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| | issue date = 09/09/2016 | | | issue date = 09/09/2016 |
| | title = Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications | | | title = Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications |
| | author name = Lacal M L | | | author name = Lacal M |
| | author affiliation = Arizona Public Service Co | | | author affiliation = Arizona Public Service Co |
| | addressee name = | | | addressee name = |
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| | page count = 6 | | | page count = 6 |
| | project = | | | project = |
| | stage = RAI | | | stage = Request |
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| {{#Wiki_filter:10 CFR 50.90 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway | | {{#Wiki_filter:10 CFR 50.90 MARIA L. LACAL Senior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 102-07330-MLL/MDD Phoenix, AZ 85072 September 9, 2016 Mail Station 7605 Tel 623.393.6491 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 |
| * Diablo Canyon Palo Verde Wolf Creek MARIA L. LACAL Senior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605
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| Tel 623.393.6491 | |
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| 102-07330-MLL/MDD September 9, 2016 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
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| ==Dear Sirs:== | | ==Dear Sirs:== |
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| ==Subject:== | | ==Subject:== |
| Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Renewed Operating License Nos. NPF-41, NPF-51, NPF-74 Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications By letter dated April 1, 2016 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML16096A337], Arizona Public Service Company (APS) submitted a license amendment request (LAR) pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, requesting approval of proposed changes to the PVNGS Technical Specifications (TS). The proposed LAR would revise TS requirements related to the degraded and loss of voltage relays that are planned to be modified to be more aligned with designs generally implemented in the industry. Specifically, the licensing basis for degraded voltage protection will be changed from reliance on a TS initial condition that ensures adequate post-trip voltage support of accident mitigation equipment to crediting automatic actuation of the degraded and loss of voltage relays to ensure proper equipment performance. | | Palo Verde Nuclear Generating Station (PVNGS) |
| | Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Renewed Operating License Nos. NPF-41, NPF-51, NPF-74 Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications By letter dated April 1, 2016 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML16096A337], Arizona Public Service Company (APS) submitted a license amendment request (LAR) pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, requesting approval of proposed changes to the PVNGS Technical Specifications (TS). The proposed LAR would revise TS requirements related to the degraded and loss of voltage relays that are planned to be modified to be more aligned with designs generally implemented in the industry. Specifically, the licensing basis for degraded voltage protection will be changed from reliance on a TS initial condition that ensures adequate post-trip voltage support of accident mitigation equipment to crediting automatic actuation of the degraded and loss of voltage relays to ensure proper equipment performance. |
| By letter dated July 21, 2016 (ADAMS Accession No. ML16203A381), APS supplemented the LAR in response to U.S. Nuclear Regulatory Commission (NRC) Probabilistic Risk Assessment Operations and Human Factors Branch (APHB) staff request for additional information (RAI) (ADAMS Accession No. ML16181A334), dated June 29, 2016. | | By letter dated July 21, 2016 (ADAMS Accession No. ML16203A381), APS supplemented the LAR in response to U.S. Nuclear Regulatory Commission (NRC) Probabilistic Risk Assessment Operations and Human Factors Branch (APHB) staff request for additional information (RAI) (ADAMS Accession No. ML16181A334), dated June 29, 2016. |
| The Instrumentation and Controls Branch (EICB) of the NRC staff provided RAIs by NRC document, dated August 17, 2016 (ADAMS Accession No. ML16230A231). The Enclosure to this letter provides the APS response to the RAIs. The RAI responses do not affect the conclusions of the no significant hazards consideration determination [10 CFR 50.91(a)] provided in the original LAR. | | The Instrumentation and Controls Branch (EICB) of the NRC staff provided RAIs by NRC document, dated August 17, 2016 (ADAMS Accession No. ML16230A231). The Enclosure to this letter provides the APS response to the RAIs. The RAI responses do not affect the conclusions of the no significant hazards consideration determination [10 CFR 50.91(a)] |
| No new commitments are being made in this submittal. Should you need further information regarding this response, please contact Michael D. Dilorenzo, Licensing Section Leader, at (623) 393-3495 | | provided in the original LAR. |
| . | | No new commitments are being made in this submittal. Should you need further information regarding this response, please contact Michael D. Dilorenzo, Licensing Section Leader, at (623) 393-3495. |
| 102-07330-MLL/MDD ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Response to EICB RAIs Regarding LAR to Revise TS Related to Degraded and Loss of Voltage Relay Modifications Page 2
| | A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway |
| | | * Diablo Canyon |
| I declare under penalty of perjury that the foregoing is true and correct.
| | * Palo Verde |
| Executed on : September 9, 2016 (Date)
| | * Wolf Creek |
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| Sincerely, MLL/MDD/CJS/af | | 102-07330-MLL/MDD ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Response to EICB RAIs Regarding LAR to Revise TS Related to Degraded and Loss of Voltage Relay Modifications Page 2 I declare under penalty of perjury that the foregoing is true and correct. |
| | Executed on : September 9, 2016 (Date) |
| | Sincerely, Digitally signed by Lacal, Lacal, Maria Maria L(Z06149) |
| | DN: cn=Lacal, Maria L(Z06149) L(Z06149) |
| | Date: 2016.09.09 13:55:30 |
| | -07'00' MLL/MDD/CJS/af |
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| ==Enclosure:== | | ==Enclosure:== |
| Response to NRC Instrumentation and Controls Staff Requests for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications cc: K. M. Kennedy NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS M. M. Watford NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS T. Morales Arizona Radiation Regulatory Agency (ARRA) | | Response to NRC Instrumentation and Controls Staff Requests for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications cc: K. M. Kennedy NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS M. M. Watford NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS T. Morales Arizona Radiation Regulatory Agency (ARRA) |
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| Enclosure | | Enclosure Response to NRC Instrumentation and Controls Staff Requests for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications |
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| Response to NRC Instrumentation a nd Controls Staff Requests for Additional Information Regardi ng License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications | |
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| Enclosure Response to NRC EICB Staff RAIs Regarding LAR to Revise Technical Specifications Related to Degraded and Loss of Voltage Relays 1
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| Introduction By letter dated April 1, 2016 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML16096A337], Arizona Public Service Company (APS) submitted a license amendment request (LAR) pursuant to the provisions of Section 50.90 of Title 10 of the
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| Code of Federal Regulations (10 CFR), for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, requesting approval of proposed changes to the PVNGS Technical Specifications (TS). The proposed LAR would revise TS requirements related to the degraded and loss of voltage relays that are planned to be modified to be more aligned with designs generally implemented in the industry. Specifically, the licensing basis for degraded voltage protection will be changed from reliance on a TS initial condition that ensures adequate post-trip voltage support of accident mitigation equipment to crediting automatic actuation of the degraded and loss of voltage relays to ensure proper equipment performance.
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| By letter dated July 21, 2016 (ADAMS Accession No. ML16203A381), APS supplemented the LAR in response to U.S. Nuclear Regulatory Commission (NRC) Probabilistic Risk Assessment Operations and Human Factors Branch (APHB) staff request for additional information (RAI) (ADAMS Accession No. ML16181A334), dated June 29, 2016. The Instrumentation and Controls Branch (EICB) of the NRC staff provided RAIs by NRC document, dated August 17, 2016 (ADAMS Accession No. ML16230A231). This enclosure provides the APS response to the EICB RAIs. The NRC staff RAIs are provided first, followed by the APS response.
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| | Enclosure Response to NRC EICB Staff RAIs Regarding LAR to Revise Technical Specifications Related to Degraded and Loss of Voltage Relays Introduction By letter dated April 1, 2016 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML16096A337], Arizona Public Service Company (APS) submitted a license amendment request (LAR) pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), for Palo Verde Nuclear Generating Station (PVNGS), |
| | Units 1, 2, and 3, requesting approval of proposed changes to the PVNGS Technical Specifications (TS). The proposed LAR would revise TS requirements related to the degraded and loss of voltage relays that are planned to be modified to be more aligned with designs generally implemented in the industry. Specifically, the licensing basis for degraded voltage protection will be changed from reliance on a TS initial condition that ensures adequate post-trip voltage support of accident mitigation equipment to crediting automatic actuation of the degraded and loss of voltage relays to ensure proper equipment performance. |
| | By letter dated July 21, 2016 (ADAMS Accession No. ML16203A381), APS supplemented the LAR in response to U.S. Nuclear Regulatory Commission (NRC) Probabilistic Risk Assessment Operations and Human Factors Branch (APHB) staff request for additional information (RAI) |
| | (ADAMS Accession No. ML16181A334), dated June 29, 2016. The Instrumentation and Controls Branch (EICB) of the NRC staff provided RAIs by NRC document, dated August 17, 2016 (ADAMS Accession No. ML16230A231). This enclosure provides the APS response to the EICB RAIs. The NRC staff RAIs are provided first, followed by the APS response. |
| NRC Staff RAI 1: | | NRC Staff RAI 1: |
| In Attachment 4, Technical Description of Modification of the Degraded and Loss of Voltage Relays, of the LAR the licensee referred to Calculation 13-EC-PB-0202, 4160 V Degraded Voltage Relay (DVR) and Loss of Voltage Relay (LoVR) Setpoint & Calibration , Revision 5. Figures 5-2 and 5-3 in Attachment 4, documents the final results of the Allowable Values derived in this calculation. These values correspond to the proposed Allowable Values in TS SR 3.3.7.4. Please provide or make Calculation 13-EC-PB-0202 available to the NRC staff for audit. | | In Attachment 4, Technical Description of Modification of the Degraded and Loss of Voltage Relays, of the LAR the licensee referred to Calculation 13-EC-PB-0202, 4160 V Degraded Voltage Relay (DVR) and Loss of Voltage Relay (LoVR) Setpoint & Calibration, Revision 5. |
| | Figures 5-2 and 5-3 in Attachment 4, documents the final results of the Allowable Values derived in this calculation. These values correspond to the proposed Allowable Values in TS SR 3.3.7.4. Please provide or make Calculation 13-EC-PB-0202 available to the NRC staff for audit. |
| The information in this calculation will be used to confirm the proposed Allowable Values in SR 3.3.7.4 conform to the criteria of Regulatory Guide 1.105, Rev. 3. | | The information in this calculation will be used to confirm the proposed Allowable Values in SR 3.3.7.4 conform to the criteria of Regulatory Guide 1.105, Rev. 3. |
| APS Response 1: | | APS Response 1: |
| APS made the calculation available for review during the NRC Audit of August 26, 2016 (ADAMS Accession No. ML16230A604). APS staff provided an overview of the calculation and a discussion of the methodology used in the derivation of the TS Surveillance Requirement (SR) allowable values. | | APS made the calculation available for review during the NRC Audit of August 26, 2016 (ADAMS Accession No. ML16230A604). APS staff provided an overview of the calculation and a discussion of the methodology used in the derivation of the TS Surveillance Requirement (SR) allowable values. |
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| Enclosure Response to NRC EICB Staff RAIs Regarding LAR to Revise Technical Specifications Related to Degraded and Loss of Voltage Relays 2 NRC Staff RAI 2:
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| Sections 5.11.2 and 5.11.3 documents the Work Order History of ABB Type 27N Relays and Agastat ETR Timers. Please provide or make data used to calculate the uncertainty limits available to the NRC staff for audit.
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| APS Response 2:
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| APS made the requested information available for review during the NRC audit of August 26, 2016 (ADAMS Accession No. ML16230A604).
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| NRC Staff RAI 3:
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| In Calculation 13-EC-PB-0202, where the parameters have been obtained from the vendors, explain how data provided is used to ensure conformance to 95/95 confidence level specified in Regulatory Guide 1.105, Rev. 3.
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| APS Response 3:
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| The channel uncertainty values in Calculation 13-EC-PB-0202, 4160 V Degraded Voltage Relay (DVR) and Loss of Voltage Relay (LoVR) Setpoint & Calibration , Revision 5, are based on vendor provided accuracy and uncertainty information. These channel uncertainties were used to ensure that the limiting setpoints and corresponding TS allowable values adequately protect the analytical limits (ALs) determined by the electrical design calculations. | | Enclosure Response to NRC EICB Staff RAIs Regarding LAR to Revise Technical Specifications Related to Degraded and Loss of Voltage Relays NRC Staff RAI 2: |
| | Sections 5.11.2 and 5.11.3 documents the Work Order History of ABB Type 27N Relays and Agastat ETR Timers. Please provide or make data used to calculate the uncertainty limits available to the NRC staff for audit. |
| | APS Response 2: |
| | APS made the requested information available for review during the NRC audit of August 26, 2016 (ADAMS Accession No. ML16230A604). |
| | NRC Staff RAI 3: |
| | In Calculation 13-EC-PB-0202, where the parameters have been obtained from the vendors, explain how data provided is used to ensure conformance to 95/95 confidence level specified in Regulatory Guide 1.105, Rev. 3. |
| | APS Response 3: |
| | The channel uncertainty values in Calculation 13-EC-PB-0202, 4160 V Degraded Voltage Relay (DVR) and Loss of Voltage Relay (LoVR) Setpoint & Calibration, Revision 5, are based on vendor provided accuracy and uncertainty information. These channel uncertainties were used to ensure that the limiting setpoints and corresponding TS allowable values adequately protect the analytical limits (ALs) determined by the electrical design calculations. |
| | APS used the results of the instrument vendors accuracy and uncertainty information, since APS does not have the instrument vendors supporting data. APS does, however, have high confidence in the use of these values as protecting the ALs. This confidence is based on the following factors. |
| | : 1. Historical data: The calculation contains tables of data from many work orders for the potential transformers [PTs, General Electric (GE)] and the under voltage relays [UVRs, ASEA Brown Boveri (ABB)]. There is limited work order data from another power plant for the secondary timer (Agastat timer). This data for the ABB relays and the Agastat timers were reviewed as part of NRC Staff audit on August, 26, 2016 (ADAMS Accession No. ML16230A604). The historical data for both the PTs and UVRs show that the instrument performance history supports the uncertainties provided in the vendor specifications. The historical data for the Agastat timers also support the vendor specifications, but with fewer data points. |
| | : 2. Future monitoring: The PVNGS surveillance test program (procedure 73DP-9ZZ14, Surveillance Testing), of which the test procedure for this equipment is a part, has steps for tracking and monitoring out-of-tolerance (OoT) conditions. Procedure 73DP-9ZZ14 requires a Condition Report be written for an OoT condition to enter it into the Corrective Action Program. Notification of control room staff is also required. Procedure 82DP-0PP01, Out of Tolerance Program Controls, is specifically mentioned as guidance to be used in procedure 73DP-9ZZ14. The OoT program monitors for incipient failures. Monitoring will have two common results: (1) the tolerances are reasonable but the particular equipment is failing 2 |
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| APS used the results of the instrument vendor's accuracy and uncertainty information, since APS does not have the instrument vendor's supporting data. APS does, however, have high confidence in the use of these values as protecting the ALs. This confidence is based on the following factors.
| | Enclosure Response to NRC EICB Staff RAIs Regarding LAR to Revise Technical Specifications Related to Degraded and Loss of Voltage Relays and, therefore, needs to be repaired or replaced; or (2) the tolerance is determined to be unreasonable and the calculation and the related uncertainties need to be revised accordingly. The setpoints and related parameters are evaluated as part of the calculation revision process. |
| : 1. Historical data: The calculation contains tables of data from many work orders for the potential transformers [PTs, General Electric (GE)] and the under voltage relays [UVRs, ASEA Brown Boveri (ABB)]. There is limited work order data from another power plant for the secondary timer (Agastat timer). This data for the ABB relays and the Agastat timers were reviewed as part of NRC Staff audit on August, 26, 2016 (ADAMS Accession No. ML16230A604). The historical data for both the PTs and UVRs show that the instrument performance history supports the uncertainties provided in the vendor specifications. The historical data for the Agastat timers also support the vendor specifications, but with fewer data points.
| | : 3. Margin for Agastat timer: In the application where the Agastat timer is used there is adequate margin between the setpoints and the limiting conditions to allow for some variation beyond the vendor data without encroaching on the ALs. |
| : 2. Future monitoring: The PVNGS surveillance test program (procedure 73DP-9ZZ14, Surveillance Testing), of which the test procedure for this equipment is a part, has steps for tracking and monitoring out-of-tolerance (OoT) conditions. Procedure 73DP-9ZZ14 requires a Condition Report be written for an OoT condition to enter it into the Corrective Action Program. Notification of control room staff is also required. Procedure 82DP-0PP01, Out of Tolerance Program Controls, is specifically mentioned as guidance to be used in procedure 73DP-9ZZ14. The OoT program monitors for incipient failures. Monitoring will have two common results: (1) the tolerances are reasonable but the particular equipment is failing Enclosure Response to NRC EICB Staff RAIs Regarding LAR to Revise Technical Specifications Related to Degraded and Loss of Voltage Relays 3 and, therefore, needs to be repaired or replaced; or (2) the tolerance is determined to be unreasonable and the calculation and the related uncertainties need to be revised accordingly. The setpoints and related parameters are evaluated as part of the calculation revision process.
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| : 3. Margin for Agastat timer: In the application where the Agastat timer is used there is adequate margin between the setpoints and the limiting conditions to allow for some variation beyond the vendor data without encroaching on the ALs.}} | |
Letter Sequence Request |
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MONTHYEARML16123A0482016-05-0202 May 2016
NRR E-mail Capture - Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Acceptance Review of Degraded and Loss of Voltage Relay Modifications License Amendment Request
Project stage: Acceptance Review
ML16181A3342016-06-29029 June 2016
NRR E-mail Capture - Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Aphb Official RAIs for Degraded and Loss of Voltage Relay Modifications License Amendment Request
Project stage: RAI
ML16203A3812016-07-21021 July 2016
Response to NRC Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications
Project stage: Request
ML16230A2312016-08-17017 August 2016
NRR E-mail Capture - Palo Verde Nuclear Generation Plant, Units 1, 2, and 3 - Official Eicb RAIs for LAR Associated with Degraded and Loss of Voltage Relay Modifications
Project stage: RAI
ML16230A6042016-08-18018 August 2016
Regulatory Audit Plan for 8/26/16 Audit at Westinghouse Facility in Rockville, MD, in Support Degraded and Loss of Voltage Relays License Amendment Request
Project stage: Other
ML16257A5442016-09-0909 September 2016
Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications
Project stage: Request
ML16251A2452016-09-0909 September 2016
Regulatory Audit Report for 8/26/16 Audit Performed at Westinghouse Facility in Rockville, MD, in Support Degraded and Loss of Voltage Relays License Amendment Request
Project stage: Other
ML16257A3302016-09-13013 September 2016
NRR E-mail Capture - Palo Verde Nuclear Generation Plant, Units 1, 2, and 3 - Official Eeeb RAIs for LAR Associated with Degraded and Loss of Voltage Relay Modifications
Project stage: RAI
ML16300A1562016-10-26026 October 2016
Response to NRC Electrical Engineering Branch Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay ...
Project stage: Request
ML17090A1642017-04-27027 April 2017
Issuance of Amendment No. 201, 201, and 201 to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications
Project stage: Approval
2016-08-17
[Table View] |
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Category:Letter
MONTHYEARML24295A0362024-10-23023 October 2024
Regulatory Audit Plan in Support of Relief Request No. 71; Resubmittal of Relief Request-30
IR 05000528/20244022024-10-22022 October 2024
Security Baseline Inspection Report 05000528/2024402 and 05000529/2024402 and 05000530/2024402
ML24296B2142024-10-22022 October 2024
Transmittal of Valve Relief Request (VRR) - 02: Alternative Request Allowing Normally Closed Valves with a Safety Function to Close to Be Exercise Tested Once Per Refueling Cycle
ML24296B2152024-10-22022 October 2024
Transmittal of Valve Relief Request (VRR) - 03: Alternative Request Allowing Removal of the Lower Acceptance Criteria Threshold from Solenoid-Operated Valves
ML24296B2172024-10-18018 October 2024
Submittal of Unit 1 Core Operating Limits Report, Revision 34, Unit 2 Core Operating Limits Report, Revision 26, and Unit 3 Core Operating Limits Report, Revision 3
ML24292A2192024-10-18018 October 2024
Core Operating Limits Report Revision 34, 26 and 33
ML24292A0322024-10-17017 October 2024
Th Refueling Outage Steam Generator Tube Inspection Report
ML24285A2562024-10-11011 October 2024
License Renewal - Alloy 600 Management Program Plan Response to Request for Additional Information
IR 07200044/20244012024-10-0808 October 2024
Independent Spent Fuel Storage Installation Security Inspection Report 07200044/2024401
ML24269A1542024-09-27027 September 2024
Summary of Presubmittal Meeting with Arizona Public Service Company to Discuss Proposed Life-of-Plant Alternatives for a Pressurizer Thermowell Nozzle Repair at Palo Verde Nuclear Generating Station, Unit 1
ML24262A0972024-09-23023 September 2024
Notification of Post-Approval Site Inspection for License Renewal and Request for Information Inspection (05000529/2024011)
ML24241A2542024-08-28028 August 2024
Inservice Inspection Request for Information
ML24241A2782024-08-28028 August 2024
License Amendment Request to Revise the Technical Specifications 3.5.1 and 3.5.2 Safety Injection Tank Pressure Bands, and to Use GOTHIC Code
ML24240A2682024-08-27027 August 2024
Transmittal of Technical Specification Bases Revision 79
IR 05000528/20240052024-08-22022 August 2024
Updated Inspection Plan for Palo Verde Nuclear Generating Station - Units 1, 2, and 3 (Report 05000528/2024005, 05000529/2024005, 05000530/2024005)
05000530/LER-2024-001-01, Inoperable Boron Dilution Alarm System(Bdas) with Technical Specification Violation2024-08-21021 August 2024
Inoperable Boron Dilution Alarm System(Bdas) with Technical Specification Violation
ML24208A0612024-08-20020 August 2024
Issuance of Amendment Nos. 224, 224, and 224 Regarding Revision to Technical Specifications 3.5.1, 3.5.2 and 3.6.5
IR 05000528/20244042024-08-0808 August 2024
Cybersecurity Inspection Report 05000528/2024404, 05000529/2024404 and 05000530/2024404
ML24213A3232024-07-31031 July 2024
Transmittal of Relief Request (RR) No. 71: Re-Submittal of RR-30
ML24213A3292024-07-31031 July 2024
Transmittal of Relief Request (RR) No. 72: Re-Submittal of RR-39
IR 05000528/20240022024-07-29029 July 2024
Integrated Inspection Report 05000528/2024002 and 05000529/2024002 and 05000530/2024002
ML24173A3302024-07-24024 July 2024
Pressurizer Surge Line Inspection Program
ML24159A4702024-07-17017 July 2024
Issuance of Amendment Nos. 223, 223, and 223 Revision to Technical Specifications 3.5.1 and 3.5.2 Using Risk Informed Process for Evaluations
ML24198A0662024-07-16016 July 2024
Program Review - Simulator Testing Methodology
ML24193A3442024-07-11011 July 2024
Fourth 10-Year Interval, Second Period Owner’S Activity Report Number 3R24
ML24129A0522024-07-0303 July 2024
Review of the Spring 2023 Steam Generator Tube Inspection Report
IR 05000528/20240042024-06-25025 June 2024
Notification of Inspection (NRC Inspection Report 05000528/2024004, 05000529/2024004, 05000530/2024004)
05000530/LER-2024-002, Invalid Specified System Actuation of Train B Emergency Diesel Generator2024-06-25025 June 2024
Invalid Specified System Actuation of Train B Emergency Diesel Generator
ML24177A3212024-06-25025 June 2024
Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Transportable Storage Canisters Identification Numbers AMZDFX180, AMZDFX181, AMZDFX182 Vertical Concrete Cask Identification Nu
ML24177A3222024-06-25025 June 2024
Invalid Specified System Actuation of Train B Emergency Diesel Generator
ML24170A9962024-06-18018 June 2024
Response to Second Request for Additional Information to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) – Operating, TS 3.5.2, Safety Injection Tanks (Sits) – Shutdown a
ML24129A2062024-06-14014 June 2024
Issuance of Amendment Nos. 222, 222, and 222 Revision to Technical Specifications to Adopt TSTF-266-A
05000530/LER-2024-001, Inoperable Boron Dilution Alarm System(Bdas) with Technical Specification Violation2024-06-0505 June 2024
Inoperable Boron Dilution Alarm System(Bdas) with Technical Specification Violation
ML24159A0262024-06-0303 June 2024
Annual Report of Guarantee of Payment of Deferred Premium
05000529/LER-2024-001, Valid Specified System Actuations of Unit 2 Train B Emergency Diesel Generator and Train B Auxiliary Feedwater2024-05-23023 May 2024
Valid Specified System Actuations of Unit 2 Train B Emergency Diesel Generator and Train B Auxiliary Feedwater
ML24135A2482024-05-14014 May 2024
Response to Second Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line
ML24164A2582024-05-0909 May 2024
10-PV-2024-04 Post-Exam Comments
ML24129A1482024-05-0707 May 2024
And Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Casks with Applied Changes
ML24128A2702024-05-0707 May 2024
Docket Nos. Stn 50-528/529/530 - Response to NRC Regulatory Issue Summary (RIS) 2024-01, Preparation and Scheduling of Operator Licensing Examinations
IR 05000528/20240012024-05-0202 May 2024
Independent Spent Fuel Storage Installation, Integrated Inspection Report 05000528/2024001, 05000529/2024001, 05000530/2024001, 07200044/2024001, and Exercise of Enforcement Discretion
ML24119A0022024-04-26026 April 2024
2023 Annual Environmental Operating Report
ML24116A2082024-04-24024 April 2024
Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report 2023
ML24109A0712024-04-22022 April 2024
NRC Initial Operator Licensing Examination Approval 05000528/2024301, 05000529/2024301, and 05000530/2024301
IR 05000528/20244012024-04-22022 April 2024
Security Baseline Inspection Report 05000528/2024401 and 05000529/2024401 and 05000530/2024401 (Cover Letter)
ML24112A0012024-04-19019 April 2024
Core Operating Limits Report, Revision 32
ML24108A1982024-04-16016 April 2024
Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Storage Casks with Applied Changes Authorized by an Amended Certificate of Compliance
ML24103A2482024-04-12012 April 2024
Emergency Core Cooling System Performance Evaluation Models, 10 CFR 50.46(a)(3)(ii) Annual Report for 2023
ML24131A0972024-04-10010 April 2024
Annual Radiological Environmental Operating Report 2023
ML24096A2202024-04-0505 April 2024
Transmittal of Technical Specification Bases Revision 78
ML24032A1542024-04-0303 April 2024
Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)
2024-09-27
[Table view]
Category:Response to Request for Additional Information (RAI)
MONTHYEARML24285A2562024-10-11011 October 2024
License Renewal - Alloy 600 Management Program Plan Response to Request for Additional Information
ML24170A9962024-06-18018 June 2024
Response to Second Request for Additional Information to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) – Operating, TS 3.5.2, Safety Injection Tanks (Sits) – Shutdown a
ML24135A2482024-05-14014 May 2024
Response to Second Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line
ML24066A0472024-03-0606 March 2024
Response to Request for Additional Information to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) – Operating, TS 3.5.2, Safety Injection Tanks (Sits) – Shutdown and TS
ML24012A2452024-01-12012 January 2024
Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line
ML23299A3052023-10-26026 October 2023
Response to Request for Additional Information – Relief Request 70 – Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle
ML23048A3202023-02-17017 February 2023
Response to NRC Requests for Additional Information Regarding 2022 Unit 1 Steam Generator Tube Inspections
ML22090A0802022-03-31031 March 2022
Response to NRC Requests for Additional Information Regarding 2021 Unit 3 Steam Generator Tube Inspections
ML22053A2122022-02-22022 February 2022
Response to Requests for Confirmation of Information for Exemption from Certain Requirements of 10 CFR 50.62(c)(1) Using Risk-Informed Process for Evaluations
ML21173A3602021-06-22022 June 2021
Response to Request for Additional Information for Permanent Extension of Type a and Type C Leak Rate Test Frequencies
ML21061A1562021-02-26026 February 2021
Spent Fuel Storage Installation, Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses
ML21005A2712020-12-29029 December 2020
102-08208 PVNGS Communication Required by Confirmatory Order EA-20-054
ML20090L9442020-03-30030 March 2020
APS Response to Request for Additional Information- Relief Request 65 Unit 2, COVID-19, Request for Relief from Bottom Mounted Instrumentation Nozzles and a Pressurizer Nozzle to Surge
ML20073R7532020-03-13013 March 2020
Independent Spent Fuel Storage Installation (ISFSI) - APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements
ML20054A2692020-02-19019 February 2020
Response to Request for Additional Information - Relief Request 64 - Unit 1 Impractical Examinations for the Third 10-Year Inservice Inspection Interval
ML19340B2142019-12-0606 December 2019
Response to NRC Request for Additional Information Regarding 2019 Steam Generator Tube Inspections
ML19331A3612019-11-26026 November 2019
Supplemental Response to NRC Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome CE16HTP Fuel
ML19277J4572019-10-0404 October 2019
Response to NRC Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome CE16HTP Fuel
ML19165A1402019-06-14014 June 2019
Response to Request for Additional Information - Relief Request 63 - Unit 3 Impractical Examinations for the Third 10-Year Inservice Inspection Interval
ML19137A1182019-05-17017 May 2019
Response to NRC Staff Request for Additional Information from Reactor Assessment and Human Performance Branch Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome High Thermal
ML19074A1382019-03-14014 March 2019
Response to Request for Additional Information - Relief Request 62 - Third and Fourth 10-Year Inservice Inspection Intervals, Proposed Alternative - Pressurizer Heater Sleeve Repairs
ML19031C9052019-01-31031 January 2019
Supplemental License Amendment Request to Revise Technical Specifications Regarding Response Time Testing of Pressure Transmitters and Request for Additional Information Response
ML18296A4662018-10-18018 October 2018
Supplemental Information Regarding License Amendment Request and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel
ML18278A2952018-10-0505 October 2018
Response to Request for Additional Information for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21
ML18264A3182018-09-21021 September 2018
Response to Request for Additional Information for Risk-Informed Completion Times
ML18194A9142018-07-13013 July 2018
Supplemental Response to Request for Additional Information 3.a for License Amendment Request to Adopt 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components
ML18152B8742018-06-0101 June 2018
Response to Electrical Engineering Operating Reactor Branch (Eeob) Request for Additional Information for Risk-Informed Completion Times
ML18138A4802018-05-18018 May 2018
Response to Request for Additional Information for Risk-Informed Completion Times
ML18129A4482018-05-0909 May 2018
APS Response to Request for Additional Information for License Amendment Request to Adopt 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components
ML17272B0332017-09-29029 September 2017
Response to Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests
ML17153A3732017-06-0202 June 2017
Response to NRC Staff Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Next Generation Fuel
ML17144A3762017-05-24024 May 2017
Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis
ML17002A0012017-01-0202 January 2017
Response to NRC Requests for Additional Information (Rais) Regarding Emergency License Amendment Request (LAR) to Extend Diesel Generator 3B Completion Time
ML17066A1842017-01-0202 January 2017
Response to NRC Requests for Additional Information (Rais) Regarding Emergency License Amendment Request (LAR) to Extend Diesel Generator 3B Completion Time
ML16358A7152016-12-23023 December 2016
Response to Request for Additional Information Regarding Emergency License Amendment Request for a One-Time Extension of the Diesel Generator Completion Time
ML16340A9882016-12-0101 December 2016
Addendum to Supplemental Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors
ML17167A2152016-11-23023 November 2016
Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised ...
ML16321A0022016-11-0909 November 2016
Response to RAI, Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised Technical Specifications and Bases and WCAP-18030, Revision 1
ML16300A1562016-10-26026 October 2016
Response to NRC Electrical Engineering Branch Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay ...
ML16286A2422016-10-0606 October 2016
Westinghouse Electric Company, WCAP-18030-NP Review, Suggested Response to Request for Additional Information
ML16286A2402016-10-0606 October 2016
Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis
ML16257A5442016-09-0909 September 2016
Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications
ML16203A3812016-07-21021 July 2016
Response to NRC Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications
ML16182A5192016-06-30030 June 2016
Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Critical Safety Analysis
ML16147A0922016-05-20020 May 2016
Response to Request for Additional Information Regarding Relief Request 54, Alternative to Flaw Removal
ML16133A6212016-05-12012 May 2016
ISFSI - Response to Request for Additional Information Regarding Proposed Changes to Emergency Action Levels
ML16102A4632016-04-11011 April 2016
Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505
ML16029A5062016-01-29029 January 2016
Response to Request for Additional Information Regarding the Request to Change the Quality Assurance Program Description
ML15273A4702015-09-30030 September 2015
IR 05000528/2015004, 05000529/2015004, and 05000530/2015004; 11/16/2015 - 11/20/2015; Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Notification of NRC Triennial Heat Sink Performance Inspection
ML15258A8482015-09-15015 September 2015
Response to Request for Additional Information Regarding Exigent License Amendment Request to Amend Technical Specification Surveillance Requirement 3.1.5.3
2024-06-18
[Table view] |
Text
10 CFR 50.90 MARIA L. LACAL Senior Vice President, Nuclear Regulatory & Oversight Palo Verde Nuclear Generating Station P.O. Box 52034 102-07330-MLL/MDD Phoenix, AZ 85072 September 9, 2016 Mail Station 7605 Tel 623.393.6491 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Renewed Operating License Nos. NPF-41, NPF-51, NPF-74 Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications By letter dated April 1, 2016 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML16096A337], Arizona Public Service Company (APS) submitted a license amendment request (LAR) pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, requesting approval of proposed changes to the PVNGS Technical Specifications (TS). The proposed LAR would revise TS requirements related to the degraded and loss of voltage relays that are planned to be modified to be more aligned with designs generally implemented in the industry. Specifically, the licensing basis for degraded voltage protection will be changed from reliance on a TS initial condition that ensures adequate post-trip voltage support of accident mitigation equipment to crediting automatic actuation of the degraded and loss of voltage relays to ensure proper equipment performance.
By letter dated July 21, 2016 (ADAMS Accession No. ML16203A381), APS supplemented the LAR in response to U.S. Nuclear Regulatory Commission (NRC) Probabilistic Risk Assessment Operations and Human Factors Branch (APHB) staff request for additional information (RAI) (ADAMS Accession No. ML16181A334), dated June 29, 2016.
The Instrumentation and Controls Branch (EICB) of the NRC staff provided RAIs by NRC document, dated August 17, 2016 (ADAMS Accession No. ML16230A231). The Enclosure to this letter provides the APS response to the RAIs. The RAI responses do not affect the conclusions of the no significant hazards consideration determination [10 CFR 50.91(a)]
provided in the original LAR.
No new commitments are being made in this submittal. Should you need further information regarding this response, please contact Michael D. Dilorenzo, Licensing Section Leader, at (623) 393-3495.
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
102-07330-MLL/MDD ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Response to EICB RAIs Regarding LAR to Revise TS Related to Degraded and Loss of Voltage Relay Modifications Page 2 I declare under penalty of perjury that the foregoing is true and correct.
Executed on : September 9, 2016 (Date)
Sincerely, Digitally signed by Lacal, Lacal, Maria Maria L(Z06149)
DN: cn=Lacal, Maria L(Z06149) L(Z06149)
Date: 2016.09.09 13:55:30
-07'00' MLL/MDD/CJS/af
Enclosure:
Response to NRC Instrumentation and Controls Staff Requests for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications cc: K. M. Kennedy NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS M. M. Watford NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS T. Morales Arizona Radiation Regulatory Agency (ARRA)
Enclosure Response to NRC Instrumentation and Controls Staff Requests for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications
Enclosure Response to NRC EICB Staff RAIs Regarding LAR to Revise Technical Specifications Related to Degraded and Loss of Voltage Relays Introduction By letter dated April 1, 2016 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML16096A337], Arizona Public Service Company (APS) submitted a license amendment request (LAR) pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), for Palo Verde Nuclear Generating Station (PVNGS),
Units 1, 2, and 3, requesting approval of proposed changes to the PVNGS Technical Specifications (TS). The proposed LAR would revise TS requirements related to the degraded and loss of voltage relays that are planned to be modified to be more aligned with designs generally implemented in the industry. Specifically, the licensing basis for degraded voltage protection will be changed from reliance on a TS initial condition that ensures adequate post-trip voltage support of accident mitigation equipment to crediting automatic actuation of the degraded and loss of voltage relays to ensure proper equipment performance.
By letter dated July 21, 2016 (ADAMS Accession No. ML16203A381), APS supplemented the LAR in response to U.S. Nuclear Regulatory Commission (NRC) Probabilistic Risk Assessment Operations and Human Factors Branch (APHB) staff request for additional information (RAI)
(ADAMS Accession No. ML16181A334), dated June 29, 2016. The Instrumentation and Controls Branch (EICB) of the NRC staff provided RAIs by NRC document, dated August 17, 2016 (ADAMS Accession No. ML16230A231). This enclosure provides the APS response to the EICB RAIs. The NRC staff RAIs are provided first, followed by the APS response.
NRC Staff RAI 1:
In Attachment 4, Technical Description of Modification of the Degraded and Loss of Voltage Relays, of the LAR the licensee referred to Calculation 13-EC-PB-0202, 4160 V Degraded Voltage Relay (DVR) and Loss of Voltage Relay (LoVR) Setpoint & Calibration, Revision 5.
Figures 5-2 and 5-3 in Attachment 4, documents the final results of the Allowable Values derived in this calculation. These values correspond to the proposed Allowable Values in TS SR 3.3.7.4. Please provide or make Calculation 13-EC-PB-0202 available to the NRC staff for audit.
The information in this calculation will be used to confirm the proposed Allowable Values in SR 3.3.7.4 conform to the criteria of Regulatory Guide 1.105, Rev. 3.
APS Response 1:
APS made the calculation available for review during the NRC Audit of August 26, 2016 (ADAMS Accession No. ML16230A604). APS staff provided an overview of the calculation and a discussion of the methodology used in the derivation of the TS Surveillance Requirement (SR) allowable values.
1
Enclosure Response to NRC EICB Staff RAIs Regarding LAR to Revise Technical Specifications Related to Degraded and Loss of Voltage Relays NRC Staff RAI 2:
Sections 5.11.2 and 5.11.3 documents the Work Order History of ABB Type 27N Relays and Agastat ETR Timers. Please provide or make data used to calculate the uncertainty limits available to the NRC staff for audit.
APS Response 2:
APS made the requested information available for review during the NRC audit of August 26, 2016 (ADAMS Accession No. ML16230A604).
NRC Staff RAI 3:
In Calculation 13-EC-PB-0202, where the parameters have been obtained from the vendors, explain how data provided is used to ensure conformance to 95/95 confidence level specified in Regulatory Guide 1.105, Rev. 3.
APS Response 3:
The channel uncertainty values in Calculation 13-EC-PB-0202, 4160 V Degraded Voltage Relay (DVR) and Loss of Voltage Relay (LoVR) Setpoint & Calibration, Revision 5, are based on vendor provided accuracy and uncertainty information. These channel uncertainties were used to ensure that the limiting setpoints and corresponding TS allowable values adequately protect the analytical limits (ALs) determined by the electrical design calculations.
APS used the results of the instrument vendors accuracy and uncertainty information, since APS does not have the instrument vendors supporting data. APS does, however, have high confidence in the use of these values as protecting the ALs. This confidence is based on the following factors.
- 1. Historical data: The calculation contains tables of data from many work orders for the potential transformers [PTs, General Electric (GE)] and the under voltage relays [UVRs, ASEA Brown Boveri (ABB)]. There is limited work order data from another power plant for the secondary timer (Agastat timer). This data for the ABB relays and the Agastat timers were reviewed as part of NRC Staff audit on August, 26, 2016 (ADAMS Accession No. ML16230A604). The historical data for both the PTs and UVRs show that the instrument performance history supports the uncertainties provided in the vendor specifications. The historical data for the Agastat timers also support the vendor specifications, but with fewer data points.
- 2. Future monitoring: The PVNGS surveillance test program (procedure 73DP-9ZZ14, Surveillance Testing), of which the test procedure for this equipment is a part, has steps for tracking and monitoring out-of-tolerance (OoT) conditions. Procedure 73DP-9ZZ14 requires a Condition Report be written for an OoT condition to enter it into the Corrective Action Program. Notification of control room staff is also required. Procedure 82DP-0PP01, Out of Tolerance Program Controls, is specifically mentioned as guidance to be used in procedure 73DP-9ZZ14. The OoT program monitors for incipient failures. Monitoring will have two common results: (1) the tolerances are reasonable but the particular equipment is failing 2
Enclosure Response to NRC EICB Staff RAIs Regarding LAR to Revise Technical Specifications Related to Degraded and Loss of Voltage Relays and, therefore, needs to be repaired or replaced; or (2) the tolerance is determined to be unreasonable and the calculation and the related uncertainties need to be revised accordingly. The setpoints and related parameters are evaluated as part of the calculation revision process.
- 3. Margin for Agastat timer: In the application where the Agastat timer is used there is adequate margin between the setpoints and the limiting conditions to allow for some variation beyond the vendor data without encroaching on the ALs.
3
