ML23132A339

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Application to Revise Technical Specifications 3.3.11 to Adopt TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls
ML23132A339
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 05/12/2023
From: Harbor C
Arizona Public Service Co
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
102-08593-CDH/MSC
Download: ML23132A339 (1)
v • d • e


Text

10 CFR 50.90 A member of the STARS Alliance, LLC Callaway

  • Diablo Canyon
  • Palo Verde
  • Wolf Creek Cary D. Harbor Vice President Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 Tel: 623.393.7953 102-08593-CDH/MSC May 12, 2023 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 3.3.11 to Adopt TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls 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 changes to TS 3.3.11 that adopts Technical Specification Task Force (TSTF)-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls. Specifically, the current Table 3.3.11-1, Remote Shutdown System Instrumentation and Controls, is to be relocated to the TS Bases, where changes can be administered under the controls of TS 5.5.14, Technical Specifications Bases Control Program.

The enclosure provides a description and assessment of the proposed changes. to the enclosure provides the existing TS pages marked up to show the proposed changes. Attachment 2 to the enclosure provides revised (re-typed) TS pages. Attachment 3 to the enclosure provides marked up TS Bases pages to show the proposed changes. The changes to the TS Bases are provided for information only.

A pre-submittal meeting for this license amendment request (LAR) was held between APS and the Nuclear Regulatory Commission (NRC) staff on April 4, 2023. Approval of the proposed amendment is requested by May 12, 2024. Once approved, the amendment will be implemented within 90 days.

PVNGS has determined that there are no significant hazards considerations associated with the proposed change and that the TS change qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).

In accordance with the PVNGS Quality Assurance Program, the Plant Review Board has reviewed and approved the 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).

102-08593-CDH/MSC ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Application to Revise Technical Specifications to Adopt TSTF-266-A Page 2 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 to the best of my knowledge.

Executed on: _May 12, 2023_

(Date)

Sincerely, CDH/MSC/cr

Enclosure:

Description and Assessment of Proposed License Amendment 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 Harbor, Cary (Z16762)

Digitally signed by Harbor, Cary (Z16762)

Date: 2023.05.12 08:54:11 -07'00'

ENCLOSURE Description and Assessment of Proposed License Amendment

Enclosure Description and Assessment of Proposed License Amendment i

Subject:

Application to Revise Technical Specifications to Adopt TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls Table of Contents 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusion

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCE ATTACHMENTS:

1.

Proposed Technical Specification Changes (Mark-up)

2.

Proposed Technical Specification Changes (Re-Typed)

3.

Revised Technical Specification Bases Changes (Page Markups - For Information)

Enclosure Description and Assessment of Proposed License Amendment Page 1 1.0

SUMMARY

DESCRIPTION Arizona Public Service Company (APS) is requesting a license amendment to amend the Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2 and 3 Technical Specifications (TS) to adopt Technical Specification Task Force (TSTF)-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls.

TSTF-266-A relocates TS Table 3.3.11-1, Remote Shutdown System Instrumentation and Controls, to the TS Bases where changes can be administered under the controls of TS 5.5.14, Technical Specifications Bases Control Program.

2.0 DETAILED DESCRIPTION 2.1 Description of the Proposed Change PVNGS Units 1, 2, and 3, TS 3.3.11, Remote Shutdown System, details the instrumentation that supports Remote Shutdown System (RSS) operability.

The specific Functions are listed on Table 3.3.11-1, Remote Shutdown System Instrumentation and Controls. This change eliminates the table of instrumentation and controls referenced in TS 3.3.11 for the RSS and relocates this table to the TS Bases. As stated in TSTF-266-A:

It is unnecessary to list specific instruments and controls in the Technical Specifications to provide adequate assurance that the functions can be performed. [General Design Criterion] GDC 19 requires that the remote shutdown capability be provided. The

[Limiting Condition for Operation] LCO provides references to the Functions described in the Bases. This is sufficient to ensure that the system will be Operable. Listing specific instrumentation and controls is unnecessary and may lead to needless expenditure of licensee and NRC resources processing license amendments to revise the table when the information can be adequately controlled by the licensee.

2.2 Reason for the Proposed Change TSTF-266-A relocates PVNGS TS Table 3.3.11-1 to TS Bases B 3.3.11, which allows for future changes to be made under TS 5.5.14, Technical Specifications Bases Control Program. The Nuclear Regulatory Commission (NRC) documented their approval of TSTF-266-A, Revision 3, in the referenced letter.

2.3 Variations from TSTF-266-A The following administrative variations are taken:

  • The information contained in the PVNGS Units 1, 2, and 3 TS Table 3.3.11-1 is somewhat different from the table included in TSTF-266-A in

Enclosure Description and Assessment of Proposed License Amendment Page 2 that the functions listed in Table 3.3.12-1 of TSTF-266-A are not identical to those listed in PVNGS TS Table 3.3.11-1. However, TSTF-266-A states that the table is for illustration purposes only, and that it does not attempt to encompass every function used at every unit. The proposed license amendment request (LAR) relocates the existing table to the TS Bases and does not alter any of the existing required instrumentation and controls.

  • The PVNGS Units 1, 2, and 3 TS includes the word instrumentation in LCO 3.3.11 and Table 3.3.11-1 is reflected in the current Action A, which differs from TSTF-266-A. These are editorial differences, which are consistent with the PVNGS licensing basis, and were introduced in License Amendment (LA) 117. NRC letter dated May 20, 1998

[Agencywide Documents Access and Management System (ADAMS)

Accession Number ML021720060], documented the issuance of LA 117.

  • The PVNGS Units 1, 2, and 3 TS LCO 3.3.11 includes RSS disconnect switches and control circuits, which is consistent with the PVNGS licensing basis, but is not included in TSTF-266-A. The addition to the LCO of the disconnect switches and control circuits was the result of them being in the original PVNGS Units 1, 2, and 3 TS and carried forward and approved in LA 117, when APS adopted the improved Combustion Engineering Standard Technical Specifications (NUREG-1432, Revision 1). This LCO element is not being changed by this LAR.

documented the issuance of LA 165.

3.0 TECHNICAL EVALUATION

The RSS provides the control room operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. A safe shutdown condition is defined as Mode 3. With the unit in Mode 3, the Auxiliary Feedwater (AFW) System and the steam generator (SG) safety valves or the SG atmospheric dump valves (ADVs) can be used to remove core decay heat and meet all safety requirements.

The long-term supply of water for the AFW System and the ability to borate the Reactor Coolant System (RCS) from outside the control room allows extended operation in Mode 3. If the control room becomes inaccessible, the operators can establish control at the remote shutdown panel, and place and maintain the unit in Mode 3. Not all controls and necessary transfer switches are located at the remote shutdown panel. Some controls and transfer switches would have to be operated locally at the switchgear, motor control panels, or other local stations.

The unit automatically reaches Mode 3 following a unit shutdown and can be maintained safely in Mode 3 for an extended period of time. The operability of the

Enclosure Description and Assessment of Proposed License Amendment Page 3 RSS control and instrumentation functions ensures there is sufficient information available on selected unit parameters to place and maintain the unit in Mode 3 should the control room become inaccessible.

Should it be necessary to go to Mode 4 or Mode 5, decay heat removal via the shutdown cooling system is available to support the transition. As noted in TSTF-266-A, the revised LCO provides references to the RSS Functions that will be described in the TS Bases. This is sufficient to ensure that the RSS as described above will be Operable.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements 4.1.1 Regulations 10 CFR 50.36, Technical specifications, sets forth the regulatory requirements for the content of the TSs. This regulation requires, in part, that the TS contain LCOs. 10 CFR 50.36(c)(2)(ii), states that TS LCOs must be established for items meeting Criteria 1-4 of 10 CFR 50.36. As stated in the TS 3.3.11 Bases, the RSS is considered an important contributor to the reduction of unit risk to accidents, and as such it has been retained in the TS. However, the RSS instrument table itself does not meet any of the criteria of 10 CFR 50.36(c)(ii) and so, may be relocated from the TS to the TS Bases.

4.1.2 General Design Criteria (GDC)

The PVNGS Updated Final Safety Analysis Report (UFSAR) contains each of the relevant the GDCs followed by a discussion of the design features and procedures that meet the intent of the criteria. The relevant GDC with the discussion of the design features and procedures that meet the intent of the relevant criterion are included below. Any exceptions to the GDCs are identified in the discussion of the corresponding criterion.

Criterion 19, Control Room A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident.

Equipment at appropriate locations outside the control room shall be provided: (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a

Enclosure Description and Assessment of Proposed License Amendment Page 4 potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.

Compliance with GDC 19 is described in Section 3.1.15 of the PVNGS UFSAR. In relevant part it states:

In the unlikely event that the control room should become inaccessible, sufficient instrumentation and controls are provided outside the control room to:

Achieve prompt hot shutdown of the reactor Maintain the unit in a safe condition during hot shutdown Achieve cold shutdown of the reactor through the use of suitable procedures Refer to subsection 7.4.1 for details on the instrumentation and controls provided outside the control room.

UFSAR subsection 7.4.1 provides a detailed description of the systems and instrumentation credited for safe shutdown of the reactor. This proposed change does not affect GDC 19 compliance.

4.2 Precedent The Vogtle Electric Generating Plant, Units 1 and 2, and Joseph M.

Farley Nuclear Plant, Units 1 and 2, included TSTF-266-A in License Amendment Requests that adopted a number of TSTF travelers. These applications were approved with the issuance of License Amendments 180/161 on June 9, 2016 (ADAMS Accession Number ML15132A569),

and 203/199 on August 3, 2016 (ADAMS Accession Number ML15233A448), respectively. Additionally, the proposed change is consistent with the TVA Sequoyah Nuclear Plant (SQN) that incorporated TSTF-266-A as part of their conversion to the Improved TS (ADAMS Accession Numbers ML15238B460, ML15236A351, ML15258A511, ML15254A509, and ML15258A516). Also, Watts Bar Nuclear Plant (Watts Bar), adopted TSTF-266-A, which was documented in NRC letter dated March 18, 2019 (ADAMS Accession Number ML19066A009).

4.3 No Significant Hazards Consideration Arizona Public Service Company (APS) is requesting an amendment to Renewed Facility Operating Licenses NPF-41, NPF-51, and NPF-74 for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2 and 3, respectively. The proposed amendment would modify Technical Specifications (TS) 3.3.11, to adopt TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls.

Specifically, the current Table 3.3.11-1, Remote Shutdown System Instrumentation and Controls, is to be relocated to the TS Bases, where

Enclosure Description and Assessment of Proposed License Amendment Page 5 changes can be administered under the controls of TS 5.5.14, Technical Specifications Bases Control Program.

APS has evaluated whether or not a significant hazards consideration is involved with the proposed amendment 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 removes the list of Remote Shutdown System (RSS) instrumentation and controls from the TS and places them in the TS Bases. The TS continue to require that the instrumentation and controls be operable. The location of the list of Remote Shutdown System instrumentation and controls is not an initiator to any accident previously evaluated. The proposed change will have no effect on the mitigation of any accident previously evaluated because the instrumentation and controls continue to be required to be operable.

Therefore, the 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 change does not involve a physical alteration to the plant (i.e., no new or different type of equipment will be installed) or a change to the methods governing normal plant operation. The changes do not alter the assumptions made in the safety analysis.

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

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

Response: No.

The proposed change removes the list of RSS instrumentation and controls from the TS and places it in the TS Bases. The review performed by the Nuclear Regulatory Commission (NRC) when the list of RSS instrumentation and controls is revised will no longer be needed unless the criteria of 10 CFR 50.59, Changes, tests and experiments, are not met such that prior NRC review is required. The TS requirement that the RSS be operable, the definition of operability, the requirements of 10 CFR 50.59, and the TS Bases

Enclosure Description and Assessment of Proposed License Amendment Page 6 Control Program are sufficient to ensure that revision of the list without prior NRC review and approval does not introduce a significant safety risk.

Therefore, the proposed changes do 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.

4.4 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.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed changes 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, Standards for Protection Against Radiation, or would change an inspection or surveillance requirement. However, the proposed changes do 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 changes meet 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 changes.

6.0 REFERENCE NRC letter to the Nuclear Energy Institute, dated September 10, 1999 (Legacy Accession Number 9909160189).

ATTACHMENT 1:

Proposed Technical Specification Changes (Mark-Up)

Changed Page(s) 3.3.11-1 3.3.11-3

Remote Shutdown System 3.3.11 PALO VERDE UNITS 1,2,3 3.3.11-1 AMENDMENT NO. 117, 165 3.3 INSTRUMENTATION 3.3.11 Remote Shutdown System LCO 3.3.11 The Remote Shutdown System Instrumentation Functions in Table 3.3.11-1 and each Remote Shutdown System disconnect switch and control circuit shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

NOTE-----------------------------------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more required Functions in Table 3.3.11.1 inoperable.

A.1 Restore required Functions to OPERABLE status.

30 days B.

One or more remote shutdown system disconnect switches or control circuits inoperable.

B.1 Restore required switch(s)/circuit(s) to OPERABLE status OR B.2 Issue procedure changes that identify alternate disconnect methods or control circuits 30 days 30 days C.

Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours

Remote Shutdown System 3.3.11 PALO VERDE UNITS 1,2,3 3.3.11-3 AMENDMENT NO. 117 Table 3.3.11-1 (page 1 of 1)

Remote Shutdown System Instrumentation and Controls FUNCTION/INSTRUMENT REQUIRED NUMBER OF CHANNELS

1.

Reactivity Control

a.

Log Power Neutron Flux 2

2.

Reactor Coolant System Pressure Control

a.

Pressurizer Pressure 1

b.

Refueling Water Tank Level 2

c.

Charging Line Pressure 1

d.

Charging Line Flow 1

3.

Decay Heat Removal (via Steam Generators)

a.

Reactor Coolant Hot Leg Temperature 1 per loop

b.

Reactor Coolant Cold Leg Temperature 1 per loop

c.

Steam Generator Pressure 2 per steam generator

d.

Steam Generator Level 2 per steam generator

e.

Auxiliary Feedwater Flow 2 per steam generator

4.

Decay Heat Removal (via Shutdown Cooling System)

a.

Shutdown Cooling Heat Exchanger Temperature 2

b.

Shutdown Cooling Flow 2

5.

Reactor Coolant System Inventory Control

a.

Pressurizer Level 2

Removed from TS and placed in the Bases as Table B 3.3.11-1. Delete page.

ATTACHMENT 2:

Proposed Technical Specification Changes (Re-Typed)

Changed Page(s) 3.3.11-1

Remote Shutdown System 3.3.11 PALO VERDE UNITS 1,2,3 3.3.11-1 AMENDMENT NO. 165, 3.3 INSTRUMENTATION 3.3.11 Remote Shutdown System LCO 3.3.11 The Remote Shutdown System Instrumentation Functions and each Remote Shutdown System disconnect switch and control circuit shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

NOTE-----------------------------------------------------

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more required Functions inoperable.

A.1 Restore required Functions to OPERABLE status.

30 days B.

One or more remote shutdown system disconnect switches or control circuits inoperable.

B.1 Restore required switch(s)/circuit(s) to OPERABLE status OR B.2 Issue procedure changes that identify alternate disconnect methods or control circuits 30 days 30 days C.

Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 4.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours

ATTACHMENT 3:

Revised Technical Specification Bases Changes (Page Markups - For Information)

Changed Page(s)

B 3.3.11-2 B 3.3.11-4 B 3.3.11-5 B 3.3.11-8

Remote Shutdown System B 3.3.11 BASES (continued)

PALO VERDE UNITS 1,2,3 B 3.3.11-2 REVISION 2 APPLICABLE 10 CFR 50, Appendix A, GDC 19 (Ref. 1) and Appendix R SAFETY ANALYSES (Ref. 2).

(continued)

The Remote Shutdown System has been identified as an important contributor to the reduction of plant accident risk and, therefore, has been retained in the Technical Specifications, as indicated in 10 CFR 50.36 (c)(2)(ii).

LCO The Remote Shutdown System LCO provides the requirements for the OPERABILITY of the instrumentation and controls necessary to place and maintain the plant in MODE 3 from a location other than the control room. The instrumentation required is listed in Table B3.3.11-1 in the accompanying LCO.

The disconnect switches and control circuits are listed in PVNGS controlled documents.

The controls, instrumentation, and transfer switches are those required for:

Reactivity Control (initial and long term);

RCS Pressure Control; Decay Heat Removal; RCS Inventory Control; and Safety support systems for the above Functions, as well as the essential spray pond system, essential cooling water system, and onsite power including the diesel generators.

A Function of a Remote Shutdown System is OPERABLE if all instrument and control channels needed to support the remote shutdown Functions are OPERABLE. That is, they are able to place the plant in a safe shutdown condition from a location other than the control room. The intent of this Technical Specification is to provide the requirements for the OPERABILITY of the instrumentation and controls necessary to place the plant in safe shutdown from a location other than the control room, not to govern safe shutdown component OPERABILITY or allowed out of service times.

i

Remote Shutdown System B 3.3.11 BASES (continued)

PALO VERDE UNITS 1,2,3 B 3.3.11-4 REVISION 42 LCO Atmospheric Dump valve SGBHV185 has been isolated via (continued) its block valve to snoop for air leakage. Entry into 3.3.11 is NOT required because the control circuitry for SGBHV185 remains operable.

Auxiliary Feedwater pump AFBP01 has been removed from service for maintenance. The supply breaker has been racked out and the control power fuses rolled to off. Entry into 3.3.11 IS required because the control circuitry for AFBP01 has been disabled.

B Class pressurizer back-up heaters are de-energized for the performance of 36ST-9SA02. Entry into 3.3.11 is NOT required because the control circuitry for the B Class heaters remains operable.

B and D PK battery chargers are in service. The BD swing charger is tagged out for maintenance. Entry into 3.3.11 IS required because the control circuitry for PKB-H16 has been disabled.

APPLICABILITY The Remote Shutdown System LCO is applicable in MODES 1, 2, and 3. This is required so that the unit can be placed and maintained in MODE 3 for an extended period of time from a location other than the control room.

This LCO is not applicable in MODE 4, 5, or 6. In these MODES, the unit is already subcritical and in the condition of reduced RCS energy. Under these conditions, considerable time is available to restore necessary instrument control Functions if control room instruments or control become unavailable.

ACTIONS A Remote Shutdown System division is inoperable when each Function listed in Table 3.3.11-1 is not accomplished by the required number of channels in Table 3.3.11-1 that satisfies the OPERABILITY criteria for the channels Function. These criteria are outlined in the LCO section of the Bases.

Remote Shutdown System B 3.3.11 BASES (continued)

PALO VERDE UNITS 1,2,3 B 3.3.11-5 REVISION 66 ACTIONS A Note has been added in the ACTIONS to clarify the (continued) application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed in Table 3.3.11-1. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A addresses the situation where one or more instrumentation channels of the Remote Shutdown System are inoperable for any required Function. This includes any Function listed in Table 3.3.11-1.

The Required Action is to restore the channels to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room.

B.1 and B.2 Condition B addresses the situation where one or more disconnect or control circuits of the Remote Shutdown System are inoperable.

The required disconnect and control circuits are listed in PVNGS controlled documents.

The required Action is to restore the required switch(s)/circuit(s) to OPERABLE status or issue procedure changes that identify alternate disconnect methods or control circuits. The Completion Time for either of the two Actions is 30 days.

C.1 and C.2 If the Required Action and associated Completion Time of Condition A are not met, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required MODE from full power conditions in an orderly manner and without challenging plant systems.

Remote Shutdown System B 3.3.11 BASES PALO VERDE UNITS 1,2,3 B 3.3.11-8 REVISION Table B3.3.11-1 (page 1 of 1)

Remote Shutdown System Instrumentation and Controls FUNCTION/INSTRUMENT REQUIRED NUMBER OF CHANNELS

1.

Reactivity Control

a.

Log Power Neutron Flux 2

2.

Reactor Coolant System Pressure Control

a.

Pressurizer Pressure 1

b.

Refueling Water Tank Level 2

c.

Charging Line Pressure 1

d.

Charging Line Flow 1

3.

Decay Heat Removal (via Steam Generators)

a.

Reactor Coolant Hot Leg Temperature 1 per loop

b.

Reactor Coolant Cold Leg Temperature 1 per loop

c.

Steam Generator Pressure 2 per steam generator

d.

Steam Generator Level 2 per steam generator

e.

Auxiliary Feedwater Flow 2 per steam generator

4.

Decay Heat Removal (via Shutdown Cooling System)

a.

Shutdown Cooling Heat Exchanger Temperature 2

b.

Shutdown Cooling Flow 2

5.

Reactor Coolant System Inventory Control

a.

Pressurizer Level 2

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