ML20183A460

Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program

ML20183A460
Person / Time
Site:	Palo Verde
Issue date:	07/01/2020
From:	Rash B Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-08124-BJR/MDD, TSTF-563
Download: ML20183A460 (13)

Text

10 CFR 50.90 BRUCE J. RASH Vice President Nuclear Engineering/Regulatory Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7602 Tel 623.393.5102 102-08124-BJR/MDD July 1, 2020 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 Renewed Operating License Number NPF-41, NPF-51, and NPF-74 Application to Revise Technical Specifications to Adopt TSTF-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) is submitting a request for an amendment to the Technical Specifications (TS) for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3.

APS requests adoption of Technical Specification Task Force (TSTF)-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program. TSTF-563 revises the TS definitions of Channel Calibration and Channel Functional Test, which currently permit performance by any series of sequential, overlapping, or total channel steps, to also allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program.

The enclosure provides a description and assessment of the proposed changes. of the enclosure provides the existing TS pages marked-up to show the proposed changes. Attachment 2 of the enclosure provides revised (clean) TS pages.

A pre-submittal meeting for TSTF-563 was held between APS and the NRC staff on June 25, 2020. Approval of the proposed amendment is requested by July 1, 2021. Once approved, the amendment will be implemented within 90 days.

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

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

A member of the STARS Alliance, LLC Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

102-08124-BJR/MDD ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Application to Revise Technical Specifications to Adopt TSTF-563 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: July 1, 2020 (Date)

Sincerely, Digitally signed by Rash, Rash, Bruce Bruce (Z77439)

DN: cn=Rash, Bruce (Z77439)

(Z77439) Date: 2020.07.01 15:20:24

-07'00' BJR/MDD/mg

Enclosure:

Description and Assessment of Proposed License Amendment cc: S. A. Morris NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS C. A. Peabody NRC Senior Resident Inspector for PVNGS B. Goretzki Arizona Department of Health Services - Bureau of Radiation Control





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-563, Revision 0, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program

1.0 DESCRIPTION

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation 2.2 Variations

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis 3.2 Conclusion 4.0 ENVIRONMENTAL EVALUATION ATTACHMENTS:

1. Proposed Technical Specification Changes (Mark-Up) 2. Revised Technical Specification Pages i



Enclosure Description and Assessment of Proposed License Amendment



1.0 DESCRIPTION Arizona Public Service Company (APS) requests adoption of Technical Specification Task Force (TSTF)-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program. TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test, which currently permit performance by any series of sequential, overlapping, or total channel steps, to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program (SFCP).

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation APS has reviewed the safety evaluation for TSTF-563 provided to the TSTF in a letter dated December 4, 2018. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-563. As described herein, APS has concluded that the justifications presented in TSTF-563 and the safety evaluation prepared by the NRC staff are applicable to Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 and justify this amendment for the incorporation of the changes to the PVNGS TS.

The SFCP was incorporated into the PVNGS TS in license amendment 188 dated December 15, 2011 [NRC Agency Documents Access and Management System (ADAMS) Accession No. ML112620293].

2.2 Variations APS is proposing the following variations from the TS changes described in TSTF-563.

The PVNGS TS contain requirements that differ from the Standard Technical Specifications (STS) on which TSTF-563 was based, but are encompassed in the TSTF-563 justification.

a) The PVNGS TS are different from Revision 4 of the Combustion Engineering (CE)

Plant STS (NUREG-1432) on which TSTF-563 is based. The definition of Channel Calibration has wording differences from the STS definition that do not change the intent. The PVNGS TS Channel Calibration definition states, "The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps so that the entire channel is calibrated." The STS states, "The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps." Elimination of the phrase "so that the entire channel is calibrated has no effect because the definition previously states that the Channel Calibration must encompass the entire channel, including the required sensor, alarm, display, and trip functions.

b) The PVNGS TS are different from Revision 4 of the CE Plant STS (NUREG-1432) on which TSTF-563 is based. The definition of Channel Functional Test has wording differences from the STS definition that do not change the intent. The PVNGS TS Channel Functional Test definition states, "The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping or



Page 1 of 4



Enclosure Description and Assessment of Proposed License Amendment



total channel steps so that the entire channel is tested." The STS states, "The CHANNEL FUNCTIONAL TEST may be performed by means of any series of sequential, overlapping, or total channel steps." Elimination of the phrase "so that the entire channel is tested has no effect because the definition of Channel Functional Test requires verification of Operability. The definition of OPERABILITY includes all necessary attendant instrumentation, controls, and other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s), which is equivalent to the language, all devices in the channel. Therefore, PVNGS will continue to test each of the devices in the channel.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis Arizona Public Service Company (APS) requests adoption of Technical Specification Task Force (TSTF)-563, Revise Instrument Testing Definitions to Incorporate the Surveillance Frequency Control Program. TSTF-563 revises the Technical Specification (TS) definitions of Channel Calibration and Channel Functional Test, which currently permit performance by any series of sequential, overlapping, or total channel steps, to allow the required frequency for testing the components or devices in each step to be determined in accordance with the TS Surveillance Frequency Control Program (SFCP).

APS has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) 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 change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. All components in the channel continue to be calibrated. The frequency at which a channel calibration is performed is not an initiator of any accident previously evaluated, so the probability of an accident is not affected by the proposed change. The channels surveilled in accordance with the affected definitions continue to be required to be operable and the acceptance criteria of the surveillances are unchanged. As a result, any mitigating functions assumed in the accident analysis will continue to be performed.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.



Page 2 of 4



Enclosure Description and Assessment of Proposed License Amendment



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 change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. The design function or operation of the components involved are not affected and there is no physical alteration of the plant (i.e., no new or different type of equipment will be installed). No credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases are introduced. The changes do not alter assumptions made in the safety analysis.

The proposed changes are consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

The proposed change revises the TS definitions of Channel Calibration and Channel Functional Test to allow the frequency for testing the components or devices in each step to be determined in accordance with the TS SFCP. The SFCP assures sufficient safety margins are maintained, and that design, operation, surveillance methods, and acceptance criteria specified in applicable codes and standards (or alternatives approved for use by the NRC) will continue to be met as described in the licensing basis. The proposed change does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by the method of determining surveillance test intervals under an NRC-approved licensee-controlled program.

Therefore, the proposed 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.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.



Page 3 of 4



Enclosure Description and Assessment of Proposed License Amendment



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 4 of 4



Enclosure Description and Assessment of Proposed License Amendment



ATTACHMENT 1:

Proposed Technical Specification Changes (Mark-Up)

Changed Page 1.1-1 (NO CHANGES - INFORMATION ONLY) 1.1-2





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ATTACHMENT 2:

Revised Technical Specification Pages Changed Page 1.1-2





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