ML23102A324

Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods That Are Untrippable Versus Inoperable

ML23102A324
Person / Time
Site:	Palo Verde
Issue date:	04/12/2023
From:	Harbor C Arizona Public Service Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
102-08594-CDH/MSC
Download: ML23102A324 (1)

Text

10 CFR 50.90 Cary D. Harbor Vice President Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 102-08594-CDH/MSC Mail Station 7602 April 12, 2023 Tel: 623.393.7953 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 Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods that are Untrippable versus Inoperable Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) submitted a request for an amendment to the Technical Specifications for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 by letter number 102-08533, dated December 7, 2022 (Agencywide Documents Access and Management System Accession Number ML22341A613). Subsequent to submittal, an editorial error was identified in Section 4.2, No Significant Hazards Consideration. The Enclosure to this letter provides the correction. Specifically, the conclusion provided for the response to question two of the no significant hazards consideration was a duplicate of the conclusion provided for question one. While the reasoning of the response to question two was appropriate, the conclusion required correction.

By copy of this letter, this license amendment request supplement 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.

Should you need further information regarding this letter, please contact Matthew S.

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

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

Executed on: _ April 12, 2023_

(Date)

Sincerely, Harbor, Cary Digitally signed by Harbor, Cary (Z16762)

(Z16762) Date: 2023.04.12 14:09:17 -07'00' CDH/MSC/cr A member of the STARS Alliance, LLC Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

102-08594-CDH/MSC ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Supplement to Application to Revise Technical Specifications - TSTF-107-A Page 2

Enclosure:

Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods that are Untrippable versus Inoperable cc: R. J. Lewis Acting NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS L. N. Merker NRC Senior Resident Inspector for PVNGS B. D. Goretzki Arizona Department of Health Services - Bureau of Radiation Control

ENCLOSURE Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods that are Untrippable versus Inoperable

ENCLOSURE Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods that are Untrippable versus Inoperable Introduction Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) submitted a request for an amendment to the Technical Specifications for Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 by letter number 102-08533, dated December 7, 2022 (Agencywide Documents Access and Management System Accession Number ML22341A613). Subsequent to submittal, an editorial error was identified in Section 4.2, No Significant Hazards Consideration. This Enclosure provides the correction.

Specifically, the conclusion provided for the response to question two of the no significant hazards consideration was a duplicate of the conclusion provided for question one. While the reasoning of the response to question two was appropriate, the conclusion required correction. The entire response to the no significant hazards consideration question two is provided below, with the margin bar indicating the correction.

Section 4.2, No Significant Hazards Consideration, Question 2

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 revise TS 3.1.5, Conditions A, C and D to clarify the actions with regard to CEA misalignments. These changes are needed to correct an ambiguity regarding CEAs that are inoperable, as compared to being out of alignment. These proposed changes are clarifications that are more precise in their meaning, are editorial in nature and are similar to the NRC approved CE STS (NUREG-1432).

The proposed change to TS 3.1.5, Condition B, addresses a condition when only one position indication channel is operable for one or more CEAs. This change does not permit routine operation with less than two operable CEA position indicator channels. The operability requirements for CEA position indicator channels remains unchanged (at least two position indicator channels for each CEA). With more than one CEA in a group having only one OPERABLE position indicator channel, each of the CEAs still have at least one OPERABLE position indicator channel to confirm the required LCO initial conditions. The duration of this operation is limited by the compensatory measures and time constraints established by the proposed TS Conditions and Required Actions.

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.

Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

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