ML17303A505

Provides Addl Revised Pages to Util 870423 Rev to 870123 Application for Amends to Licenses NPF-41,NPF-51 & NPF-65, Revising Boration Requirements When in Shutdown by Modifying Shutdown Margin Requirements.Tech Specs Encl

ML17303A505
Person / Time
Site:	Palo Verde
Issue date:	07/17/1987
From:	HAYNES J G ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML17303A506	List: ML17303A505
References
161-00377-JGH-L, 161-377-JGH-L, TAC-64676, TAC-64677, TAC-64678, TAC-65693, TAC-65694, TAC-65695, NUDOCS 8707240221
Download: ML17303A505 (12)

Text

/REGULARLY INFORMATION DISTR IBUTIO SYSTEM (RIDB)ACCESSION NOR: 8707240221 DOC.DATE: 87/07/17 NOT RIZED: NO DOCKET O FACIL: BTN-50-528 Palo Verde Nuclear Stations Unit ii Arizona Publi 05000528 STN-50-529 Palo'erde Nuclear Stations Unit 2i Arizona Pub li 05000529 BTN-50-530 Palo Verde Nuclear Stationi Unit 3i Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION HAYNES'.G.Arizona Nuclear Poujer ProJect (formerly Arizona Public Berv RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk>

SUBJECT:

Provides addi revised pages to util 870423 rev to 870123 application for amends to Licenses NPF-.4ii NPF-51 5 NPF-65'evising boration requirements when in shutdoujn bg modifying shutdoujn margin requirements.

Tech Specs encl.DIBTRIBUTIDN CODE:*00ID CDPIEB RECEIVED: LTR I ENCL j BIZE: CP+5~TITLE: OR Submittal:

General Distribution NOTES: Standardi zed plant.M.Davisi NRR: iCg.Standardized plant.M.Davis'RR: 1Cg.Standardized plant.M.Davis'RR: iCg.05000528 0500052'P 05000530 RECIPIENT ID CODE/NAME PD5 LA LICITRA>E INTERNAL: ACRS NRR/DEST/ADE NRR/DEBT/CEB NRR LRB F 01 EXTERNAL: EQ8(Q HRUBKEs S NRC PDR NOTES: COP IEB LTTR ENCL 0 1 1 6 6 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME PD5 PD DAVIS>M ARM/DAF/LFMB NRR/DEST/ADB NRR/DOEA/TSH OGC/HDB1 RES/DE/EIH LPDR NBIC COPIES LTTR ENCL 5 5 1 1 0 1 1 1 0 1 1 1 1 1 TOTAL NUMBER OF COPIEB REQUIRED: LTTR 28 ENCL 25 2 s t 0 a 1I 1 Arizona Nuclear Power Project P.o.BOX 52034~PHOENIX.ARIZONA 85072-2034 July 17, 1987 161-00377-JGH/LJM U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington D.C., 20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3 Docket Nos.STN 50-528 (License NPF-41)STN 50-529 (License NPF-51)STN 50-530 (License NPF-65)Revision to Technical Specification Amendment Sections 1.0, 2.2, 3/4.1, 3/4.3, 3/4.10 File: 87-F-005-419.05 87-A-056-026

Dear Sir:

(1)Letter from J.G.Haynes (ANPP)to G.W.Knighton (NRC)dated January 23, 1987 (ANPP-39798).

Subject:

Technical Specification Amendment-Section 1.0, 2.2, 3/4.1, 3/4.3, 3/4.10.(2)Telecon between Manny Licitra (NRC), B.J.Albert (ANPP), and Gerry Sowers (ANPP)on June 15 and 16,1987.

Subject:

Temperature Dependent Shutdown Margin Technical Specification Amendment Request.(3)Letter from J.G.Haynes (ANPP)to Document Control Desk (NRC)dated April 23, 1987 (161-00167).

Subject:

Revision to Technical Specification Amendment-Sections 1.0,~'2.2, 3/4.1, 3/4.3;3/4.10.The Reference (1)letter submittal proposed changes to the PVNGS Unit 1, 2,~*and 3 Technical Specifications to reduce the boration requirements when in shutdown, by modification of the shutdown margin requirements.

Reference (3)provided revised pages to the Reference (1)submittal based on a March 3, 1987 discussion with the NRC staff.This letter provides additional revised pages to Reference (3)as follows.The Reference (2)telecon requested additional information on the amendment request.This information is provided in Attachment-1.Attachment 2 discusses additional new revisions.

resulting from the original change and which have recently been identified by ANPP and discussed with the NRC.Attachment 3 provides revised pages to the Reference (3)letter reflecting the information discussed in Attachment 1 and Attachment 2.'he revised pages replace the corresponding pages in the submittal of Reference (3).By copy of this letter, appropriate state agency.>>07240m>8707>7 PDR ADOCK 05000528 P PDR we are also forwarding the revisions to the pal~l "A~>Q t<USNRC Document Control Desk Revision to Technical Specification Amendment 161-00377 Page 2 If you have any questions, please call W.F.Quinn at (602)371-4087.Very Truly Yours,.G.Haynes, Vice President Nuclear Production JGH/LJM/ls Attachment cc: 0.M.E.E.A.C.R.P.J.B.G.M.E.A.C.E.De Michele (all w/a)Van Brunt, Jr.Gehr Zimmerman Martin Knighton Licitra Tedford I\L ATTACHMENT 1 ANPP RESPONSE TO NRC QUESTIONS't On June 15 and 16, 1987, telephone conversations were held between ANPP (B.J.Albert and G.W.Sowers)and Mr.E.A.Licitra of the NRC Staff.During the telephone conversations, Mr.sLicitra asked several questions concerning the Temperature Dependent Shutdown Margin Techni.'cal Specification amendment request.Mr.Licitra also asked ANPP to formally document the responses to these NRC questions.

The'ANPP responses to these NRC questions are provided below: NRC Question Concerning revised Limiting Condition for Operation (LCO)3.1.1.1, the mode applicability for Special Test Exception (STE)3.10.9 does not correspond to the applicable modes of LCO 3.1.1.1.ANPP~Res onse STE 3.10.9 can be used only in Modes 4 and 5.The mode applicability section of LCO 3.1.1.1 has been revised to note that STE 3.10.9 is applicable in modes 4 and 5.Revised page 3/4 1-1 for the PVNGS Units 1,', and 3 Technical Specifications is included in Attachment 3 of this letter.2.NRC Question The NRC expressed an editorial comment concerning the revised wording of the action statements of LCOs 3.1.2.2, 3.1.2.4, and 3.1.2.6.The NRC comment was that instead of just deleting the words"and borated to a SHUTDOWN MARGIN equivalent to at least 6X delta K/K at 210 F" ANPP should replace the deleted statement with"and borated to a SHUTDOWN MARGIN in accordance with Specifications 3.1.1.1 and 3.1.1.2".ANPP~Res onse The editor'ial comment will not be incorporated.

ANPP provided the NRC with justification for deleting any reference to shutdown margin requirements in the Action Statements for 3.1.2.2, 3.1.2.4, and 3.1.2.6 in the Reference (3)letter, (Attachment 1, Item 4).3.NRC Question In the safety evaluation section of the Technical Specification amendment request (refer to page 7 of Reference 3 letter)ANPP stated,"an alarm will alert the operator of an unplanned boron dilution at least 15 minutes prior to a complete loss of shutdown margin." This does not satisfy the requirements for a minimum 30 minute time interval in Mode 6 from the time an alarm makes the operator aware of unplanned boron dilution before a loss of shutdown margin occurs.

0 A l II I 1"+I lk f ANPP es onse As stated in the Reference 3 letter, the time of complete loss of shutdown margin for the most limiting inadvertent boron dilution is 50 minutes.This ensures that an alarm will alert the operator of an unplanned boron dilution at least 15 minutes prior to complete loss of shutdown margin for Modes 1 through 5 and at least 30 minutes prior to complete loss of shutdown for Mode 6.

ATTACHMENT 2 I.Reason for Changes During Unit 1 Cycle 2 Reload Technical Specification (T.S.)review, ANPP questioned the validity of the proposed changes to the Backup Boron Dilution Detection Tables of Technical Specification 3.1.2.7.It appeared that the assumed mixing volume used in the modes 4 and 5 calculations were too large.ANPP requested the vendor, CE, to investigate this concern and inform the Project of the results of the investigation.

The following is a summary of those results: 1)The assumed mixing volume used in the calculations for Modes 4 and 5 was nonconservative under certain conditions.

2)Due to this fact the Temperature Dependent Shutdown Margin amendment should be modified.(see section III of this attachment) 3)The approved Technical Specifications are adequate as long as the present shutdown margin requirements are maintained.(see section II of this attachment)

II.Justification for Using Present Technical Specifications Whenever fewer than two reactor, coolant pumps are operating, the low RCS coolant flow trip will generate a continuous tr'ip signal so the trip breakers will be open.This precludes operation with CEAs withdrawn during conditions when stagnation in the RCS loops may occur.The effect of having all CEAs inserted is,to lengthen the time to criticality during a boron dilution event.An analysis of the Boron Dilution event has been pe'rformed using the following assumptions:

1.Beginning of cycle (BOC)1 conditions..

2.All CEAs initially inserted.3.Initial Boron concentration is set by the T.S.shutdown margin of 4'or Mode 5 or 6X for Mode 4.In the all rods in condition the core would be subcritical by the sum of the shutdown margin required by the T.S.and the stuck rod allowance required in the definition of shutdown margin.This corresponds to a K ff of less than.92 for Mode 5 and less than.9 for Mode 4.4.A primary coolant volume of 5100 ft is available for mixing.This 3 excludes all portions of the RCS which might be stagnant but includes the volume of one shutdown cooling system train.5.The dilution occurs at the maximum possible rate of 132 GPM corresponding to 3 charging pumps in operation.

The resulting time to criticality was longer than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for both modes 4 and 5 operation.

This time is longer than the time to criticality of 95 minutes previously reported in CESSAR section 15.4.6 for the Mode 5 filled case and is long enough that the Boron Dilution alarms will provide at least 15 minutes for operator action after alarm.Therefore, the surveillance intervals given in the table were found to be adequate.

I' 1.Based'on a reevaluation of safety analysis assumptions for Inadvertent Deboration, the changes'o the Technical Specifications proposed in letter ANPP-39798-JGH/PGN/98.05 dated January 23, 1987'should be modified as follows: a.Figure 3.1-1A has been modified to increase the required shutdown margin at 210 F from 1X delta K/K to 3.5%%uo delta K/K.b.LCO 3.1.2.3 requires that only one charging pump may be in operation during operation in MODE 5 when the system has been drained for maintenance.

This specification is made less restrictive.

The proposed change removes this restriction since the revised supporting analysis bounds MODE 5 operation with the system partially drained.c~Tables 3.1-1 through 3.1-5 specify surveillance intervals during periods when a boration dilution alarm is inoperable.

The proposed changes make these tables more restrictive.

The applicability of the surveillance intervals which apply during MODE 5 drained conditions is expanded to also apply during MODE 4 or MODE 5 operation when the reactor is being cooled by the shutdown cooling system.Several of the surveillance frequencies given in the tables have been changed consistent with the supporting analysis.MODE 6 requirements have been deleted where the requirements conflict with the MODE definition (K ff(.95)2.The proposed changes match the guidance of 51 FR 7751 the example: 3.(ii)A change that constitutes an additional limitation, restriction or control not presently included in the Technical Specification; for example, a more stringent surveillance requirement.

The supporting analysis for inadvertent deboration has been changed.Changes are noted by bars in the margin.4.Amendment changes are noted by bars in the margin.MARKED-UP TECHNICAL SPECIFICATION CHANGE PAGES: Limiting Conditions for Operation and Surveillance Requirements:

3/4 1-2a 3/4 1-9 3/4 1-16 3/4 1-17 3/4 1-18 3/4 1-19 3/4 1-20