appropriate response during performance of required testing on the inoperable channel. Examples An example of demonstrating the OPERABILITY of other equipment Is-are taking an inoperable channel or trip system out of the tripped condition 1) to prevent the trip function from occurring during the performance of required testing on another channel in the other trip system- A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped cendition. or-2) to permit the logic to function and indicate the appropriate response during the performance of required testing on another channel in the same trip system.

The administrative controls in LCO 3.0.5 apply in all cases to systems or components in Chapter 3 of the Technical Specifications, as long as the testing could not be conducted while complying with the Required Actions. This includes the realignment or repositioning of redundant or alternate equipment or trains previously manipulated to comply with ACTIONS, as well as equipment removed from service or declared inoperable to comply with ACTIONS.

(continued)

PALO VERDE UNITS 1,2,3 B 3.0-11 REVISION m

SR Applicability B 3.0 BASES SR 3.0.2 accomplishes the function of the inoperable equipment in an (continued) alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as an operational convenieoGe-to extend Surveillance intervals (other than those consistent with refueling intervals) or periodic Completion Time intervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met. Reference Bases Section 3.0.2 for discussion and applicability of Frequency and 25% extension.

When a Section 5.5, Programs and Manuals, specification states that the provisions of SR 3.0.3 are applicable, it permits the flexibility to defer declaring the testing requirement not met in accordance with SR 3.0.3 when testing has not been completed within the testing interval (including the allowance of SR 3.0.2 if invoked by the Section 5.5 specification).

This delay period provides an adequate time to Gomplete-perform Surveillances that have been missed. This delay period permits with Required Actions or other remedial measures that might The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a Frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is (continued)

PALO VERDE UNITS 1,2,3 B 3.0-21 REVISION ©7

SR Applicability B3.0 BASES SR 3.0.3 discovered to not have been performed when specified, SR 3.0.3 (continued) allows for the full delay period of up to the specified Frequency to perform the Surveillance. However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

SR 3.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by Required Actions.

SR 3.0.3 is only applicable if there is a reasonable expectation the associated equipment is OPERABLE or that variables are within limits, and it is expected that the Surveillance will be met when performed. Many factors should be considered, such as the period of time since the Surveillance was last performed, or whether the Surveillance, or a portion thereof, has ever been performed, and any other indications, tests, or activities that might support the expectation that the Surveillance will be met when performed. An example of the use of SR 3.0.3 would be a relay contact that was not tested as required in accordance with a particular SR, but previous successful performances of the SR included the relay contact: the adjacent, physically connected relay contacts were tested during the SR performance: the subject relay contact has been tested by another SR: or historical operation of the subject relay contact has been successful. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation a Surveillance will be met when performed should increase based on the length of time since the last performance of the Surveillance. If the Surveillance has been performed recently, a review of the Surveillance history and eguipment performance may be sufficient to support a reasonable expectation that the Surveillance will be met when performed. For Surveillances that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the eguipment is OPERABLE. The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.

(continued)

PALO VERDE UNITS 1,2,3 B 3.0-22 REVISION §?

SR Applicability B3.0 BASES SR 3.0.3 Failure to comply with specified Frequencies for SRs is expected (continued) to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience repeatedly to extend l Surveillance intervals. While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance. This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRG Regulatory Guide 1.160, Revision 3, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown. The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide. The risk evaluation may use quantitative, qualitative, or blended methods. The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively. If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion (continued)

PALO VERDE UNITS 1,2,3 B 3.0-23 REVISION 67