ML23093A025
| ML23093A025 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/30/2023 |
| From: | Arizona Public Service Co |
| To: | Dennis Galvin NRC/NRR/DORL/LPL4 |
| Lingam S, 301-415-1564 | |
| References | |
| EPID L-2023-LRM-0016 | |
| Download: ML23093A025 (1) | |
Text
Pre-Submittal Presentation - Containment Temperature &
Safety Injection Tank Volume Requirements LAR April 2023
2 Agenda Description of Proposed Changes Proposed TS and TS Bases Changes Precedence Submittal Timeline
3 Description of Proposed Changes The proposed change to surveillance requirements (SRs) 3.5.1.2 and 3.5.2.2 for TS Limiting Condition for Operation (LCO) 3.5.1, Safety Injection Tanks (SITs) - Operating, and LCO 3.5.2, Safety Injection Tanks (SITs) - Shutdown, will revise the LCO SRs such that the SIT volume design values are expressed in cubic feet, with no instrument uncertainties.
The proposed change will list the SIT volumes as analytical values from the Design Basis Accident (DBA) analysis with no instrument uncertainties included.
To ensure the DBA analytical limits will not be exceeded, the surveillance procedures supporting TS SRs 3.5.1.2 and 3.5.2.2 will continue to use the current instrument uncertainties.
Allows the use of both NR and WR level indication.
4 Description of Proposed Changes The proposed change to the current TS LCO 3.6.5, Containment Air Temperature, will revise the LCO limit for containment average air temperature from less than or equal to 117°F to be less than or equal to 120°F, without instrument uncertainty.
- Original PVNGS TS LCO limit for containment average air temperature was 120 °F but it was changed to 117 °F, at APS request, in license amendment (LA) 117 (ADAMS Accession Number ML021720060).
- Restoring TS LCO limit to design basis analytical value more closely aligns TS 3.6.5, Containment Air Temperature, with Combustion Engineering (CE) Standard Technical Specification (STS).
5 Description of Proposed Changes TS LCO 3.6.5, Containment Air Temperature
- Provides consistency as it aligns LCO 3.6.5 with other LCOs which list design basis analytical values as limits.
- Does not change initial condition for average containment temperature in PVNGS safety analyses.
- No current plans to change surveillance procedure acceptance criterion, TS Bases markup reflects current SR criterion.
6 Proposed Changes to TS 3.5.1
7 Proposed Changes to TS 3.5.2
8 Proposed Changes to TS Bases 3.5.1 APPLICABLE SAFETY ANALYSES
9 Proposed Changes to TS Bases 3.5.2 APPLICABLE SAFETY ANALYSES
10 Proposed Changes to TS 3.6.5
11 Proposed Changes to TS Bases 3.6.5
12 Proposed Changes to TS Bases 3.6.5 TS Bases being updated to remove reference to specific temperature indicators to be consistent with the Standard Technical Specification Bases.
How surveillances are performed not typically described in TS Bases.
13 Precedents Changes more closely align PVNGS TS with CE Standard Technical Specifications (NUREG-1432, Vol 1, Rev 5) in that analytical limits are provided in lieu of instrument inaccuracy.
14 Submittal Timeline Submit to NRC April 2023 - Request to submit one license amendment request (LAR) vs. two separate LAR for changes to TS LCO 3.6.5, LCO 3.5.1, and LCO 3.5.2 Estimated 1-yr NRC review time Requesting a 90-day implementation time
Questions