ML15005A028

Palo Verde, Units 1, 2, & 3, Response to Request for Additional Information Regarding Application for Technical Specification Change Regarding Moderator Temperature Coefficient Surveillance for Startup Test Activity Reduction Program

ML15005A028
Person / Time
Site:	Palo Verde
Issue date:	12/19/2014
From:	Mims D C Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-06973-DCM/TNW
Download: ML15005A028 (5)

Text

I10 CFR 50.90DWIGHT C. MIMSSenior Vice President, NuclearRegulatory & OversightPalo VerdeNuclear Generating StationP.O. Box 52034Phoenix, AZ 85072Mail Station 7605102-06973-DCM/TNW Tel 623 393 5403December 19, 2014ATTN: Document Control DeskU.S. Nuclear Regulatory CommissionWashington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating StationUnits 1, 2, and 3Docket Nos. STN 50-528/529/530Response to Request for Additional Information RegardingApplication for Technical Specification Change RegardingModerator Temperature Coefficient (MTC) Surveillance forStartup Test Activity Reduction (STAR) Program Using theConsolidated Line Item Improvement Process (CLIIP)By letter number 102-06784, dated November 20, 2013 (Agencywide DocumentsAccess and Management System (ADAMS) Accession No. ML13329A037), assupplemented by letter number 102-06819, dated January 16, 2014 (ADAMSAccession No. ML14027A701), Arizona Public Service Company (APS) requested anamendment to the Palo Verde Nuclear Generating Station (PVNGS) technicalspecifications relating to the moderator temperature coefficient surveillancerequirements for Startup Test Activity Reduction Program.The U.S. Nuclear Regulatory Commission (NRC) staff provided a request foradditional information (RAI) by e-mail dated December 1, 2014, to complete itsreview of the license amendment request. A draft RAI was originally transmitted onNovember 13, 2014, and a clarification call relating to the draft RAI was held onNovember 24, 2014, with participants from NRC and APS. The NRC staff requestedthe APS response to the final RAI within 30 days of December 1, 2014.The enclosure to this letter provides the APS response to the NRC RAI. The RAIresponse remains consistent with the conclusion of the no significant hazardsconsideration determination [10 CFR 50.91(a), Notice for public comment] providedin the original LAR.By copy of this letter, this LAR update is being forwarded to the Arizona RadiationRegulatory Agency (ARRA) pursuant to 10 CFR 50.91(b)(1), State consultation.A member of the STARS (Strategic Teaming and Resource Sharing) Alliance A oCallaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• Wolf Creek KI 102-06973-DCM/TNWATTN: Document Control DeskU.S. Nuclear Regulatory CommissionResponse to Request for Additional Information Regarding Application for TechnicalSpecification Change Regarding Moderator Temperature Coefficient (MTC)Surveillance for Startup Test Activity Reduction (STAR) Program Using theConsolidated Line Item Improvement Process (CLIIP)Page 2No new commitments are being made to the NRC by this letter. Should you needfurther information regarding this submittal, please contact Thomas N. Weber,Licensing Department Leader, at (623) 393-5764.I declare under penalty of perjury that the foregoing is true and correct.Executed onSincerely,DCM/TNW(Date)

Enclosure:

Response to Request for Additional Information Regarding Applicationfor Technical Specification Change Regarding Moderator TemperatureCoefficient (MTC) Surveillance for Startup Test Activity Reduction(STAR) Program Using the Consolidated Line Item ImprovementProcess (CLIIP)cc: M. L. DapasB. K. SingalM. M. WatfordC. A. PeabodyA. V. GodwinT. MoralesNRC Region IV Regional AdministratorNRC NRR Project Manager for PVNGSNRC NRR Project ManagerNRC Senior Resident Inspector for PVNGSArizona Radiation Regulatory Agency (ARRA)Arizona Radiation Regulatory Agency (ARRA)

EnclosureResponse to Request for Additional InformationRegarding Application for Technical SpecificationChange Regarding Moderator Temperature Coefficient(MTC) Surveillance for Startup Test Activity Reduction(STAR) Program Using the Consolidated Line ItemImprovement Process (CLIIP)

Response to Request for Additional Information Regarding Application forTechnical Specification Change Regarding Moderator TemperatureCoefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR)Program Using the Consolidated Line Item Improvement Process (CLIIP)IntroductionBy letter number 102-06784, dated November 20, 2013 (Agencywide Documents Accessand Management System (ADAMS) Accession No. ML13329A037), as supplemented byletter number 102-06819, dated January 16, 2014 (ADAMS Accession No. ML14027A701),Arizona Public Service Company (APS) requested an amendment to the Palo Verde NuclearGenerating Station (PVNGS) technical specifications relating to the moderator temperaturecoefficient surveillance requirements for Startup Test Activity Reduction Program.The U.S. Nuclear Regulatory Commission (NRC) staff provided a request for additionalinformation (RAI) by e-mail dated December 1, 2014, to complete its review of the licenseamendment request. A draft RAI was originally transmitted on November 13, 2014, and aclarification call relating to the draft RAI was held on November 24, 2014, with participantsfrom NRC and APS. The NRC staff requested the APS response to the final RAI within 30days of December 1, 2014.The NRC request is stated first followed by the APS response.NRC Request 1(a)1. Arizona Public Service (APS) has proposed a modification to the PVNGS TechnicalSpecifications (TS) that would allow the plant to perform a calculation in lieu of ameasurement to complete Surveillance Requirement (SR) 3.1.4.2, which supportsthe Limiting Condition for Operation (LCO) for most negative Moderator TemperatureCoefficient (MTC) established in LCO 3.1.4.a. How would APS ensure that PVNGS remains within LCO 3.1.4 if the plantdeviates from normal operation, up to the TS limits, after performance of thetwo-thirds cycle surveillance required by SR 3.1.4.2?APS ResponseAPS performs a reload analysis (reload core safety evaluation) each cycle that includes aconservative calculation of the most negative MTC possible during the planned operatingcycle. The analysis includes the biases, uncertainties and operating allowances required toensure margin is maintained to the limits of LCO 3.1.4. The as-built core MTC will remainwithin the limits of LCO 3.1.4 provided the plant operates within the bounds established bythe TS, the Core Operating Limits Report (COLR), and the cycle length evaluated in thereload analysis. If plans were made to operate in a condition beyond that which wasevaluated in the reload analysis, then an additional evaluation would be performed tovalidate that the limits of LCO 3.1.4 would not be challenged by the planned change.For example, the cycle specific reload analysis evaluates MTC beyond the planned cycleduration for operating margin. If plans were made to extend the expected life of the corebeyond the burnup limit established in the reload analysis, an evaluation would beperformed to validate that MTC remained within the bounds of LCO 3.1.4.1

-Response to Request for Additional Information Regarding Application forTechnical Specification Change Regarding Moderator TemperatureCoefficient (MTC) Surveillance for Startup Test Activity Reduction (STAR)Program Using the Consolidated Line Item Improvement Process (CLIIP)In addition,Section VIII, Deviation from Normal Operation, of topical report,CE NPSD-91 l-A, Analysis of Moderator Temperature Coefficients in Support of a Change inthe Technical Specification End of Cycle Negative MTC Limit, dated September 15, 2000(ADAMS Accession No. ML003752592), which is referenced in APS letter number 102-06784, dated November 20, 2013, uses PVNGS as an example for evaluations on the effectsof off-normal plant operation on MTC. The topical report concludes that off normal plantoperation has only minor effects on MTC.NRC Request 1(b)b. If the answer to the previous question involves comparison of predicted valuesto the LCO limit, what criteria would APS use to determine whether or not areanalysis of the MTC prediction would be required?APS ResponseIf plans were made to operate in a condition beyond that which was evaluated in the reloadanalysis, then an additional evaluation would be performed to validate that the limits of LCO3.1.4 would not be challenged by the planned change. If the analysis performed for the offnormal operation, including appropriate biases and uncertainties, predicted that MTC wouldexceed the LCO limit, then a revised operating plan would be needed to operate at lesschallenging conditions such that the predicted MTC will not challenge the LCO limits.2