Letter Sequence Response to RAI |
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TAC:ME8160, Eliminate Use of Term Core Alterations in Actions and Notes (Withdrawn, Closed) |
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MONTHYEARML12076A0452012-03-0808 March 2012 Request for Amendment to Eliminate the Use of the Term Core Alteration in the Technical Specifications Project stage: Request ML1213103802012-05-10010 May 2012 Acceptance Review Email, License Amendment Request to Revise Technical Specifications to Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Revision 3 Project stage: Acceptance Review ML12248A1502012-09-0404 September 2012 E-mail Draft Request for Additional Information, Request to Revise Technical Specifications to Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Revision 3 Project stage: Draft RAI ML12250A7202012-09-11011 September 2012 Request for Additional Information, Request to Revise Technical Specifications to Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Revision 3 Project stage: RAI ML12286A3302012-10-11011 October 2012 Response to Request for Additional Information Regarding License Amendment Request to Eliminate the Use of the Term Core Alteration in the Technical Specifications Project stage: Response to RAI ML12341A1292012-12-0505 December 2012 E-mail, Draft Request for Additional Information, Round 2, Request to Revise Technical Specifications to Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev. 3 (TAC ME8160/ME8162) Project stage: Draft RAI ML12347A0402012-12-19019 December 2012 Request for Additional Information, Round 2, Request to Revise Technical Specifications to Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev. 3 (TAC ME8160-ME8162) Project stage: RAI ML12362A2922013-01-0303 January 2013 Request for Additional Information, Round 3, Request to Revise Technical Specifications to Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev. 3 (TAC ME8160-ME8162) Project stage: RAI ML13039A0132013-01-31031 January 2013 Response to Request for Additional Information Regarding License Amendment Request to Eliminate the Use of the Term Core Alteration in the Technical Specifications Project stage: Response to RAI ML13072A1822013-03-13013 March 2013 Email, Draft Request for Additional Information, Round 4, Request to Revise Technical Specifications to Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev. 3 (TAC ME8160-ME8162) Project stage: Draft RAI ML13127A2432013-05-0808 May 2013 5/29/13 Meeting Via Conference Call with Arizona Public Service Company to Discuss Palo Verde Request to Revise Technical Specifications; Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev 3 (TAC ME8160-ME81 Project stage: Meeting ML13150A0812013-06-0303 June 2013 Request for Additional Information, Round 4, Request to Revise Technical Specifications to Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev. 3 Project stage: RAI ML13154A4502013-06-26026 June 2013 Summary of Meeting Via Conference Call with Arizona Public Service Co. to Discuss Palo Verde Request to Revise Technical Specifications; Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev 3 (TAC ME8160-ME816 Project stage: Meeting ML13210A2382013-07-25025 July 2013 Response to Request for Additional Information Regarding License Amendment Request to Eliminate the Use of the Term Core Alteration in the Technical Specifications Project stage: Response to RAI ML14051A1032014-02-13013 February 2014 Withdrawal of Request for Amendment to Eliminate the Use of the Term Core Aleration in the Technical Specifications Project stage: Request ML14059A1782014-03-0707 March 2014 Withdrawal of License Amendment Request to Revise Technical Specifications; Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev 3 Project stage: Withdrawal ML14059A1812014-03-0707 March 2014 FRN - Withdrawal of License Amendment Request to Revise Technical Specifications; Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev 3 Project stage: Withdrawal 2013-01-03
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Category:Letter
MONTHYEARIR 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 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 IR 05000528/20240042024-06-25025 June 2024 Notification of Inspection (NRC Inspection Report 05000528/2024004, 05000529/2024004, 05000530/2024004) 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 ML24159A0262024-06-0303 June 2024 Annual Report of Guarantee of Payment of Deferred Premium 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 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 ML24129A1482024-05-0707 May 2024 and Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Casks with Applied Changes 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 IR 05000528/20244012024-04-22022 April 2024 Security Baseline Inspection Report 05000528/2024401 and 05000529/2024401 and 05000530/2024401 (Cover Letter) IR 05000528/20243012024-04-22022 April 2024 NRC Initial Operator Licensing Examination Approval 05000528/2024301, 05000529/2024301, and 05000530/2024301 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) ML24089A1892024-03-28028 March 2024 Present Levels of Financial Protection ML24068A2522024-03-0808 March 2024 License Amendment Request to Revise Technical Specifications 3.5.1 and 3.5.2 Using Risk-Informed Process for Evaluations 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 IR 05000528/20240122024-03-0404 March 2024 Age-Related Degradation Inspection Report 05000528/2024012, 05000529/2024012 and 05000530/2024012 IR 05000528/20230062024-02-28028 February 2024 Annual Assessment Letter for Palo Verde Nuclear Generating Station, Units 1, 2 and 3 Report 05000528/2023006 and 05000529/2023006 and 05000530/2023006 ML24053A3972024-02-22022 February 2024 License Renewal - Alloy 600 Management Program Plan ML24047A3632024-02-16016 February 2024 Independent Spent Fuel Storage Installation - Registration of Dry Spent Fuel Transportable Storage Canisters Identification Numbers AMZDFX177, AMZDFX178, AMZDFX179 Vertical Concrete Cask Identification No. AMZDNE179, AMZDNE178 IR 05000528/20230042024-02-12012 February 2024 Integrated Inspection Report Report 05000528/2023004 and 05000529/2023004 and 05000530/2023004 ML24019A2012024-01-19019 January 2024 Fourth 10-Year Interval, Second Period Owners Activity Report Number 1R24 ML24019A1362024-01-18018 January 2024 Inservice Inspection Request for Information ML24012A2452024-01-12012 January 2024 Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML24010A1532024-01-10010 January 2024 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection ML23341A0062023-12-21021 December 2023 Project Manager Assignment IR 05000528/20230112023-12-18018 December 2023 License Renewal Inspection Report 05000528/2023011 ML23335A0782023-11-30030 November 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23325A1602023-11-17017 November 2023 Supplemental Submittal - Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20234032023-11-13013 November 2023 NRC Security Inspection Report 05000528 2023403, 05000529 2023403, 05000530 2023403 (Full Report) ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23299A3052023-10-26026 October 2023 Response to Request for Additional Information Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20230032023-10-17017 October 2023 Integrated Inspection Report 05000528 2023003 and 05000529 2023003 and 05000530 2023003 ML23270B9232023-09-28028 September 2023 Notification of Age-Related Degradation Inspection (05000528/2024012, 05000529/2024012, and 05000530/2024012) and Request for Information 2024-08-08
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10 CFR 50.90 4 L f A subsidiaryof PinnacleWest CapitalCorporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Senior Vice President Tel. 623-393-5403 P. O. Box 52034 Generating Station Nuclear Regulatory and Oversight Fax 623-393-6077 Phoenix, Arizona 85072-2034 102-06604-DCM/CJS October 11,2012 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission 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 Response to Request for Additional Information Regarding License Amendment Request to Eliminate the Use of the Term CORE ALTERATION in the Technical Specifications By letter number 102-06486, dated March 8, 2012 [Agencywide Documents Access arid Management System (ADAMS) Accession No. ML12076A045], Arizona Public Service Company (APS) requested an amendment to the Technical Specifications (TS) that are incorporated as Appendix A to Renewed Facility Operating License Nos. NPF-41, NPF-51, and NPF-74, for PVNGS Units 1, 2, and 3, respectively. The proposed license amendment request (LAR) would eliminate the use of the term CORE ALTERATIONS throughout the TSs consistent with Technical Specification Task Force (TSTF) Traveler 471-A, Revision 1, "Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes."
By letter dated September 11, 2012 (ADAMS Accession No. ML12250A720), the Nuclear Regulatory Commission (NRC) provided a request for additional information (RAI) to support the NRC staff review. The APS response to the RAI is provided in the Enclosure to this letter.
No commitments are being made to the NRC by this letter.
By copy of this letter, this LAR RAI response is being forwarded to the Arizona Radiation Regulatory Agency (ARRA) pursuant to 10 CFR 50.91 (b)(1).
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway 0 Comanche Peak
- South Texas 0 Wolf Creek CL
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to Request for Additional Information Regarding License Amendment Request to Eliminate the Use of the Term CORE ALTERATION in the Technical Specifications Page 2 Should you need further information regarding this LAR, please contact Robert K.
Roehler, Licensing Section Leader, at (623) 393-5241.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on (Date)
Sincerely, DCM/RKR/CJS/hsc Enclosure - Response to Request for Additional Information Regarding License Amendment Request to Eliminate the Use of the Term CORE ALTERATION in the Technical Specifications cc: E. E. Collins Jr. NRC Region IV Regional Administrator L. K. Gibson NRC NRR Project Manager for PVNGS M. A. Brown NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA)
T. Morales Arizona Radiation Regulatory Agency (ARRA)
ENCLOSURE Response to Request for Additional Information Regarding License Amendment Request to Eliminate the Use of the Term CORE ALTERATION in the Technical Specifications NRC Request The proposed REQUIRED ACTION A.1 of TS 3.9.2 states that with one startup range monitor (SRM) inoperable, the operator is required to suspend positive reactivity additions.
This REQUIRED ACTION is inconsistent with guidance in TS 3.9.2 of NUREG-1432, Revision 4, "Standard Technical Specifications, Combustion Engineering," April 2012 (STS)
(ADAMS Accession No. ML12102A165). For Condition A of TS 3.9.2 of the STS, the REQUIRED ACTION states that if one required SRM is inoperable, the operators are required to suspend immediately: (A. 1) positive reactivity additions, and (A.2) introduction of coolant into the reactor coolant system (RCS) with boron concentration less than required to meet the minimum boron concentration of limiting condition for operation (LCO) 3.9.1.
The proposed TS 3.9.2 does not adopt REQUIRED ACTION A.2 as stated above.
Suspending introduction of coolant inventory from sources that have a boron concentration less than that what would be required in the RCS for minimum refueling boron concentration could prevent the boron dilution event from occurring.
Please address the acceptability of the proposed TS 3.9.2 without inclusion of the REQUIRED ACTION A.2 specified in STS 3.9.2. In particular, please explain what is captured by "suspend positive reactivity additions" for Palo Verde.
APS Response The proposed TS 3.9.2 does not adopt REQUIRED ACTION A.2, as this ACTION in the STS is the result of TSTF-286, entitled Define "operationsInvolving Positive Reactivity Additions,"
which has not been implemented at PVNGS. TSTF-286 was developed to provide operational flexibility, while also limiting any potential for excess positive reactivity additions.
Specifically, most TS Actions that required suspension of operations involving positive reactivity additions were revised in the TSTF-286 to only limit the introduction into the RCS of reactivity more positive than that required to meet the required shutdown margin (SDM) or refueling boron concentration.
The TS Actions that preclude positive reactivity changes and/or reduction in boron concentration are ensuring either no power increases, or continued margin to core criticality operations. During conditions in which these TS Actions may be required, various unit operations must continue. RCS inventory must be maintained, and RCS temperature must be controlled.
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Response to Request for Additional Information Regarding License Amendment Request to Eliminate the Use of the Term CORE ALTERATION in the Techniical Specifications These operational activities may involve additions to the RCS of cooler water (a positive reactivity effect in most cases) and may involve inventory makeup from sources that are al:
boron concentrations less than RCS concentration. As stated in TSTF-286 these operational activities should not be precluded if the worst-case overall effect on the core would still assure adequate SDM or the required refueling boron concentration is maintained. Thus, TSTF-286, REQUIRED ACTION A.2 of TS 3.9.2, reflected in the STS, is an Action that provides greater operational flexibility, while controlling minimum boron concentration.
The APS proposed REQUIRED ACTION, A.1, Suspend positive reactivity additions, and its COMPLETION TIME of immediately ensures that the sources of positive reactivity additions are suspended. The PVNGS LAR does not include the latitude provided by TSTF-286 to introduce coolant into the RCS with boron concentrations below the existing RCS boron concentration, but above the minimum boron concentration of LCO 3.9.1, which is specified in the Core Operating Limits Report (COLR).
TS 3.9.2 applies in MODE 6 only (i.e., at least one reactor vessel head closure bolt less than fully tensioned). In this mode of operation, what is captured by "suspend positive reactivity additions" includes evolutions that may noticeably degrade the existing SDM, even if there is margin between the existing SDM and the minimum SDM requirements. The following types of evolutions would be suspended, if in progress at the time of LCO 3.9.2, Condition A, entry:
" Withdrawal of control element assemblies (CEAs) from the reactor core
- Movement of fuel assemblies (either irradiated or non-irradiated) either over or into the reactor vessel
- Movement of neutron sources (PVNGS does not currently have neutron sources installed in the reactor vessel)
- Changes in shutdown cooling system alignments, such as heat exchanger bypass valve position, which would create a cooldown of the RCS water temperature, as defined in operating procedures
- Changes in the plant that would decrease RCS boron concentration by more than the inherent uncertainty in boron measurements This would not preclude makeup from a borated water source (RVVT, SFP) that has at least the same boron concentration as the RCS, nor would it exclude minor plant evolutions, under administrative controls, for removal of an item from the refueling pool and cleaning or decontamination of that item with small quantities of demineralized water. In addition, it would not preclude the completion of the movement of a component or assembly to a safe position, as described in the TS 3.9.2 Bases.
In conclusion, the APS proposed LCO 3.9.2, Action A.1, which requires suspension of positive reactivity additions, includes suspension of the introduction of coolant into the RCS with boron concentration less than the existing RCS boron concentration. The LAR provides confidence that boron concentrations will be controlled, and is more restrictive than TSTF-286.
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