ML20141H746
| ML20141H746 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/18/1997 |
| From: | ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | |
| Shared Package | |
| ML17312B589 | List: |
| References | |
| NUDOCS 9708010157 | |
| Download: ML20141H746 (760) | |
Text
{{#Wiki_filter:- - - _ _ _ . . . _ _ . _ . _ _ . _ _ _ - - _ - . _ _ - - _ _ - - - - - - - - - _ _ _ _ - _ _ - - - - - - - - _ _ _ - - - - - _ _ _ _ _ _ - - - _ _ _ - - - - 4 mme gN PVNGS ITS 3.4.17 RCS SPECIFIC ACTIVITY I
*G ISSUE # DOC #
or CTS /STS REF DESCRIPTION OF ISSUE PVNGS RESPONSES:. Od JFD # t c m j New - - N/A ITS Bases B 3.4.17. "RCS Specific Activity," Applicable ;
$$8 issue Safety Analysis, includes a discussion of plant operation e with RCS dose equivalent iodine-131 activity levels above the LCO limit but below the limits of Figure 3.4.17-1, as allowed by ITS LCO 3.4.17 Action A. The Revision A ITS Bases, which utilized the NUREG-1432 Bases B 3.4.16, stated that "The occurrence of an SGTR accdent at these permissible levels could increase the site boundary dose levels, but still be within 10 CFR 100 dose guideline -
limits." The PVNGS safety analyses do not support that i statement. Instead, ITS Bases has been revised in i Revision B to reflect the PVNGS current licensing bases, CTS Bases 3/4.4.7, by stating "The allowable limits shown , I on Figure 3.4.17-1 accommodate possible iodine spiking phenomenon which may occur following changes in ! THERMAL POWER." i .i I i I
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c_ _ _ _ .._..._ _ _ _ . _ . _ _ _ . . _ - - - _ - _ _ _ _ _ _ _ _ _ _ . l PVNGS l Palo Verde Nuclear Generating Station ! Units 1, 2, and 3 ' j Improved Technical Specifications k } l I
ITS REVIEW PAbKAGE CONTENTS JVolume 93 r I / CJD 3.4.1 J l we; , 5 Smooth Copy i ITS Bases .
's No Significant Hazards ;
Consideration 1 I Discussionof Changes Smooth Copy r Jens 1 CTS Markup ITS Spec.fications
- i. means NUREG Exceptions !
- NUREG Bases Markup NUREG Spec Markup l 3 ty taie-.4 g -
e JEMB U&$.* U l WSJ ; Additional sections of CJD's (Collection of Justification Documentation) are added as necessary to complete the specific ITS ,
- Section/ Chapter.
ITS REVIEW PACisAGE CONTENTS (Volume 10, continued from Volume 9) CJD 3.4.7 - 3.4.17 i i 6;*T , J l 1%Ett t J ! Mk t No Significant Hazards Consideration i Discussion of Changes CTS Markup NUREG Exceptions NUREG Bases Maricsp NUREG Spec Markup r Additional sections of CJD's (Coffection of Justification Docurnentation) are added as necessary to complete the specJic ITS Section/ Chapter.
l
~
l PVNGS ITS I SECTION 3.4 - REACTOR COOLANT SYSTEM (RCS) l l l
l I , i 1 1 4 i r b l l 1 l l t i SMOOTH COPY ! ITS SECTION 3.4 I l I l l l l l l I I l I l l I l G l
RCS Pressure. Temperature, and Flow DNB Limits 3.4.1 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 RCS Pressure. Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits LCO 3.4.1 RCS DNB parameters for pressurizer pressure, cold leg temperature, and RCS total flow rate shall be within the limits specified below:
- a. Pressurizer pressure a 2130 psia and s 2295 psia; and
- b. RCS cold leg temperature (T c
) shall be within the area of acceptable operation shown in Figure 3.4.1-1: and
- c. RCS total flow rate 2155.8 E6 lbm/ hour.
APPLICABILITY: MODE 1 for RCS total flow rate. MODES 1 and 2 for pressurizer pressure. MODE 1 for RCS cold leg temperature (Tc). MODE 2 with K,,, = 1 for RCS cold leg temperature (Tc).
-----------------------------NOTE----------------------------
Pressurizer pressure limit does not apply during:
- a. THERMAL POWER ramp > 5% RTP per minute: or
- b. THERMAL POWER step > 10% RTP.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RCS flow rate not A.1 Restore RCS flow rate 2 hours within limit. to within limit. B. Required Action and B.1 Be in MODE 2. 6 hours associated Completion Time of Condition A not met. PALO VERDE UNITS 1.2.3 3 :s b : REV. B
RCS Pressure. Temperature, and Flow DNB Limits 3.4.1 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME C. Pressurizer pressure C.1 Restore parameter (s) 2-hours or RCS cold leg to within limits. temperature not within limits. D. Required Action and D.1 Be in MODE 3. 6 hours associated Completion Time of Condition C not met. SURVEILLANCE REQUIREMENTS i SURVEILLANCE. FREQUENCY SR 3.4.1.1 Verify pressurizer pressure a 2130 psia and 12 hours s 2295 psia. SR 3.4.1.2 Verify RCS cold leg temperature within 12 hours limits as shown in Figure 3.4.1-1.
------------------NOTE------------------ l Required to be met in MODE 1 with j all RCPs running. l 12 hours SR 3.4.1.3 Verify RCS total flow rate
= 155.8 E6 lbm/ hour.
k 3 a t PALO VERDE UNITS 1,2,3 3.4.1-2 REV. B
i ! l , l RCS Pressure. Temperature, and Flow DNB Limits I 3.4.1 l l Figure 3.4.1-1 l Reactor Coolant Cold Leg Temperature vs. Core Power Level l l l l l l l l l l l l l 570 (30,568)
,u. 570 -
uf
$ 565 565 -
(100,560) l g 560 m, 560 - l 3 ammataomm)? l 550 '^ - ' ' ' 550 - o O 545 - 545 - l 540 l 0
- 10 20 30 40 50 60 70 80 90 100 l
CORE POWER LEVEL,% OF RATED THERMAL POWER (3876 MW) REACTOR COOLANT COLD LEG TEMPERATURE vs. CORE POWER LEVEL 4 l PALO VERDE UNITS 1,2,3 3.4.1 3 REV. B l l t . l l
I RCS Minimum Temperature for Criticality ) 3.4.2 j i 3.4 REACTOR-COOLANT SYSTEM (RCS) 3.4.2 -RCS Minimum Temperature for Criticality LCO 3.4.2 Each RCS loop temperature (T co jo) shall be a 545 F. APPLICABILITY: MODE 1. MODE 2 with K,r, a 1.0. ACTIONS j CONDITION REQUIRED ACTION COMPLETION TIME l l A. i n one or more A.1 Be in MODE 3. 30 minutes ; T red' loops not within I limit. ) l i SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1- Verify RCS Tcoia in each loop a 545'F. ------NOTE----- Only required if any RCS loop Tcoi, < 550 F. 30 minutes AND Once within 30 minutes prior to reaching criticality PALO VERDE UNITS 1.2.3 3.4.2-1 REV. A
, . . . . - -. ~. - .- - .- - _ . . . _ = . - _ . - .
RCS P/T Limits ' , 3.4.3 l l 3.4 REACTOR COOLANT SYSTEM (RCS) 1 i 3.4.3 RCS Pressure and Temperature (P/T) Limits LC0 3.4.3 RCS pressure. RCS temperature, and RCS heatup and cooldown ; l rates shall be limited in accordance with the limits shown + in Figures 3.4.3-1 or 3.4.3-2 during heatup. cooldown l criticality, and inservice leak and hydrostatic testing with:
- a. Maximum heatup and cooldown !
specified in Table 3.4.3-1.
- b. A maximum temperature change of 10*F in any 1-hour period during '
inservice hydrostatic testing operations. ; APPLICABILITY: At all times; exce)t when reactor vessel head is fully detensioned such t1at the RCS cannot be pressurized. ; ACTIONS ; CONDITION REQUIRED ACTION . COMPLETION TIME , i A. ---------NOTE--------- A.1 Restore parameter (s) 30 minutes ! Required Action A.2 to within limits. ' shall be completed . whenever this AND Condition is entered. A.2 Determine RCS is 72 hours acceptable for Requirements of LCO continued operation. not met in MODE 1, 2.
- 3. or 4.
B. Required Action and B.1 Be in MODE 3. 6 hours l associated Completion : Time of Condition A AND not met. B.2 Be in MP'E J 5 with 36 hours ; RCS prcssure
< 500 psia. ;
i (continued) l l PALO VERDE UNITS 1.2.3 3.4.3-1 REV. A
l RCS P/T Limits 3.4.3 ACTIONS (continued) CONDITION REQUIRED ACTION l COMPLETION TIME i l C. ---------NOTE--------- C.1 Initiate action to Immediately Required Action C.2 restore parameter (s) I shall be completed to within limits. whenever this Condition is entered. AND l 1 C.2 Determine RCS is Prior to l l Requ;remcats of LCO acceptable for entering MODE 4 not met any time in continued operation. Other than MODE 1, 2, 3 or 4. l l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 - -----------------NOTE-------------------- Only required to be performed duri ,9 RCS heatup and cooldown operations r;a RCS
, inservice leak and hydrostatic cesting.
Verify RCS pressure RCS temperature, and 30 minutes RCS heatup and cooldown rates within i limits specified in Table 3.4.3-1, and i Figures 3.4.3-1 and 3.4.3-2. l l-t i i I a PALO VERDE UNITS 1,2,3 3.4.3-2 REV. A
. . _ _ _. _ __. _ __ _ . _ _ . . ~ . _ - . _ . . _ . . __ . . _ _ . _ .
4 RCS P/T Limits 3.4.3 TABLE 3.4.3-1 i- Maximum Allowable Heatuo and Cooldown Rates 2
<8 Fffective Full Power Years i Heatup Cooldown
- T" c (*F) Rate ( F/HR) Tc " ( F) Rate (*F/HR) j < 128 F 20*F/HR s 93 F See Figure 3.4.3-3 128"F - 180*F 30*F/HR 94 F - 114 F- 10*F/HR ,
i 181 - 230 F 50*F/HR 115 F - 148 F 20 F/HR
> 230*F 75 F/HR > 148 F 100 F/HR 8-32 Effective Full Power Years Heatup Cooldown !
1 T" c (*F) Rate ( F/HR) T"c ( F) Rate (*F/HR)
< 116*F 10 F/HR s 108 F See Figure 3.4.3-4 117*F - 150 F 20*F/HR- 109* - 126*F 10 F/HR
]
151 - 199 F' 30*F/HR 127*F - 147 F 20 F/HR 200*F - 246*F 50 F/HR 148"F - 162 F 40 F/HR l
> 246 F 75*F >162 F 100*F/HR 1
- Indicated Cold Leg Temperature PALO VERDE UNITS 1.2.3 3.4.3-3 REV. A
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1 1 J l RCS P/T Limits 3.4.3 Figure 3.4.3 3 Maximum Allowable Cooldown Rates
< 8 EFPY l
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0 80 90 93 Tc - INDICATED RCS TEMPERATURE ( F) PALO VERDE UNITS 1,2,3 3.4.3 6 REV. B
- RCS P/T Limits 3.4.3
- Figure 3.4.3 4 Maximum Allowable Cooldown Rates 8 32 EFPY i
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2 g - i 80 90 100 108 i INDICATED RCS TEMPERATURE, T c, F pal.0 VERDE UNITS 1.2,3 3.4.3 7 REV. B i
- RCS Loops-MODES 1 and 2 -
3.4.4 4 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.4 RCS Loops-MODES 1 and 2 LCO 3.4.4 Two RCS loops shall be OPERABLE and in operation. 1 I j APPLICABILITY: MODES 1 and 2. j t ACT20NS . \ 4 CONDITION REQUIRED ACTION COMPLETION TIME ! I ! A. Requirements of LCO A.1 Be in MODE 3. 6 hours l
- not met.
i l l j
- SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY i
l SR 3.4.4.1 Verify each RCS loop is in operation. 12 hours i i J d 5 l l l PALO VERDE UNITS 1.2.3 3.4.4-1 REV. A
L i RCS Loops-MODE 3 [ -1
'3.4.5 3.4 ' REACTOR COOLANT SYSTEM (RCS)
'3.4.5 RCS Loops-MODE 3 LC0 3.4.5 Two RCS loops shall be OPERABLE and one RCS loop shall be in operation. -)
i
----------------------------NOTE-----------------------------
All reactor coolant pumps may be de-energized for s 1 hour per 8 hour period, provided:
- a. No o rrations are permitted that would cause reduction l of tie RCS boron concentration: and.
- b. Core outlet temperature is maintained at least 10 F i below saturation temperature. J APPLICABILITY: MODE 3. l i
ACTIONS I l CONDITION REQUIRED ACTION COMPLETION TIME t A. One required RCS loop A.1 Restore required RCS 72 hours ' inoperable. loop to OPERABLE status, i
)
B. Required Action and B.1 Be in MODE 4. 12 hours ) associated Completion i Time of Condition A not met. l (continued) l i f PALO VERDE UNITS 1.2.3 3.4.5-1 REV. A
i ! , RCS Loops-MODE 3 j 3.4.5 i ) ACTIONS (continued) j CONDITION REQUIRED ACTION COMPLETION TIME l 1 l L C. No RCS loop OPERABLE. C.1 Suspend all Immediately operations involving 4 QR a reduction of RCS boron concentration.
.No RCS loop in operation. AND C.2 Initiate action to Immediately 1 restore one RCS loop i to OPERABLE status and operation.
l 1 SURVEILLANCE REQUIREMENTS I SURVEILLANCE FREQUENCY SR 3.4.5.1 Verify required RCS loop is in operation. 12 hours ) 4 SR 3.4.5.2 Verify secondary side water level in each 12 hours j steam generator = 25%. SR 3.4.5.3 Verify correct breaker alignment and 7 days l indicated power available *o the required 1 pump that is not in operation. J l PALO VERDE UNITS 1.2.3 3.4.5-2 REV. A
. . -. ~ ,. -
_ _ ~ _ . . _ _ . . . _ _ _ . _ _ . _ _ . _ . . _ . _ _ . _ . _ . _ _ _ _ _ _ _ _ . . _ t
.t r.
- RCS Loops-MODE 4 l- . 3.4.6 l
3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Loops -MODE 4 LCO 3.4.6 Two loops or trains consisting of any combination of RCS loops and shutdown cooling (SDC) trains shall be OPERABLE l and at least one loop or train shall be in operation. _; i
----------------------------NOTES---------------------------
- 1. All reactor coolant pumps (RCPs) and SDC pumps may be de-energized for s 1 hour per 8 hour period, provided:
- a. No operations are permitted that would cause reduction of the RCS boron concentration; and
- b. Core outlet temperature is maintained at least 10 F below saturation temperature l 2. No RCP shall.be started with any RCS cold leg l temperature s 214"F during cooldown or s 291 F during l
heatup, unless the secondary side water temperature in-each Steam Generator (SG) is < 100*F above each of the RCS cold leg temperatures. l l 3. No more than 2 RCPs may be in operation with RCS cold leg temperature 5 200 F. No more than 3 RCPs may be in
- operation with RCS cold leg temperature > 200*F but s 500*F.
APPLICABILITY: MODE 4. ACTIONS i CONDITION REQUIRED ACTION COMPLETION TIME l A. One required RCS loop A.1 Initiate action to Immediately inoperable. restore a second loop or train to OPERABLE N AN) status. Two SDC trains l inoperable. (continued) e l PALO VERDE UNITS 1.2.3 3.4.6-1 REV. B
l RCS Loops-MODE 4 ! 3.4.6 l ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME L B. One required SDC train B.1 Be in MODE 5. 24 hours inoperable. , r . AND l L Two required RCS loops I inoperable. . l I l 1 C. No RCS loop or SDC C.1 Suspend all Imediately 1 train OPERABLE. operations involving 1 l reduction of RCS l QR boron concentration. No RCS loop or SDC AND train in operation. C.2 Initiate action to Imediately restore one loo) or train to OPERAB.E . status and operation. l l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1 Verify one RCS loop or SDC train is in 12 hours operation. l l SR 3.4.6.2 Verify secondary side water level in 12 hours required SG(s) is = 25%. ; 1 l \ l (continued) l i i PALO VERDE UNITS 1.2.3 3.4.6-2 REV. A
l RCS Loops-MODE 4 3.4.6 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY l SR 3.4.6.3 Verify correct breaker alignment and 7 days indicated power available to the required pump that is not in operation. l l I l l I r F PALO VERDE UNITS 1.2.3 3.4.6-3 REV. A
RCS Loops-MODE 5. Loops Filled 3.4.7 i 3.4 REACTOR COOLANT SYSTEM (RCS) ; i 3.4.7 RCS Loops-MODE 5. Loops F1lled , i i LCO 3.4.7 One Shutdown Cooling (SDC) train shall be OPERABLE and in operation, and either: I
- a. One additional SDC train shall be OPERABLE: or. ;
- b. The secondary side water level of each Steam Generator i (SG) shall be a 25%. j
----------------------------NOTES--------------------------- !
- 1. The SDC pump of the train in operation may be 1 de-energized for s 1 hour per 8 hour period provided:
- a. No operations are permitted that would cause l reduction of the RCS boron concentration: and I
l b. Core outlet temperature is maintained at least 10*F below saturation temperature. l l l ' u
- 2. One required SDC train may be inoperable for up to 1 2 hours for surveillance testing provided that the other SDC train is OPERABLE and in operation, i
- 3. No Reactor Coolant Pump (RCP) shall be started with one
! or more of the RCS cold leg temperatures s 214 F during cooldown, or s 291 F during heatup unless the secondary side water temperature in each SG is < 100 F above each of the RCS cold leg temperatures.
- 4. No more than 2 RCPs may be in operation with RCS cold
-leg temperature s 200 F. No more than 3 RCPs'may be in operation with RCS cold leg temperature > 200*F but s 500*F.
- 5. All SDC trains may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation.
I APPLICABILITY: MODE 5 with RCS loops filled.
~
P b L PALO VERDE UNITS 1.2.3 3.4.7 1 REV. B I l l
RCS Loops--MODE 5. Loops Filled , 3.4.7 l ACTIONS l CONDITION R'EQUIRED ACTION COMPLETION TIME. : l A. One SDC train A.1 Initiate action to Immediately l inoperable, restore a second SDC ! train to OPERABLE : ! AND status, t l Any SG with secondary QR : i side water level not i i within limit. A.2 Initiate action to Immediately 1 restore SG secondary l l side water levels to l within limits. 1 1 I B. Required SDC train B.1 Suspend all- Immediately i inoperable. operations involving reduction in RCS
,08 boron concentration.
No SDC train in .A_ND l operation. B.2 Initiate action to Immediately restore one SDC train to OPERABLE status and operation.
~ , , .
i PALO VERDE UNITS 1,2,3 3.4.7-2 REV. A
RCS Loops-MODE 5. Loops Filled 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.1 Verify one SDC train is in operation. 12 hours SR 3.4.7.2 Verify required SG secondary side water 12 hours
. level is a: 25%.
l i 1
-SR 3.4.7.3 Verify correct breaker alignment and 7 days j indicated )ower available to the required l l SDC pump tlat is not in operation. ;
i l I 1 I I ! l i ! 1 1 ; I l l i l l t l l PALO VERDE UNITS 1.2.3 3.4.7-3 REV. A i . l i
l RCS Loops-MODE 5, Loops Not Filled 3.4.8 l i 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 RCS Loops-MODE 5. Loops Not Filled LCO 3.4.8 Two Shutdown Cooling (SDC) trains shall be OPERABLE and one SDC train shall be in operation.
....--------NOTES--------------------------- i
- 1. All SDC pu ps may be de-energized for s 1 hour per 8 !
hour perio :
- a. The core outlet temperature is maintained > 10 F below saturation temperature;
- b. No operations are permitted that would cause a reduction of the RCS boron concentration: and j l c. No draining operations to further reduce the RCS water volume are permitted. I
- 2. One SDC train may be inoperable for s 2 hours for i surveillance testing provided.the other SDC train is J OPERABLE and in operation.
j APPLICABILITY: MODE 5 with RCS loops not filled. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One SDC train A.1 Initiate action to Immediately ! inoperable. restore SDC train to OPERABLE status. i (continued) 1
- i i
b l 4 l
- i. PALO VERDE UNITS 1.2.3 3.4.8-1 REV. A I- - _ _ __, __ _. _ , . _ _ __ ___
I RCS Loops-MODE 5, Loops Not Filled i 3.4.0' ACTIONS (continued) l CONDITION REQUIRED ACTION COMPLETION TIME B. Required SDC trains B.1 Suspend all Imediately j inoperable. operations involving ! reduction of RCS 08 boron concentration. ! No SDC train in AND l operation. B.2 Initiate action to Immediately restore one SDC train to OPERABLE status j and operation. 1 l l SURVEILLANCE REQUIREMENTS l SURVEILLANCE FREQUENCY
- SR 3.4.8.1 Verify one SDC train is in operat' ion. 12 hours I
SR 3.4.8.2 Verify correct breaker alignment and 7 days indicated )ower available to the required SDC pump tlat is not in operation. l l 1 PALO VERDE UNITS 1.2.3 3.4.8-2 REV. B
. - - - - _ - . . - -. _ ~ - . - - . .. . . . . . ... - . -
E l l Pressurizer 3.4.9 ; i 3.4 REACTOR COOLANT SYSTEM (RCS) ; f 3.4.9 Pressurizer 3 LC0 3.4.9 The pressurizer shall be OPERABLE with: i
- a. Pressurizer water level a 27% and s 56%: and
- b. Two groups of pressurizer heaters OPERABLE with the capacity of each group = 125 kW and capable of being ,
powered from an emergency power supply. APPLICABILITY: MODES 1. 2. and 3.
-----------------------------NOTE----------------------------
The pressurizer water level limit does not apply during:
- a. THERMAL POWER ramp > 5% RTP per minute: or
- b. THERMAL POWER step > 10% RTP. .
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l l
. A. Pressurizer water A.1 Be in MODE 3 6 hours ;
l level not within with reactor ' l limit. trip breakers [ open. i AND A.2 Be in MODE 4. 12 hours B. One required group of B.1 Restore required 72 hours pressurizer heaters group of pressurizer inoperable. heaters to OPERABLE status. e (continued) 5 I f PALO VERDE UNITS 1.2.3 3.4.9-1 REV. B ! l i i l
2 Pressurizer l 3.4.9 I l ACTIONS (continued) , CONDITION' REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours associated Completion Time of Condition B AND not met. C.2 Be in MODE 4. 12 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY I l SR 3.4.9.1 Verify pressurizer water 7evel is a 27% and 12 hours ! s 56%. l SR 3.4.9.2 Verify capacity of each required group of 92 days 1
- pressurizer heaters a 125 kW.
l l l i PALO VERDE UNITS 1.2.3 3.4.9-2 REV. A
! Pressurizer Safety Valves-MODES 1. 2. and 3 l 3.4.10 l' 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Pressurizer Safety Valves - Modes 1. 2 and 3 LC0 3.4.10 Four pressurizer safety valves shall be OPERABLE with lift i settings a: 2450.25 psia and 5 2549.25 psia. l APPLICABILITY: MODES 1. 2. and 3.
-----------------------------NOTE---------------------------
The lift settings are not required to be within LC0 limits l during MODES 3 and 4 for the purpose of setting the l pressurizer safety valves under ambient (hot) conditions. This exception is allowed for 72 hours following entry into MODE 3 provided a preliminary cold setting was made prior to heatup. ACTIONS-CONDITION REQUIRED ACTION COMPLETION TIME A. One pressurizer safety A.1 Restore valve to 15 minutes ! valve inoperable. OPERABLE status. B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time not met. AJN 08 B.2 Be in MODE 4 12 hours Two or more pressurizer safety valves inoperable.
-l l
i 1 ! l l PALO VERDE UNITS 1.2.3 3.4.10-1 REV. A s
I Pressurizer Safety Valves-MODES 1. 2 and 3
- 3.4.10 SURVEILLANCE REQUIREMENTS
' SURVEILLANCE FREQUENCY SR 3.4.10.1 Verify each pressurizer safety valve is In accordance OPERABLE in accordar:ce with the Inser'.' ice with the Testing Program. Following testing, lift Inservice settings shall be within i 1%. Testing Program l ,
t l l t l l I l i i i i I PALO VERDE UNITS 1.2.3 3.4.10-2 REV. A
Pressurizer Safety Valves-MODE'4 3.4.11 j 3.4 REACTOR COOLANT SYSTEM (RCS) ! i j 3.4.11 Pressurizer Safety Valves-MODE 4 ' i LC0 3.4.11 One pressurizer safety valve shall be OPERABLE with a lift I setting a 2450.25 psia and s 2549.25 psia. t APPLICABILITY: MODE 4 with all RCS cold leg temperatures > 214 F during cooldown, or 3 l , MODE 4 with all RCS cold leg temperatures >. 291 F during heatup. t
..... ___... ......____...... NOTE----------------------------
The lift settings are not required to be within LC0 limits during MODES 3 and 4 for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. This exception is allowed for 72-hours following entry into MODE 3-provided a preliminary cold setting was made prior to I heatup. ' ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME l A. All pressurizer safety A.1 Be in MODE 4 with Immediately valves inoperable. one Shutdown Cooling System suction line relief valve in service. AND A.2 Perform SR 3.4.11.2 Immediately and SR 3.4.11.3 for the required Shutdown Cooling System suction line relief valve to comply with Action A.1. AND A.3 Be in MODE 4 with 8 hours all RCS cold leg temperatures s 214 F during cooldown or s 291'F during heatup. PALO VERDE UNITS 1.2.3 3.4.11-1 REV. B
i Pressurizer Safety Valves-MODE 4 3.4.11
- SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 Verify the required pressurizer safety In accordance valve is OPERABLE in accordance with the with the ,
j Inservice Testing Program. Following Inservice i i testing. lift settings shall be within Testing Program i 1%. i l i SR 3.4.11.2 --------------------NOTE------------------- 12 hours for Only required to be performed when a unlocked. not Shutdown Cooling System suction line relief sealed or valve is being used for overpressure otherwise not protection. secured open pathway vent valve (s) Verify the required Shutdown Cooling System suction line relief valve aligned to AND 3rovide overpressure protection for the RCS. 31 days for locked, sealed, or otherwise secured open pathway vent valve (s) SR 3.4.11.3 Verify the required Shutdown Cooling System In accordance suction line relief valve OPERABLE with the with the required setpoint. Inservice Testing Program PALO VERDE UNITS 1.2.3 3.4.11-2 REV. A
1 Pressurizer Vents l 3.4.12 i 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Pressurizer Vents ! LC0 3.4.12 Four pressurizer vent paths shall be OPERABLE. l 1 APPLICABILITY: MODES 1. 2. 3. and MODE 4 with RCS pressure a 385 psia.
> ACTIONS -
V i l L CONDITION REQUIRED ACTION COMPLETION TIME l A. Two or three required A.1 Restore required 72 hours i l' pressurizer vent paths pressurizer vent ' inoperable. paths to OPERABLE status. _l J B. All pressurizer vent B.1 Restore one 6 hours , paths inoperable. pressurizer vent path ! to OPERABLE status.
.l' C. Required Action and C.1 Be in MODE 3. 6 hours-associated Completion Time of Condition A. bM or B not met.
l C.2 Be in MODE 4 with RCS 24 hours pressure < 385 psia. l l l ! SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Perform a complete cycle of each 18 months Pressurizer Vent Valve. i SR 3.4.12.2 Verify flow through each 18 months
- pressurizer vent path. ;
~
l. j PALO VERDE UNITS 1.2.3 3.4.12-1 REV. A
- LTOP System i
3.4.13 i 3.4 REACTOR COOLANT' SYSTEM (RCS) i
- 3.4.13 Low Temperature Overpressure Protection (LTOP) System '
n LCO 3.4.13 An LTOP System shall be OPERABLE consisting of: ! a. Two OPERABLE Shutdown Cooling System suction line relief l valves with lift settings s 467 asig aligned to provide 1 overpressure protection for the RCS: or 4
- b. The RCS depressurized and an RCS vent of j a.16 square inches. -
.__.____---NOTE----------------------------
No RCP shall'be started unless the. secondary side water l . tem)erature in each steam generator (SG) is s 100 F above [ eac1 of the RCS cold leg temperatures. APPLICABILITY: MODE 4 when any RCS cold leg temperature is s 214 F during i cooldown, MODE 4 when any RCS cold leg temperature is s 291 F during heatup, MODE 5. - MODE 6 when the reactor vessel head is on.
----------------------------NOTE----------------------------
When one or more cold legs reach 214*F. this LCO remains applicable during periods of steady state temperature conditions until all RCS cold leg temperature reach 291 F. If a cooldown is terminated prior to reaching 214 F and a heatup is commenced, this LC0 is applicable until all RCS cold leg temperatures reach 291 F. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 1
------------NOTE------------ l A. -One required Shutdown LC0 3.0.4 is not applicable Cooling System suction ----------------------------
line relief valve ) inoperable in MODE 4. A.1 Restore required 7 days Shutdown Cooling System suction line relief valve to OPERABLE status. (continued) l PALO VERDE UNITS 1.2.3 3.4.13-1 REV. B
, __ . . . . . ~ . -. .. _. - -. -..._ .-. ~._ - - _. - . . . ...-.- .- . - LTOP System t 3.4.13 ACTIONS / continued) ; l. CONDITION REQUIRED ACTION COMPLETION TIME l B. One required Shutdown B.1 Restore. required 24 hours Cooling System suction Shutdown Cooling line relief valve System suction line inoperable in MODE 5 relief valve to or 6. OPERABLE status. C. Two required Shutdown C.1 Depressurize RCS and 8 hours . Cooling System suction establish RCS vent of line relief valves a 16 square inches. inoperable. 03 l Required Action and ! associated Completion Time of Condition A, or B not met. l < l 4 1 i i l i I PALO VERDE UNITS 1,2,3 3.4.13-2 REV. A l l
)
LTOP System ' 3.4.13 SURVEILLANCE FREQUENCY l l l SR 3.4.13.1 Verify RCS Vent = 16 square' inches is 12 hours for unlocked, not open. sealed, or otherwise not secured open vent pathway (s) AND 31 days for l locked, sealed, or otherwise , l secured open vent pathway (s) SR 3.4.13.2 Verify each Shutdown Cooling System 12 hours for 1 suction line relief valve aligned to unlocked, not : 3rovide overpressure protection for the sealed, or RCS. otherwise not secured open pathway vent valve (s) AND 31 days for locked, sealed, or otherwise secured open pathway vent valve (s). i SR 3.4.13.3 Verify each Shutdown Cooling System In accordance suction line relief valve OPERABLE with with the the required setpoint. Inservice Testing Program, l i i l l l PALO VERDE UNITS 1,2,3 3.4.13-3 REV. A i
,. - , , + , , . -
RCS Operational LEAKAGE l 3.4.14 l i l 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.14 RCS Operational LEAKAGE i 1 i LC0 3.4.14 RCS operational LEAKAGE shall be limited to: ; i a .- No pressure boundary LEAKAGE: '
- b. 1 gpm unidentified LEAKAGE: 1 1
- c. 10 gpm identified LEAKAGE:
- d. 1 gpm total primary to ' secondary LEAKAGE through all steam generators (SGs); and,
- e. 720 gallons per day primary to secondary LEAKAGE through any one SG.
APPLICABILITY: MODES 1. 2. 3. and 4. ACTIONS , I CONDITION REQUIRED ACTION COMPLETION TIME i A. RCS LEAKAGE not within A.1 Reduce LEAKAGE to 4 hours limits for reasons within limits. Other than pressure boundary LEAKAGE. B. Required Action and B.1 Be in MODE 3. 6 hours i associated Completion ! Time of Condition A MQ i not met. B.2 Be in MODE- 5. 36 hours E l Pressure boundary LEAKAGE exists. l C. One or more SGs C.1 Enter 3.0.3. Immediately inoperable. 1 I l PALO VERDE. UNITS 1.2.3 3.4.14-1 REV. A
RCS Operational LEAKAGE 3.4.14 SURVEILLANCE REQUIREMENTS SURVEILLANCE FRE0VENCY SR 3.4.14.1 -------------------NOTE-------------------- -----NOTE------ Not required to be performed in MODE 3 or 4 Only required until 12 hours of steady state operation. to be performed
------------------------------------------- during steady state operation Perform RCS water inventory balance. 72 hours SR 3.4.14.2 Verify SG tube integrity is in accordance In accordance with the Steam Generator Tube Surveillance with the Steam Program. Generator Tube Surveillance Program PALO VERDE UNITS 1.2.3 3.4.14-2 REV. A )
; RCS PIV Leakage 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) j .
3.4.15 RCS Pressure Isolation Valve (PIV) Leakage
- LC0 3.4.15 Leakage from each RCS PIV shall be within limits. *
~ APPLICABILITY: MODES 1. 2. and 3. MODE 4. except valves in the shutdown cooling (SDC) flow
- path when in, or during the transition to or from, the l SDC mode of operation.
j ' ACTIONS -
- -------------------------------------NOTES------------------------------------
- 1. Separate Condition entry is allowed for each flow path.
[ i 2. Enter a)plicable Conditions and Required Actions for systems made inopera)le by an inoperable PIV. 4 1 CONDITION REQUIRED ACTION COMPLETION TIME ____________ NOTE------------- i' A. One or more flow paths Each valve used to satisfy with leakage from one- Required Action A.1 and or more RCS PIVs not required Action A.2 must within limit have been verified to meet
- SR 3.4.15.1 and be on the i RCS pressure boundary.
A.1 Isolate the high 4 hours pressure portion of the affected system from the low pressure portion by use of one closed manual. deactivated automatic, or check valve. AND A.2 Restore RCS PIV to 72 hours within limits (continued) PALO VERDE UNITS 1.2.3 3.4.15-1 REV. A
RCS PIV Leakage 3.4.15 ACTIONS (Continued) CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion Time for Condition A AND not met. B.2 Be in MODE 5. 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 -------------------NOTES-------------------
- 1. Not required to be performed in MODES 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the SDC flow path when in the shutdown cooling mode of ,
operation.
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than !
once if a repetitive testing loop cannot be avoided. Verify leakage from each RCS PIV is 18 months equivalent to s 0.5 gpm per nominal inch of AND valve size up to a maximum of 5 gpm at an RCS pressure a: 2230 psia and s 2270 psia. Prior to entering MODE 2 l whenever the ! unit has been in MODE 5 for 7 days or more, 1 if leakage ; testing has not ; been performed ! in the previous 9 months, except for SDC PIVs AM (continued) PALO VERDE UNITS 1.2.3 3.4.15-2 REV. A
RCS PIV Leakage
- 3.4.15 SURVEILLANCE REQUIREMENTS (Continued)
[ SURVEILLANCE FREQUENCY a p SR 3.4.15.1 (continued) Within 24 hours
- following valve i actuation due to automatic or manual action i or flow through j the valve, except for SDC PIVs.
3 i SR 3.4.15.2 Verify SDC System open permissive interlock 18 months prevents the valves from being opened with a simulated or actual RCS pressure signal a 410 psia.
~
I
. 1 l
l l PALO VERDE UNITS 1.2.3 3.4.15-3 REV. A r .- - ~ --. - % - .
RCS Leakage Detection Instrumentation l 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Leakage Detection Instrumentation , 1 LCO 3.4.16 Both of the following RCS leakage detection instrumentation i shall be OPERABLE:
- a. One containment sump monitor: and l
- b. One containment atmosphere radioactivity monitor (gaseous and particulate).
l l APPLICABILITY: MODES 1, 2. 3. and 4. ACTIONS l 1 CONDITION REQUIRED ACTION COMPLETION TIME
------------NOTE------------
A. Required containment LCO 3.0.4 is not applicable. sump monitor ---------------------------- inoperable. A.1 Perform SR 3.4.14.1. Oncs per 24 hours AND A.2 Restore containment 30 days sum) monitor to OPERABLE status. (continued) 1 I I PALO VERDE UNITS 1.2.3 3.4.16-1 REV. B
1 1 RCS Leakage Detection Instrumentation j 3.4.16 i ACTIONS (continued) i CONDITION REQUIRED ACTION COMPLETION TIME
------------NOTE------------
- B. Required containment LC0 3.0.4 is not applicable.
- atmosphere ----------------------------
! radioactivity monitor i inoperable. B.1.1 Analyze grab samples Once per
- of the containment 24 hours-atmosphere.
l QB - I . i B.1.2 Perform SR 3.4.14.1. Once per ! 24 hours i AND ! i B.2 Restore required 30 days containment 4 atmosphere ! radioactivity ' monitor to OPERABLE : status. l' i C. Required Action and C.1 Be in MODE 3. 6 hours !. associated Completion
- Time not met. AND I C.2 Be in MODE 5. 36 hours
- D. All required monitors D.1 Enter LCO 3.0.3 Immediately
, inoperable. F SURVEILLANCE REQUIREMENTS 4
- SURVEILLANCE FREQUENCY
/I [ SR 3.4.16.1 Perform CHANNEL CHECK of the required 12 hours I containment atmosphere radioactivity j monitor, i-SR 3.4.16.2 Perform CHANNEL FUNCTIONAL TEST of the 92 days i recuired containment atmosphere i racioactivity monitor. i 4 ] (continued) 1 i PALO VERDE UNITS 1.2.3 3.4.16-2 REV. B i i e e n - n- , , - , - . - - - , . . , , . ,, - .r., e
RCS Leakage Detection Instrumentation 3.4.16 SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY-SR 3.4.16.3 Perform CHANNEL CALIBRATION of the required 18. months containment sump monitor. SR 3.4.16.4 Perform CHANNEL CALIBRATION of the required 18 months containment atmosphere radioactivity monitor. l 1 i i j PALO VERDE UNITS 1.2.3' 3.4.16-3 REV. A
RCS Specific Activity l_ 3.4.17 I 3.'4 REACTOR COOLANT SYSTEM (RCS) ! 3.4.17 RCS Specific Activity LC0 3.4.17 The specific activity of the reactor coolant shall be within limits. APPLICABILITY: MODES 1 and 2. MODE 3 with RCS cold leg temperature (Teo w) = 500 F. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT I-131 ----------------NOTE----------
> 1.0 pC1/gm. LC0 3.0.4 is not applicable.
A.1 Verify DOSE Once per EQUIVALENT I-131 within 4 hours the acceptable region of Figure 3.4.17-1. AND A.2 Restore DOSE EQUIVALENT I-131 to within 48 hours limit. (continued) PALO VERDE UNITS 1,2,3 3.4.17-1 REV. A
_ . _ _ - - . _ . _ _ . . . . . . . _ _ _ . . . -.. ._. . . . . _ . . . ~ _ . _ _ _ . _ _ . _ . _ . . . _ RCS Specific Activity - 3.4.17 j i ACTIONS (continued) , i _. . CONDITION REQUIRED ACTION COMPLETION TIME I 1 \ l B. Required Action and B.1 Be in MODE 3 with 6 hours i associated Completion Tcoi, < 500 F. l l Time of Condition A l not met. l l 08 ) DOSE EQUI'.'ALENT I-131 ) in the unacceptable ' region of Figure 3.4.17-1. C. Gross specific C.1 Perform SR 3.4.17.2. 4 hours f activity of the reactor coolant not AND l within limit. ! C.2 Be in MODE 3 with 6 hours
- Tcoio < .500*F.
l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify reactor coolant gross specific 7 days ! activity 5 100/E yC1/gm. i i i l (continued) i l 8 PALO VERDE UNITS 1.2.3 3.4.17-2 REV. A i
I RCS Specific Activity ; 3.4.17 ; i SURVEILLANCE REQUIREMENTS (continued)
-. . SURVEILLANCE FREQUENCY !
SR 3.4.17.2 Verify reactor coolant DOSE -------NOTE------ EQUIVALENT I-131 specific activity Only required to : s 1.0 pCi/gm. be performed in , MODE 1. i 14 days I
\
AND 1 1 Between 2 and 6 hours after THERMAL POWER change , of a 15% RTP within I a 1 hour period SR 3.4.17.3 ------------------NOTE--------------- Not required to be performed until 31 days after a minimum of 2 EFPD and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for a 48 hours. Determine E from a sample taken in 184 days , MODE 1 after a minimum of 2 EFPD and 1 20 days of MODE 1 operation have i' elapsed since the reactor was last subcritical for a 48 hours. I j I 1 l 1 PALO VERDE UNITS 1.2.3 3.4.17-3 REV. A , l I
l I i i l RCS Specific Activity ; 1 3.4.17 1 I J
- X ..- 4... . . . .,.. , . .
s x . . . . . . .
'.x l
}" 250 -
. 1 .
. i
. . i .
k . . .
- v. t . . . . . . .... ..., . ,,
j \ . J
. . ...x . . . . . . . . .
l X . . . . L
\
l
> \
, p:200 l \g l u UNACCEPTABLE l " X e . . . . OPERATION l 2 u,. .
... x w- ...
Q ' . N ... 1
. e .
E . 1 . .
** ... .v. . . . . ..
IE 150 . \ . . l
..s . .
t
. . .. 1
. ... g.
j . - i .... 4 . se. , .... . . . .. , j y ,
. .. . .. .. xi . .. ,
e... , i, it.i .... E -
... ... . .y . .
P
.... ... . . u .,, . .
G *
. .1
\ .
6.100 . . . . . . .' . ' .' . . ... . . . , g. E -
. . . . ... .., . ... . ... s.
. .4 . . . .... . . . . . . . s.
l g . i e.e.
.x. , , .
g . . , , , . . , i .
... . . . . ,g, ,
t
> . 4 ... ..ai . , , ,
. .x .. .
2 ACCEPTABLE - . . i . . . ....s i 5 go OPERAT30N :: . . .' . . .. l 3 I - .. . . , e W [ . 6 t . 8 0 20 30 40 50 80 70 80 90 100 PERCENT OF RATED THERMAL POWER Figure 3.4.171 (page 1 of 1) Reactor Coolant DOSE EQUIVALENT I 131 Specific Activity Limit ! Versus Percent of RATED THERMAL POWER With Reactor Coolant i Specific Activity > 1.0 pC1/gm DOSE EQUIVALENT I 131 s l PALO VERDE UNITS 1.2.3 3.4.17 4 REV. B
I I l ! l 1 i I l
\
i SMOOTH COPY ; 1 ITS SECTION 3.4 - BASES i l i l I l s I l r w
RCS Pressure. Temperature. and Flow DNB Limits - B.3.4.1 B 3.4 REACTOR COOLANT SYSTEM (RCS) ! B 3.4.1 RCS Pressure. Temperature, and Flow Departure from. Nucleate Boiling , (DNB) Limits BASES , b BACKGROUND These Bases address requirements for maintaining RCS pressure, temperature, and flow rate within limits assumed in the safety analyses. The safety analyses (Ref. 1) of , normal operating conditions and anticipated operational i ! occurrences assume initial conditions within the normal l steady state envelose. The limits placed on DNB related l parameters ensure t1at these parameters will not be less : conservative than were assumed in the analyses and thereby > 3rovide assurance that the minimum Departure from Nucleate 3 oiling Ratio (DNBR) will meet the required criteria for each of the transients analyzed. l The LC0 limits for minimum and maximum RCS pressures as measured at the pressurizer are consistent with operation within the nomir.al operating envelope and are bounded by those used as the initial pressures in the analyses. The LC0 limit for minimum and maximum RCS cold leg temperatures are in accordance sith the area of acceptable operation shown in Figure 3.4.1-1. are consistent with o>eration at the indicated power level, and are bounded by tiose used as~the initial temperatures in the analyses. The LCO limit for minimum RCS flow rate is bounded by those used as the initial flow rates in the analyses. The RCS flow rate is not expected to vary during plant operation l with all pumps running. i , APPLICABLE The requirements of LCO 3.4.1 represent the initial SAFETY ANALYSES conditions for DNB limited transients analyzed in the safety analyses (Ref. 1). The safety analyses have shown that transients initiated from the limits of this LCO will meet the DNBR criterion of = 1.3. This is the acceptance limit for the RCS DNB parameters. Changes to the facility that could impact these parameters must be assessed for their impact on the DNBR criterion. (continued) l PALO VERDE UNITS 1.2.3 B 3.4.1-1 REV. A
RCS Pressure. Temperature, and Flow DNB Limits , B 3.4.1 i l BASES l l APPLICABLE The transients analyzed for include loss of coolant flow l l SAFETY ANALYSES events and dropped or stuck Control Element Assembly (CEA) ! i (continued) events. A key assumption for the analysis of these events ' i is that the core power distribution is within the limits of , ? LC0 3.1.7, " Regulating CEA Insertion Limits".: LCO 3.1.8. / "Part Length CEA Insertion Limits": LC0 3.2.3, " AZIMUTHAL i POWER TILT (T )": and LC0 3.2.5, " AXIAL SHAPE INDEX (ASI). 1 The safety an,alyses are performed over.the following range l l of initial values: RCS pressure 2105-2320 psia, core inlet !' l temperature 548-572 F and reactor vessel inlet coolant flow l rate > 95%.
.l
, The RCS DNB limits satisfy Criterion 2 of 10 CFR l 50.56(c)(2)(ii). r LCO This LC0 specifies limits on the monitored process ! variables-RCS pressurizer pressure. RCS cold leg I temperature, and RCS total flow rate-to ensure that the l core operates within the limits assumed for the plant safety ) analyses. Operating within these limits will result in i meeting the DNBR criterion in the event of a DNB limited ' transient. The LC0 numerical value for minimum flow rate is given for the measurement location but has not been adjusted for instrument error. Plant specific limits of instrument error are established by the plant staff to meet the operational l requirements of minimum flow rate. APPLICABILITY In MODE 1 for RCS flow rate, MODES 1 and-2 for RCS pressurizer pressure. Mode 1 for RCS cold leg temperature, and MODE 2 with K,,, > 1 for RCS cold leg temperature, the limits must be maintained during steady state operation in ;
- order to ensure that DNBR criteria will be met in the event l of an unplanned loss of forced coolant flow or other DNB limited transient. In all other MODES, the power level is low enough so that DNBR is not a concern. !
l l (continued) PALO VERDE UNITS 1,2,3 B 3.4.1-2 REV. B
RCS Pressure Temperature, and Flow DNB Limits B 3.4.1 . BASES i r - APPLICABILITY A Note has been added to indicate the limit on pressurizer (continued) pressure may be exceeded during short term operational transients such as a THERMAL POWER ramp increase of > 5% RTP per minute or a THERMAL POWER step increase of > 10% RTP. ' These conditions represent short term perturbations where actions to control pressure variations might be counterproductive, Also, DNBR margin exists to offset the l temporary pressure variations / Another set of limits on DNB'related parameters is provided in Safety Limit (SL) 2.1.1 " Reactor Core Safety Limits." ; Those limits are less restrictive than the limits of this l LCO, but violation of SLs merits a stricter, more severe L Required Action. Should a violation of this LC0 occur, the l operator should check whether or not an SL may have been j exceeded. l l l L ACTIONS M l l RCS flow rate is not a controllable parameter and is not l expected to vary during steady state operation. If the flow l rate is not within the LC0 limit then power must be ! reduced, as required by Required Action B.1, to restore DNB - margin and eliminate the potential for violation of the accident analysis bounds.
- The 2 hour Completion Time for restoration of RCS flow rate provides sufficient time to determine the cause of the off normal condition. and to restore the readings within limits.
The Completion Time is based on plant operating experience. M If Required Action A.1 is not met within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 2 within 6 hours. In MODE 2. the reduced power condition eliminates the potential for violation of the accident analysis bounds. l
- - (continued) l
- PALO VERDE UNITS 1.2.3 B 3.4.1-3 REV. A
+- y n y --
-m e- m- n , -w w
i l
- RCS Pressure. Temperature, and Flow DNB Limits l i
B 3.4.1 i r ! ! l BASES i ACTIONS fL1 (continued) l Six hours is a reasonable time that permits the plant power i to be reduced at an orderly rate in conjunction with even control of Steam Generator (SG) heat removal. L1 Pressurizer pressure and cold leg temperature are I , controllable and measurable parameter (s). If a parameter is not within the LCO limits, action must be taken to restore the parameter. The 2 hour Completion Time is based on plant operating experience that shows that these parameter (s) can be restored in this time period. [L1 If Required Action C.1 is not met within the associated I l Completion Time, place the plant in MODE 3. In MODE 3 the l potential for violation of the DNB limits is greatly reduced. The 6 hour Completion Time is a reasonable time that 3ermits power reduction at an orderly rate in conjunction wit 1 even i control of SG heat removal. l l l l l (continued) PALO VERDE UNITS 1.2.3 B 3.4.1-4 REV. A
. - - - .- . - - - -.- - . ,. - - - - - . - . ~ - . . . . - . - - - ..
I e RCS Pressure. Temperature and Flow DNB Limits . B 3.4.1 . l . I BASES (continued) ! SURVEILLANCE SR 3.4.1.1 ' REQUIREMENTS Since Required Action C.1 allows a Completion Time of i 2 hours to restore parameters that are not within limits, , l the 12 hour Surveillance Frequency for pressurizer pressure
- is sufficient to ensure that the pressure can be restored to l a normal operation, steady state condition following load
- changes and other expected transient operations. The- ;
! 12 hour interval has been shown by operating practice to be j sufficient to regularly assess for potential degradation and - l verify operation is within safety analysis assumptions. i l l SR 3.4.1.2 l l Since Required Action C.1 allows a Completion Time of l 2 hours to restore parameters that are not within limits. . l the 12 hour Surveillance Frequency for cold leg temperature is sufficient to ensure that the RCS coolant temperature can ' be restored to a normal operation, steady state condition t j following load changes and other expected tratsient ' l operations. The 12 hour interval has been sh(wn by operating practice to be sufficient to regularly assess for i L potential degradation and to verify operation .s within
~
safety analysis assumptions. 1 i l SR 3.4.1.3 l l The 12 hour Surveillance Frequency for RCS total flow rate is )erformed using the installed flow instrumentation. The ] l 12 lour Frequency has been shown by operating experience to l be sufficient to assess for potential degradation and to verify operation is within safety analysis assumptions. This SR is modified by a Note that orly requires performance ; of this SR in MDDE 1. The Note is necessary to allow i l measurement of RCS flow rate at normal operating conditions at power with all RCPs running. REFERENCES 1. UFSAR, Section 15, 1 1 i n PALO VERDE. UNITS 1.2.3 B 3.4.-1-5 REV. A
l l i RCS Minimum Temperature for Criticality ; B 3.4.2 l l B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.2 RCS Minimum Temperature for Criticality I BASES BACKGROUND Establishing the value for the minimum temperature for reactor criticality is based upon considerations for:
- a. Operation within the existing instrumentation ranges and accuracies:
- b. Operation within the bounds of the existing accident analyses: and
- c. Operation with the reactor vessel above its minimum nil ductility reference temperature when the reactor is critical.
The reactor coolant moderator temperature coefficient used ! in core operating and accident analysis is typically defined for the normal operating temperature range (550 F to 611 F). i NominalT'do for making Safety an operating the reactor analyses for lowercritical is 565*F. temperature have not been made. APPLICABLE There are no accident analyses that dictate the minimum i SAFETY ANALYSES temperature for criticality, but all low power safety ' I analyses assume initial temperatures near the 545 F limit (Ref. 1). The RCS minimum temperature for criticality satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). LCO The purpose of the LC0 is to prevent criticality below the I minimum normal operating temperature (550 F) and to prevent l l operation in an unanalyzed condition. ; i a 1.0 The and LC0 is only provides applicable indistance a reasonable MODES to 1 and 2 withofK,7$45 F. the limit This allows adequate time to trend its a3proach and take ' corrective actions prior to exceeding the limit. (continued) pal's VERDE UNITS 1.2.3 8 3.4.2-1 REV. A l
l l RCS Minimum Temperature for Criticality l B 3.4.2 l l BASES (continued) l l l APPLICABILITY The reactor has been designed and analyzed to be critical in MODES 1 and 2 only and in accordance with this speci fication. Criticality is not permitted in any other MODE. Therefore, this LCO is applicable in MODE 1. and a 1.0. Monitoring is required at or below a MODE 2 when K,,,The no load temperature of 565 F is l Tocoj of 550 F. l maintained by the Steam Bypass Control System. l l l ACTIONS .A_l If T is below 545 F the plant' must be brought to a MODE l inwffi'chtheLCOdoesnotapply. To achieve this status, l the plant must be brought to MODE 3 within 30 minutes. Ra)id reactor shutdown can be readily and practically aclieved within a 30 minute period. The allowed time , reflects the ability to perform this action and to maintain the plant within the analyzed range. , i l SURVEILLANCE SR 3.4.2.1 REQUIREMENTS T i is required to be verified a 545*F once within 38 ominutes after any RCS loop Tcojo < 550 F and every l 30 minutes thereafter. The 30 minute time period is frequent enough to prevent inadvertent violation of the LCO. A Note states the Surveillance is required whenever the reactor is critical and temperature is below 550 F. A second Frequecy requires coiT , to be verified within 30 minutes of reaching criticality. This will require repeated performance of SR 3.4.2.1 since a reactor startup takes longer than 30 minutes. The 30 minute time period is frequent enough to prevent inadvertent violation of the LCO. REFERENCES 1. UFSAR. Section 15. I l l PALO VERDE UNITS 1.2.3 B 3.4.2-2 REV. A
__ ____..m . _ - . . - ._ _.. _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ l RCS P/T Limits I B 3.4.3 ! B 3.4 REACTOR COOLANT SYSTEM (RCS) f B 3.4.3 RCS~ Pressure and Temperature (P/T) Limits BASES BACKGROUND All components of the RCS are designed to withstand effects of cyclic loads due to system pressure and temperature changes. These loads are introduced by startup (heatup) and , shutdown (cooldown) o)erations, power transients, and reactor trips. This _C0 limits the pressure and temperature : l changes during RCS heatup and cooldown, within the design ) j assumptions and the stress limits for cyclic operation. j l Each P/T limit curve defines an acceptable region for normal operation. The usual use of the curves is operational guidance during heatup or cooldown maneuvering, when pressure and temperature indications are monitored and ; compared to the applicable curve to determine that operation is within the allowable region. . The LCO establishes operating limits that provide a margin i to brittle failure of the reactor vessel and piping of the Reactor Coolant Pressure Boundary (RCPB). The vessel is the component most subject to brittle failure, and the LC0 limits apply mainly to the vessel. The limits do not apply to the pressurizer, which has different design characteristics and operating functions, ' 10 CFR 50 Appendix G (Ref. 1), requires the establishment i of P/T limits for material fracture toughness requirements ! of the RCPB materials. Reference 1 requires an adequate 1 margin to brittle failure during normal operation, anticipated operational occurrences, and system hydrostatic tests. It mandates the use of the ASME Code. Section III, Appendix G (Ref. 2).
- The actual shift in the RTem of the vessel material will be established periodically by removing and evaluating the l irradiated reactor vessel material specimens, in accordance with ASTM E 185 (Ref. 3) and Appendix H of 10 CFR 50 (Ref. 4). The operating P/T limit curves will be adjusted, as necessary, based on the evaluation findings and the recommendations of Reference 2.
i i (continued) l i PALO VERDE UNITS 1.2.3 8 3.4.3-1 REV. A
e f RCS P/T Limits B 3.4.3 l BASES
. BACKGROUND The P/T limit curves are composite curves established by (continued) superimposing limits derived from stress analyses of those portions of the reactor vessel and head that are the most ;
2 restrictive. At any specific pressure, temperature, and - 4 temperature rate of change, one location within the reactor vessel will dictate the most restrictive limit. Across the i span of the P/T limit curves, different locations are more restrictive, and, thus, the curves are coinposites of the
- most restrictive regions.
!~ The heatup curve represents a different set of restrictions .l j- than the cooldown curve because the directions of the thermal gradients through the vessel wall are reversed. The thermal gradient reversal alters the location of the tensile stress between the outer and inner walls. The criticality limit includes the Reference 1 requirement that the limit be no less than 40"F above the heatup curve or the cooldown curve and not less than the minimum permissible temperature for inservice leak and hydrostatic (ISLH) testing. However, the criticality limit is not operationally limiting: a more restrictive limit exists in 1 LC0 3.4.2. "RCS Minimum Temperature for Criticality." The consequence of violating the LCO limits is that the RCS has been operated under conditions that can result in brittle failure of the RCPB. possibly leading to a nonisolable leak or loss of coolant accident. In the event these. limits are exceeded, an evaluation must be performed to determine the effect on the structural integrity of the RCPB components. The ASME Code. Section XI. Appendix E (Ref. 5). provides a recommended methodology for evaluating an operating event that causes an excursion outside the limits. APPLICABLE The P/T limits are not derived from Design Basis Accident SAFETY ANALYSES (DBA) Analyses. They are prescribed during normal operation < to avoid encountering pressure, temperature, and temperature ) rate of change conditions that might cause undetected flaws 1 to propagate and cause nonductile failure of the RCPB. an unanalyzed condition. (continued) i PALO VERDE UNITS 1.2.3 B 3.4.3-2 REV. A
RCS P/T Limits : B 3.4.3 i BASES-APPLICABLE Since the P/T limits are not derived from ' SAFETY-ANALYSES any DBA there are no acceptance limits related to the P/T ! (continued) limits. Rather, the P/T limits are acceptance limits themselves since they preclude operation in an unanalyzed ! condition. , The RCS P/T limits satisfy Criterion 2 of 10 CFR i 50.36(c)(2)(ii). LCO The two elements of this LC0 are: l
- a. The limit curves for heatup, cooldown, and ISLH !
testing; and
- b. Limits on the rate of change of temperature.
The LC0 limits apply to all components of the RCS except i the pressurizer. l These limits define allowable operating regions and permit a large number of operating cycles while providir.g a wide margin to nonductile failure. 1 The limits for the rate of change of temperature control the
, thermal gradient through the vessel wall and are used as inputs.for calculating the heatup, cooldown, and ISLH testing'P/T limit curves. Thus.-the LC0 for the rate of change of temperature restricts stresses caused by thermal gradients and also ensures the validity of the P/T-limit curves.
l' Violating the LC0 limits places the reactor vessel outside of the bounds of the stress analyses and can increase ! stresses in other RCPC components. The consequences depend { on several factors, as follows: -
- a. The severity of the departure from the allowable :
o)erating P/T regime or the severity of the rate of u clange of temperature; ;
- b. The length of time the limits were violated (longer violations allow the temperature gradient in the thick vessel walls to become more pronounced); and i
{ (continued) 1 PALO VERDE UNITS 1.2.3 B 3.4.3-3 REV. A l l l . . _ . . .
RCS P/T Limits l B 3.4.3 ! i j BASES i l LC0 c. The existences, sizes, and orientations of flaws in l (continued) the vessel material. i APPLICABILITY The RCS P/T limits Specification provides a definition of I acceptable operation for prevention of nonductile failure in ( accordance with 10 CFR 50 Appendix G (Ref. 2). Although ; the P/T limits were developed to provide guidance for ! operation during heatu or cooldown (MODES 3. 4. and 5) or i ISLH testing, their Ap licability is at all times, except ; when reactor vessel he d is fully detensioned such that the ; RCS cannot be pressurized in keeping with the concern for ; nonductile failure. The limits do not apply to the : I pressurizer. l \ \ During MODES 1 and 2. other Technical Specifications provide I limits for operation that can be more restrictive than or i can supplement these P/T limits. LC0 3.4.1, "RCS Pressure. l Temperature, and Flow Departure from Nucleate Boiling (DNB) ; Limits": LCO 3.4.2. "RCS Minimum Temperature for i Criticality": and Safety Limit 2.1, " Safety Limits." also. I provide operational restrictions for pressure and I temperature and maximum pressure. Furthermore. MODES 1 ; l and 2 are above the temperature range of concern for i nonductile failure, and stress analyses have been performed for normal maneuvering profiles, such as power ascension or descent. The actions of this LCO consider the premise that a violation of the limits occurred during normal plant maneuvering. Severe violations caused by abnormal i ! transients, at times accompanied by equipment failures, may also require additional actions from emergency operating procedures. 1 ACTIONS A.1 and A.2 0)eration outside the P/T limits must be corrected so that t7e RCPB is returned to a condition that has been verified by stress analyses. 1 (continued) ? PALO VERDE UNITS 1.2.3 B 3.4.3-4 REV. A
l RCS P/T Limits B 3.4.3 I BASES 1 ACTIONS A.1 and A.2 (continued) The 30 minute Completion Time reflects the urgency of restoring the parameters to within the analyzed range. Most violations will not be severe, and the activity can be accomplished in this time in a controlled manner. l Besides restoring operation to within limits, an evaluation . l is required to determine if RCS operation can continue. The evaluation must verify the RCPB integrity remains acceptable and must be completed before continuing operation. Several methods may be used, including comparison with pre-analyzed transients in the stress analyses, new analyses, or inspection of the components. ASME Code Section XI, Ap)endix E (Ref. 5), may be used to support the evaluation. iowever, its use is restricted to ! i evaluation of the vessel beltline. l i l l The 72 hour Completion Time is reasonable to accomplish the evaluation. The evaluation for a mild violation is possible within this time. but more severe violations may require special. event specific stress analyses or inspections. A favorable evaluation must be completed before continuing to operate. ;
- Condition A is modified by a Note requiring Required i
Action A.2 to be completed whenever the Condition is entered. The Note emphasizes the need to perform the . evaluation of the effects of the excursion outside the ! allowable limits. Restoration alone per Recuired Action A.1 ! is insufficient because higher than analyzec stresses may l l have occurred and may have affected the RCPB integrity. ' ! B.1 and B.2 If a Required Action and associated Completion Time of l Condition A are not met, the plant must be placed in a lower i MODE because:
- a. The RCS remained in an unacceptable P/T region for an extended period of increased stress; or (continued) l PALO VERDE UNITS 1,2,3 B 3.4.3-5 REV. A
1 l RCS P/T Limits l B 3.4.3 . 1 BASES l l ACTIONS B.1 and B.2 (continued) , b. A sufficiently severe event caused entry into an f unacceptable region. , Either possibility indicates a need for more careful I examination of the event, best ' accomplished with the RCS at reduced pressure and temperature. With reduced pressure and temperature conditions, the possibility of propagation of undetected -flaws is decreased. L Pressure and tem)erature are reduced by. placing the plant in i MODE 3 within 6 lours and in MODE 5 with RCS pressure
< 500 psia within 36 hours.
! The Completion Times are reasonable, based on operating l experience, to reach the required plant conditions from full 1 power conditions in an orderly manner and without l challenging plant systems, i l C.1 and C.2 The actions of this LCO, anytime other than in MODE 1, 2, 3. l or 4 consider the premise that a violation of the limits occurred during normal plant maneuvering. Severe violations caused by abnormal transients, at times accompanied by equipment failures, may also require additional ~ actions from , emergency operating procedures. Operation outside the P/T l limits must be corrected so that tie-RCPB is returned to a condition that has been verified by stress analyses.
- The Completion Time of "immediately" reflects the urgency of l
restoring the parameters to within the analyzed range. Most l violations will not be severe, and the activity can be
- accomplished in a short period of time in a controll.ed i manner.
i l l i f (continued) PALO VERDE UNITS 1.2.3 B 3.4.3-6 REV. A
RCS P/T Limits i B 3.4.3 BASES ACTIONS C.1 and C.2 (continued) Besides restoring operation to within limits, an evaluation is required to determine if RCS operation can continue. The evaluation must verify that the RCPB integrity remains i' acceptable and must be completed before continuing operation, Several methods may be used, including comparison with pre-analyzed transients in the stress
- analyses, new analyses, or inspection of the components.
ASME Code. Section XI Ap)endix E-(Ref. 5). may be used to support the evaluation. iowever, its use is restricted to j evaluation of the vessel beltline. I The Completion Time of prior to entering MODE 4 forces the evaluation prior to entering a MODE where temperature and pressure can be significantly increased. The evaluation for a mild violation is possible within several days, but more j severe violations may require special, event specific stress [ analyses or inspections. Condition C is modified by a Note requiring Required Action C.2 to be completed whenever the Condition is entered. The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Recuired Action C.1 u is insufficient because higher than analyzec stresses may i have occurred and may have affected the RCPB integrity. SURVEILLANCE SR 3.4.3.1 ; REQUIREMENTS Verification that operation is within limits is required ) l every 30 minutes when RCS pressure and temperature conditions are undergoing planned changes. This Frequency is considered reasonable in view of the control room indication available to monitor RCS status. Also, since temperatur. rate of change limits are specified in hourly increments 4 minutes permits assessment and correction for minor devi within a reasonable time. Surveilla ." heatup cooldown, or ISLH testing may be discontinus the definition given in the relevant plant procedure f , jing the activity is satisfied.
- . (continued)
PALO VERDE UNITS 1.2.3 B 3.4.3-7 REV. A i
RCS P/T Limits i B 3.4.3 BASES SURVEILLANCE SR 3.4.3.1 (continued) REQUIREMENTS This SR is modified by a Note that requires this SR be performed only during RCS system heatup, cooldown, and ISLH-testing. No SR is given for criticality operations because LCO 3.4.2 contains a more restrictive requirement. REFERENCES 1. 10 CFR 50, Appendix G.
- 2. ASME, Boiler and Pressure Vessel Code, Section III.
Appendix G.
- 3. ASTM E 185-82. July 1982.
- 4. 10 CFR 50, Appendix H.
- 5. ASME. Boiler and Pressure Vessel Code, Section XI.
Appendix E. l 1 l l 4 PALO VERDE UNITS 1.2.3 B 3.4.3-8 REV. A
RCS Loops-MODES 1 and 2 l B 3.4.4 - I F B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.4 RCSl Loops-MODES 1 and 2 BASES \ l BACKGROUND The primary function of the RCS is removal of the heat generated in the fuel due to the fission process and ! transfer of this heat, via the steam generators (SGs), to the secondary plant. The secondary functions of the RCS include: ;
- a. Moderating the neutron energy level to the thermal .
state, to increase the probability of fission:
- b. Improving the neutron economy by acting as a reflector -
- c. Carrying the soluble neutron poison, boric acid;
- d. Providing a second barrier against fission product ,
release to the environment; and
- e. Removing the heat generated in the fuel'due to fission
- product decay following a unit shutdown.
The RCS configuration for heat transport uses two RCS loops. I Each RCS loop contains a SG and two Reactor Coolant Pumps !
- (RCPs). An RCP is located in each of the two SG cold legs.
- The pump flow rate has been sized to provide core heat !
removal with appropriate margin to Departure from Nucleate i Boiling (DNB) during power operation and for anticipated i transients originating from power operation. This Specification requires two RCS loops with both RCPs in operation in each loop. The intent of the Specification is to require core heat removal with forced flow during power operation. S)ecifying two RCS loops provides the minimum i necessary patas (two SGs) for heat removal, i i APPLICABLE Safety analyses contain various assumptions for the Design SAFETY ANALYSES Bases Accident (DBA) initial conditions including RCS pressure. RCS temperature, reactor power level. core '
)
parameters, and safety system setpoints. The important (continued) PALO VERDE UNITS 1.2.3 8 3.4.4-1 REV. A
RCS Loops-MODES 1 and 2 B 3.4.4 i BASES
- APPLICABLE aspect for this LCO is the reactor coolant forced flow rate.
SAFETY ANALYSES which is represented by the number of RCS loops in service. (continued) Both transient and steady state analyses have been performed ' to establish the effect of flow on DNB. The transient or l accident analysis for the plant has been performed assuming four RCPs are in operation. The majority of the plant safety analyses are based on initial conditions at high core power or zero )ower. The accident analyses that are of most
- importance to RCP operation are the four pump coastdown. l l single pum coastdown)p locked
, and rotor single rod withdrawal pump(Ref.
events (broken 1). shaft or Steady state DNB analysis had been performed for the four aump combination. For four pum) operation, the steady state
)NB analysis, which generates tie pressure and temperature and Safety Limit (i.e., the departure from nucleate boiling ratio (DNBR) limit) assumes a maximum power level of 107% RTP. This is the design overpower condition for four pump operation. The 107% value is the accident analysis i setpoint of the nuclear overpower (high flux) tria and is !
based on an analysis assumation that bounds possi)le instrumentation errors. T1e DNBR limit defines a locus of 3ressure and temperature points that result in a minimum JNBR greater than or equal to the critical heat flux correlation limit. RCS Loops-MODES 1 and 2 satisfy Criteria 2 and 3 of 10 CFR 50.36 (C)(2)(ii). LCO The purpose of this LCO is to require adequate forced flow for core heat removal. Flow is represented by having both RCS loops with both RCPs in each loop in operation for removal of heat by the two SGs. To meet safety analysis acceptance criteria for DNB. four pumps are required at rated power. Each OPERABLE loop consists of two RCPs providing forced flow for heat transport to an SG that is OPERABLE in accordance with the Steam Generator Tube Surveillance l Program. SG. and hence RCS loop. OPERABILITY with regard to l l SG water level is ensured by the Reactor Protection System j (RPS) in MODES 1 and 2. A reactor trip places the plant in 1 l (continued) 1 PALO VERDE UNITS 1.2.3 B 3.4.4-2 REV. A ; l . _. - . _ -.
RCS Loops-MODES 1 and 2 B 3.4.4 BASES LCO MODE 3 if any SG level is s 44% wide range level as sensed - (continued) by the RPS. The minimum water level to declare the SG OPERABLE in MODES 1 or 2 is 44% wide range level. APPLICABILITY In MODES I and 2. the reactor is critical and thus has the potential to produce maximum THERMAL POWER. Thus, to ensure that the assumptions of the accident analyses remain valid, all RCS loo 3s are required to be OPERABLE and in operation in these M0]ES to prevent DNB and core damage. The decay heat production rat'e is much lower than the full aower heat rate. As such. the forced circulation flow and leat sink requirements are reduced for lower. noncritical MODES as indicated by the LCOs for MODES 3. 4. 5. and 6. Operation in other MODES is covered by: LCO 3.4.5. "RCS Loops-MODE 3": LCO 3.4.6. "RCS Loops -MODE 4"; LCO 3.4.7. "RCS Loops-MODE 5. Loops Filled": LCO 3.4.8. "RCS Loops-MODE 5. Loops Not Filled"; LC0 3.9.4. " Shutdown Cooling (SDC) and Coolant Circulation-High Water Level" (MODE 6); and LC0 3.9.5. " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level" (MODE 6). ACTIONS .A_l If the requirements of the LC0 are not met the Required Action is to reduce power and bring the plant to MODE 3. This lowers power level and thus reduces the core heat removal needs and minimizes the possibility of violating DNB limits. It should be noted that the reactor will trip and place the 31 ant in MODE 3 as soon as the RPS senses less than four RCPs operating. The Completion Time of 6 hours is reasonable based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging safety systems. (continued) PALO VERDE UNITS 1.2.3 B 3.4.4-3 REV. E
^
l RCS Loops-MODES 1 and 2 B 3.4.4 l BASES : 1 i SURVEILLANCE SR 3.4.4.1 : REQUIREMENTS i This SR requires verification every 12 hours that the required number of RCS loops are in operation and circulating reactor coolant. Verification includes flow , rate, temperature, or pump status monitoring, which help to ensure that forced flow is providing heat removal while ! maintaining the margin to DNB. The Frequency of 12 hours has been shown by operating practice to be sufficient to regularly assess degradation and verify operation within safety analyses assumptions. In addition, control room i indication and alarms will normally indicate loop status. l REFERENCES 1. UFSAR Section 15. l l l i l l PALO VERDE UNITS 1.2.3 B 3.4.4-4 REV. A l
.. . . _ _ _ ._ _ . . _ . _ . _ _ _ _ . _ . ~ ._ _
RCS Loops-MODE 3 ! B 3.4.5 B 3.4 REACTOR _ COOLANT SYSTEM (RCS) -i B 3.4.5 RCS Loops-MODE 3 i BASES l r BACKGROUND The primary function of the reactor coolant in MODE 3 is
- removal of decay heat and transfer of this heat, via the i Steam Generators (SGs), to the secondary plant fluid. The r secondary function of the reactor coolant is to act as a ;
carrier for soluble neutron poison, boric acid. In MODE 3.. Reactor Coolant Pumps (RCPs) are used to provide ' forced circulation heat removal during heatup and cooldown. '" The MODE 3 decay heat removal requirements are low enough that a single RCS loop with one RCP is sufficient to remove core decay heat. However, two RCS loops are required to be OPERABLE to provide redundant paths for decay heat removal. , Only one RCP needs to be OPERABLE to declare the associated RCS loop OPERABLE. l Reactor coolant natural circulation is not normally used but ! is sufficient for core cooling. However, natural ! ! circulation does not provide turbulent flow conditions. l Therefore, boron reduction in natural circulation is l prohibited because mixing to obtain a homogeneous l concentration in all portions of the RCS cannot be ensured. l l APPLICABLE Analyses have shown that the rod withdrawal event from SAFETY ANALYSES MODE 3 with one RCS loop in o)eration is bounded by the rod withdrawal initiated from MODE 2. l Failure to provide heat removal may result in challenges to ! a fission product barrier. The RCS loops are part of the primary success path that functions or actuates to prevent l or mitigate a Design Basis Accident or transient that either
- assumes the failure of, or presents a challenge to, the j integrity of a fission product barrier.
RCS Loops-MODE 3 satisfy Criterion 3 of 10 CFR 50.36 l (c)(2)(ii). L 4 (continued) l PALO VERDE UNITS 1.2.3 B 3.4.5-1 REV. A
l 1 RCS Loops -MODE 3 I B 3.4.5 BASES l I LCO The purpose of this LC0 is to require two RCS loops to be I available for heat removal, thus providing redundancy. The l LC0 requires the two loops to be OPERABLE with the intent of I requiring both SGs to be capable (a 25% wide range water level) of transferring heat from the reactor coolant at a controlled rate. Forced reactor coolant flow is the ! required way to transport heat, although natural circulation flow provides adequate removal. A minimum of one running RCP meets the LC0 requirement for one loop in operation. The Note permits a limited period of operation without RCPs. All RCPs may be de-energized for s 1 hour per 8 hour )eriod. ; This means that natural circulation has been establisled. I When in natural circulation, a reduction in boron ; concentration is prohibited because an even concentration . distribution throughout the RCS cannot be ensured. The I intent is to stop any known or direct positive reactivity j additions to the RCS due to dilution. Core outlet i temperature is to be maintained at least 10 F below the l saturation temperature so that no vapor bubble may form and l possibly cause a natural circulation flow obstruction. i In MODE 3 it is sometimes necessary to stop all RCPs ; (e.g., to perform surveillance or startup testing, or to ' avoid operation below the RCP minimum net positive suction head limit). The time period is acceptable because natural , circulation is adequate for heat removal, or the reactor ! coolant temperature can be maintained subcooled and boron l stratification affecting reactivity control is not expected. ] An OPERABLE RCS loop (loop 1 or loop 2) consists of at least one associated RCP providing forced flow for heat trans) ort I and an associated SG that is OPERABLE in accordance wit 1 the l Steam Generator Tube Surveillance Program. An RCP is ! OPERABLE if it is capable of being powered and is able to l provide forced flow if required. APPLICABILITY In MODE 3 the heat load is lower than at power: therefore, one RCS loop in operation is adequate for transport and heat removal. A second RCS loop is required to be OPERABLE but not in operation for redundant heat removal capability. (continued) PALO VERDE UNITS 1,2,3 B 3.4.5-2 REV. B
RCS Loops-MODE 3 B 3.4.5 BASES f APPLICABILITY Operation in other MODES is covered by: l (continued) l LC0 3.4.4 "RCS Loops-MODES 1 and 2": i LC0 3,4,6. "RCS Loops-MODE 4": - LCO 3.4.7. "RCS Loops-MODE 5. Loops Filled": LCO 3.4.8 "RCS~ Loops-MODE 5. Loops Not F111ed"; LCO 3.9.4, " Shutdown Cooling (SDC) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level" (MODE 6). ACTIONS M . If one required RCS loop is inoperable, redundancy for - i forced flow heat removal is lost. The Required Action is restoration of the required RCS loop to OPERABLE status within a Completion Time of 72 hours. This time allowance is a justified period to be without the redundant. , nonoperating loop because a single loop-in operation has a I heat transfer capability greater than thac needed to remove the decay heat produced in the reactor core. l l fL1 If restoration is not possible within 72 hours, the unit must be placed in MODE 4 within 12 hours. In MODE 4. the ' plant may be placed on the SDC System. The Completion Time of 12 hours.is compatible with required operation to achieve cooldown and depressurization from the existing plant conditions in an orderly manner and without challenging plant systems. I l
- (continued) i PALO VERDE UNITS 1,2,3 B 3.4.5-3 REV. A l
4
. - - -. .. .. . . . - . . . - . - - _ . .. . - ~ .-
RCS Loops-MODE 3 B 3.4.5 BASES i
- ACTIONS C.1 antL2 (continued)
If no RCS loop is OPERABLE or in operation, all operations , involving a reduction of RCS boron concentration must be
- immediately suspended. This is necessary because boron dilution requires forced circulation for proper 4
homogenization. Action to restore one RCS loop to OPERABLE e status and operation shall be initiated immediately and 4 continued until one RCS 1000 is restored to OPERABLE status
- and operation. The imediate Completion Times reflect the importance of maintaining operation for decay heat removal. i 4
! SURVEILLANCE SR 3.4.5.1
- REQUIREMENTS ;
This SR requires verification every 12 hours that.the required number of RCS loops are in operation and circulating Reactor Coolant. Verification includes flow 1 j rate, temperature, or pump status monitoring, which help i ensure that forced flow 1s 3roviding heat removal. The ; , 12 hour interval has been slown by operating practice to be ! l. sufficient to regularly assess degradation and verify : operation within safety analyses assumptions. In addition, ' control room indication and alarms will normally indicate j loop status. J- SR 3.4.5.2 i This SR requires verification every 12 hours that the secondary side water level in each SG is a 25% wide range. q 4 An adequate SG water level is required in order to have a heat sink for removal of the core decay heat from the - reactor coolant. The 12 hour interval has been shown by . operating practice to be sufficient to regularly assess i degradation and verify operation within the safety analyses assumptions. 3 (continued) PALO VERDE UNITS 1.2.3 8 3.4.5-4 REV. A
RCS Loops-MODE 3 l B 3.4.5 l BASES (continued) SURVEILLANCE. SR 3. 4. L3 REQUIREMENTS (continued) Verification that the required number of RCPs are OPERABLE ensures that the single failure criterion is met and that an additional RCS loo) can be placed in operation, if needed. l to maintain decay leat removal and reactor coolant ! circulation. Verification is performed by verifying proper i breaker alignment and power availability to the required RCPs. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. REFERENCES None. l l l I l PALO VERDE UNITS 1.2.3 B 3.4.5-5 REV. A'
i l l RCS Loops-MODE 4 B 3.4.6 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.6 RCS Loops-MODE 4 i l BASES i BACKGROUND In MODE 4. the primary function of the reactor coolant is l the removal of decay heat and transfer of this heat to the ! Steam Generators (SGs) or Shutdown Cooling (SDC) heat 1 l exchangers. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric l l acid. ; i : l In MODE 4. either Reactor Coolant Pumps (RCPs) or SDC trains l can be used for coolant circulation. The intent of this LC0 is to provide forced flow from at least one RCP or one SDC l train for decay heat removal and transport. The flow ; l provided by one RCP loop or SDC train is adequate for heat ' removal. The other intent of this LC0 is to require that two paths be available to provide redundancy for heat i removal, s APPLICABLE In MODE 4. RCS circulation is considered in the SAFETY ANALYSES determination of the time available for mitigation of the accidental boron dilution event. The RCS loops and SDC trains provide this circulation. RCS Loops-MODE 4 have been identified in 10 CFR. 50.36 l (c)(2)(11) as important contributors to risk reduction. l l LC0 The purpose of this LCO is to require that at least two I loops e trains. RCS or SDC. be OPERABLE in MODE 4 and one of these loops or trains be in operation. The LC0 allows the two loops that are recuired to be OPERABLE to consist of any combination of RCS anc SDC System loops. Any one loop or train in operation provides enough flow to remove the decay heat from the core with forced circulation. An additional loop or train is required to be OPERABLE to provide redundancy for heat removal. (continued) PALO VERDE UNITS 1.2.3 B 3.4.6-1 REV. A
l l RCS Loops-MODE 4 ' B 3.4.6 BASES l LCO Note 1 permits all RCPs and SDC pumps to be de-energized (continued) s 1 hour per 8 hour period. This means that natural circulation should be established, after the operating RCP or SDC pump is secured, using the SGs. Depending on decay ! heat and current RCS temperature, it may be difficult to l establish verifiable natural circulation. The Note prohibits boron dilution when forced flow is stopped because an even concentration distribution cannot be ensured. The intent is to stop any known or direct positive reactivity additions to the RCS due to dilution. Core outlet l temperature is to be maintained at least 10 F below saturation temperature so that no vapor bubble may form and possibly cause a natural circulation flow obstruction. The l response of the RCS without the RCPs or SDC pumps depends on i the core decay heat load and the length of time that the aumps are stopped. As decay heat diminishes, the effects on RCS temperature and pressure diminish. Without cooling by forced flow, higher leat loads will cause the reactor coolant temperature and pressure to increase at a rate , proportional to the decay heat load. Because pressure can increase, the applicable system 3ressure limits (Pressure l and Temperature (P/T) limits or _ow Temperature Overpressure Protection (LTOP) limits) must be observed and forced SDC flow or heat removal via the SGs must be re-established prior to reaching the pressure limit. The circumstances for stopping both RCPs or SDC pumps are to be limited to situations where:
- a. Pressure and temperature increases can be maintained well within the allowable pressure (P/T limits and LTOP) and 10 F subcooling limits: or
- b. An alternate heat removal path through the SGs is in operation.
Note 2 requires, that before an RCP may be started with any RCS cold leg tem)erature 5 214*F during cooldown, or s 291 F during heatup, tlat secondary side water temperature (saturation temperature corresponding to SG pressure) in each SG is < 100 F above each of the RCS cold leg temperatures. Satisfying the above condition will preclude a large pressure surge in the RCS when the RCP is started. l l (continued) PALO VERDE UNITS 1.2.3 B 3.4.6-2 REV. A
RCS Loops-MODE 4 ; B 3.4.6 - l BASES , I i l LCO Note 3 restricts RCP operation to no more than 2 RCPs with ; (continued) RCS cold leg temperature 5 200*F, and no more than 3 RCPs I with RCS cold leg temperature >200 F but 5 500 F. Satisfying these conditions will maintain the analysis assumptions of the flow induced presure correction factors due to RCP operation (Ref. 1) An OPERABLE RCS loop consists of at least one OPERABLE RCP and an SG that is OPERABLE in accordance with the Steam Generator Tube Surveillance Program and has the minimum water level specified in SR 3.4.6.2. Similarly, for the SDC System, an OPERABLE SDC train is composed of an OPERABLE SDC pump (CS or LPSI) capable of 3roviding flow to the SDC heat exchanger for heat removal. TCPs and SDC pumps are OPERABLE if they are capable of being powered and are able to provide flow, if required. APPLICABILITY In MODE 4, this LC0 applies because it is possible to remove core decay heat and to provide proper boron mixing with either the RCS loops and SGs or the SDC System. Operation in other MODES is covered by: LCO 3.4.4 "RCS Loops e,0 DES 1 and 2": LC0 3.4.5, "RCS Loops-MODE 3"; LCO 3.4.7, "RCS Loops-MODE 5 Loops Filled": LC0 3.4.8. "RCS Loops-MODE 5 Loops Not Filled": LC0 3.9.4. " Shutdown Cooling (SDC) and Coolant . Circulation-High Water Level" (MODE 6); and ! LC0 3.9.5, " Shutdown Cooling (SDC) and Coolant l Circulation-Low Water Level" (MODE 6). i ACTIONS A.,J. If only one required RCS loop is OPERABLE and in o>eration, redundancy for heat removal is lost. Action must )e initiated immediately to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for decay heat removal. (continued) PALO VERDE UNITS 1.2.3 B 3.4.6-3 REV. B
1 i RCS Loops-MODE 4 i B 3.4.6 l l BASES i ACTIONS fL1 ; l (continued) - If only one required SDC train is OPERABLE and in operation. ! redundancy for heat removal is lost. The i placed in MODE 5 within the next 24 hours. plant must Placing thebe ' plant in MODE 5 is a conservative action with regard to decay heat removal. With only one SDC train OPERABLE. l redundancy for decay heat removal is lost and, in the event ! of a loss of the remaining SDC train, it would be safer to , l l initiate that loss from MODE 5 (s 210 F) rather than MODE 4 l (210 F to 350 F)._ The Completion Time of 24 hours is ' reasonable, based on operating experience, to reach MODE 5 from MODE 4, with only one SDC train operating, in an orderly manner and without challenging plant systems. , l C.1 and C.2 l If no RCS loops or SDC trains are OPERABLE. or in operation. all operations involving reduction of RCS boron concentration must be suspended and action to restore one l RCS loop or SDC train to OPERABLE status and operation must l be initiated. Boron dilution requires forced circulation for proper mixing, and the margin to criticality must not be ! reduced in this type of operation. The immediate Completion j l Times reflect the importance of decay heat removal. .The j action to restore must continue until one loop or train is
- restored to operation.
SURVEILLANCE SR 3.4.6.1 REQUIREMENTS l This SR requires verification every 12 hours that one required loop or train is in operation and circulating reactor coolant at a flow rate of greater than or equal to 4000 gpm. This ensures forced flow is providing heat removal. Verification includes flow rate, temperature. or
- pump status monitoring. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess RCS loop status. In addition, control room ;
indication and alarms will normally indicate loop status. i i } (continued) l PALO VERDE UNITS 1.2.3 B 3.4.6-4 REV. B , l l I
l l RCS Loops-MODE 4 B 3.4.6 i BASES SURVEILLANCE SR 3.4.6.2 REQUIREMENTS (continued) This SR requires verification every 12 hours of secondary i side water level in the required SG(s) 2: 25% wide range. An I adequate SG water level is recuired in order to have a heat sink for removal of the core cecay heat from the reactor . coolant. The 12 hour interval has been shown by operating l practice to be sufficient to regularly assess degradation l and verify operation within safety analyses assumptions. I SR 3.4.6.3 J Verification that the required pump is OPERABLE ensures that l an additional RCS loop or SDC train can be placed in j operation, if needed to maintain decay heat removal and j reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to ) the required pumps. The Frequency of 7 days is considered 4 reasonable in view of other administrative controls available and has been shown to be acceptable by operating , experience. ! REFERENCES 1. PVNGS Operating License Amendments 52, 38 and 24 for j Units 1. 2 and 3. respectively, and associated NRC Safety Evaluation dated July 25. 1990. j l l 1 PALO VERDE UNITS 1.2.3 B 3.4.6-5 REV. B 1 l
RCS Loops-MODE 5. Loops Filled B 3.4.7 l B 3.4 . REACTOR COOLANT SYSTEM-(RCS) l B 3.4.7 RCS Loops-MODE 5. Loops Filled l BASES i ! a BACKGROUND In MODE 5 with the RCS loops filled. the primary function of ! the reactor coolant is the removal of decay heat and - transfer this heat either to the Steam Generator (SG) : secondary side coolant or the essential cooling water via the Shutdown Cooling (SDC) heat exchangers. While the : principal means for decay heat removal is via the SDC : System, the SGs are specified as a backup means for ! l' redundancy. Even though the SGs cannot produce steam in this MODE. they are capable of being a heat sink due to their large contained volume of secondary side water. As l long as the SG secondary side water is at a lower temperature than the reactor coolant, heat transfer will ' occur. The rate of heat transfer is directly proportional ! to the temperature difference. The secondary function of I the reactor coolant is to act as a carrier for soluble neutron poison, boric acid. In MODE 5 with RCS loops filled, the SDC trains are the principal mean,. for decay heat removal The number of ; trains in operation can vary to suit the operational needs. , l The intent of this LC0 is to provide forced flow from at ' ! least one SDC train for decay heat removal and transport. ! The flow provided by one SDC train is adequate for decay - l heat removal. The other intent of this LCO is to require i that a second path be available to provide redundancy for l decay heat removal. l The LC0 provides for redundant paths of decay heat removal I ca) ability. The first path can be an SDC train that must be OPERABLE and in operation. The second path can be another OPERABLE SDC train. or through the SGs. each having an adequate water level. APPLICABLE In MODE 5. RCS circulation is considered in the SAFETY ANALYSES determination of the time available for mitigation of the accidental boron dilution event. The SDC trains provide i this circulation. 1 i , (continwd) l f l' PALO VERDE UNITS 1.2.3 B 3.4.7-1 REV. A
i ! RCS Loops-MDDE 5. Loops Filled ! B 3.4.7 i f BASES- ] l j APPLICABLE RCS Loops-MODE 5 (Loops Filled) have been identified in 10 SAFETY ANALYSES CFR 50.36 (c)(2)(ii) as important contributors to risk ,
- (continued) reduction. l 4
?
5 LCO The purpose of this LC0 is to require at least one of the , SDC trains be OPERABLE and in operation with an additional
- SDC train OPERABLE or secondary side water level of each SG shall be a 25% wide range level. One SDC train provides 2
sufficient forced circulation to perform the safety , 4 functions of the reactor coolant under these conditions. ! The second SDC train is normally maintained OPERABLE as a ! backup to the operating SDC train to provide redundant paths { for decay heat removal. However, if the standby SDC train ; is not OPERABLE, a sufficient alternate method to provide
, redundant paths for decay heat removal is two SGs with their :
secondary side water levels a 25% wide range. Should the 1 o)erating SDC train fail, the SGs could be used to remove ! t1e decay heat. l i Note 1 permits all SDC pumps to be de-energized 5 1 hour per 8 hour period. . The circumstances for stopping both SDC - trains are to be limited to situations where pressure and temperature increases can be maintained well within the ' allowable pressure (pressure and temperature and low , temperature overpressure protection) and 10 F subcooling : limits. or an alternate heat removal path through the SG(s)
- r. in operation.
This LC0 is modified by a Note that prohibits boron dilution when SDC forced flow is stopped because an even concentration distribution cannot be ensured. The intent is to stop any known or direct positive reactivity changes to the RCS due to dilution. Core outlet temperature is to be maintained at least 10 F below saturation temperature so that no vapor bubble would form and possibly cause a natural circulation flow obstruction. In this MDDE, the SG(s) can be used as the backup for SDC heat removal. To ensure their availability. the RCS loop flow path is to be maintained with subcooled liquid. ! (continued) PALO VERDE UNITS 1.2.3 B 3.4.7-2 REV. A
I ! 'RCS Looos-MODE 5. Loops Filled l B 3.4.7 , BASES l l LCO In MODE 5. it is sometimes necessary to sto) all RCP or SDC l (continued) forced circulation. This is permitted to clange operation from one SDC train to the other, perform surveillance or startup testing, perform the transition to and from the SDC. or to avoid operation below the RCP minimum net positive ' l suction heed limit. The time Jeriod is acce) table because i natural circulation is accepta)le for decay leat removal the . reactor coolant temperature can be maintained subcooled, and boron stratification affecting reactivity control is not expected. Note 2 allows one SDC train to be inoperable for a period of up to 2 hours provided that the other SDC train is OPERABLE i and in operation. This permits periodic surveillance tests to be performed on the inoperable train during the only time when such testing is safe and possible. Note 3 requires that before an RCP may be started with any RCS cold leg temperature s 214 F during a cooldown, or s 291 F during a heatup, the secondary side water i temperaturc (saturation temperature corresponding to SG pressure) in each SG must be < 100 F above each of the RCS cold leg temperatures. Satisfying the above condition will preclude a low ' temperature overpressure event due to a thermal transient when the RCP is started.
- Note 4 restricts RCP operation to no more than 2 RCPs with '
RCS cold leg temperature 5 200 F. and no more than 3 RCPs with RCS cold leg temperature > 200 F but 5 500 F. Satisfying these conditions will maintain the analysis
- assumptions of the flow induced pressure correction factors due to RCP operation (Ref. 3).
Note 5 provides for an orderly transition from MODE 5 to MODE 4 during a planned heatup by permitting removal of SDC trains from operation when at least one RCP is in operation. This Note provides for the transition to MODE 4 where an RCP is permitted to be in operation and re) laces the RCS circulation function provided by the S)C trains. . An OPERABLE SDC train is composed of an OPERABLE SDC pump l (CS or LPSI) capable of providing flow to the SDC heat exchanger for heat removal. I (continued) PALO VERDE UNITS 1.2.3 B 3.4.7-3 REV. B
i RCS Loops-MODE 5, Loops Filled B 3.4.7 ) BASES LC0 SDC pumps are OPERABLE if they are capable of being powered j (continued) and are able to orovide flow (current Section XI), if., requi red. An OPERABLE SG can perform as a heat sink when it i is OPERABLE in accordance with the SG Tube Surveillance. 1 Program and has the minimum water level specified in 1 SR 3.4.7.2. i When entering RCS Loops-MODE 5 Loops Filled from RCS Loops MODE 5 Loops not Filled the additional requirement of total gas concentration must be addressed for SGs to be considered - as a heat sink. A total gas concentration of < 20 cc/kg is required for MODE 5 operations. This limit ensures that gases coming out of solution in the SG U-tubes will not u adversely affect natural circulation with RCS pressure at atmospheric conditions. Normal operating procedures implement the findings for determination of when RCS loops j are considered filled, which in turn allows for transition from RCS Loops-MODE 5 Loops not Filled to RCS Loops-MODE 5 i Loops Filled. j The ability to feed and the ability to steam SGs is not a requirement. Since RCS temperature is less than 210 F in MODE 5-Loops Filled, no boiling (i.e. loss of SG inventory) will occur, therefore, the ability to feed and the ability to steam SGs is not a requirement. However, a means to feed and steam the-SGs whenever the Unit is in MODE 5-Loops Filled. should be provided. Feed sources available are not limited only to Essential Auxiliary Feedwater Pumps and the Condensate Storage Tank. Steaming capability is usually via ADVs. Also, the RCS must be intact (ability to pressurize to at least 100 psia) for the SGs to be considered as a heat sink. With the RCS not intact a majority of heat removal, assuming a loss of SDC flow, will be out the vent (Ref. 2). Therefore, with the RCS not intact, transition to LCO 3 4.8. RCS Loops-MODE 5 Loops not Filled, is appropriate.
)
(continued) PALO VERDE UNITS 1.2.3 B 3.4.7-4 REV. B
l l RCS Loops-MODE 5. Loops Filled B 3.4.7 l BASES (continued) l l APPLICABILITY In MODE 5 with RCS loops filled. this LCO requires forced l circulation to remove decay heat from the core and to l provide proper boron mixing. One SDC train provides l sufficient circulation for these purposes. Operation in other MODES is covered by: LCO 3.4.4. "RCS Loops-MODES 1 and 2". LC0 3.4.5, "RCS Loops-MODE 3": LC0 3.4.6. "RCS Loops-MODE 4": LCO 3.4.8 "RCS Loops-MODE 5. Loops Not Filled": LCO 3.9.4. " Shutdown Cooling (SDC) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.5. " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level" (MODE 6). ACTIONS A.1 and A.2 If a SDC train is inoperable and any SGs have secondary side water levels < 25% wide range, redundancy for heat removal is lost. Action must be initiated immediately to restore a second SDC train to OPERABLE status or to restore the water level in the required SGs. Either Required Action A.1 or Required Action A.2 will restore redundant decay heat removal paths. The immediate Completion Times reflect the importance of maintaining the availability of two paths for decay heat removal. B.1 and B.2 If the required SDC train is not OPERABLE or no SDC train is in operation, all operations involving the reduction of RCS boron concentration must be suspended. Action to restore one SDC train to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation for proper mixing and the margin to criticality must not be reduced in this type of operation. The immediate Completion Times reflect the importance of maintaining operation for decay heat removal. (continued) PALO VERDE UNITS 1.2.3 B 3.4.7-5 REV. A
h RCS Loops-MODE 5. Loops Filled B 3.4.7 l BASES (continued) ! SURVEILLANCE SR 3.4.7.1 . REQUIREMENTS This SR requires verification every 12 hours that one SDC train is in operation and circulating reactor coolant at a ! flow rate of greater than or equal.to 3780 gpm. Verification i includes flow rate, temperature, or pump status monitoring, i which help ensure that forced flow is providing decay heat i l removal. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation ' and verify operation is within safety analyses assumptions. . In addition, control room indication and alarms will . l normally indicate loop status. l' The SDC flow is established to ensure that core outlet temperature is maintained sufficiently below saturation to allow time for swapover to the standby SDC train should the l operating train be lost.
,SR 3.4.7.2 Verifying the SGs are OPERABLE by ensuring their secondary l
side water levels are a 25% wide range level ensures that redundant heat removal 3aths are available if the second SDC train is inoperable. T1e Surveillance is required to be performed when the LCO requirement is being met by use of l the SGs. If both SDC trains are OPERABLE. this SR is not needed. The 12 hour Frequency has been shown by operating , practice to be sufficient to regularly assess degradation -l and verify operation within safety analyses assumptions. i l SR 3.4.7.3 l Verification that the second SDC train is OPERABLE ensures that redundant paths for decay heat removal are available. The requirement also ensures that the additional train can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required a' umps. The Surveillance is required to be performed w1en the LCO requirement is being met by one of two SDC trains, e.g., both SGs have < 25% wide l: range water level. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience; l l l 1
, (continued)
( PALO VERDE UNITS 1.2.3 B 3.4.7-6 REV. B !
RCS Loops-MODE 5. Loops Filled B 3.4.7 BASES (continued) REFERENCES 1. Not Used
- 2. CEN-PSD-770 Analysis for Lower Mode Functional
- Recovery Guidelines.
4
- 3. PVNGS Operating License Amendmants 52, 38, and 24 for Units 1. 2 and 3, respectively, and associated NRC
- Safety Evaluation dated July 25, 1990.
i 4 5 l 1 PALO VERDE UNITS 1.2.3 B 3.4.7-7 REV. B
l l RCS Loops-MODE 5. Loops Not Filled B 3.4.8 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.8 RCS Loops-MODE 5. Loops Not Filled BASES BACKGROUND In MODE 5 with the RCS loops not filled, the primary l function of the reactor coolant is the removal of decay heat and transfer of this heat to the Shutdown Cooling (SDC) heat exchangers. The Steam Generators (SGs) are not available as a heat sink when the loops are not filled. The secondary ! function of the reactor coolant is to act as a carrier for the soluble neutron poison, boric acid. In MODE 5 with loops not filled only the SDC System can be used for coolant circulation. The number of trains in , operation can vary to suit the operational needs. The I intent of this LCO is to provide forced flow from at least one SDC train for decay heat removal and transport and to require that two paths be available to provide redundancy , for heat removal. l APPLICABLE In MODE 5. RCS circulation is considered in determining SAFETY ANALYSES the time available for mitigation of the accidental boron dilution event. The SDC trains provide this circulation. The flow provided by one SDC train is adequate for decay heat removal and for boron mixing. RCS loops-MODE 5 (loops not filled) have been identified in 10 CFR 50.36 (c)(2)(ii) as important contributors to risk reduction. LC0 The pur)ose of this LC0 is to require a minimum of two SDC trains 3e OPERABLE and one of these trains be in operation. An OPERABLE train is one that is capable of tran rerring heat from the reactor coolant at a controlled rate. Heat cannot be removed via the SDC System unless forced flow is used. A minimum of one running SDC pump meets the LCO requirement for one train in o)eration. An additional SDC train is required to be OPERAB.E to meet the single failure l criterion. (continued) l PALO VERDE UNITS 1.2.3 B 3.4.8-1 REV. A
RCS Loops-MODE 5, Loops Not Filled
- . B 3.4.8 BASES LCO Note 1 permits all SDC pumps to be de-energized s 1 hour per (continued) 8 hour period. The circumstances for stopping both SDC !
pumps are to be limited to situations when the outage time is short and the core outlet temperature is maintained
> 10*F below saturation temperature. The Note prohibits 3
)
boron dilution or draining operations when SDC forced flow is stopped. Note 2 allows one SDC train to be inoperable for a period of l 2 hours provided that the other train is OPERABLE and in ! operation. This permits periodic surveillance tests to be performed on the inoperable train during the only time when , these tests are safe and possible. I An OPERABLE SDC train is composed of an OPERABLE SDC pump , (CS or LPSI) capable of providing flow to the SDC heat i exchanger for heat removal. SDC pumps are OPERABLE if they are capable of being powered and are able to provide flow (current Section XI), if required. l APPLICABILITY In MODE 5 with loops not filled, this LC0 requires core heat removal and coolant circulation by the SDC System. Operation in other MODES is covered by: LC0 3.4.4. "RCS Loops-MODES 1 and 2": LC0 3.4.5 "RCS Loops-MODE 3": LC0 3.4.6. "RCS Loops-MODE 4": LC0 3.4.7. "RCS Loops-MODE 5. Loo LC0 3.9.4. " Shutdown Cooling (SDC)ps Filled": and Coolant 1 Circulation-High Water Level" (MODE 6); and l LC0 3.9.5. " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level" (MODE 6). ACTIONS .A_j. If a SDC train is inoperable, redundancy for heat removal is lost. Action must be initiated immediately to restore a second train to OPERABLE status. The Completion Time reflects the importance of maintaining the availability of two paths for heat removal. (continued) PALO VERDE UNITS 1.2.3 8 3.4.8-2 REV. A i
RCS Loops-MODE 5. Loops Not Filled B 3.4.8 BASES ACTIONS E_.1 and B.2 (continued) If no SDC train is OPERABLE or in operation, except as l provided in NOTE 1. all operations involving the reduction of RCS boron concentration must be suspended. Action to l restore one SDC train to OPERABLE status and operation must be initiated immediately. Boron dilution requires forced circulation for proper mixing and the margin to criticality l must not be reduced in this type of operation. The ! immediate Completion Time reflects the importance of ! maintaining operation for decay heat removal. l SURVEILLANCE SR 3.4.8.1 ' l REQUIREMENTS This SR requires verification every 12 hours that one SDC ; train is in operation and circulating reactor coolant. 1 Verification includes flow rate of greater than or equal to l 3780 gpm. temperature, or pump status monitoring, which help ensure that forced flow is providing decay heat removal. The 12 hour Frequency has been shown by operating practice l 4 to be sufficient to regularly assess degradation and verify ' operation is within safety analyses assumptions. SR 3.4.8.2 l Verification that the required number of trains are OPERABLE ensures that redundant paths for heat removal are available and that an additional train can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and indicated power available to the required pumps. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. l REFERENCES None. l PALO VERDE UNITS 1.2.3 B 3.4.8-3 REV. B i
Pressurizer ! B 3.4.9 B 3.4 REACTOR COOLANT SYSTEMS (RCS) B 3.4.9 Pressurizer ., i BASES BACKGROUND The pressurizer provides a point in the RCS where liquid and vapor are maintained in equilibrium under saturated conditions for pressure control' aurposes to prevent bulk boiling in the remainder of the RCS. Key functions include i maintaining required primary system pressure during steady state operation and limiting the pressure : changes caused by . reactor coolant thermal expansion and contraction during normal load transients. The pressure control components addressed by this LCO : include the pressurizer water level, the required heaters and their backup heater controls, and emergency power ! i supplies. Pressurizer safety valves and pressurizer vents are addressed by LCO 3.4.10 " Pressurizer Safety Valves-MODES : 1.2. and 3." LCO 3.4.11 " Pressurizer Safety Valves-MODE 4." 2 and LC0 3.4.12 " Pressurizer Vents" respectively. - i The maximum steady state water level limit has been established to ensure that a liquid to vapor interface exists to permit RCS pressure control, using the sprays and heaters during normal o)eration and proper 3ressure response !
- for anticipated design ) asis transients. T1e maximum and i j minimum steady state water level limit serves two purposes
- ,
J' i
- a. Pressure control during normal operation maintains subcooled reactor coolant in the loops and thus in the preferred state for heat transport: and i
- b. By restricting the level to a maximum, expected transient reactor coolant volume increases (3ressurizer insurge) will not cause excessive level c1anges that could result in degraded ability for pressure control.
The maximum steady state water level limit permits pressure l control equipment to function as designed. The limit i
) reserves the steam space during normal operation, thus, j
)oth sprays and heaters can operate to maintain the design 1 oaerating pressure. The level limit also prevents filling '
t1e pressurizer (water solid) for anticipated design basis I transients, thus ensuring that pressure relief devices i i (continued) PALO VERDE UNITS 1.2.3 B 3.4.9-1 REV. A
.~. _ _ ___ ___ _ _ . _ _ _ _ _ _ . . .-. - _ _ _
i Pressurizer B 3.4.9 BASES BACKGROUND (pressurizer safety valves) can control pressure by ' (continued) steam relief rather than water relief. If the level limits ' l were exceeded prior to a transient that creates a large pressurizer insurge volume leading to water relief, the ; maximum RCS pressure might exceed the Safety Limit of .i 2750 psia. ; j The minimum steady state water level in the pressurizer :
- assures pressurizer heaters, which are required to achieve !
and maintain pressure control, remain covered with water to l prevent failure, which could occur if the heaters were , energized uncovered. The requirement to have two groups of pressurizer heaters ensures that RCS pressure can be maintained. The pressurizer heaters maintain RCS pressure to keep the reactor coolant subcooled. Inability to control RCS : pressure during natural circulation flow could result in loss of single phase flow and decreased capability to remove core decay heat. l APPLICABLE In MODES 1. 2. and 3. the LCO requirement for a steam bubble SAFETY ANALYSES is reflected implicitly in the accident analyses. No safety analyses are performed in lower MODES. All analyses performed from a critical reactor condition assume the 1 existene of a steam bubble and saturated conditions in the ; pressurizer. In making this assumption, the analyses ' neglect the small fraction of noncondensable gases normally present. Safety analyses 3 resented in the UFSAR do not take credit for pressurizer 1 eater operation: however, an implicit initial condition assumption of the safety analyses is that the RCS is operating at normal pressure. (continued)
.PALO VERDE UNITS 1.2.3 B 3.4 9-2 REV. A
-. _- ,+n. 7
Pressurizer l B 3.4.9 l BASES APPLICABLE Although the heaters are not specifically used in accident ! SAFETY ANALYSES analysis, the need to maintain subcooling in the long term (continued) during loss of offsite power, as indicated in NUREG-0737 l (Ref.1), is the reason for their inclusion. The-l requirement for emergency power supplies is based on NUREG-0737 (Ref. 1). The intent is to keep the reactor l coolant in a subcooled condition with natural circulation at hot, high pressure conditions for an undefined. but extended, time period after a loss of offsite power. While l loss of offsite power is a coincident occurrence assumed in the accident analyses, maintaining hot, high pressure conditions over an extended time period is not evaluated in the accident analyses. The pressurizer satisfies Criterion 2 and Criterion 3 of 10 CFR 50.36(c)(2)(ii). LCO The LC0 requirement for the pressurizer to be OPERABLE with water level a 27% and s 56% ensures that a steam bubble exists. Limiting the maximum operating water level
] reserves the steam space for 3ressure control. The LCO has Jeen established to minimize t1e consequences of potential overpressure transients. Requiring the presence of a steam bubble is also consistent with analytical assumptions.
The LCO requires two groups of OPERABLE pressurizer heaters, each with a capacity = 125 kW and capable of being powered from an emergency power supply. The minimum heater capacity required is sufficient to maintain the RCS near normal o)erating pressure when accounting for heat losses through t1e pressurizer insulation. By maintaining the pressure near the operating conditions, a wide subcooling margin to saturation can be obtained in the loops. APPLICABILITY The need for pressure control is most )ertinent when core neat can cause the greatest effect on RCS temperature resulting in the greatest effect on 3ressurizer level and RCS pressure control. Thus. Applica)ility has been designated for MODES 1 and 2. The Applicability is also provided for MODE 3. It is assumed pressurizer level is under steady state conditions. The purpose is to prevent solid water RCS operation during heatup and cooldown to avoid rapid pressure rises caused by normal operational
- (continued) l PALO VERDE UNITS 1.2.3 B 3.4.9-3 REV. A
Pressurizer B 3.4.9 BASES APPLICABILITY 3erturbation, such as reactor coolant pump startup. The (continued) _C0 does not apply to MODE 5 (Loops Filled) because LC0 3.4.13. " Low Temaerature Overpressure Protection (LTOP) System." applies. T1e LCO does not apply to MODES 5 and 6 with partial loop operation. Also, a Note has been added to indicate tne limit on pressurizer level may be exceeded during short term operational transients such as a THERMAL POWER ramp increase of > 5% RTP per minute or a THERMAL POWER step increase of > 10% RTP. In MODES 1. 2. and 3. there is the need to maintain the availability of pressurizer heaters capable of being powered from an emergency power supply. In the event of a loss of offsite power, the initial conditions of these MODES gives the greatest demand for maintaining the RCS in a hot pressurized condition with loop subcooling for an extended period. For MODES 4. 5. or 6 it is not necessary to control pressure (by heaters) to ensure loop subcooling for heat transfer when the Shutdown Cooling System is in service and therefore the LC0 is not applicable. l ACTIONS A.1 and A.2 i With 3ressurizer water level not within the limit, action must Je taken to restore the plant to operation within the bounds of the safety analyses. To achieve this status, the - unit must be brought to MODE 3. with the reactor trip breakers open. within 6 hours and to MODE 4 within 12 hours. This takes the plant out of the applicable MODES and restores the plant to operation within the bounds of the safety analyses. Six hours is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without challenging plant systems. Further pressure and temperature reduction to MODE 4 brings the plant to a MODE where the LCO is not applicable. The 12 hour time to reach the nonapplicable MODE is reasonable based on operating experience for that evolution. J 1 (continued) PALO VERDE UNITS 1.2.3 B 3.4.9-4 REV. A
- . _ = .
1 Pressurizer B 3.4.9 l i l BASES ACTIONS B.J. (continued) If one required group of pressurizer heaters is inoperable, restoration is required within 72 hours. The Completion Time of 72 hours is reasonable considering that a demand caused by loss of offsite power would be unlikely in this period. Pressure control may be maintained during this time using normal station powered heaters. C.1 and C.2 l If one required group of pressurizer heaters is inoperable and cannot be restored within the allowed Completion Time of i Required Action B.1. the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 6 hours and to MODE 4 within 12 hours. The Completion Time of 6 hours is i reasonable, based on operating experience, to reach MODE 3 ! from full power in an orderly manner and without challenging safety systems. Similarly, the Completion Time of 12 hours is reasonable. based on operating experience, to reach MODE 4 from full power in an orderly manner and without challenging plant systems. SURKILLANCE SR 3.4.9.1 REQUIREMENTS This Surveillance ensures that during steady state operation, pressurizer water level is maintained below the nominal upper limit to provide a minimum space for a steam bubble. T1e Surveillance is performed by observing the indicated level. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess the level for any deviation and verify that operation is within safety analyses assumptions. Alarms are also available for early detection of abnormal level indications. l I (continued) PALO VERDE UNITS 1.2.3 B 3.4.9-5 REV. A
l l Pressurizer B 3.4.9 ! i BASES l SURVEILLANCE SR 3.4.9.2 REQUIREMENTS (continued) The Surveillance is satisfied when the power supplies are : demonstrated to be capable of producing the minimum power l and the associated pressurizer heaters are verified to be at i their design rating. (This may be done by testing the power ! supply output and by performing an electrical check on heater element continuity and resistance.) The Frequency of 92 days is considered adequate to detect heater degradation j and has been shown by operating experience to be acceptable. ) REFERENCES 1. NUREG-0737. November 1980. I I l l l l t PALO VERDE UNITS 1.2.3 B 3.4.9-6 REV. A
_. _. . . _ . ~ _ . -. _ _ .__ _ _ _ _ _ . . . _ . _ _ _ . _ . ._ ___ _ Pressurizer Safety Valves-MODES 1. 2. and 3 B 3.4.10 i i l B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.10 Pressurizer Safety Valves
)
l l BASES BACKGROUND The purpose of the four spring loaded pressurizer safety valves is to provide RCS overpressure protection. Operating i in conjunction with the Reactor Protection System. four ! valves are used to ensure that the Safety Limit (SL) of i 2750 psia is not exceeded for analyzed transients during l operation in MODES 1. 2 and 3. One safety valve used for MODE 4. For MODE 5..and MODE 6 with the head on. overpressure protection is provided by operating procedures and the LCO 3.4.13. " Low Temperature Overpressure Protection (LTOP) System." The self actuated pressurizer safety valves are designed in accordance with the requirements set forth in the ASME, Boiler and Pressure Vessel Code. Section III (Ref. 1). The required lift pressure is 2475 psia +3%. -1%. The safety valves discharge steam from the pressurizer to a quench tank located in the containment. The discharge flow is indicated by an increase in temperature downstream of the safety valves and by an increase in the quench tank torperature and level. The lift setting is for the ambient conditions associated with MODES 1, 2 and 3. This requires either that the valves be set hot or that a correlation between hot and cold settings be established. The pressurizer safety valves are part of the primary success path and mitigate the effects of postulated accidents. OPERABILITY of the safety valves ensures that the RCS pressure will be limited to 110% of design pressure. The consequences of exceeding the ASME pressure limit (Ref. 1) could include damage to RCS components, increased leakage, or a requirement to perform additional stress analyses prior to resumption of reactor operation. 4 (continued) l PALO VERDE UNITS 1.2.3 8 3.4.10-1 REV. A
]
1 l
i Pressurizer Safety Valves-MODES 1. 2. and 3 B 3.4.10 l BASES , i APPLICABLE All accident analyses in the UFSAR that require safety valve SAFETY ANALYSES actuation assume operation of four pressurizer safety valves ) to limit increasing reactor coolant pressure. The ;
- overpressure protection analysis is also based on operation '
l of four safety valves and assumes that the valves o)en at ( the high range of the setting (2475 psia + 3%). T1ese valves must accommodate pressurizer insurges that could ! occur during a startup, rod withdrawal. ejected rod, loss of main feedwater., or main feedwater line break accident. The Loss of Load with Delayed Reactor Tri) accident establishes the minimum safety valve capacity. T1e Loss of Load with Delayed Reactor Trip accident is assumed to occur at l 100% power. Single failure of a safety valve is neither i assumed in the accident analysis nor required to be I addressed by the ASME Code. Compliance with this l specification is required to ensure that the accident analysis and design basis calculations remain valid. ! The pressurizer safety valves satisfy Criterion 3 of 10 CFR l 50.36 (c)(2)(ii). I l l ! LC0 The four pressurizer safety valves are set to open at 25 l psia less than RCS design pressure (2475 psia) and within the ASME specified tolerance to avoid exceeding the maximum RCS design pressure SL to maintain accident analysis ! ! assumptions, and to comply with ASME Code requirements. The limit protected by this s)ecification is the Reactor Coolant Pressure Boundary (RC)B) SL of 110% of design l pressure. Ino)erability of one or more valves could result in exceeding tie SL if a transient were to occur. The l consecuences of exceeding the ASME pressure limit could incluce damage to one or more RCS components, increased leakage, or additional stress analysis being required prior to resumption of reactor operation. i
- APPLICABILITY In MODES 1. 2. and 3. OPERABILITY of four valves is required l
because the combined capacity is recuired to keep reactor coolant pressure below 110% of its cesign value during certain accidents. MODE 3 is conservatively included, although the listed accidents may not require four safety valves for protection. (continued) PALO VERDE UNITS 1.2.3 B 3.4.10-2 REV. A l.
Pressurizer Safety Valves-MODES 1, 2. and 3 B 3.4.10 ' BASES APPLICABILITY The requirements for overpressure protection in other MODES (continued)- are covered by LC0 3.4.11. " Pressurizer Safety Valves-MODE 4," and LCO 3.4.13. "LTOP System." The Note allows entry into MODES 3 and 4 with the lift i settings outside the LC0 limits. This aermits testing and ! examination of the safety valves at higi pressure and temperature near their normal operating range, but only , after the valves have had a preliminary cold setting. The : cold setting gives as:surance that the valves are OPERABLE ' near their design condition. Only one valve at a time will be removed from service for testing. The 72 hour exception is based on 18 hour outage time for each of the four valves. The 18 hour period is derived from operating experience that hot testing can be performed within this timeframe. ACTIONS L1 With one pressurizer safety valve ino)erable, restoration-must take place within 15 minutes. T1e Completion Time of 15 minutes reflects the importance of maintaining the RCS overpressure protection system. An inoperable safety valve coincident with an RCS overpressure event could challenge the integrity of the RCPB. ' B.1 and B.2 l If the Required Action cannot be met within the required Completion Time or if two or more 3ressurizer safety valves are inoperable, the plant must be arought to a MODE in which the requirement does rot apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours and to MODE 4 within 12 hours. The 6 hours allowed is reasonable, based on cperating experience, to reach MODE 3 ' from full Similarly, power the 12 without challenging hours allowed plant systems. is reasonable, based on operating experience, to reach MODE 4 without challenging plant systems. (continued) PALO VERDE UNITS 1.2.3 B 3.4.10-3 REV. B
_m. _ .. _ _ _ - _ . _ _ _ . - . _ _ _ . _ - _ _ .. _. . _ . . _ . . _ _... Pressurizer Safety Valves-MODES 1. 2. and 3 B 3.4.10 BASES ACTIONS B.1 and B.2 (continued) The change from MODE 1, 2 or 3 to MODE 4 reduces the RCS : energy (core power and pressure), lowers the potential for large pressurizer insurges, and thereby removes the need for overpressure protection by four pressurizer safety valves. SURVEILLANCE SR 3.4.10.1 REQUIREMENTS SRs are specified in the Inservice Testing Program. Pressurizer safety valves are to be tested in accordance with the requirements of Section XI of the ASME Code. (Ref.1), which provides the acti'lities and the Frequency necessary to satisfy the SRs. No additional requirements are specified. 1 The pressurizer safety valve setpcint is +3% - 1% for OPERABILITY: however, the valves are reset to 1% during the Surveillance to allow for drif t (Ref. 2). The lift , setting pressure shall correspond :o ambient conditions of the valve at nominal operating temperature and pressure. i REFERENCES 1. ASME, Boiler and Pressure Vessel Code, Section III, Section XI. I
- 2. PVNGS Operating License Amendment Nos. 75, 61, and 47 for Units 1. 2. and 3, respectiveiy, and associated NRC Safety Evaluation dated May 16, 1994.
l l l i PALO VERDE UNITS 1.2.3 B 3.4.10-4 REV. B
-. . - - - - . . - . . ~. - . - - . . . ~ .
Pressurizer Safety Valves-MODE 4 B 3.4.11 l-B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.11 Pressurizer Safety Valves-MODE 4 l. BASES BACKGROUND The purpose of-the four spring loaded pressurizer safety valves is to provide RCS overpressure protection. One safety valve is used for portions of MODE 4 For the i remainder of MODE 4. MODE 5. and MODE 6 with the head on, overpressure protection is provided by operating procedures and the LCO 3.4.13. " Low Temperature Overpressure Protection (LTOP) System." l The self actuated pressurizer safety valves are designed in l accordance with the requirements set forth in the ASME, Boiler and Pressure Vessel Code. Section III (Ref. 1). The required lift pressure ~ is '2475 psia +3%, -1%. The safety valves discharge steam from the pressurizer to a quench tank l located in the containment. The discharge flow is indicated i by an increase in temperature downstream of the safety ' valves and by an increase in the quench tank temperature and
- level ,
The lift setting is for the ambient conditions associated with MODES 1, 2, and 3. This requires either that the
- valves be set hot or that a correlation between hot and cold r settings be established.
The pressurizer safety valves are part of the primary success path and mitigate the effects of postulated l accidents. OPERABILITY of the safety valves ensures that i the RCS pressure will be limited to 110% of design pressure. The consequences of exceeding the ASME pressure limit i (Ref. 1) could include damage to RCS components, increased l leakage, or a requirement to perform additional stress analyses prior to resumption of reactor operation. i ; f i (continued) PALO VERDE UNITS 1.2.3 B 3.4.11-1 REV. A r i
Pressurizer Safety Valves-MODE 4 8 3.4.11 BASES-
- . BACKGROUND Pressurizer Safety Valve Reauirements l' (continued)
The pressurizer code safety valves operate to prevent the RCS from being 3ressurized above its Safety Limit (SL) of 2750 psia. Eac1 safety valve is designed to relieve a minimum of 460,000 lb per hour of saturated steam at valve setpoint. The relief capacity of a single safet valve is adequatetorelieveanyover)ressureconditionw{nichcould occur during shutdown above -Top System temperatures. Shutdown Coolina System Suction Line Relief Valve Reauirements [ A single Shutdown Cooling System suction line relief valve provides overpressure relief capability and will prevent RCS
, overpressurization in the event that no pressurizer safety valves are OPERABLE.
i 1 APPLICABLE All accident analyses in the UFSAR that require safety valve SAFETY ANALYSES actuation assume operation of four pressurizer safety valves to limit increasing reactor coolant pressure. The overpressure protection analysis is also based on operation 4 of four safety valves and assumes that the valves open at the high range of the setting (2475 psia + 3%). These i valves must accommodate pressurizer insurges that could
- occur during a startup, rod withdrawal, ejected rod, loss of
- main feedwater, or main feedwater line break accident. The
! Loss of Load with Delayed Reactor Tri) accident establishes j the minimum safety valve capacity. T1e Loss of Load with Delayed Reactor Trip accident is assumed to occur at 100% power. Single failure of a safety valve is neither assumed in the accident analysis nor required to be addressed by the ASME Code. Compliance with this specification is required to ensure that the accident analysis and design basis calculations remain valid. The pressurizer safety valves satisfy Criterion 3 of 10 CFR 50.36 (c)(2)(ii). (continued) PALO VERDE UNITS 1,2,3 B 3.4.11-2 REV. A
f Pressunzer Safety Valves-MODE 4 8 3.4.11 BASES (continued) l LC0 One pressurizer safety valve is required to be OPERABLE in MODE 4 with no Shutdown Cooling System suction line relief valves in service. The four pressurizer safety valves are set to open 25 psia less than RCS design pressure (2475 l psia) and within the ASME specified tolerance to avoid exceeding the maximum RCS design pressure SL to maintain i accident analysis assumptions, and to comply with ASME Code requirements. The limit protected by this specification is j the Reactor Coolant Pressure Boundary (RCPB) SL of 110% of l design pressure. Inoperability of all valves could result in exceeding the SL if a transient were to occur. The consecuences of exceeding the ASME pressure limit could incluce damage to one or more RCS components, increased leakage, or additional stress analysis being required prior to resumption of reactor operation. l APPLICABILITY In MODE 4 above the LTOP System temperatures OPERABILITY of ! one valve is required. MODE 4 is conservatively included, although the listed accidents may not require a safety valve for protection. The requirements for overpressure protection in other MODES - and in MODE 4 at or below the LTOP System temperatures are covered by LCO 3.4.10. " Pressurizer Safety Valves - MODES 1. t 2 and 3." and LCO 3.4.13. "LTOP System." The Note allows entry into MODES 3 and 4 with the lift settings outside the LC0 limits. This 3ermits testing and examination of the safety valves at higi pressure and temperature near their normal operating range, but only after the valves have had a preliminary cold setting. The cold setting gives assurance that the valves are OPERABLE near their design condition. Only one valve at a time will be removed from service for testing. The 72 hour exception is based on 18 hour outage time for each of the four valves. The 18 hour period is derived from operating experience that hot testing can be performed within this timeframe. (continued) l PALO VERDE UNITS 1.2.3 B 3.4.11-3 REV. B r- g
Pressurizer Safety Valves-MODE'4' B 3.4.11 BASES (continued) ACTIONS A.1. A.2. and A.3 If all pressurizer safety valves are inoperable, the plant
.must be brought to a condition where overpressure protection is provided, then to a MODE in which the requirement does not apply. To achieve this status, one Shutdown Cooling System suction line relief must be placed in service immediately, then the plant must be brought to at least MODE 4 with all RCS cold leg temperatures s 214 F during i cooldown or s 291 F during heatup within 8 hours, so that 1 LC0 3.4.12 (LTOP System) would apply. It is reasonable to l pursue the ACTION to place a shutdown cooling system suction relief valve in service immediately (without delay) because the plant is already within the shutdown cooling system I entry temperature of less than 350 F. The Completion Time of immediately requires that the required action be pursued without delay and in a controlled manner, and reflects the importance of maintaining the RCS overprotection system. I The 8 hours allowed to be in MODE 4 with all RCS l
. temperatures s 214*F during cooldown or s 291 F during !
heatup is reasonable, based on operating experience, to l reach this condition without challenging plant systems.
]
For the Shutdown Cooling System suction line relief valve ) that is required to be in service in accordance with ; Required Action A.1, SR 3.4.11.2 and SR 3.4.11.3 must be ) performed or verified performed within 12 hours. This ensures that the required Shutdown Cooling System suction line relief valve is OPERABLE. A Shutdown Cooling System suction line relief valve is OPERABLE when its isolation valves are open. its lift setpoint is set at 467 psig or less, and testing has proven its ability to open at that setpoint. 1 If the Required Actions and associated Completion Times are not met, overpressurization is possible. The 8 hours Completion Time to be in MODE 4 with all RCS cold leg temperatures s214 F during cooldown or s291*F during heatup places the unit in a condition where the LCO does not apply. 1 (continued) PALO VERDE UNITS 1,2,3 B 3.4.11-4 REV. B l
l Pressurizer Safety Valves-MODE 4 B 3.4.11 } BASES (continued). SURVEILLANCE SR 3.4.11.1 REQUIREMENTS. SRs are specified in the Inservice Testing Program. Pressurizer safety valves are to be tested in accordance i with the requirements of Section XI of the ASME Code ' l (Ref. 1), which provides the activities and the Frequency necessary to satisfy the SRs. No additional requirements
- are specified.
?- The pressurizer safety valve setpoint is +3%. -1% for i OPERABILITY: however, the valves are reset to 1% during
- the Surveillance to allow for drift (Ref. 3). The lift
- setting pressure shall correspond to ambient conditions of
- the valve at nominal operating temperature and pressure.
j. i SR 3.4.11.2 t l SR 3.4.11.2 requires that the required Shutdown Cooling i System suction line relief valve is OPERABLE by verifying l its open pathway condition either: I i
- a. Once every 12 hours for a valve that is unlocked, not sealed, or otherwise not secured open in the vent ;
- pathway, or l b. Once every 31 days for a valve that is locked, sealed .
! or otherwise secured open in the vent pathway. { ' i i The SR has been modified by a Note that requires performance ! < only if a Shutdown Cooling System suction line relief valve i is being used for overpressure protection. The Frequencies consider operating experience with mispositioning of unlocked and locked pathway vent valves. SR 3.4.11.3 SRs are specified in the Inservice Testing Program. Shutdown Cooling System suction line relief valves are to be tested in accordance with the requirements of Section XI of the ASME Code (Ref. 2), which provides the activities and the Frequency necessary to satisfy the SRs. The Shutdown ' Cooling System suction line relief valve setpoint is 467 psig. (continued) l PALO VERDE UNITS 1.2.3 B 3.4.11-5 REV. B
Pressurizer Safety Valves-MODE 4 B 3.4.11 BASES (continued) REFERENCES 1. ASME. Boiler and Pressure Vessel Code. Section III. Section XI.
- 2. ASME, Boiler and Pressure Vessel Code. Section XI.
- 3. PVNGS Operating License Amendment Nos. 75. 61, and 47 for Units 1. 2. and 3 respectively, and associated NRC Safety Evaluation dated May 16. 1994.
i i l l
)
PALO VERDE UNI.3 1.2.3 B 3.4.11-6 REV. B
l Pressurizer Vents B 3.4.12 l- B 3.4 : REACTOR COOLANT SYSTEM (RCS) l B 3.4.12 Pressurizer Vents l BASES , l! BACKGROUND The pressurizer vent is ) art of the reactor coolant gas vent ! system (RCGVS) as descri Jed in UFSAR 18.II.B.1 (Ref.1). The !
. pressurizer can be vented remotely from the control room !
through the following four paths (see UFSAR l Figure 18.II.B-1): j t
- 1. From the pressurizer vent through SOV HV-103, then !
through SOV HV-105 to.the reactor drain tank (RTD). i
- 2. From the pressurizer vent through S0V HV-103, then j through S0V HV-106 directly to the containment atmosphere. ;
- 3. From the )ressurizer vent through S0Vs HV-108 and )
-HV-109, tien through S0V HV-105 to the reactor drain ,
tank (RTD). ; 4 From the )ressurizer vent through S0Vs HV-108 and l HV-109. tien through SOV HV-106 directly to the i l containment atmosphere. ; The RCGVS also includes the reactor head vent, which can be ; used along with the pressurizer vent to remotely vent gases > that could inhibit natural circulation core cooling during post accident situations. However, this' function does not i meet the criteria of 10 CFR 50.36(c)(2)(11) to require a - Technical Specification LCO, and therefore tha reactor head vent is not included in these Technical Specifications. l l l l (continued) { PALO VERDE UNITS 1.2.3 B 3.4.12-1 REV. B l
Pressurizer Vents 3.4.12 I BASES 4 L APPLICABLE The requirement for pressurizer path vent path to be SAFETY ANALYSES OPERABLE is based on the steam generator tube rupture (SGTR) i with loss of offsite power (LOP) and a single failure safety 4 analysis, as described in UFSAR 15.6.3 (Ref. 4). It is '. assumed that the auxiliary pressurizer spray system (APSS) i is not available for this event. Instead. RCS depressurization is performed. 2 hours after the initial SGTR, by venting the RCS via a pressurizer vent path and i throttling HPSI flow. The analysis also incorporates an additional failure by assuming that only the smallest of the four available 3ressurizer vent paths is used. This is
- identified as t1e orificed flow path to the RDT.
The results of the analysis for steam generator tube rupture i with a loss of offsite power and a fully stuck open ADV
- using the pressurizer vent system, forwarded to the NRC in
! Reference 3. states that the analysis assumes that the APSS
- is inoperable and the pressurizer gas vent system aerforms
- the functions of RCS dearessurization. The staff las reviewed and accepted t1e results of the analysis and the ,
i design of the pressurizer gas vent system. The staff's ! detailed eveluation has been reported in Supplement No. 9 to i i PVNGS SER (Ref. 2). !
- The 3ressurizer vent paths satisfy Criterion 3 of 10 C:R 50,36 (c)(2)(ii).
LC0 The LCO requires four pressurizer vent paths be OPERABLE. The four vent paths are:
- 1. From the pressurizer vent through SOV HV-103, then ;
through SOV HV-105 to the reactor drain tank (RTD). !
- 2. From the pressurizer vent through S0V HV-103, then through SOV HV-106 directly to the containment atmosphere.
- 3. From the 3ressurizer vent through SOVs HV-108 and '
HV-109. tien through SOV HV-105 to the reactor drain tank (RTD).
- 4. From the 3ressurizer vent through SOVs HV-108 and HV-109. tien through S0V HV-106 directly to the containment atmosphere.
(continued) PALO VERDE UNITS 1.2.3 B 3.4.12-2 REV. B
. . . -. _ - - . ~ .. - _ _ . - - . . ~ . _ . - - - .
i Pressurizer Vents , 3.4.12 ( BASES j LCO A vent path is flow capability from the pressurizer to the l l (continued RDT or from the pressurizer to containment atmosphere, i ! Loss of any single valve in the pressurizer vent system will cause two flow paths to become inoperable. A pressurizer t vent path is required to depressurize the RCS in a SGTR ; design basis event which assumes LOP and APPS unavailable. ! APPLICABILITY In MODES 1. 2. 3. and MODE 4 with RCS pressure 2 385 asia 1 the four pressurizer vent paths are required to be OPERABLE.. The safety analysis for the SGTR with LOP and a.Sitgle , Failure (loss of APSS) credits a pressurizer vent path to i reduce RCS pressure. : i In MODES 1, 2. 3. and MODE 4 with RCS pressure 2 385 asia ! the SGs are the primary means of heat removal in the RCS. , until shutdown cooling can be initiated. In MODES 1. 2. 3. and MODE.4 with RCS pressure t 385 psia assuming the APSS is not available, the pressurizer vent paths are the - credited means to depressurize the RCS to Shutdown Cooling System entry conditions. Further depressurization into MODE. i 5 requires use of the pressurizer vent paths. In MODE 5 with ! the reactor vessel head in place. temperature requirements ! of MODE 5 (< 210*F) ensure the RCS remains depressurized. : In MODE 6 the RCS is depressurized. ACTIONS L.1 If two or three pressurizer vent paths are inoperable, they must be restored to OPERABLE status. Loss of any single valve in the pressurizer vent system will cause two flow paths to become inoperable. Any vent path that provides flow capability from the pressurizer to the RDT or to the containment atmosphere, independent of which train is powering the valves in the flow path, can be considered an operable vent path. The Completion Time of 72 hours is reasonable because there is at least one pressurizer vent j path that remains OPERABLE. (continued) i PALO VERDE UNITS 1.2.3 B 3.4.12-3 REV. B l
! Pressurizer Vents
- 3.4.12 l
I l BASES-l U ! If all pressurizer vent paths are inoperable, then restore l at least one pressurizer vent path to OPERABLE status. The l Completion Time of 6 hours is reasonable to allow time to correct the situation, yet emphasize the im)ortance of ! restoring at least one pressurizer vent pat 1. If at least one pressurizer vent path is not restored to OPERABLE within the Completion Time, then Action C is entered. C .1 If the recuired Actions. A and B, cannot be met within the associatec Completion Times, the plant must be brought.to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least. MODE 3 within 6 hours, and to MODE 4 with RCS pressure < 385 psia ! within 24 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the recuired plant conditions from full power conditions in an orcerly manner without challenging plant systems. i SURVEILLANCE SR 3.4.12.1 REQUIREMENTS SR 3.4.12.1 requires complete cycling of each pressurizer vent path valve. The vent valves must be cycled from the control room to demonstrate their operability. Pressurizer vent path valve cycling demonstrates its function. The frequency of 18 months is based on a typical refueling cycle : and industry accepted practice. This surveillance test must j be performed in Mode 5 or Mode 6. 1 SR 3.4.12.2 SR 3.4.12.2 requires verification of flow through each pressurizer vent path. Verification of pressurizer vent path flow demonstrates its function. The frequency of 18 months is based on a typical refueling cycle and industry accepted practice. This surveillance test must be performed in Mode 5 or Mode 6. ! 4 (continued) i PALO VERDE UNITS 1.2.3 B 3.4.12-4 REV. B
. ., . ..n -
Pressurizer Vents 3.4.12 BASES REFERENCES 1. UFSAR. Section 18.
- 2. NUREG-0857. initial issue. November 1981. through Supplement 12. November 1987.
3 Letter from Arizona Nuclear Power Project to NRC (ANPP-33905) dated November 4, 1985. "Information Concerning the PVNGS Auxiliary Pressurizer Spray."
- 4. UFSAR. Section 15.
t I t i l l l l i f PALO VERDE UNITS 1.2.3 B 3.4.12-5 REV. B l
LTOP System B 3.4.13 - B 3.4 REACTOR COOLANT SYSTEM (RCS) ! B 3.4.13 Low Temperature Overpressure Protection (LTOP) System BASES-BACKGROUND The LTOP System controls RCS pressure at low temperatures so : the integrity of the Reactor Coolant Pressure Boundary * (RCPB) is not compromised by violating the Pressure and l Temperature (P/T) limits of 10 CFR 50. Appendix G (Ref. 1). The reactor vessel is the limiting RCPB component for demonstrating such protection. LC0 3.4.3, "RCS Pressure and - Tem)erature (P/T) Limits," provides the allowable ! com)inations for operational pressure and temperature during I cooldown, shutdown, and heatup to keep from violating the : Reference 1 requirements during the LTOP MODES. , The reactor vessel material is less tough at low i temperatures than at normal operating temperatures. As the - vessel neutron exposure accumulates, the material toughness : decreases and becomes less resistant to pressure stress at , low temperatures (Ref. 2). RCS pressure, therefore, is ! maintained low at low temperatures and is increased only as temperature is increased. The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only while shutdown; a pressure fluctuation can occur more quickly than an operator can react to relieve the condition. Exceeding the RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel. LCO 3.4.3 requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the P/T limits. , l This LC0 provides RCS overpressure protection by having l adequate pressure relief capacity. The pressure relief capacity requires either two OPERABLE redundant Shutdown Cooling System suction line relief valves or the RCS depressurized and an RCS vent of sufficient size. One l Shutdown Cooling System suction line relief valve or the RCS vent is the overpressure protection device that acts to terminate an increasing pressure event. (continued) PALO VERDE UNITS 1,2,3 B 3.4.13-1 REV. A l
_- - . . - . . . - . . . - ~ - . . . . - - - - . - - - . - _ _ _ ~ . . - LTOP System BASES BACKGROUND The LTOP System for pressure relief consists of two Shutdown ' (continued) Cooling System suction line relief valves or an RCS vent of sufficient size. Two relief valves are required for redundancy. One Shutdown Cooling System suction line relief : valve has adequate relieving capability to prevent ! over]ressurization for the required coolant input capa]ility. i Shutdown Coolina System Suction Line Relief Valve I Reauirements ; As designed for the LTOP System, each Shutdown Cooling System suction line relief valve is designed to lift and relieve RCS pressure if RCS pressure approaches the Shutdown i Cooling System suction line relief valve lift setpoint. l Each Shutdown Cooling System suction line relief valve is designed to protect the reactor vessel given-a single failure in addition to a failure that initiated the pressure
- transient. No single failure of a Shutdown Cooling System i suction line relief valve isolation valve (SI-651, 652, 653, or 654) will prevent one Shutdown Cooling System suction line relief valve-from performing its intended function (Ref, 7).
The OPERABILITY of two Shutdown Cooling System suction line \ l relief valves, while maintaining the limits imposed on the j ( RCS heatup and cooldown rates, ensures that the RCS will be l l protected from analyzed pressure transients. Either j l Shutdown Cooling System suction line relief valve provides : l overpressure protection for the RCS due to the most limiting l l transients initiated by a single operator or equipment failure. I a. The start of an idle RCP with secondary water temperature of the SG s 100 F above RCS cold ler i temperatures 1
- b. An inadvertent SIAS with two HPSI pumps injecting into a water solid RCS, three charging pumps injecting, and I letdown isolated.
These events are the most limiting energy and mass addition transients, respectively, when the RCS is at low temperatures (Refs. 7, 8 and 9). { R ) (continued) i i PALO VERDE UNITS 1.2.3 B 3.4.13-2 REV. A
_ _ _ _ . _ _ . .. - ~ _ _ _ _ _ _ __ _ _ _ _ _ ._ ._. LTOP System B 3.4.13 BASES BACKGROUND Shutdown Coolina System Suction Line Relief Valve (continued) Recuirements. (continued) When a Shutdown Cooling System suction line relief valve lifts due to an increasing pressure transient, the release i of coolant causes the pressure increase to slow and reverse. As the Shutdown Cooling System suction line relief valve releases coolant, the system pressure decreases until valve reseat pressure is reached and the Shutdown Cooling system suction line relief valve closes. l At low temperatures with the Shutdown Cooling System suction line relief valves aligned to the RCS. it is necessary to restrict heatup and cooldown rates to assure that P-T limits are not exceeded. These P-T limits are usually applicable to a finite time period such a one cycle. 5 EFPY. etc. and art based upon irradiation damage prediction by the end of i the period. Accordingly, each time P-T limits change, the LTOP System needs to be reanalyzed and modified, if necessary, to continue its function. ; l Once the RCS is de)ressurized a vent exposed to the containment atmosplere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the i relieving requirements of the transient do not exceed the , i capabilities of the vent. Thus, the vent path must be ' l capable of relieving the flow resulting from the limiting i LTOP mass or heat input transient and maintaining pressure l below the P/T limits. The required vent capacity may be provided by one or more vent paths. For an RCS vent to meet the specified flow capacity, it requires removing all pressurizer safety valves, or similarly establishing a vent by opening the 3ressurizer manway (Ref. 11). The vent path (s) must be a]ove the level of reactor coolant, so as not to drain the RCS when open. l l l (continued) i PALO VERDE UNITS 1.2,3 B 3.4.13-3 REV. A l
l' I LTOP System B 3.4.13 BASES (continued) APPLICABLE Safety analyses (Ref 3) demonstrate that the reactor vessel SAFETY ANALYSES is adequately protected against exceeding the Reference 1 P/T limits during shutdown. In MODES 1, 2. and 3. and in MODE 4 with any RCS cold leg tem)erature exceeding 214 F during cooldown or 291 F during leatup. the pressurizer safety valves prevent RCS pressure from exceeding the Reference 1 limits. At about 214 F and below. during : cooldown or 291*F and below during heatup overpressure ; prevention falls to the OPERABLE Shutdown Cooling System , suction line relief valves or to a dearessurized RCS and a . sufficient sized RCS vent. Each of t1ese means has a , limited overpressure relief capability. The actual temperature at which the pressure in the P/T limit curve falls below the pressurizer safety valve , setpoint increases as the reactor vessel material toughness : decreases due to neutron embrittlement. Each time the P/T lirnt curves are revised, the LTOP System will be re evaluated to ensure its functional requirements can still be ratisfied using the Shutdown Cooling System suction line relief valve method or the depressurized and vented RCS condition. Refereace 3 contains the acceptance limits that satisfy the LTOP requirements. Any change to the RCS must be evaluated against these analyses to determine the impact of the change on the LTOP acceptance limits. Transients that are capable of overpressurizing the RCS are ! categorized as either mass or heat input transients, examples of which follow: Mass Inout Tvoe Transients
- a. Inadvertent safety injection; or j
- b. Charging / letdown flow mismatch. !
l Heat Inout Tvoe Transients
- a. Inadvertent actuation of pressurizer heaters; i
- b. Loss of shutdown cooling (SDC): or j
- c. Reactor coolant pump (RCP) startup with temperature !
asymmetry within the RCS or between the RCS and steam generators. i l l (continued) i PALO VERDE UNITS 1.2.3 B 3.4.13-4 REV. A l
LTOP System i B 3.4.13 L BASES APPLICABLE References 3. 7. 8 and 9 analyses demonstrate that either SAFETY ANALYSES one Shutdown Cooling System suction line relief valve or the (continued) RCS vent can maintain RCS pressure below limits for the two most limiting analyzed events: i a. The start of an idle RCP with secondary water temperature of the SG s 100 F above RCS cold leg temperatures.
- b. An inadvertent SIAS with two HPSI pumps injecting into a water solid RCS. three charging pumps injecting, and letdown isolated.
Fracture mechanics analyses established the temperature of LTOP Applicability at 214 F and below during cooldown and l 291 F and below during heatup. Above these temperatures. f the pressurizer safety vahes provide the reactor vessel pressure protection. The vessel materials ' were assumed to have a neutron irradiation accumulation equal to 32 effect1ve full power years of operation. The consequences of a small break Loss Of Coolant Accident , (LOCA) in LTOP MODE 4 conform to 10 CFR 50.46 and 10 CFR 50. Appendix K (Refs. 4 and 5). , The fracture mechanics analyses show that the vessel is protected when the Shutdown Cooling System suction line relief valves are set to open at or below 467 psig. The i setpoint is derived by modeling the performance of the LTOP System, assuming the limiting allowed LTOP transient. The Shutdown Cooling System suction line relief valves setpoints at or below the derived limit ensure the Reference 1 limits will be met. The Shutdown Cooling System suction line relief valves setpoints will be re-evaluated for compliance when the revised P/T limits conflict with the LTOP analysis limits. The P/T limits are periodically modified as the reactor vessel material toughness decreases due to embrittlement caused by neutron irradiation. Revised P/T limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens. The Bases for LC0 3.4.3. "RCS Pressure and Temperature (P/T) Limits." discuss these examinations. (continued) l PALO VERDE UNITS 1.2.3 B 3.4.13-5 REV. A
t LTOP System B 3.4.13 < BASES APPLICABLE The Shutdown Cooling System suction line relief valves are , SAFETY ANALYSES considered active components. Thus, the_ failure of one. ~ (continued) Shutdown Cooling System suction line relief valve represents 3 the worst case, single active failure. RCS Vent Performance With the RCS depressurized, analyses show a vent size of 16 square inches is capable of mitigating the limiting allowed LTOP overpressure transient. In that event, this i size vent maintains RCS pressure less than the maximum RCS pressure on the P/T limit curve. ; The RCS vent size will also be re-evaluated for compliance ! each time the P/T limit curves are revised based on the results of the vessel material surveillance. The RCS vent is passive and is not subject to active failure. LTOP System satisfies Criterion 2 of 10 CFR 50.36 (c)(2)(ii). 1 LCO This LCO is required to ensure th'at the LTOP System is OPERABLE. The LTOP System is OPERABLE when the pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference 1 limits as a result of an operational transient. The elements of the LC0 that provide overpressure mitigation through pressure relief are: l
- a. Two OPERABLE Shutdown Cooling System suction line relief valves; or
! b. The depressurized RCS and an RCS vent. ( A Shutdown Cooling System suction line relief valve is OPERABLE for LTOP when its isolation valves are open, its lift set)oint is set at 467 psig or less and testing has proven its a)ility to open at that setpoint. ; An RCS vent is OPERABLE when open with an area = 16 square inches. For an RCS vent to meet the specified flow capacity, it requires removing all pressurizer safety valves, or ' similarly establishing a vent by opening the 3ressurizer manway.(Ref. 11). The vent path (s) must be a)ove the level of reactor coolant, so as not to drain the RCS when open. ? (continued) i PALO VERDE UNITS 1,2,3 B 3.4.13-6 REV. B 1
LTOP System B 3.4.13 BASES LC0 Each of these methods of overpressure prevention is capable (continued) of mitigating the limiting LTOP transient. The Note requires that, before an RCP may be started, the l secondary side water temperature (saturation temperature l corresponding to SG pressure) in each SG is s 100 F above each of the RCS cold leg temperatures. Satisfying this condition will preclude a large pressure surge in the RCS l when the RCP is started. l APPLICABILITY This LCO is applicable in MODE 4 when the temperature of any RCS cold leg is s 214 F during cooldown or s 291 F during heatup, in MODE 5. and in MODE 6 when the reactor vessel head is on. The pressurizer safety valves provide overpressure protection that meets the Reference 1 P/T limits above 214 F during cooldown and 291 F during heatup. l The requirements for overpressure arotection in MODES 1, 2 and 3. and in MODE 4 above the LTO) System temperatures are covered by LCO 3.4.10. " Pressurizer Safety Valves - MODES 1.
- 2. and 3," and LCO 3.4.11. " Pressurizer Safety Valves -
MODE 4." When the reactor vessel head is off l overpressurization cannot occur. l l LCO 3.4.3 provides the operational P/T limits for all MODES. l Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event. l The Applicability is modified by a Note stating when one or
- more cold legs reach 214 F. this LC0 remains applicable l l during periods of steady state temaerature conditions until all RCS cold leg temperatures reac1291 F. Also, if a i cooldown is terminated prior to reaching 214 F and a heatup l is commenced, this LCO is ap)licable until all RCS cold leg temperatures reach 291 F. T11s Note provides clarification about Applicability intent. Since PVNGS uses two different temperatures at which the Shutdown Cooling System suction line relief valves must be placed in service there is some possibility of confusion. This Note clarifies those circumstances where the Shutdown Cooling System suction line relief valves must be placed in service.
(continued) PALO VERDE UNITS 1.2.3 B 3.4.13-7 REV. B
( LTOP System ! B 3.4.13 : l BASES (continued) ! ACTIONS A J. i. The Required Action is modified by a Note stating that ' LC0 3.0.4 is not applicable. In MODE 4 when any RCS cold leg temperature is s 214 F during cooldown or s 291 F during heatup with one Shutdown , Cooling System suction line relief valve inoperable. two Shutdown Cooling System suction line relief valves must be - restored to OPERABLE status within a Completion Time of 7 days. Two valves are required to meet the LC0 requirement and to provide low temperature overpressure mitigation while withstanding a single failure of an active component. ! The Completion Time is based on the facts that only one Shutdown Cooling System suction line relief valve is required to mitigate an overpressure transient and that the likelihood of an active failure of the remaining valve path i during this time period is very low. ; i l The consequences of operational events that will ; l
~
overpressure the RCS are more severe at lower temperature ! (Ref. 6). Thus, one required Shutdown Cooling System ! suction line relief valve inoperable in MODE 5 or in MODE 6 with the head on, the Completion Time to restore inoperable valve to OPERABLE status-is 24 hours, l The 24 hour' Completion Time to restore two Shutdown Cooling l System suction line relief valves OPERABLE in MODE 5 or in MODE 6 when the vessel head is on is a reasonable amount of time to investigate and repair several types of Shutdown l Cooling System suction line relief valve failures without , exposure to a lengthy period with only one Shutdown Cooling l System suction line relief valve OPERABLE to protect against overpressure events. l l (continued) PALO VERDE UNITS 1.2.3 B 3.4.13-8 REV. B L _ - . ___
LTOP System
- B 3.4.13 l BASES i
ACTIONS L1 (continued) If two required Shutdown Cooling System suction line relief l valves are inoperable, or if a Recuired Action and the associated Completion Time of Concition A or B are not met.
- the RCS must be depressurized and a vent established within j 8 hours. The vent must be sized at least 16 square inches
'l to ensure the flow capacity is greater than that recuired for the worst case mass input transient reasonable curing the applicable MODES. This action protects the RCPB from a low temperature overpressure event and a possible brittle failure of the reactor vessel. For personnel safety considerations, the RCS cold leg temperature must be reduced to less than 200 F prior to venting. l The Com)letion Time of 8 hours to depressurize and vent the l RCS is 3ased on the time re uired to place the plant in this ! condition and the relativel low probability of an i overpressure event during t is time period due to increased l operator awareness of administrative control requirements. i SURVEILLANCE SR 3.4.13.1 and 3.4.13.2 l REQUIREMENTS SR 3.4.13.1 and SR 3.4.13.2 require verifying that the RCS vent is open a 16 square inches or that the Shutdown Cooling System suction line relief valves be aligned to 3rovide i overpressure protection for the RCS is proven OPERABLE by verifying its open pathway condition either: Shutdown Coolina System suction /line relief valves
- a. Once every 12 hours for a valve that is unlocked, not sealed, or otherwise not secured open in the vent pathway, or
- b. Once every 31 days for a valve that is locked sealed.
or otherwise secured open in the vent pathway. RCS Vent
- a. Once every 12 hours for a vent pathway that is
! unlocked, not sealed, or otherwise not secured open
- b. Once every 31 days for a vent pathway that is locked, sealed, or otherwise secured open.
For an RCS vent to meet the specified flow capacity it requires removing all pressurizer safety valves, or similarly establishing a vent by opening the 3ressurizer
- manway (Ref. 11). The vent path (s) must be a)ove the level of reactor coolant, so as not to drain the RCS when open.
(continued) PALO VERDE UNITS 1.2.3 B 3.4.13-9 REV. B l l t
l ! LTOP System B 3.4.13 BASES l- 1 1 1 ! SURVEILLANCE SR 3.4.13.1 and 3.4.13.2 (continued) I l REQUIREMENTS I The passive vent arrangement must only be open (vent pathway I l exists) to be OPERABLE. These Surveillances need only be l performed if the vent or the Shutdown Cooling System suction l line relief valves are being used to satisfy the ! requirements of this LCO. The Frequencies consider l 0 erating experience with mispositioning of unlocked and 1 cked pathway vent valves, and passive pathway i obstructions. l SR 3.4.13.3 SRs are specified in the Inservice Testing Program. Shutdown Cooling System suction line relief valves are to be tested in accordance with the requirements of Section XI of the ASME Code (Ref. 10), which provides the activities and I the Frequency necessary to satisfy the SRs. The Shutdown Cooling System suction line relief valve set point is 467 psig l REFERENCES 1. 10 CFR 50, Appendix G.
- 2. Generic Letter 88-11.
- 3. UFSAR, Section 15.
- 4. 10 CFR 50.46.
- 5. 10 CFR 50. Appendix K.
l
- 6. Generic Letter 90-06.
- 7. UFSAR. Section 5.2.
- 8. V-PSAC-009. Pressure Transient Analysis.
- 9. V-PSAC-010. Mass Input Pressure Transient in Water i Solid RCS. l
- 10. ASME Boiler and Pressure Vessel Code. Section XI.
I 11. 13-C00-93-016. Sensitivity Study cr ! :ssurizer Vent Paths vs. Days Post Shutdown. i PALO VERDE UNITS 1.2.3 B 3.4.13-10 REV. A
- - ~ . . ._ - .. - - - -- - - ... - .. - _ .- - - . - .. - - .-. ..
RCS Operational LEAKAGE i B 3.4.14-l B 3.4 REACTOR COOLANT SYSTEM (RCS) ! l l B 3.4.14 RCS Operational LEAKAGE i BASES 6 BACKGROUND Components that contain or transport the coolant to or from the reactor core make up the RCS. Component joints are made by welding, bolting, rolling, or pressure loading, and valves isolate connecting systems from the RCS. During plant life, the joint and valve interfaces can produce varying amounts of reactor coolant LEAKAGE. through , either normal operational wear or mechanical deterioration. . The purpose of the RCS Operational LEAKAGE LC0 is to limit system operation in the presence of LEAKAGE from these sources to amounts that do not compromise safety. This LC0 specifies the types and amounts of LEAKAGE. 10 CFR 50. Appendix A. GDC 30 (Ref.1). requires means for detecting and, to the extent ]ractical, identifying the source of reactor coolant LEA (AGE. Regulatory Guide 1.45 - t (Ref. 2) describes acceptable methods for selecting leakage i detection systems. The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring reactor coolant LEAKAGE into the l containment area is necessary. Quickly se)arating the identified LEAKAGE from the unidentified LEAKAGE is i necessary to provide quantitative information to the operators, allowing them to take corrective action should a leak occur detrimental to the safety of the facility and the ; public. , A limited amount of leakage inside containment is expected from auxiliary systems that cannot be made 100% leaktight. - Leakage from these systems should be detected, located, and isolated from the containment atmosphere, if possible, to not interfere with RCS LEAKAGE detection. This LC0 deals wit.h protection of the Reactor Coolant Pressure Boundary (RCPB) from degradation and the core from inadequate cooling, in addition to preventing the accident analysis radiation release assumptions from being exceeded. t The consequences of violating this LCO include the l possibility of a Loss Of Coolant Accident (LOCA). (continued) PALO VERDE UNITS.1.2.3 B 3.4.14-1 REV. A
)
RCS Operational LEAKAGE B 3.4.14 BASES (continued) j i l APPLICABLE Except for primary to secondary LEAKAGE. the safety analyses i SAFETY ANALYSES .do not address operational LEAKAGE. However, other ( operational LEAKAGE is related to the safety analyses for L LOCA: the amount of leakage can affect the probability of such an event. The safety analysis for an event resulting ! l in steam discharge to the atmosphere assumes a 1 gpm primary ! l to secondary LEAKAGE as the initial condition. l Primary to secondary LEAKAGE is a factor in the dose l l releases outside containment resulting from a Steam Line l l Break (SLB) accident. To a lesser extent other accidents 1 l or transients involve secondary steam release to the l atmosphere, such as a Steam Generator Tube Rupture (SGTR). ) The leakage contaminates the secondary fluid. The UFSAR (Ref. 3) analysis for SGTR assumes the contaminated secondary fluid is only briefly released via l safety valves and the majority is steamed to the condenser. ! The 1 gpm primary to secondary LEAKAGE is relatively inconsequential. The SLB is more limiting for site radiation releases. The safety analysis for the SLB accident assumes 1 gpm primary I to secondary LEAKAGE in one generator as an initial l condition. The dose consequences resulting from the SLB l accident are well within the limits defined in 10 CFR 50 or ) the staff approved licensing basis (i.e., a small fraction of these limits). i RCS operational LEAKAGE satisfies Criterion 2 of 10 CFR 50.36 (C)(2)(ii). LCO RCS operational LEAKAGE shall be limited to:
- a. Pressure Boundary LEAKAGE No pressure boundary LEAKAGE is allowed being indicative of material deterioration. LEAKAGE of this type is unacceptable as the leak itself could cause further deterioration, resulting in higher LEAKAGE.
Violation of this LC0 could result in continued . degradation of the RCPB. LEAKAC: 3ast seals and l !. gaskets is not pressure boundary LEAKAGE. i (continued) PALO VERDE UNITS 1.2.3 8 3.4.14-2 REV. A
i 1 RCS Operational LEAKAGE B 3.4.14 BASES i l LC0 b. Unidentified LEAKAGE l (continued)
- One gallon per minute (gpm) of unidentified LEAKAGE is allowed as a reasonable minimum detectable amount that the containment air monitoring and containment sump level monitoring equipment can detect within a reasonable time period. Violation of this LCO could result in continued degradation of the RCPB, if the LEAKAGE is from the pressure boundary,
- c. Identified LEAKAGE i Up to 10 g)m of identified LEAKAGE is considered allowable 3ecause LEAKAGE is from known sources that do not interfere with detection of identified LEAKAGE and is well within the capability of the RCS makeup system. Identified LEAKAGE includes LEAKAGE to the containment from specifically known and . located '
l sources, but does not include pressure boundary l l LEAKAGE or controlled Reactor Coolant Pump (RCP) seal leakoff (a normal function not considered LEAKAGE). . Violation of this LCO could result in continued I degradation of a component or system. i LC0 3.4.14. "RCS Pressure Isolation Valve (PIV) l Leakage." measures leakage through each individual PIV l and can impact this LCO. Of the two PIVs in series in l each isolated line, leakage measured through one PIV l does not result in RCS LEAKAGE when the'other is leaktight. If both valves leak and result in a loss of mass from the RCS. the loss must be included in the allowable identified LEAKAGE.
- d. Primary to Secondary LEAKAGE throuah All Steam Generators (SGs)
Total 3rimary to secondary LEAKAGE amounting to 1 gpm throug1 all SGs produces acceptable offsite doses in the SLB accident analysis. Violation of this LC0 could exceed the offsite dose limits for this accident analysis. Primary to secondary LEAKAGE must be included in the total allowable limit for identified LEAKAGE. i (continued) > l PALO VERDE UNITS 1.2.3 B 3.4.14-3 REV. A
.RCS Operational LEAKAGE B 3.4.14 l
BASES LC0 e. Primary to Secondary LEAKAGE throuah Any One SG l (continued) The 720 gallon per day limit on primary to secondary l LEAKAGE through any one SG allocates the total 1 gpm l allowed primary to secondary LEAKAGE equally between
- the two generators.
APPLICABILITY In MODES 1, 2, 3, and 4, the potential for RCPB LEAKAGE is , greatest when the RCS is pressurized. In MODES 5 and 6. LEAKAGE limits are not required because
- the reactor coolant pressure is far lower, resulting in lower stresses and reduced potentials for LEAKAGE.
l ACTIONS 6.J. ! Unidentified LEAKAGE, identified LEAKAGE, or primary to l secondary LEAKAGE in excess of the LC0 limits must be reduced to within limits within 4 hours. This Completion <
- Time allows time to verify leakage rates and either identify 1 i unidentified LEAKAGE or reduce LEAKAGE to within limits before the reactor must be shut down. This action is necessary to prevent further deterioration of the RCPB. !
B.1 and B.2 l If any pressure boundary LEAKAGE exists or if unidentified. l identified, or primary to secondary LEAKAGE cannot be reduced to within limits within 4 hours, the reactor must be brought to lower pressure conditions to reduce the severity of the LEAKAGE and its potential consequences. The reactor must be brought to MODE 3 within 6 hours and to MODE 5 within 36 hours. This action reduces the LEAKAGE and also i reduces the factors that tend to degrade the pressure l boundary. I r (continued) PALO VERDE UNITS 1.2.3 B 3.4.14-4 REV. A i
-- . .-. . .- . - . . .- _ - . - ~ - . - . . - . . - . . - .
l l' RCS Operational LEAKAGE
- j. .
B,3.4.14 : l'
^
BASES ACTIONS B.1 and B.2 (continued) l The allowed Completion Times are reasonable, based on l operating experience, to reach the required conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 5. the ]ressure stresses acting on the RCPB are much lower, and furtier deterioration is much less likely. C.J. l If one or more SGs are inoperable, due to SR 3.4.14.2, the unit is in a condition outside the accident analyses.
- Therefore. LCO 3.0.3 must be entered immediately.
l SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LC0 limits ensures , the integrity of the RCPB is maintained. Pressure boundary ! l LEAKAGE would at first appear as unidentified LEAKAGE and ! can only be positively identified by inspection. l Unidentified LEAKAGE and identified LEAKAGE are determined ! by performance of an RCS water inventory balance. Primary I to secondary LEAKAGE'is also measured by performance of an RCS water inventory balance.in conjunction with effluent monitoring within the secondary steam and feedwater systems. The RCS water inventory balance must be performed with the reactor at steady state operating conditions and near operating pressure. Therefore, this SR is not required to , be performed in MODES 3 and 4. until 12 hours of steady state o)eration near operating pressure have elapsed. This . means tlat once steady state operating conditions are ! established 12 hours is allowed for completing the Surveillance if the Surveillance Frequency interval was exceeded in MODE 5 or 6. Further discussion of SR note format is found in Section 1.4, Frequency. i (continued) PALO VERDE UNITS 1,2,3 B 3.4.14-5 REV. A
RCS Operational LEAKAGE B 3.4.14 ! BASES l SURVEILLANCE SR 3.4.14,1 (continued) REQUIREMENTS l The Note in the Frequency column allows for SR 3.4.14.1 nonperformance due to planned or unplanned power manipulations. This Note is not intended to allow Jower
- manipulations solely for the purpose of avoiding S13.4.14.1 performance. Steady state operation is required to perform ,
l a proper water inventory balance: calculations during L maneuvering are not useful and a Note requires the j Surveillance to be met when steady state is established. l For RCS operational LEAKAGE determination by water inventory balance, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows. l An early warning of pressure Doundary LEAKAGE or L unidentified LEAKAGE is provided by the automatic systems l" that monitor the containment atmosphere radioactivity and
~
the containment sump level. These leakage detection systems are specified in LCO 3.4.16. "RCS Leakage Detection Instrumentation." - The 72 hour Frequency is a reasonable interval to trend
- LEAKAGE and recognizes the inportance of early leakage l detection in the prevention of accidents. A Note under the i Frequency column states that this SR.is required to be-
- performed during steady state operation.
SR 3.4.14.2 l This SR provides t!ne means recessary to determine SG ! OPERABILITY in an operationtl MODE. The requirement to l demonstrate SG tube integrity in accordance with the Steam Generator Tube Surveillance Program emphasizes the l importance of SG tube integrity, even though this Surveillance cannct be performed at normal operating l conditions. REFERENCES 1. 10 CFR 50. Appendix A. GDC 30.
- 2. Regulatory Guide 1.45. May 1973.
l 3. UFSAR Section 15. i PALO VERDE UNITS 1.2.3 8 3.4.14-6 REV. B rv
RCS PIV Leakage ! B 3.4.15 l t B 3.4 REACTOR COOLANT SYSTEM (RCS) { B 3.4.15 RCS Pressure Isolation Valve (PIV) Leakage 1 i BASES BACKGROUND- 10 CFR 50.2, 10 CFR 50.55a(c). and GDC-55 of 10 CFR 50. l Appendix A (Refs.1. 2. and 3), define RCS PIVs as any two i normally closed valves in series within the RCS pressure l boundary that separate the high pressure RCS from an l attached low pressure system. During their lives.' these l valves can produce varying amounts of reactor coolant leakage through either normal operational wear or mechanical 1 deterioration. The RCS PIV LC0 allows RCS high pressure i operation when leakage through these valves exists in l amounts that do not compromise safety. The PIV leakage limit applies to each individual valve. Leakage through both PIVs in series in a line must be included as part of the identified LEAKAGE. governed by 1 LC0 3.4.14. "RCS Operational LEAKAGE." This is true during J operation only when the loss of RCS mass through two valves l l in series is determined by a water inventory balance ! l (SR 3.4.14.1). A known component of the identified LEAKAGE i L before operation begins is the least of the two individual leakage rates determined for leaking series PIVs during the . l required surveillance testing: leakage measured through one I L PIV in a line is not RCS operational LEAKAGE if the other is ll leaktight. l Although this specification provides a limit on allowable PIV leakage ~ rate, its main purpose is to prevent overpressure failure of the low pressure portions of l connecting systems. The leakage limit is an. indication that
~
the PIVs between the RCS and the connecting systems are degraded or degrading. PIV leakage could lead to overpressure of the low pressure piping or components. Failure consequences could be a Loss of Coolant Accident (LOCA) outside of containment, an unanalyzed condition that could degrade the ability for low pressure injection. L The basis for this LC0 is the 1975 NRC " Reactor Safety l Study" (Ref. 4) that identified potential intersystem LOCAs l as a significant contributor to the risk of core melt. A i subsequent study (Ref. 5) evaluated various PIV l configurations to determine the probability of intersystem LOCAs. (continued) ' l PALO VERDE UNITS 1.2.3 B 3.4.15-1 REV. A e
i l RCS PIV Leakage B 3.4.15 BASES BACKGROUND PIVs are provided to isolate'the RCS from the following (continued) typically connected systems:
- a. Shutdown Cooling (SDC) System; and
- b. Safety Injection System.
The PIVs are listed in UFSAR section (Ref. 6). ! Violation of this LCO could result in continued degradation i of a PIV. which could lead to overpressurization of a low , pressure system and the loss of the integrity of a fission product barrier. APPLICABLE Reference 4 identified potential intersystem LOCAs as a ) SAFETY ANALYSES significant contributor to the risk of core melt. The l dominant accident sequence in the intersystem LOCA category is the failure of the low 3ressure portion of the SDC System outside of containment. T1e accident is the result of a l
)ostulated failure of the PIVs. which are part of the teactor Coolant Pressure Boundary (RCPB), and the subsequent pressurization of the SDC System downstream of the PIVs from !
the RCS. Because the ' low pressure portion of the SDC System ) is typically designed for 485 psig, overpressurization i failure of the SDC low pressure line would result in a LOCA 2 outside containment and subsequent risk of core melt. Reference 5 evaluated various PIV configurations, leakage testing of the valves, and operational changes to determine the effect on the probability of intersystem LOCAs. This study concluded that periodic leakage testing of the PIVs can substantially reduce the probability of an intersystem j LOCA. i RCS PIV leakage satisfies Criterion 2 of 10 CFR 50.36 (C)(2)(ii). l LCO RCS PIV leakage is identified LEAKAGE into closed systems connected to the RCS. Isolation valve leakage is usually on the order of drops per minute. Leakage that increases ! (continued) i PALO VERDE UNITS 1.2.3 B 3.4.15-2 REV. A
RCS PIV Leakage B 3.4.15 BASES LC0 significantly suggests that something is operationally wrong (continued) and corrective action must be taken. The LC0 PIV leakage limit is 0.5 gpm per nominal inch of valve size, with a maximum limit of 5 gpm. The previous criterion of 1 gpm for all valve sizes imposed an unjustified penalty on the larger valves without providing information on potential valve degradation and resulted in higher personnel radiation exposures. A study concluded a leakage rate limit based on valve size was superior to a single allowable value. Reference 7 permits leakage testing at a lower pressure differential than between the specified maximum RCS pressure and the normal pressure of the connected system during RCS operation (the maximum 3ressure differential) in those types of valves in which the ligher service pressure will tend to diminish the overall leakage channel opening. In such cases. the observed rate may be adjusted to the maximum pressure differential by assuming leakage is directly proportional to the pressure differential to the one half power. APPLICABILITY In MODES 1. 2. 3. and 4. this LC0 ap) lies because the PIV leakage potential is greatest when t1e RCS is pressurized. , In MODE 4. valves in the SDC flow path are not required to meet the requirements of this LC0 when in, or during the transition to or from, the SDC mode of operation. In MODES 5 and 6. leakage limits are cot provided because the lower reactor coolant pressure results in a reduced potential for leakage and for a LOCA outside the containment. ACTIONS The Actions are modified by two Notes. Note 1 is added to provide clarification that each flow path allows se)arate entry into a Condition. This is allowed based on t7e functional independence of the flow path. Note 2 requires an evaluation of affected systems if a PIV is inoperable. The leakage may have affected system operability or isolation of a leaking flow path with an alternate valve may (continued) PALO VERDE UNITS 1.2.3 B 3.4.15-3 REV. A l
RCS PIV Leakage ! B 3.4.15 i- !
-BASES ACTIONS have degraded the ability of the interconnected system to :
(continued) perform its safety function. A.1 and A.2 The flowpath must be isolated by two valves. Required 1 I Actions A.1 and A'.2 are modified by a Note stating that the valves used for isolation must meet the same leakage l requirements as PIVs and must be in the RCPB. ' ! Required Action A.1 recuires that the isolation with one valve must be performec within 4 hours. Four hours provides time to reduce leakage'in excess of the allowable limit and to isolate if leakage cannot be reduced. The 4 hours allows i
- the actions and restricts the operation with-leaking
! isolation valves, f L The 72 hour Completion Time after exceeding the limit allows ; i for the restoration of the leaking PIV to OPERABLE status. ! This timeframe considers the time required to complete this l Action and the low probability of a second valve failing ! l during this period. j B.1 and B.2 l- If leakage cannot be reduced the system isolated or. other
~ Required Actions accomplished the plant must be brought to l a MODE in which the LCO does not apply. To achieve this
! status, the plant must be brought to MODE 3 within 6 hours l and to MODE 5 within 36 hours. This Action reduces the leakage and also reduces the potential for a LOCA outside the containment. The allowed Completion Times are reasonable, based on operating experience, to reach the ! recuired plant conditions from full power conditions in an I orcerly manner and without challenging plant systems. SURVEILLANCE SR 3.4 15.1 REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 or A.2 is recuired to verify that leakage is below the s)ecified limit anc to identify each leaking valve. The leacage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition. } (continued)- PALO VF.RDE UNITS 1.2.3 8 3.4.15-4 REV. A
RCS PlV Leakage B 3.4.15 BASES SURVEILLANCE 2 3.4.15.1 (continued) REQUIREMENTS For the two PIVs in series, the leakage requirement ap] lies
.to each valve individually and not to the combined leacage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage rec uirement. In this situation, the protection provided by ,
recundant valves would be lost. l Testing is to be performed every 9 months, but may be extended up to 18 months, a typical refueling cycle, if the plant does not go into MODE 5 for at least 7 days. The , 18 month Frequency is consistent with 10 CFR 50.55a(g) (Ref. 8), is within frequency allowed by the American Society of Mechanical Engineers (ASME) Code. Section XI (Ref. 7). and is based on the need to perform the Surveillance under conditions that apply during a plant outage and the potential for an unalanned transient if the Surveillance were performed with t1e reactor at power. In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours after the valve has been reseated. Within 24 hours is a reasonable and practical time limit for performing this test after opening or reseating a valve. The SDC PIVs excepted in two of the three FRE0VENCIES are l UV-651. UV-652. UV-653. and UV-654 due to position indication of the valves in the control room. Although not explicitly required by SR 3.4.15.1. performance i of leakage testing to verify leakage is below the specified limit must be performed prior to returning a valve to service following maintenance, repair or replacement work on the valve in order to demonstrate operability. t The leakage limit is to be met at the RCS pressure l associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures. (continued) i PALO VERDE UNITS 1.2.3 B 3.4.15-5 REV. B l
l l RCS PlV Leakage L B 3.4.15 1 1 BASES SURVEILLANCE SR 3.4.15.1 (continued) i REQUIREMENTS ! Entry into MODES 3 and 4 is allowed to estabiish the t necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is comalimentary to the Frequency of a 3rior to entry into MDDE 2 wienever the unit has been in iODE 5 for 7 days or more, if leakage testing has not been , i; performed in the previous 9 months. In addition. this ' Surveillance is not required to be performed on the SDC
, System when the SDC System is aligned to the RCS in the i shutdown cooling mode of operation. PIVs contained in the 8
SDC shutdown cooling flow path must be leakage rate tested
- after SDC is secured and stable unit conditions and the
!. necessary differential pressures are established. ; I. ) } SR 3.4.15.2 ) 2 Verifying that the SDC open permissive interlocks are l i OPERABLE ensures that RCS pressure will not pressurize the ; L SDC system beyond 125% of its design pressure of 485 3sig. )
- The interlock setpoint that 3revents the valves from aeing opened is set so the actual RCS pressure must be 410 psia to i
j open the valves. This setpoint ensures the SDC design ' 4 pressure will not be exceeded and the SDC relief valves will not lift. . The 18 month Frecuency is based on the need to perform this Surveillance uncer conditions that apply during , a plant outage. The 18 month Frequency is also acceptable 3 based on consideration of the design reliability (and i confirming operating experience) of the. equipment. d (continued) PALO VERDE UNITS 1.2.3 B 3.4.15-6 REV. B ,
RCS PIV Leakage B 3.4.15 BASES (continued) ; REFERENCES 1. 10 CFR 50.2.
- 2. 10 CFR 50.55a(c). ;
1
- 3. 10 CFR 50. Appendix A. Section V. GDC 55. I
- 4. WASH-1400 (NUREG-75/014) Appendix V. October 1975. !
l
- 5. NUREG-0677. May 1980.
- 6. UFSAR. Section 3.9.6.2 - ;
i
- 7. ASME. Boiler and Pressure Vessel Code. Section XI.
- 8. 10 CFR 50.55a(g).
I 1 l 1 l l I PALO VERDE UNITS 1.2.3 B 3.4.15-7 REV. A
. . . - . - - - - -. ~. - .. . . -_ .- -
RCS Leakage Detection Instrumentation B 3.4.16 B 3.4 REACTOR COOLANT SYSTEM (RCS) l B 3.4.16 RCS Leakage Detection Instrumentation l l BASES I l l l BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref.1) recuires means . ' for detecting and. to the extent 3ractical. icentifying the' l location of the source of RCS LEA (AGE. Regulatory Guide 1.45 (Ref. 2) describes acceptable methods for i l selecting leakage detection systems. I Leakage detection systems must have the capability to detect 1 significant Reactor Coolant Pressure Boundary (RCPB) degradation as soon after occurrence as practical to ! minimize the potential for propagation to a gross tailure. ' Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE. l Industry practice has shown that water flow changes of 0.5 gpm to 1.0 gpm can readily be detected in contained volumes by monitoring changes in water level, in flow rate, , or in the operating frequency of a pump. The containment sump monitor consists of instrumentation used to monitor i containment sump level and flow (pump run time). The 2 containment sump used to collect u11dentified LEAKAGE is instrumented to alarm at 1.0 gpm 2.bove normal flow for 1 hour (Ref. 3). This sensitivity i; acceptable for detecting increases in unidentified LEAKAGE. The reactor coolant contains radioactivity that, when released to the containment, can be detected by radiation ' monitoring instrumentation. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter until activated corrosion products have l been formed and fission products appear from fuel element cladding contamination or cladding defects. Instrument sensitivities of 10 4 monitoring and of 10'fi/ccpCi/ccradioactivity for gaseous radioactivity for particulate monitoring are practical for these leakage detection systems. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and responses to RCS LEAKAGE. l (continued) PALO VERDE UNITS 1.2.3 B 3.4.16-1 REV. A 1 l l
RCS Leakage Detection Instrumentation B 3.4.16 BASES J BACKGROUND An increase in humidity of the containment atmosphere would (continued) indicate release of water vapor to the containment. Dew Joint temperature measurements can'thus be used to monitor lumidity levels of the containment atmosphere as an indicator of potential RCS LEAKAGE. A 1 F increase in dew point is well within the sensitivity range of available instruments. Since the humidity level is influenced by several factors. a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid flow into or from the containment sump. Humidity level monitoring is considered most useful as an indirect alarm or indication to alert the operator to a potential problem. Humidity monitors are not required by this LCO. Air temperature and pressure monitoring methods may also be used to infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values may indicate RCS LEAKAGE into the containment. The relevance of temperature and pressure measurements are affected by containment free volume and, for temperature, detector location. Alarm signals from these instruments can be valuable in recognizing a sizable leakage to the containment. Temperature and pressure l monitors are not required by this LCO. APPLICABLE The need to evaluate the severity of an alarm or an SAFETY ANALYSES indication is important to the operators, and the ability to compare and verify with indications from other systems is necessary. The RCS leakage detection instrumentation is described in the UFSAR (Ref. 3). Multiple instrument locations are utilized, if needed, to help identify the location of the LEAKAGE source. I i i (continued) PALO VERDE UNITS 1.2.3 B 3.4.16-2 REV. A
RCS Leakage Detection Instrumentation B 3.4.16 BASES APPLICABLE The safety significance of RCS LEAKAGE varies widely SAFETY ANALYSES depending on its source, rate, and duration. Therefore. 4 (continued) detecting and monitoring RCS LEAKAGE into the containment area are necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should leakage occur detrimental to the safety of the facility and the public. RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR (C)(2)(ii). ' 2 LC0 One method of protecting against large RCS LEAKAGE derives from the ability of instruments to detect extremely small leaks. This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that extremely small leaks are detected in time , to allow actions to place the plant in a safe condition when RCS LEAKAGE indicates possible RCPB degradation. The LCO is satisfied when monitors of diverse measurement , means are available. Thus, the containment sump monitor in combination with a particulate and gaseous radioactivity monitor (RU-1) provides an acceptable minimum. It has been determined that it is acceptable to continue tc call the containment sump OPERABLE with one containment t. ump pump out of service. APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1,
- 2. 3. and 4. RCS leakage detection instrumentation is required to be OPERABLE.
In MODE 5 or C. the temperature is s 210 F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2. 3. and 4. the likelihood of leakage and crack propagation is much smaller. Therefore, the requirements of this LC0 are not applicable in MODES 5 and 6. 1 i (continued) l PALO VERDE UNITS 1.2.3 B 3.4.16-3 REV. B
f RCS Leakage Detection Instrumentation [ B 3.4.16 - i , BASES (continued) , ACTIONS The Actions are modified by a Note that indicates the I 3rovisions of LCO 3.0.4 are not applicable. As a result, a
)
iODE change is allowed when the containment sump and ' i required containment atmosphere radioactivity monitor , l channels are inoperable. This allowance is provided because l other means are available to monitor for RCS LEAKAGE. t A.1 and A.2
- If the containment sump monitor is inoperable, no other form of sampling can provide the equivalent information.
However, the containment atmosphere radioactivity monitor j will provide indications of changes in leakage. Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance. SR 3.4.14.1 must be performed i at an increased frequency of 24 hours to provide information that is adequate to detect leakage.
- Restoration of the sump monitor to OPERABLE status is-
- required to regain the function in a Completion Time of
. 30 days after the monitor's failure. This time is
- acceptable considering the frequency and adequacy of the RCS
- water inventory balance required by Required Action A.1.
l \ , B.1.1. B.1.2. and B.2
- With either the gaseous or particulate containment i atmosphere radioactivity monitoring instrumentation channels !
L inoperable, alternative action is required. Either grab 4 samples of the containment atmosphere must be taken and analyzed, or water inventory balances, in accordance with SR 3.4.14.1 must be performed to provide alternate periodic information. With a sample obtained and analyzed or an
- inventory balance performed every 24 hours, the reactor may
- be o)erated for up to 30 days to allow restoration of both i of tie radioactivity monitors.
The 24 hour interval provides Jeriodic information that is adequate to detect leakage. T1e 30 day Completion Time 4 recognizes at least one other form of leakage detection is available. i l
! (continued)
PALO VERDE UNITS 1.2.3 B 3.4.16-4 REV. B
l RCS Leakage Detection lnstrumentation ; ! B 3.4.16 l l BASES (continued) i L : ACTIONS _C.,1 (continued) ' l If-any Required Action of Condition A or B cannot be met within the required Completion Time, the plant must be , brought to a MODE in which the LCO does not apply. To ! ! achieve this status, the plant must be brought.to at least l MODE 3 within 6 hours and to MODE 5 within 36 hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full ; power conditions in an orderly manner and without challenging plant systems. D.1 1 If all required monitors are ino3erable, no automatic means of monitoring leakage are availa)le and immediate plant . shutdown in accordance with LCO 3.0.3 is required. ! I SURVEILLANCE SR 3.4.16.1 REQUIREMENTS SR 3.4.16.1 requires the performance of a CHANNEL CHECK of ; the required containment atmosphere radioactivity monitors. ; The check gives reasonable confidence the channel is operating properly. The Frequency of 12 hours is based'on ; instrument reliability and is reasonable for detecting off i normal conditions. S.R_.1.4.16.2 R
],
SR 3.4.16.2 requires the performance of a CHANNEL FUNCTIONAL l TEST of the required containment atmosphere radioactivity monitors. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 92 days considers instrument reliability, and operating experience has shown it proper for detecting degradation. The alarm setpoints for the cor.tainment building atmosphere monitor (RU-1) are: particulate s 2.3 x 10 4pCi/cc CS-137 gaseous s 6.6 x 10 2gCi/cc Xe-133 l l (continued) PALO VERDE UNITS 1.2.3 8 3.4.16-5 REV. B i
a RCS Leakage Detection Instrumentation ! B 3.4.16 l BASES (continued) 1 SURVEILLANCE SR 3.4.16.3. SR 3.4.16.4 REQUIREMENTS (continued) These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation 1 channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Operating experience has shown this Frequency is acceptable. REFERENCES 1. 10 CFR 50. Appendix A. Section IV. GDC 30.
- 2. Regulatory Guide 1.45.
- 3. UFSAR. Section 5.2.5.
l 4 l PALO VERDE UNITS 1.2.3 8 3.4.16-6 REV. A
.. .- = = . .
i l RCS Specific Activity B 3.4.17 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.17 RCS Specific Activity BASES 1 BACKGROUND The Code of Federal Regulations 10 CFR 100 (Ref.1) specifies the maximum dose to the whole body and the thyroid an individual at the site boundary can receive for 2 hours during an accident. The limits on specific activity ensure that the doses are held to a small fraction of the 10 CFR 100 limits during analyzed transients and accidents. The RCS specific activity LC0 limits the allowable concentration level of radionuclides in the reactor coolant. The LC0 limits are established to minimize the offsite radioactivity dose consequences in the event of a steam generator tube rupture (SGTR) accident. The LCO contains specific activity limits for both DOSE EQUIVALENT I-131 and gross specific activity. The allowable levels are intended to limit the 2 hour dose at the site boundary to a small fraction of the 10 CFR 100 dose guideline limits. The limits in the LCO are standardized I based on parametric evaluations of offsite radioactivity dose consequences for typical site locations. The parametric evaluations showed the potential offsite dose i levels for an SGTR accident were an appropriately small ) fraction of the 10 CFR 100 dose guideline limits. Each evaluation assumes a broad range of site applicable atmospheric dispersion factors in a parametric evaluation. i APPLICABLE The LCO limits on the specific activity of the reactor SAFETY ANALYSES coolant ensure that the resulting 2 hour doses at the site ; boundary will not exceed a small fraction of the 10 CFR 100 dose guideline limits following an SGTR accident. The SGTR safety analysis (Ref. 2) assumes the specific activity of the reactor coolant at the LCO limits and an existing reactor coolant steam generator (SG) tube leakage rate of 1 gpm. The analysis for the SGTR accident establishes the acceptance limits for RCS specific activity. Reference to l (continued) f PALO VERDE UNITS 1.2.3 B 3.4.1'-1 REV. A
l-RCS Specific Activity i B 3.4.17 BASES l APPLICABLE this analysis is used to assess changes to the facility that $ SAFETY ANALYSES could affect RCS specific activity as they relate to the (continued) acceptance limits. ' t l The rise in pressure -in the ruptured SG causes radioactively ' ! contaminated steam to discharge to the atmosphere through , l the atmospheric dump valves or the main steam safety valves. l The atmospheric discharge stops when the turbine bypass to the condenser removes the excess energy to rapidly reduce : the RCS pressure and close the valves. The unaffected SG ' L removes core decay heat by venting steam until the cooldown ! ends. The safety analysis shows the. radiological consequences of an SGTR accident are within a small fraction of the Reference 1 dose guideline limits. 0)eration with iodine specific activity levels greater than , tie.LCO limit is permissible if the activity levels do not : exceed the limits shown in Figure 3.4.17-1 for more than . L 48 hours. The above-limit permissible iodine levels shown in Figure 3.4.17-1 are acceptable because of the low probability of an SGTR accident occurring during the , established 48 hour time limit The allowable limits shown on Figure 3.4.17-1 accomodate bossible iodine spiking phenomenon which may occur following changes in thermal power. RCS specific activity satisfies Cri.terion 2 of 10 CFR 50.36 (c)(2)(ii). LCO The specific iodine activity is limited to 1.0 pCi/gm DOSE EQUIVALENT I-131. and the gross specific activity in the primary coolant is limited to the number of pCi/gm equal to i 100 divided by E (average disintegration energy of the sum of the average beta and gama energies of the coolant-nuclides). The limit on DOSE EQUIVALENT I-131 ensures the. 2 hour thyroid dose to an individual at the site boundary during the Design Basis Accident (DBA) will be a small l fraction of the allowed thyroid dose. The limit on gross specific activity ensures the 2 hour whole body dose to an ; individual at the site boundary during the DBA will be a 1 L small fraction of the allowed whole body dose. ! l (continued) l PALO VERDE UNITS 1.2.3 B 3.4.17-2 REV. B lw i ,s - - - . - - m _..,m - . . . . ..w-m--, -, ,. v-...- , j
RCS Specific Activity l B 3.4.17 L
' BASES LCO The SGTR accident analysis (Ref. 2) shows that the 2 hour (continued) site boundary dose levels are within acceptable limits.
Violation of the LC0 may result in reactor coolant ' radioactivity levels that could, in the event of an SGTR. ' l lead to site. boundary doses that exceed the 10 CFR 100 dose ; guideline limits. i APPLICABILITY In MODES 1 and 2. and in MODE 3 with RCS cold leg tem 3erature a 500 F. operation within the LC0 limits for . DOSE EQUIVALENT I-131 and gross specific activity is ! necessary to contain the potential consequences of an SGTR to within the acceptable site boundary dose values. . For operation in MODE 3 with RCS cold leg temperature
< 500 F. and in MODES 4 and 5. the release of radioactivity !
in the event of an SGTR is unlikely since the saturation - i pressure of the reactor coolant is below the' lift pressure - settings of the atmospheric dump valves and main steam ! safety valves. j ACTIONS A.1 and A.2 , With the DOSE EQUIVALENT I-131 greater than the LCO limit, , samples at intervals of 4 hours must be taken to demonstrate l the limits of Figure 3.4.17-1 are not exceeded. The ' Completion Time of 4 hours is required to obtain and analyze a sample. Sampling must continue for trending. The DOSE EQUIVALENT
- I-131 must be restored to within limits within 48 hours.
The Completion Time of 48 hours is required if the limit violation resulted from normal lodine spiking. i l (continued) i l PALO VERDE UNITS 1.2.3 B 3.4.17-3 REV. A
RCS Specific Activity B 3.4.17 i BASES j ACTIONS A.1 and A.2 (continued)
- A Note to the Required Actions of Condition A excludes the i MODE change restriction of LC0 3.0.4. This exception allows entry into the applicable MODE (S) while relying on the
, ' ACTIONS even though the ACTIONS may eventually require plant j shutdown. This exception is acceptable due to the significant conservatism incorporated into the specific activity limit, the low probability of an event which is limiting due to exceeding this limit, and the ability to restore transient specific activity excursions while the
- plant remains at, or proceeds to power operation.
fL1 } If a Required Action and associated Completion Time of Condition A is not met or if the DOSE EQUIVALENT I-131 is in the unacceptable region of Figure 3.4.17-1. the reactor must
- be brought to MODE 3 with RCS cold leg temperature < 500 F
! within 6 hours. The allowed Completion Time of 6 hours is required to reach MODE 3 below 500 F without challenging plant systems. C.1 and C.2 With the gross specific activity in excess of the allowed limit an analysis must be performed within 4 hours to determine DOSE EQUIVALENT I-131. The Completion Time of 4 hours is required to obtain and analyze a sample. The change within 6 hours to MODE 3 and RCS cold leg temperature < 500 F lowers the saturation pressure of the l reactor coolant below the setpoints of the main steam safety valves and minimizes the potential for venting the SG to the environment in an SGTR event. The allowed Completion Time of 6 hours is required to reach MODE 3 below 500 F from full power conditions and without challenging plant systems. I l l (continued) PALO VERDE UNITS 1.2.3 B 3.4.17-4 REV. A
i
- RCS Specific Activity '
B 3.4.17 l BASES (continued) SURVEILLANCE- SR 3.4.17.1 REQUIREMENTS The Surveillance requires aerforming a gamma. isotopic analysis as a measure of tie gross specific activity of the ! reactor coolant at least once per 7 days. While basically a i quantitative measure of radionuclides with half lives longer
'than 15 minutes, excluding iodines, this measurement is the sum of the degassed gamma activities and the gaseous gamma l' activities in the sample taken. This Surveillance provides -
an indication of any increase in gross specific activity, i Trending the results of this Surveillance allows proper
- remedial action to be taken before reaching the LC0 limit under normal operating conditions. The Surveillance is applicable in MODES 1 and 2. and in MODE 3 with RCS cold leg l temperature at least 500 F. The 7 day Frequency considers the unlikelihood of a gross fuel failure during the time.
-i SR 3.4.17.2 l This Surveillance is performed to ensure iodine remains >
within limit during normal operation and following fast
)ower changes when fuel failure is more apt to occur. ,
Juring normal operation, the 14 day Frequency is adequate to a trend changes in the iodine activity level considering gross activity is monitored every 7 days. The 14 day surveillance l frequency is modified by the Note "Only required to be performed in MODE 1." This is acceptable because the level i of fission aroducts generated in MODES 2 and 3 is much less than in MODE 1. The Frequency, between 2 hours and 6 hours 1 after a )ower change of a 15% RTP within a 1 hour period, is ' establisled because the iodine levels peak during this time following fuel failure: samples at other times would provide inaccurate results. One sample is sufficient if the plant has gone through a shutdown or if the transient is complete in 6 hours. SR 3.4.17.2 14 day Frequency is modified by a Note which requires the Surveillance to only be performed in MODE 1. This is required because the level of fission products
. generated in other MODES is much less. Also, fuel failures associated with fast power changes is more apt to occur in MODE 1 than in MODES 2 or 3.
(continued) PALO VERDE UNITS 1.2.3 B 3.4.17-5 r<EV. B
RCS Specific Activity B 3.4.17 BASES SURVEILLANCE SR 3.4.17.3 REQUIREMENTS (continued) A radiochemical analysis for [ determination is required , every 184 days (6 months) with the plant operating in MODE 1 equilibrium conditions. The E determination directly relates to the LCO and is required to verify plant operation within the specified gross activity LC0 limit. The analysis for E is a measurement of the average energies per disintegration for isotopes with half lives longer than 15 minutes excluding iodines. The Frequency of 184 days recognizes [ does not change rapidly This SR has been modified by a Note that indicates sampling is required to be performed within 31 days after 2 effective full power days and 20 days of MODE 1 operation have elapsed since the reactor was last subcritical for a 48 hours should the 184 day Frequency interval be exceeded. Further discussion of SR Note format is found in Section 1.4 Frequency. This ensures the radioactive materials are at equilibrium so the analysis for E is representative and not skewed by a crud burst or other similar abnormal event. REFERENCES 1. 10 CFR 100.11, 1973. I
- 2. UFSAR. Section 15.6.3. l l
PALO VERDE UNITS 1.2.3 B 3.4.17-6 REV. A
l t l i l CE STS NUREG-1432 REV. I j SPECIFICATION 3.4.1 MARK UP l l l i l I l l
1 l l l 1 g RCSPressure, Temperature,andFlow[DNB{Lm CT - j 3.4 REACTOR COOLANT SYSlEM (RCS) 3.4.1 RCS Pressure, Temperature, and Flow { Departure from Nucleate Boiling (DNB)KLimits LC0 3.4.1 RCS DNB parameters for pressurizer pressure, cold leg temperature, and RCS total flow rate shall be within the ; limits specified below: g d L(,0 3.C..D a. Pressurizer pressure 2 psia and 5 psia; k(,Q 3,1,(o) b. RCS cold leg temperature T [535]'F d 5 [558) 6J me ors \h ] 70] ibm Eye. 3$.I*I
- (LCD.S.r. 6 ) . c. 1 flow rate E6] hour gncys [17f.6 g 55.B A y 2
APPLICABILITY: MODE 1 o, FCb ich\ ChuEchat. j f , hatt.h i sed 2 for cr.o or o,, , Pressurizer pressure limit does not apply during: (C0( L,\ h I a. THERMAL POWER ramp > 5% RTP per minute; or j I
- b. THERMAL POWER step > 10% RTP.
==
j -%- _- Mom i ev Ecs c td 19 +eaircraba U< ) M ope 1 Wefk Kaff li A r Ec5 cold leg femperebe f Tc h ACTIONS _ CONDITION REQUIRED ACTION COMPLETION TIME l h ,2.,5 X,T. ) A. P ssuriz/r pres /ure 1 A.] Restore girarapeerty; 2 hours ; CS flow r3te not k to within limit. I withinlimitK. 'N (.1.E.!kAr."T7 B. Required Action and 8.1 Be in MODE 2. 6 hours 2 associated Completion Time of Condition A not met. t (continued)
.) x.f .
B) )(/0Z/J9
' i 1\b 3 QUede \,1,'o 3.4-1 Re,(q.,
MT
l l
, 1 RCSPressure, Temperature,andFlow(DNB[ Limits 3.4.1 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME 1 Q~ g (QtPW_LtLQ - C.! 2 hours 3.E.(eh)C.XScold ure not w W n\ R Restore [c e ' " (3.7..% AC.T) kehe t h,2,,6 QT)D. Required Action and D.1 Rguce THERM. POWERT 6 hours associated Completion W s' [301%/TP. f)
<3 E S $N C Time of Condition C not met.
'^
- -__j SU'RVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.8. .$ SR 3.4.1.1 Verify urizer pressure 2 a 12 hour [
'"' 5 3_.g -
,2,, (,a SR 3.4.1.2 Verifv RCS cold leo temperatur 12 houri ena wsam/eM[B t gg;vam%c1. _
4.2. ,3 SR 3.4.1.3 -------------------NOTE i Required to be met in MODE 1 with all RCPs running. Ver'fy RCS,t I w ra 12 hours b J y V (continued) 7dbUrda - UnAs \,L,b 6 du pr'.,] 3.4-2 Rev 04 #7 /YJ
~ -_ - .- - . - . . - - , . . .
l {- l l I l j l RCSPressure, Temperature,andFlow{DNkLimits l l t 3.4.1 l SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY l p. 3.4.1 4 - --
----/-------NOTE
--^-
l Notrequirfdtobeperformed[ntil [24] hour after2[90]%RTPf j 1 Veri fy y precision heat 1itsspecifiedi lance that RCS [18] months l ' total f ow rate within 1 the C0 R.
%^ tib wrc tuu us 4 tma ,e c 1 v.s . (.o,s. hr 616p,4. 3 t-\ l t )
i s g O G'dO.,-Onhd) k d [D 3.4-3 h RevK 03Ar//jpf)
4 Qhakm hA.\
-r j
FIG URE -._ . s.NSERT) a REACTOR COOLANT COLD LEG '
- TE.TIPERATURE VS. CORE POWER LEVEL 4
575 I 1 I i i i 1 J i i 4-
,u. 570 -
(30.568). 570 -
,g 8 i 5 565 h 565 -
] F 560 A
\ (100.560) ,
560 N's ....::';;:...,4. L 4 l
\ -
NN h \ s so _ / , 8
\ 545 p-- ,
545 - ! I i 540 .' j 10 20 30 40 50. 60 70 80-
- . SO 100 CORE POWER LEVEL,t'. OF RATED THERMAL POWER (3876 M,W)
REACTOR COOLANT COLD LEG TEMPERATURE vs. CORE POWER LEVEL v& i be. CT5 Fye. 3,F_-l~/1T5 5.us. SAa-i f<orn CTd 3/4 2-IL +o hace. g
/
A M h \,Lp C
a w- .a--4 _m a a 4 __ aA ,,4 J A- . _ s-- -A-.J._J & J4 . % CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.1 BASES MARK UP t
l l l l RCS Pressure. Temperature, and Flow DNB Limits 3.4.1 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.1 RCS Pressure, Temperature, and Flow [ Departure from Nucleate Boiling (DNB)KLimits BASES BACKGROUND These Bases address requirements for maintaining RCS pressure, temperature, and flow rate within limits assumed in the safety analyses. The safety analyses (Ref. 1) of normal operating conditions and anticipated operational occurrences assume initial conditions within the normal steady state envelope. The limits placed on DNB related parameters ensure that these parameters will not be less conservative than were assumed in the analyses and thereby provide assurance that the minimum eparture from cleat hoiling (atio (DNBR) will meet the required criteri 4 p/ each of transients analyzed.
~
The LCO ts for minimum and maximum RCS pressures as measured at the pressurizer are consistent with operation within the nominal operating envelope and are bounded by those used as the initial pressures in the analyses. _ The LCO limits for minimum and maximum RCS cold leg I temperatures d are consistent with operation at the indicated gm m power levegand are bounded by those used as the initial t Jah h Arten saf temperatures in the analyses.' ; i Y The LCO limit)( for minimum guvmeLRCS flow ratel eae-bounded by those used as the initial flow rates in the L bn in E wre. 3 analyses. The RCS flow rate is not expected to vary during g 3.g plant operation with all pumps running. APPLICABLE The requirements of LCO 3.4.1 represent the initial SAFETY ANALYSES conditions for DNB limited transients analyzed in the safety analyses (Ref. 1). The safety analyses have shown that transients initiated fr th3 limits of this LCO will meet the DNBR criterion of 2 1.35 This is the acceptance limit for the RCS DNB paramet rs. Changes to the facility that could impact these parameters must be assessed for their impact on the DNBR criterion. The transients analyzed for include loss of coolant flow events and dropped or st)(uck 0 hpntrolAlementyssembly(CEA) events. A key assumption for tne an ysis of these events is that the core power 1
& /-/ (continued)
I _f - B 3.4-1 Rev fi/0]d) w'A;5/9a . w w
RCS Pressure, Temperature, and Flow DNB Lm BASES APPLICABLE distributioniswithinthelimitsof_fj.003.1.7," Regulating SAFETY ANALYSES CEA Insertion Limits"; LCO 3.1.8, "Part length CEA (continued) Insertion Limits"; LCO 3.2.3, " AZIMUTHAL POWER TILT (T,)"; and LCO 3.2.5. " AXIAL SHAPE INDEX (ASI) "" : W : g LC 3.1.7, "R ulating Rod Josertion Lim yT" ; LLO' 3. 2 A ,7
" MUTHAL P0 R TILT (T )"f and LCO 3.2.y, "AXI AL SHWE 1 DEX (Anal )*1f ine safety analyses are performed ov mc &
the following range of initial values: RCS press 15 57c. F, ano ^ g_y we-two reactor uma inlet vessel core coolant inlet temperature flow rate 9f@;.,0-;;^ E (-
? Th_e RCS DNB it g y_Cr_it fyhe NRC @
mNmu V to FEL so.Mm (C.T 2.T(II) .h, LCO This LCO specifies limits on the monitored process variables-RCS pressurizer pressure, RCS cold leg temperature, and RCS total flow rate-to ensure that the core operates within the limits assumed for the plant safety b analyses. Operating within these limits will result in meeting the D R criterion in the event of a DNB limite $ transient g The LCO merical value for(or6ssure.AemoeraMee, apO flow rate given for the measurement location but Melnot n been adjusted for instrument error. Plant specific limits c of instrument error are established by the olant staff to meet the operational requirements o )(is C 3 yro rrt.y q b t o lo APPLICABILITY In MODE If the/imits on /CS presshizer pre /sure, RCVcold X 4/ Qe m eraturf. and RCSfflow ratsmust be maintained ourlog Hea y 5 ate operation in order to ensure that DNBR criteria will be met in the event of an unplanned loss of forced / coolant flow or other DNB limited transient. In all other 'N \ MODES, the power level is low enough so that DNBR is r.ot a concern. A Note has been added to indicate the limit on pressurizer pressure may be exceeded during short term operational transients such as a THERMAL POWER ramp increase of > 5% RTP per minute or a THERMAL POWER step increase of > 10% RTP. These conditions represent short term perturbations where actions to control pressure variations might be (continued) N C rA rIo B 3.4-2 Rev(IM4/97S9 NNWYCWL.- Ordtc \ g 2. ) % 1
. INSERT FOR ITS BASES 3.4.1 I APPLICABILITY BASES (Units i, ?, and 3) , INSER_13 i-APPLICABILITY for RCS flow rate, MODES I and 2 for RCS pressurizer pressure, MODE 1 for RCS cold leg temperature, and MODE 2 with K,g> 1 for ! RCS cold leg temperature, the limits l I I
l s f I i l l l l l l 1 RCSPressureTemperature,andFlowfDNB Limits 3.4.1 .! l 3 BASES APPLICABILITY counte-productive. Also,fsinc/they repr/sent tranfient (continued) ( iryrtiaced ffom powee'1evels (A00% RTP. In increased N margin exists to offset the temporary pressure variations. Another set of limits on DNB related parameters is provided in Safety Limit (SL) 2.1.1, " Reactor Core Safety Limits." Those limits are less restrictive than the limits of this LCO, but violation of SLs merits a stricter, more severe Required Action. Should a violation of this LCO occur, the , operator should check whether or not an SL may have been i exceeded. I ACTIONS L1 4 [ Pressur zer pressure is a co rollable and measur le ( parame er, ilith this param er not within the L limits, , i actio must be taken to re ore the parameter. Th 2 hour Completion Ti is based on plant crating j e erience that shows t parameter can be r. stored in this me period. RCS flow' rate is not a controllable parameter and is not expected to vary during steady state operation. If the flow rate is not within the LCO limit, then power must be j redu:ed, as required by Required Action B.1, to restore DNB j margin and eliminate the potential for violation of the 10 accident analysis bounds. m e
@ brado The 2 hour Completion Time for restoration of dw carmnetecy provides sufficient time ce cam 1 ei n car R.asto determine the cause of the off normal condition, and Yo
~
restore the readings within limits. The Completion Time is based on plant operating experience. L1 If Required Action A.1 is not met within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 2 within 6 hours. In MODE 2, the reduced power condition eliminates the potential for violation of the accident analysis bounds. } (continued) (c.s4G 5(D B 3.4-3 Rev 6,/t4 /07/93
- e 'Pob Verde,- Unb ?-lb
1 RCSPressure, Temperature,andflowkDNB Limits 3.4.1 BASES ACTIONS jL1 (continued) Six hours is a reasonable time that permits the plant power I to be reduced at an orderly rate in conjunction with even p- control o eam g g tor (SG) heat removal.
, A g rce60/L20.r (c.l":ts.kO od old leg temperature controllable and measurable vamcTen If parameter is not within the LCO limits, !
.. action must be en to restore the parameter, cfN, The 2 hour Com ion Time is based on plant operating experience that shows that parag(etTD can be restored in 6 this time period. Q gag g N ph k h d nrs MDD6. 3. '
If Required ActionM.1 s not met within h_e assoc e Comoletion Ti i w1AL PO must be r ced to 5[ %FRlP. nt operat n may conti for an inde it p lod of tim in this c itien. At e reduced no l vel theo potential for violation of th DNB limits is I grea yTeduced. gg3 The 6 hour Completion Time is a reasonable time that permits power reduction at an orderly rate in conjunction with even control of SG heat removal. SURVEILLANCE LR 3.4.1.1 b i REQUIREMENTS Since Required Action 1 allows a Completion Time of 2 hours to restore para,eters that are not within limits, the 12 hour Surveillance frequency for pressurizer pressure is sufficient to ensure that the pressure can be restored to a normal operation, steady state condition folinwing load changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and i l verify operation is within safety analysis assumptions. (continued) (CIM5G StD B 3.4-4 Rev b4 mM19 m
?cAo Verde. - Onb bbb
I I l j l I RCSPressure, Temperature,andFlow[0NBYLimits 8'B 3.4.1
' BASES SURVEILLANCE SR 3.4.1.2 <
I REQUIREMENTS (continued) Since Required Action 1 allows a Completion Time of I 2 hours to restore parameters that are not within limits, J the 12 hour Surveillance Frequency for cold leg temperature is sufficient to ensure that the RCS coolant temperature can be restored to a normal operation, steady state condition following load changes and other expected transient operations. The 12 hour interval has been shown by operating practice to be sufficient to regularly assess for potential degradation and to verify operation is within
. safety analysis assumptions.
SR 3.4.1.3 The 12 hour Surveillance Frequency for RCS total flow rate I is performed using the installed flow instrumentation. The 12 hour Frequency has been shown by operating experience to be sufficient to assess for potential degradation and to verify operation is within safety analysis assumptions. q This SR is modified by a Note that only requires performance f of this SR in MODE 1. The Note is necessary to allow measurement of RCS flow rate at normal operating conditions at power with all RCPs running. hR 3.4.1.4 Measurement of CS total flow r e by performane of a precision ca rimetric heat ba nee once every 18) months. This allow he installed RCS flow instrument ton to be calibrate and verifies tha the actual RCS ow rate is within e bounds of the a lyses. The F equency of (18) m ths reflects th importance of ver, ying flow after a efueling outage here the core has b altered, which have caused an iteration of flow sistance. The SR is modifi by a Note that ates the SR is on1 required to be eformed [24) hou s after ;t [90]% RTP The L Note is neces to allow meas ement of the flow te at T Qormal operat g conditions at ower in MODE 1. T 4
} (continued) frihcITD B 3.4-5 Rev(t/04/Df/99 O YGirdt,
- UNh Mh
. ~ . . .. . - , . . . . - . _ - . . ~ . . . . - .- - - . . - - ..
l i P i I RCSPressure, Temperature,andFlowfDN Limits 3.4.1 f l BASES ! SURVEILLANCE SR 3.4.1.4 (continued) . _ . . . REQUIREMENTS- f 3
-Survell nce cannot b performed in E 2 or below, nd l
will t yield accu te results if rformed below RTP.~) s REFERENCES E 1. FSAR,SectionX15%. l
~
1 i
)
l I r ! Bi bde. Unsh 1,a 3 (Dk
-~ Rev ;, ::/; i;",
C !?! B 3.4-6
= -
NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.1 I I t l
i ! PALO VERDE ITS CONVERSION l NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.1 - RCS Pressure, Temperature, and Flow (DNB) Limits
- 1. ITS 3.4.1 uses a figure to stipulate area of acceptable operation for RCS cold leg temperature. NUREG-1432. 3.4.1. uses textual description to
! describe the area of acceptable operation for RCS cold leg temperature. l Because PVNGS plant specific data concerning RCS cold leg temperature is l not conducive to textual format. PVNGS will continue to apply the current l licensing basis and use Figure 3.4.1-1 in ITS for RCS cold leg i temperature. The Bases has also been revised to be consistent with the LC0. l 2. The plant specific titles, nomenclature, number, parameter /value reference, system description, system design, operating practices or : ! analysis description was used (additions. deletions, and/or changes are included). Plant specific parameter / values are directly transferred from t the CTS to the ITS. ;
- 3. ITS eliminates the NUREG-1432. SR 3.4.1.4 requirement to perform a precision heat balance every 18 months to ensure total RCS flow rate is within limits specified in the COLR. ITS 3.3.1. Reactor Protective Instrumentation - Operating, allows the use of either calorimetric or RCP differential pressure instrumentation with ultrasonic flow meter adjusted RCP curves for flow verification. PVNGS uses the RCP differential pressure -
instrumentation with ultrasonic flow meter adjusted RCP curves option and , will continue its use due do the additional margin it provides in the ! safety analyses. Use of the calorimetric method penalizes PVNGS safety analyses with less margin. RCS flow rate verification, by use of RCP differential pressure instrumentation with ultrasonic flev meter adjusted , RCP curves, ensures that the actual flow rate is within the bounds of the i safety analysis and the PVNGS Cycle Independent Data Assumption List. Also. ITS SRs 3.3.1.2 and 3.3.1.5 satisfy NUREG-1432 SR 3.4.1.4 on a 12 hour and 31 day Frequency. respectively, rather than an 18 month Frequency. Performing NUREG-1432 SR 3.4.1.4 precision heat balance every ; 18 months is not needed when CTS licensing bases allows use of the RCP l differential pressure instrumentation with ultrasonic flow meter adjusted RCP curves method on a 12 hour and 31 day Frequency. This is consistent with PVNGS licensing basis. l l l l l PALO VERDE - UNITS 1,2, AND 3 1 REV.A I
l PALO VERDE ITS CONVERSION , NIJREG-1432 EXCEPTIONS j SPECIFICATION 3.4.1 - RCS Pressure, Temperature, and Flow (DNB) Limits ) 1 l 4. NUREG-1432. 3.4.1. requires that the Unit enter MODE 2 if pressurizer ! l pressure is not within limits for > 2 hours. Also, NUREG-1432, 3.4.1. l allows a power reduction to approximately 30% when RCS cold leg i l temperature is not within limits for > 2 hours. ITS 3.4.1 requires that ! l the Unit enter MODE 3 under the same circumstances for pressurizer l pressure and RCS cold leg temperature. This is based on the fact that j there exists safety analysis for Heat Removal Accidents. CEA Ejection, and ) Steam Line Break in MODES 1 and 2 that assume pressurizer pressure and RCS ! cold leg temperature are within expected values for initial conditions. These expected values are derived from the pressurizer pressure and RCS cold leg temperature parameter values stated in the ITS. Therefore. PVNGS will continue to use MODE 1 and 2 Applicability for pressurizer pressure and RCS cold leg temperature, and require Unit entry into MODE 3 if corrective Actions can not restore, within 2 hours, the parameter (s) to i within limits. Also, pressurizer pressure is moved from Action A to ' Action C since RCS cold leg temperature and pressurizer pressure have the same Actions. This is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO. i 5. NUREG-1432. 3.4.1 LCO Bases, makes a statement that the numerical values for pressure, temperature, and flow rate are given for the measurement location but have not been adjusted for instrument error. ITS 3.4.1 does not include this statement, as it pertains to pressurizer pressure and cold leg temperature, as part of the LC0 Bases. The values for pressurizer pressure and cold leg temperature used in ITS 3.4.1 are already compensated for instrument error. This is consistent with PVNGS licensing basis.
- 6. NUREG-1432. LC0 3.4.1 includes a maximum RCS flow rate value. ITS LCO 3.4.1 does not use a maximum RCS flow rate value. Maximum RCS flow rate is not a parameter considered to be limiting by PVNGS safety analysis. PVNGS UFSAR clearly implies that the minimum RCS flow rate will be used for thermal margin analysis. It also clearly states that design maximum flow rate is used in the determination of design hydraulic loads, without mentioning thermal analysis. This is logical as design maximum flow rate is not a concern for thermal margin analyses, higher flow rates will only l produce better (larger) margins to DNB. Since RCS flow rate is not a l controllable parameter, is not expected to vary during steady state l operation, and maximum flow rate is not used in thermal margin analysis, there is no reason to include RCS maximum flow rate as part of LCO 3.4.1.
The removal of RCS maximum flow rate is a deviation from NUREG-1432 but is consistent with PVNGS Licensing basis. The Bases has also been revised to be consistent with the LCO. j PALO VERDE - UNITS 1,2. AND 3 2 REV.A
PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.1 - RCS Pressure, Temperature, and Flow (DNB) Limits I l
- 7. NUREG-1432. 3.4.1 Applicability Bases states that since transients are initiated from power levels < 100%, an increased DNBR margin exists to offset 'any temporary pressure variations. This implies that the 4
pressurizer pressure exclusion does not apply a 100% RTP. This is not i correct. PVNGS is digital plant with CPCs that dynamically monitor pressure, flow rate, and power to calculate DNBR. If the condition arises where high power, low flow, and low pressure cause DNBR to approach its ' safety limit, a reactor trip will occur. Sufficient DNBA is maintained at any power level since CPCs dynamically monitors DNBR and trips 'he reactor ! prior to challenging the DNBR safety limit. The bases has been modified so i that it does not infer this exclusion only applies < 100% RTP. The bases states, "Also, DNBR margin exists to offset the temporary pressure variations." This is consistent with PVNGS licensing basis.
- 8. Grammar and/or editorial changes have been made to enhance clarity. No technical or intent changes to the Specification are made by this change.
. 9. PVNGS is not an analog plant therefore, any references to analog TSs or SRs have been deleted.
- 10. Bases section deleted / revised because the associated Specification / Surveillance was deleted / revised. j PALO VERDE - UNITS 1,2. AND 3 3 REV.A
PVNGS CTS : j SPECIFICATION 3.4.1 l MARK UP i l j I i , j l l l I
l I(th4.JO b.k.
~ f ~ .. f a b,k 2ff_. CA N #b /
(P4WER DISTR}4UT
, ~. ,- ~J"W ~.
34 \ i R LOW R#Ib TYZ91SL.,D.Dij AM. AND Fw be.toATA.E.
% hfan }NJ ' F ATf., tOMW (DMM(J.M"L.TD RINTING CMDTTIWJOR hPUmTIOM ' h D 5.4.\.c.. The actual Reactor Coolant System total flow rate shall be greater than or equal to 155.8 x 108 lba/h*.
APPLICABILITY: MODE 1. ACTION: h h %oy m4a. o p n lyme5, m 2 rats,
> l.g'I With the actual Rene or Coolant System total flow rateMemigd to-pEffeld 7g han the above limit reduce THERMAL POWER to less than 5% of RATED THERMAL ]
"' " " i ' " ' " '"' "' * *f " '# ) '
/ Tb -
SURVEILLANCEREQUIReMEh1 / . t-+ The actual Reactor Coolant System total flow rate shall be determined M b.k.k. to be greater than or equal to its limit at least once per 12 hours. QORM~h -
.$hhi.\,b und we> bL m 4- m NDDE. \
g
- usk .o\\
SLPa runnsq-.-- - - - -M ,
-- A e -
I Nove cTI Ih,2. f (< o-crs g z g y, 4 f t., , l l l l 3/4 2-6 Palo Verde - Units 1, 2, 3 l l l l
b hlMM d. 4. I ik ^ hYv4rr (4 DiMCUW k
'-~" y -
3,k \ 0 / ^ . C . ', ' 0 70': 000it,%T COLD LEG TEMPERATURE,lub % tsuvu, rm mg "LLI% ( D A2h lim 1Tb tim unu ce,Diiio, r; :=T: A g g *g erb 4 The reactor coolant cold leg temperature (Tg ) shall be within the Area pf Acceptable Operation shown in Fioure 3,2-1 A APPLICABILI : MODE la and 2*f. ACTION: i fy { With the reacto' coolant cold leg temperature exceedina its_)Jait. restore thel temoerat_ure to within ill_ limit within 2 hourskr be in HOT STANDBY within g fthenext6 hours. SURVEILLANCE REQUIREMENTS l 4-h + The reactor coolant cold leg temperature shall be determined to be l /y g 3 9'g'g within its limit at least once oer 12 hours, ] j l$ 0 VC .$ (D M l cT5 f ag ' 3/4 2 y 4 o h e N_ {* fee Soeci / Test Exc/otion 3 4 .a 3
#With K gg greater than or equal to 1 3/4 2-7 .
Palo Verde - Units 1, 2, 3
tc aboa bA. I i ! .4.\ - i l FIG URE ._ . ,INSE..T) ! REACTOR COOLANT COLD LEG TE.TIPERATURE VS. CORE - POWER LEVEL 'N N f , i i i i ! i i i i i 1 \
,u. 570 (30.568) 570 -
\
w 5 565 h 565 - I 00 ansco l,,:.RkLxx 'Nx \xN M,,, _
~ ~
o : , 545 P 545 - i 540 -
.l 7
Z , 1 10 20 30 40 50 60 70 80 90 1C0 ! CORE POWER LEVEL.% OF RATED THERMAL POWER (3876 M,W) REACTOR COOLANT COLD LEG TEMPERATURE vs. CORE POWER LEVEL N N CI h E caure. 3. 2 - \ b .d hca n m e o eci b ! iTs 34.\-\ . k6a IT5 s A.\ trx_.A 1 l E- a-m l- )
M \Qh b.$. \ 34 h v CfDLAT O D - .
^p vi3TaievTien yi nip ~. f ' s w- - - _n ,n - (.
Q,4,) 13/K2.8 PRESSUR/2ER PRES $ URB, TIN \Pt.AATV6, AND h N.t NL. Fro #\
'N"'Ph
'~
@ M,) o The pressurizer pressure shall be maintained between M psia ald) 5 - APPLICABILITY: MODES 1 and 2*.
^
. ACTION:-
}M ,3 With the pressurizer pressure outside its above limits, restore the pressurel
- o within its limit within 2 hoursfor be in at least HOT STANDBY within the 7 next 6 hours.
~
SURVEILLANCE REQUIREMENTS b( SA,\ \ 4-e-4 The pressurizer pressure shall be determined to be within its limit at ) least once per 12 hours. > l l plove CTS 3/4,2.5 / rom r CTS pp 1/y 2-ta do h ere . A e M ec /l T/st peep on)[10)I) f PALO VERDE - UNIT 3 1,f. ord 3 3/4 2-10 l
INSERT FOR CTS 3.2.8 APPLICABILITY NOTE A AND B (Units 1,2, and 3) INSERT 1
.._.-N OTE---..--.-. -- .-----
Pressurizer pressure limit does not apply during:
- a. THERMAL POWER ramp > 5% per minute; or. ;
- b. THERMAL POWER step > 10% RTP. ,
1 l l 1 l
DISCUSSION OF CHANGES SPECIFICATION 3.4.1 l l
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.1 - RCS Pressure, Temperature, and Flow (DNB) Limits ADMINISTRATIVE CHANGES A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432, Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station (PVNGS) Improved Technical Specifications (ITS) should be more readable, and therefore understandable. by plant operators as well as other users. During the reformatting and renumbering of the ITS, no technical changes (either actual or interpretational) to the Current Technical Specifications (CTS) were made unless they were identified and justified. Editorial rewording (either adding or deleting) is made consistent with NUREG-1432. During NUREG-1432 development, certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more detail does not result in a technical change. 1 A.2 CTS 3.2.6 Footnote references "See Special Test Exception 3.10.4" and CTS 3.2.8 Footnote (Unit 2 only) references "See Special Test Exception 3.10.5." Cross references are not used in the ITS or NUREG-1432. Removing cross references does not alter the requirements of the referenced Specification. Therefore, this is an administrative change with no impact i on safety. This change is consistent with NUREG-1432. A.3 NOT USED A.4 CTS LCO 3.2.8. Pressurizer Pressure. is being modified to reflect the more restrictive limits specified in the proposed PVNGS license amendment submitted to the NRC in letter No. 102-03713 dated June 17, 1996. 4 l l 7 PALO VERDE - UNITS 1,2, AND 3 1 REV.B i
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES l SPECIFICATION 3.4.1 - RCS Pressure, Temperature, and Flow (DNB) Limits TECHNICAL CHANGES - MORE RESTRICTIVE M.1 CTS 3.2.5 places no requirement for the performance of SR 4.2.5. ITS SR 3.4.1.3. CTS SR 4.2.5 equivalent, requires that the Surveillance be perform in Mode 1. The addition of this requirement constitutes a more restrictive change to PVNGS operating practice. This is acceptable because this allows measurement of RCS flow rate at normal operating conditions at power with all RCPs running. This change is consistent with NUREG-1432. TECHNICAL CHANGES - RELOCATIONS None TECHNICAL CHANGES LESS RESTRICTIVE L.1 ITS LCO 3.4.1 introduces a note that gives two specific instances when the pressurizer pressure LC0 does not apply.
. THERMAL POWER ramp > 5% RTP per minute: or '
. THERMAL POWER step > 10% RTP.
CTS makes no such allowance for pressurizer pressure. ITS is less restrictive since it explicitly states conditions when the Pressurizer , Pressure LCO does not apply. This is acceptable because the Note represents i short term perturbations where actions to control pressure variations may ! be counterproductive. Also, since they represent transients initiated from power levels < 100% RTP an increased DNBR margin exists to offset the temporary pressure variations. Therefore, this change does not detrimentally affect plant safety. This change clarifies the question of applicability so that this LC0 is applied as intended. This change is consistent with NUREG-1432.
]
L.2 CTS 3.2.5 Action Statement requires that thermal power be reduced to less than 5% within 4 hours when actual RCS flow rate is determined to be less than the limit (155.8 x 10 6lbm/hr). ITS relaxes the Action requirement by allowing 2 hours to restore RCS flow plus allowing 6 hours to reach Mode 2 (which is defined as < 5% power) if flow is not restored to within limits in 2 hours. Allowing more time, an additional 4 hours, for the Completion Time is less restrictive. This is acceptable because an 8 hour Completion Time for these Actions is a reasonable time that permits plant power to be ! reduced at an orderly rate. This change is consistent with NUREG-1432. l l PALO VERDE - UNITS 1,2, AND 3 2 REV.A
NO SIGNIFICANT HAZARDS CONSIDE3ATION SPECIFICATION 3.4.1 l l l
I NO SIGNIFICANT IIAZARDS CONSIDERATsON ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNil) Limits ADMINISTRATIVE CHANGES (ITS 3.4.1 Discussion of Changes Labeled A.1. A.2, A.3 and A.4) Arizona Public Service Company. Palo Verde Nuclear Generating Stat'on (PVNGS). Units 1. 2. and 3. is converting to the ITS as outlined in NUREG-1432. " Standard ) Technical Specifications. Combustion Engineering Plants." The proposed changes i involve the reformatting, renumbering, rewording of the Technical Specifications I (TS) and Bases with no change in intent. and the incorporation of current l operating practices consistent with NUREG-1432. These changes, since they do not involve technical changes to the Current TS (CTS) are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this : Section/ Chapter to NUREG-1432. l 1 The Commission has provided standards for determining whether a significant I hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards I consideration if operation of the facility. in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or ; consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these ;
standards as they relate to this amendment request follows: J Standard 1.-- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? ' The proposed changes involve reformatting, renumbering. and rewording of the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting renumbering. and rewording along with the other changes listed above, involves no technical changes to the CTS. Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432, certain wording preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these l changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. l PALO VERDE - UNITS 1,2. AND 3 1 Rev. A i
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNB) Limits ADMINISTRATIVE CHANGES (ITS 3.4.1 Discussion of Changes Labeled (A.1, A.2, A.3 and A.4) (continued) Standard 2. Does the proposed change create the possibility of a new or l different kind of accident from any accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the CTS. along with the incorporation of PVNGS current operating practices and other changes, as discussed in order to be consistent with NUREG-1432. The proposed changes do not involve a physical alteration of the plant (no l new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3. Does the proposed change involve a significant reduction in a margin of safety? The proposed changes involve reformatting renumbering, and rewording of the CTS. along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes are administrative in nature and will not involve any technical changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. l l ! PALO VERDE - UNITS 1,2, AND 3 2 Rev. A
NO SIGNIFICANT IIAZARDS CONSIDERATION l ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNB) Limits TECHNICAL CHANGES MORE RESTRICTIVE (ITS 3.4.1 Discussion of Changes Labeled H.1) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3 is converting to the ITS as outlined in NUREG-1432. This particular NSHC is for the changes labeled " Technical Changes - More Restrictive" described in the specific Discussion of Changes listed above. The proposed changes incorporate more restrictive changes into the CTS by either making current requirements more stringent or adding new requirements which currently do not exist. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or ; consequences of an accident previously evaluated: 2) create the possibility of ' a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. - Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes provide more stringent requirements than previously existed in the CTS. The more stringent requirements will not result in operation that will increase the probability of initiating an analyzed event. If anything, the new requirements may decrease the probability or consequences of an analyzed event by incorporating the more restrictive changes discussed in the specific Discussion of Changes listed at'ove. These changes will not alter assumptions relative to mitigation of an accident or transient event. The more restrictive requirements will not l alter the operation and will continue to ensure process variables, I structures, systems, or components are maintained consistent with safety analyses and licensing basis. These changes have been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident evaluated. PALO VERDE - UNITS 1,2, AND 3 3 Rev. A
l l NO SIGNIFICANT IIAZARDS CONSIDERATION ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNB) Limits l TECHNICAL CHANGES MORE RESTRICTIVE (ITS 3.4.1 Discussion of Changes Labeled H.1) (continued) Standard 2. Does the proposed change create the possibility of a new or , different kind of accident from any accident previously evaluated? Making existing requirements more restrictive and adding more restrictive requirements to the CTS will not alter the plant configuration (no new or differeni, type of equipment will be installed) or change the methods governing normal plant operation. These changes do impose different requirements. However, they are consistent with the assumptions made in the safety analyses, licensing basis, and NUREG-1432. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3. Does the proposed change involve a signif; cant reduction in a margin of safety? The proposed changes provide more stringent requirements than previously existed in the CTS. An evaluation of these changes concluded that adding these more restrictive requirements either increases or has no impact on the margin of safety. The changes provide additional restrictions which may enhance plant safety. These changes maintain requirements of the safety analysis licensing basis, and NUREG-1432. As such. no question of safety is involved. Therefore, these changes will not involve a significant reduction in a margin of safety. PALO VERDE - UNITS 1,2. AND 3 4 Rev.A i
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNB) Limits TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.1 Discussion of Changes Labeled L.1) i Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). , Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the description of this less restrictive change and the NSHC for the conversion to NUREG 1432. i L.1 ITS LCO 3.4.1 introduces a note that gives two specific instances when the pressurizer pressure LC0 does not apply. '
. THERMAL POWER ramp > 5% RTP per minute: or
. THERMAL POWER step > 10% RTP.
l CTS makes no such allowance for pressurizer pressure. ITS is less restrictive since it explicitly states conditions when the Pressurizer Pressure LC0 does not apply. This is acceptable because the Note represents short term perturbations where actions to control pressure variations may be counterproductive. Also, since they represent transients initiated from l power levels < 100% RTP , an increased DNBR margin exists to offset the l temporary pressure variations. Therefore, this change does not detrimentally affect plant safety. This change clarifies the question of applicability so that this LCO is applied as intended. This change is consistent with NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these i standards as they relate to this amendment request follows:
i l PALO VERDE - UNITS 1,2, AND 3 5 Rev. A
'l NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNB) Limits TECHNICAL CHANGES - LESS RESTRICTIVE >
(ITS 3.4.1 Discussion of Changes Labeled L.1) (continued) Standard 1. Does the proposed change involve a significant increase in the , probability or consequences of an accident previously evaluated? ; The proposed change adds a Note to indicate the limit on pressurizer pressure may be exceeded during short term operational transients such as a THERMAL POWER ramp increase of > 5% per minute or a THERMAL POWER step j increase of > 10%. These conditions represent short term perturbations ' where actions to control pressure variations might be counterproductive. l In addition, since they represent transients initiated from power levels l
< 100% RTP, an increased DNBR margin exists to offset the temporary pressure variations. These changes will not result in operation that will increase the probability of initiating an analyzed event. These changes ,
will not alter assumptions relative to mitigation of an accident or transient event. The proposed changes have been reviewed to ensure that no previously evaluated accident has been adversely affected, therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. Standard 2.- Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed change adds a Note to indicate the limit on pressurizer pressure may be exceeded for a short period of time. The CTS does not I provide this guidance. This change will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes do relax CTS requirements, however they are consistent with the assumptions made in the safety analyses. NUREG-1432. and licensing basis. Therefore, they will not create the possibility of a new or different kind of accident from any accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 6 Rev. A
_ _- =- . - . - _ - _ . NO SIGNIFICANT IIAZARDS CONSIDERATION ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNB) Limits TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.1 Discussion of Changes Labeled L.1) (continued) Standard 3.- Does the proposed ' change involve a significant reduction in a margin of safety? The proposed changes provide additional guidance and flexibility indicating that the limit on pressurizer pressure may be exceeded during short term operational transients. An evaluation of these changes concluded that relaxing these requirements has no impact on the margin of safety. The changes maintain requirements of the safety analysis, consistent with NUREG-1432, and licensing basis. As such, no question of safety is involved. Therefore, these changes will not involve a significant reduction in a margin of safety. I l PALO VERDE - UNITS 1,2, AND 3 7 Rev. A
- _ __ .m _ _ _ _ . - _. _ .. . . _ _ _ _ _ . _ _ _ - . . - .
l NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNB) Limits l TECHNICAL CHANGES LESS RESTRICTIVE - l (ITS 3.4.1 Discussion of Changes Labeled L.2) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS), l Units 1, 2. and 3 is converting to the ITS as outlined in NUREG-1432. The l proposed change involves making the CTS less restrictive. Below is the description of this less restrictive change and the NSHC for conversion to NUREG-1432. L.2 CTS 3.2.5 Action Statement requires that thermal power be reduced to less than 5% within 4 hours when actual RCS flow rate is determined to be less than the limit (155.8 x 10 6lbm/hr). ITS relaxes the Action requirement by l allowing 2 hours to restore RCS flow rate plus allowing 6 hours to reach Mode 2 (which is defined as < 5% power) if flow is not restored to within limits in 2 hours. Allowing more time, an additional 4 hours, for the i Completion Time is less restrictive. This is acceptable because an 8 hour Completion Time for these Actions is a reasonable time that permits plant power to be reduced at an orderly rate. This change is consistent with NUREG-1432. . The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
l i .I { PALO VERDE - UNITS 1,2, AND 3 8 Rev. A 4
i NO SIGNIFICANT IIAZARDS CONSIDERATION ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNB) Limits TECHNICAL CHANGES LESS RESP TCTIVE (ITS 3.4.1 Discussion of Changes Labeled L.2) (continued) Standard 1.- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change increases the time from 4 hours to 8 hours to reduce reactor power to less that 5% (Mode 2) in the event that RCS flow rate is below LC0 limits. The plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least Mode 2 within 8 hours. In Mode 2. the reduced power condition eliminates the potential for violation of the accident analysis bounds. The 8 hours is a reasonable time that permits the plant power to be reduced at an orderly rate. This change will not result in operation that will increase the probability of initiating an analyzed event. These changes will not alter assumptions relative to mitigation of an accident or transient event. The proposed changes have been reviewed to ensure that l no previously evaluated accident has been adversely affected. Therefore. ; these changes will not involve a significant increase in the probability l or consequences of an accident previously evaluated. 1 Standard 2.-- Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? Relaxing the total Completion Time to reach Mode 2 from 4 hours to 8 hours does not introduce any new mode of plant operation, does not alter the plant configuration (no new or different equipment will be installed) or change the method governing normal plant operation. These changes do relax requirements in the CTS. however, they are consistent with the assumptions made in the safety analyses, licensing basis, and consistent with NUREG-1432. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. i 1 PALO VERDE - UNITS 1,2, AND 3 9 Rev. A
.= - - - -. .-.
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.1 - RCS Pressure, Temperature and Flow (DNB) Limits TECHNICAL CllANGES LESS RESTRICIIVE (ITS 3.4.1 Discussion of Changes. Labeled L.2) (continued) Standard 3. - Does the proposed change involve a significant reduction in a margin of safety? The proposed change relaxes the total Completion Time for placing the reactor in Mode 2 in the event that RCS flow rate is below LCO limits. An evaluation of the change concluded that this change has no impact on the margin of safety. The change maintains requirements of the safety analysis, licensing basis, and is consistent with NUREG-1432. As such, no question of safety is involved. Therefore, these changes will not involve a significant reduction in a margin of safety. l f PALO VERDE - UNITS 1,2, AND 3 10 Rev. A
I l l l 1 i I i l CE STS l NUREG-1432 REV.1 SPECIFICATION 3.4.2 MARK UP I l l l { l l
l l I RCS Minimum Temperature for Criticality 3.4.2 MT9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.2 RCS Minimum Temperature for Criticali 3 4 j
\e b 3,g,),Q LCO 3.4.2 Each RCS loop (norage) temperature shall be it F. l
~% i b I i
APPLICABILITY: MODE 1 f in one f more RC loops cops < % 5]*F, MODE with _ in any or more <A535]*F an K,,,2 1.0. k i ACTIONS l CONDITION REQUIRED ACTION COMPLETION TIME bi,\ A ACf) A. n one or more RCS A.1 Be in MODE 3. 30 minutes s not within
- limit.
J yoh Onh "Acprad if cang v.s % h < 5Ef F. SURVEILLANCE REQUIREMENTS - SURVEILLANCE
\ FREQUENCY (4.1,\.D SR 3.4.2.1 Verify RCS ach loop 2 *F. 30 minutes timereartery
' AMD Onca aihn m 4 en de.o pror +o dg trNcdhq 4
M 1 3.4-4 RevG704/47/eO r
' Pcd o W e d e. U n n o 1 ,2 , b g
i l l l l l l l i 1 l l l CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.2 BASES MARK UP l l
)
l l l i 1 [ l
I I RCS Minimum Temperature for Criticality B 3.4.2
) B 3.4 REACTOR COOLANT SYSTEM (RCS)
B 3.4.2 RCS Minimum Temperature for Criticality BASES BACKGROUND Establishing the value for the minimum temperature for reactor criticality is based upon considerations for:
- a. Operation within the existing instrumentation ranges and accuracies;
- b. Operation within the bounds of the existing accident analyses; and
- c. Operation with the reactor vessel above its minimum nil ductility reference temperature when the reactor is critical.
The reactor coolant moderator temperature coefficient used in core operating and accident analysis is tvo< cally defin_ed for the normal eneratino temnerature range 65Jd7 M 5R"F}) 550,( +o (o f If 1
'The Re ctor Prot tion Syst(m receiv inputs m the N narro range ho leg tempe ature det,ctors, wh h have a b .
) I rang of 520*F to 620*F. he RCS 1 op average temper ture QT ) is con olled usi inouts e the sama anae Nomina or making the reactor critical is 4 M* g Safety a o rating analyses for lower temperature a
.been made. 7 APPLICABLE There are no accident analyses that dictate,the minimum SAFETY ANALYSES temperature for criticality, but all low power safety analyses assume initial temperatures near the 'F imit (Ref. 1).
The RCS minimum temperature for criticality satisfies Criterion 2 ofJDfi Mc Vcwv swd4
$b CM So,3d.DD M?.M t O. 6 v_ -
LCO The purpose of the LC0 is to prevent criticality th m e e
~--
normal operating r,Me (QF"F to PJ"Fj an to rev n operation in an nanalyzea cono m on. _( g ap g g geg) R s (continued) l (TEDG SJ6 B 3.4-7 Rev 0 A4 /#/9D Ci GMQ -Unb kdh
RCS Minimum Temperature for Criticality B 3.4.2 BASES LCO o The LCO is only applicableDratw lysoi3F and provides a g,, (continued) reasonable distance to the limit of Q5EF This_ allows adequate time to trend its approach and tike corrective 'd actions prior to exceeding the limit. APPLICABILITY The reactor has been designed and analyzed to be critical in MODES I and 2 only and in accordance with this l specification. Criticality is not permitted in any other MODE. Therefore, this LCO is applicable in MODE 1. and MODE 2 when K m > 1.0./Eoppled with t applicabi)4ty idefiefition forfriticalitfis a temo_ ature limitz honttoring is required at or below a f. @ . The no load temperature of F is maintaine by the Steam Control System.
~
ACTIONS M If is below , the plant must be brought to a MOD in which th LCO does not apply. To achieve this status, the plant must be brought to NODE.3 within 30 minutes. Rapid reactor shutdown can be readily and practically achieved within a 30 minute period. The allowed time reflects the ability to perform this action and to maintain the plant within the analyzed range. l h e;%] ^ :- v l SURVEILLANCE SR 3.4.2.1 Dac8 eh Jo ~ vec oCh j arsa @ toopp, im'F ord REQUIREMENTS W _x
< is required to be verified 2
- very 30 miniites--
30 minute time period is freq e t enough to prevent g g ) l
'~
inadvertent violation of the LCO. the Surveillance is - never the reactor is crit cal and temperature is below Ffin actice t e surveill nce is mo - when the eactor is rought opriary ouring the peri ical.f w REFERENCES ?.IhSAR,Sectic
'^' "" N ow iac.-u~w ha 3
l INSERT FOR ITS BASES 3.4.2 SR 3.4.2.2 (Units 1,2, and 3) INSERT 1 BASES SURVEILLANCE A see nd Frequency requires Teoia to be verified within 30 minutes of reaching criticality. This will require repeated performance of SR ! REQUIREMENTS 3.4.2.1 since a reactor startup takes longer than 30 minutes. The 30 minute time period is frequent enough to prevent inadvertent violation of the LCO. l l l I l l I
i -1 If 4
- NUREG-1432 EXCEPTIONS 4
SPECIFICATION 3.4.2 i 4 ? i 1 4 I,
PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.2 - RCS Minimum Temperature For Criticality
- 1. Grammar and/or editorial changes have been made to enhance clarity. No technical or intent changes to the Specification are made by this change.
- 2. The plant specific titles, nomenclature, number, parameter /value, reference, system description, system design, operating practices or analysis description was used (additions, deletions, and/or changes are included). Plant specific parameters / values are directly transferred from the CTS to the ITS.
- 3. NUREG-1432 uses T,,, in 3.4.2. RCS Minimum Temperature for Criticality. ITS 3.4.2. RCS Minimum Temperature for Criticality. uses Tc ,3,. Palo Verde presently uses_and will continue to use T coie rather than T,,,. All PVNGS safety analysis that specifies an initial RCS temperature expresses this in terms of cold leg temperature. Also. UFSAR (15.6.3.3.2), post-trip E0P analysis assumptions regarding operator actions, assumes operators use ADVs and auxiliary feed to maintain the post-trip cold leg temperature.
The continued use of Tcoi, is a deviation from NUREG-1432 but is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO.
- 4. ITS SR 3.4.2.1. 2nd Frequency, is created to ensure LCO compliance.
NUREG-1432 requires performance of SR 3.4.2.1 prior to achieving criticality. This is achieved by approaching criticality at a temperature below NUREG-1432, 3.4.2 Applicability. Because RCS temperature is below NUREG-1432. 3.4.2 Applicability. SR 3.4.2.1 is performed on a 30 minute Frequency. This ensures RCS temperature is monitored 30 minutes prior to reaching criticality. This is not the case with PVNGS. PVNGS achieves criticality at a temperature (565 F) greater than required for ITS SR 3.4.2.1 performance (550 F). It is necessary to create a second Surveillance Frequency that verifies T coia . >545 F 30 minutes prior to reaching criticality. This also requires an associated change to the LC0 Applicability. The temperature requirement now exists in SR 3.4.2.1. first Frequency Note. This ensures compliance with NUREG-1432. LCO 3.4.2. intent. This change is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the Surveillance. PALO VERDE - UNITS 1,2, AND 3 1 REV.A
1 l l \ l ! 4 l l l i l l i i I l PVNGS CTS 1 SPECIFICATION 3.4.2 i MARK UP I i i i l l 1 l
M OA .N. b k,k 2.s vmimJe xC0hTHOL SYS7 EMS)3nutt (RfAC11VIJY y MINIMUM TEMPERATURE FOR CRITICALITY (LM ITING C0(DITION F0( OpERATIG O e _ _ _ _ ((pb,4.E (1dl1/)@ Reactor sha 1 be greaterCoolant SystemQdest than or eaual to 545'F. 96eratihloop temperature (T,,i
)---
APPLICABILITY: MODES I and 2#. ACTION: less than ] dk With a Reactor 545'F,(re>< Coolant ore i.4,, System to wittnn within the next GerJminutes. J its operating loop/15 i t; nit witnin temperature minutes oobe(T,,g) inmen syND8n/ r SVRVElllANCE RE0V EMENTS b.L
>@,1, } 14) The Reactor Coolant System temperature (T,,w) shall be determined to--
be greater than or equal to 545'F:
@ Within minutes prior to achieving reactor criticality, ang
- ' b6 23 ,12. . \ @ At least once per 30 minutes when the reactor is critical and the Reactor Coolant System T mg is less than 550*F.
J I t
\aQd fWith K,,, greater than or equal to 1.0.)
PALO VERDE - UNITil i f,b 3/4 i-5 s
em 4 l l l DISCUSSION OF CHANGES l SPECIFICATION 3.4.2 , i
PALO VERDE ITS CONVERSION DISCUSSION OF CIIANGES SPECIFICATION 3.4.2 - RCS Minimum Temperature For Criticality ADMINISTRATIVE CHANGES A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432. Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station (PVNGS) Improved Technical Specifications (ITS) should be more readable, and therefore understandable, by plant operators as well as other users. l During the reformatting and renumbering of the ITS, no technical changes
- (either actual or interpretational) to the Current Technical Specifications
! (CTS) were made unless they were identified and justified. Editorial rewording (either adding or deleting) is made consistent with j NUREG-1432. During NUREG-1432 development, certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. l Additi6nal information has also been added to more fully describe each l subsection. This wording is consistent with NUREG-1432. Since the design l is already approved by the NRC, adding more detail does not result in a , l technical change. j l A.2 CTS 3.1.1.4 Action allows 15 minutes to return RCS Cold Leg Temperature to j . = 545 F and then take action to reduce power to enter Mode 3 within the l following 15 minutes. This results in a 30 minute allowance prior to
- required Mode 3 entry. ITS only requires that Mode 3 be achieved within 30 )
l minutes after RCS Cold Leg Temperature drops below 545 F. ITS does not ! l split the allowance into a 15 minute interval to correct RCS Cold Leg ; l Temperature and a 15 minute interval to shutdown. However. CTS and ITS both ' allow temperature to be returned within limits within the initial 30 minutes which terminates the requirement for Mode 3 entry. Therefore, this
- change is considered administrative and does not detrimentally affect plant safety. This change is consistent with NUREG-1432.
TECHNICAL CHANGES - MORE RESTRICTIVE None i i
- TECHNICAL CHANGLS RELOCATIONS None l
i l PALO VERDE - UNITS 1,2, AND 3 1 REV.A l l l.
- _ . - _ . = ... . . .__. _-. . - _ . .. _ - - _-. -
, PALO VERDE ITS CONVERSION l DISCUSSION OF CHANGES l SPECIFICATION 3.4.2 - RCS Minimum Temperature For Criticality l 4 , f TECHNICAL CHANGES LESS RESTRICTIVE l L.1 CTS SR 4.1.1.4 requires that RCS cold leg temperature be determined to be !
= 545 F within 15 minutes prior to achieving criticality. ITS relaxes this requirement to 30 minute intervals. The 30 minute time period is frequent i
- enough to prevent inadvertent violation of the LCO. Therefore, this change ,
does not detrimentally affect plant safety. This change is consistent with l NUREG-1432. l I i l I PALO VERDE - UNITS 1,2, AND 3 2 REV.A
i l l I l NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.4.2 l l l 4
l NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.2 - RCS Minimum Temperature For Criticality ADMINISTRATIVE CHANGES (ITS 3.4.2 Discussion of Changes Labeled A.1 and A.2) l l Arizona Public Service Company Palo Verde Nuclear Generating Station (PVNGS), l Units 1, 2, and 3 is converting to the ITS as outlined in NUREG-1432. " Standard Technical Specifications. Combustion Engineering Plants." The proposed changes involve the reformatting, renumbering, rewording of the Technical Specifications l (TS) and Bases with no change in intent, and the incorporation of current l operating practices consistent with NUREG-1432. These changes, since they do not involve technical changes to the Current TS (CTS), are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. l The Commission has provided standards for determining whether a significant l hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards l consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of j a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
I Standard 1. - Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? l The proposed changes involve reformatting, renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating l practices and other changes to the CTS as discussed in the specific ! Discussion of Changes listed above in order to be consistent with . NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. l Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432, certain wording preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or j consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 1 Rev. A [
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.2 - RCS Minimum Temperature For Criticality ADMINISTRATIVE CHANGES (ITS 3.4.2 Discussion of Changes Labeled (A.1 and A.2) (continued) ! Stan@rd 2.- Does the proposed change create the possibility of a new or l different kind of accident from any accident previously evaluated? i l The proposed changes involve reformatting. renumbering, and rewording of the CTS. along with the incorporation of PVNGS current operating practices l and other changes, as discussed, in order to be consistent with NUREG-1432. l The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? The proposed changes involve reformatting. renumbe' ring, and rewording of the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed in order to be consistent with NUREG-1432. The proposed changes are administrative in nature and will not involve any technical changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature. no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 2 Rev. A 1
NO SIGNIFICANT HAZARDS CON $1DERATION ITS Section 3.4.2 - RCS Minimum Temperature For Criticality l TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.2 Discussion of Changes Labeled L.1) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the description of this less restrictive change and the NSHC for the conversion to NUREG 1432. L.1 CTS SR 4.1.1.4 requires that RCS cold leg temperature be determined to be , a 545 F within 15 minutes prior to achieving criticality. ITS relaxes this requirement to 30 minute intervals. The 30 minute time period is frequent enough to prevent inadvertent violation of the LCO. Therefore, this change does not detrimentally affect plant safety. This change is consistent with NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility. in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or ; consequences of an accident previously evaluated: 2) create the possibility of I a new or different kind of accident from any accident previously evaluated; or l
- 3) involve a significant reduction in a margin of safety. A discussion of these
. standards as they relate to this amendment request follows:
)
i PALO VERDE - UNITS 1,2, AND 3 3 Rev.A
l NO SIGNIFICANT HAZARDS CONSIDERATION l ITS Section 3.4.2 - RCS Minimum Temperature For Criticality l l TECHNICAL CHANGES - LESS RESTRICTIVE ! (ITS 3.4.2 Discussion of Changes Labeled L.1) (continued) i l Standard 1.- Does the proposed change involve a significant increase in the l probability or consequences of an accident previously evaluated? l The proposed change relaxes the frequency for performing the surveillance to verifying RCS T m in each loop > 545 F prior to achieving criticality L from 15 minutes to 30 minutes. The 30 minute time interval is frequent l enough to prevent inadvertent violation of the LCO. Therefore, this change l will not result in operation that will increase the probability of initiating an analyzed event. This change does not alter any assumptions l relative to mitigation of an accident or transient event. This change has l been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. i Standard 2.-- Does the proposed change create the possibility of a new or i different kind of accident from any accident previously evaluated? l Relaxing the frequency for performing the SR from 15 minutes to 30 minutes l does not alter the plant configuration (no new or different type of ! equipment will be installed) or change the methods governing normal plant operation. These changes do relax the performance of the SR by 15 minutes ! however, it is consistent with the assumptions made in the safety analysis, I licensing basis, and consistent with NUREG-1432. Therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated. l Standard 3.-- Does the proposed change involve a significant reduction in a l margin of safety? The proposed change provides a relaxation for performing the associated SR. l An evaluation of this change concluded that this reduction has no impact l on the margin of safety. The change maintains requirements of the safety analysis, licensing basis, and is consistent with NUREG-1432. As such, no i question of safety is involved. Therefore, this change will not involve a significant reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 4 Rev. A
l 1 i 1 1 CE STS NUREG-1432 REV. I l l SPECIFICATION 3.4.3 4 MARK UP l I r t t i ( 1 i i I
- - _ - .I h l p~N l.maaA incauordanc.A wdh b. li%do c h irs l
( g u e 3 . 4.S -L e,. 3 .4 . b - 2. A ,,, 3 bbp , ccolkwn ! c.e AUMw e oad maan ir a f ul s.rd hy&pwwiic. 42k% O iM* { O. 3(cnunum hookop cxrd ccrnson nahts syeuQ,c,M 5.4.bl. j k A mm, +qerebre. c.hc.3a al c*i nony IhPad b'a3 I inwfou hpd*dt idd% cphn'3 ' 44 "'S"M I 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.3 RCS Pressure and Temperature (P/T) Limits {,Q 3,4,%.) LCO 3.4.3 RCS pressure, CS temperature, and RCS hentun and cooldown rates shall b EflEalrytained/wlthin /he lipts spepfied i APPLICABILITY: t al i , q t w btsresc$Dr- M M \t b dlLitf\$beack :r.xh 4hcT. ik O cc.eveh be ACTIONS j CONDITION REQUIRED ACTION COMPLETION TIME
.+.8,( kC,T A. ----NOTE A.1 Restore parameter (s) 30 minutes
' Required Action A.2 to within limits. !
shall be completed i l
<D'f. A,b whenever this Condition is entered.
6.G l ! --- ---- A.2 Determine RCS is 72 hours ! 3 acceptable for !- Requirements of LCO continued operation. not met in MODE 1, 2, 3, or 4. l l B. Required Action and 8.1 Be in MODE 3. 6 hours
,4, % , \ associated Completion Time of Condition A 8ND not met.
B.2 Be in MODE 5 with 36 hours
- RCS pressur
<{500Kpsi l
(continued) l
'n
} A
@ ) 4 na S 3.4-5 Rev ( /J!./0(/99 (g4G @
l
.. - - .. -- -~ - -. . . . - - .
l l l l l 1 - 1 . { RCS P/T Limits 3.4.3 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME I C. --- NOT E-- C.1 Initiate action to immediately Required Action C.2 restore parameter (s) to within limits. l ( g o *3 shall be completed whenever this Condition is entered. M!Q C.2 Determine RCS is Prior to Requirements of LCO acceptable for entering MODE 4 not met any time in continued operation.
* ' ~
dDOC. M.h SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY ! b.k.1 k.\ SR 3.4.3.1 - - -
---------NOT E - - - - -
Only required to be perfonned during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing. Verify RCS pressure, RCS temperature, and 30 minutes RCS heatup and cooldown rates within limits 2 specified in 6 , VdJe, 'o.tb -} i pQfyr e 5.i.5-\ cul 5%-2.. __m_ SwT 49e. b.4.5- \ ond t F9 <o.3 S.4.b-i,t..b aa 4. CEOG STS 3.4-6 Rev 1, 04/07/95
. . . . - - _ ~ _ - _ - - -
'^
$pw SA.s
,g' ',,.-s..
t
' TABLE 4-4 g, _ g Maximum Allowable Heatup and oo own ates
<8 Effective Full Power Years Heatup Cooldown Ia Rate ("f/HK) I } ** }
c ( r) c
< 128'F 20*F/HR 1 93*F See Figure 3.4-2c 128' - 180'F 30'F/HR 94* - 114*F , 10*F/HR
\
181* - 230'F 50*F/HR 115'F - 148'F 20*F/HR
> 230'F 75'F/HR > 148'F 100'F/HR 7
8-32 Effective Full Power Years Heatup Cooldown , Ic " (~r) Rate ( r/HR) Ig = ( r) Rate ( r/MR)
< 116*F 10'F/HR 1 108'F See Figure 3.4-2d 117' - 150'F 20'F/HR 109' - 126'F 10'F/HR 151' - 199'F 30'F/HR 127'F - 147'F 20*F/HR !
. 200'F - 246*F 50*F/HR 148'F - 162*F 40'F/HR
> 246'F 75'F/HR > 162*F 100'F/HR /
l ' ham. CIS%k M-b / Tth 1A h-\ frte CT5 % S 4 A tS c. + o k nn.
" Indicated Cold Leg Temperature 3/4 4-28a da.- On65 \ . f b Qk l
.___ . _. _m. .. _ _ .- _ _ _ _..___ _. _ .. _ ..-.. _-.__ _ _ _ _ _.. _ _. ._._._.__
V.fo . s FlGURE 3 4=ce 3.4.D- \
- REACTOR COOL. ANT SYSTEM PRE MPERATURE i LIMITATIONS FOR LESS THAN 8 EFFECTIVE i
? FULL POWER YEARS OF OPERATION 2500
- i _
g J: 1 ? 2 E 2: ? t > i
- . .- g _
si 2000 - g 4 * -
._ Lowest -
< SERVICE - _,
g w .(- g y _g grplr j TEMP. 1488F= - E a
- &; g i
g -g gi - ' . 1500 g 2 F j
!lf
): ==-a )n!!i
==- ? w, .w< =>
L l c
- -i 5 .. 5 [!!
E Et
'coe i
1
. E m
=
_ y? 1 38 == l 1 1 i E. e - } W - l l !30'F/HR [HEATUP -- ' - 4 i i 1 (513 PSIA) . - - 3 Boo j l sf_ io*F/HR _ - =mr. (Sod PSIA) -_
=
1 - r
- COOLDOWN E' _j
!' I MINIMUM SOLTUP:: #' TEMP. 808Fr -
- 3
}
- 0 100 200 300 400 i .
500
/
INDICATED AC3 TEMPERATURE ('F) ' h t g 3.&toI T* - i . d5 3.4.1-1 6Ctb b 1
.S/4 4-ZA +e, ham
{ 3/4 4 29 i f i 1bbtr&.-Ms i.z.a e<A. 4 4 4
k\tGhn b.i.b i y FIGURE 3.6-:: 4. l REACTOR COOLANT SYSTEM PRES URE LIMITATIONS FOR 8 TO 32 EFFECTIVE FULL i POWER YEARS OF OPERATION 2500 i _ ! - Lowtsi + 2 - { sEnvict :~ *
,:::::::: TEM ,
i geog w.P..~ - -Mfi
~
8U
+ !
g 5! -- l i g =p {l ' w - E l I i \ w 150s f_ll g l - E ff
- sf i '
1 i 1 - [f . . _xp e .,
= -s !!
~
E 1000 - -
$ =
m i g - E == E ; =u3
-=
< so'FMR -
i N HEATUP- $ _ _ 6. Eg 3 t g ."~~ { g - - l , t 513 PSIA) _ '
)
Soo ~
~y _. -:15e4 P51A):
_4 ! 1o*HHR = 1 C.0,,%,O_OyN i CORE CRITICAL E-MINitt'UM BOLTUP - 3 TEMP.So'F,. 6
--]
, E-j -
_ - - j o too 200 aoo 400 soo i INDICATED ACS TEMPERATURE ('F) j b Cb Eove 5A-ab/ I i
- m _% A.S-7 6 4.M A-2%
f NI"\Q/UL - 4 1 e/4 4-29a J 1 b
- b e I Y 1_
)
h i e-
.3pseden 5.4 b
\ . s . m
%- N F I GURE 3. ' 2c 3,4.5-3 MAXIMUM ALLOWABLE C00LD0 N ATES.
< 8 EFPY 10 :
i i i : i i g ......:.. . . . . . . . . . . . . . _ . . . .
"I UNACCEPTAB(.E i ! !
s .# . : ,. . .......4... _ . . . . 1.L i. i. !. !. O i -
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i 80 90 93 TC - INDICATED REACTOR COOLANT l TEMPERATURE, OF
//be. crd s <,. aA-r.c /
ITS SA.b _% %%
. S/4 4 2 % % ka e 3 /4 4-29b hha. - tMs i .2.. b av A et
phcohon 3Ah
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FIGURE 3.'-2d M . S -+ MAXIMUM ALLOWABLE C00LDOW , 8-32 EFPY l l l
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i
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0 . . . . . . . . . . . . . . . 80 90 100 108 f. l l IN I. ATED RC'S TEMPERATURE, Tc , F 6 L% F y. . -M/ i tt$ ~% A b4 b % l a/4 4- dc.+o b e I l 3 /4 4-29c - U
- l l Y
f l l l CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.3 BASES MARK UP : 4 l l t
o RCS P/T Limits B 3.4.3 s i B 2.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.3 RCS Pressure and Temperature (P/T) Limits FASES BACKGROUND All components of the RCS are designed to withstand effects of cyclic loads due to system pressure and temperature changes. These loads are introduced by startup (heatup) and shutdown (cooldown) operations, pawer transients, and reactor trips. This LCO limits the pressure and temperature changes during RCS heatup and cooldown, within the design assumptions and the stress limits for cyclic operation. [ThePTL contains P/ limit curves f r heatup, coold , and 2. inserv e leak and drastatic (IS ) testing, and ta for the m imum rate of change of reac or coolant temp ature QRef 1). Each P/T limit curve defines an acceptable region for nonnal operation. The usual use of the curves is operational guidance during heatup or cooldown maneuvering, when pressure and temperature indications are monitored and compared to the applicable curve to determine that operation
) is wit a e rg ion.
The LCO stabli s opera 'ng limits that provide a margin 3 to brit fail re of the reactor vessel and piping of the 6 actor colant % essure oundary (RCPB). The vessel is the component most subject to brittle failure, and the LC0 limits apply mainly to the vessel. The limits do not apply to the pressurizer, which has different design characteristics and operatj functions. 10 CFR 50, Appendix G (Re .
>\ , requires the establishment of P/T limits for material fractur ughness requirements of the RCPB materials. Reference quires an adequate margin to tirittle failure during normal operation, anticipated operational occurrences, and system hydrostatic tests, it mandates the use of the ASME Code, Section III, Appendix G (Ref. .
The actual shift n t e RT, of the vessel material will be established periodically by removing and evaluating the irradiated reactor y el material specimens, in accordance l with ASTM E 185 (Re , and Appendix H of 10 CFR 50 (Ref. . The operating P/T limit curves will be adjusted,
) (continued) 6 8 3.4-9 Rev(1/04/0Z/9J M b D li E Gi rib
l l RCS P/T Limits B 3.4.3 BASES l l BACKGROUND as necessary, based on the eval tion findings and the (continued) recommendations of Reference The P/T limit curves are composite curves established by superimposing limits derived from stress analyses of those portions of the reactor vessel and head that are the most restrictive. At any specific pressure, temperature, and temperature rate of change, one location within the reactor vessel will dictate the most restrictive limit. Across the span of the P/T limit curves, different locations are more restrictive, and, thus, the curves are composites of the , most restrictive regions. ,
- The heatup curve represents a different set of restrictions than the cooldown curve because the directions of the l thermal gradients through the vessel wall are reversed. The l thermal gradient reversal alters the location of the tensile stress between the outer and inner walls.
The criticality limit includes the Reference qu rement that the limit be no less than 40*F above the heatup curve or the cooldown curve and not less than the minimum permissible temperature for esting. However, the criticality limit is not operational limiting; a more .3 restrictive limit exists in LCO 3.4.2 RCS Minimum Temperature for Criticality." gg qg g gg The consequence of violating the LCO limits is that the CS has been operated under conditions that can result in brittle failure of the RCPB, possibly leading to a nonisolable leak or loss of coolant accident. In the event these limits are exceeded, an evaluation must be performed to determine the effect on the structural integrity of the RCPB ponents. The ASME Code, Section XI, Appendix E (Re , provides a recommended methodology for evaluating an o ating event that causes an excursion outside the limits. APPLICABLE The P/T limits are not derived from Design Basis Accident SAFETY ANALYSES (DBA) Analyses. They are prescribed during normal operation to avoid encountering pressure, temperature, and temperature rate of change conditions that might cause undetected flaws n nrPB, an to propagate unanalyzed and causehonductile condition, encefes%ish fail"r= ^' (continued) . O_ B 3.4-10 Rev u /04 /c7/oD
l s J l 4 ! i l i
)
RCS P/T Limits j B 3.4.3 l BASES APPLICABLE M for determini/a the //T e the P/T limits are not derived from any'DBA, there are no acceptance SAFETY ANALYSES (continued) limits related to the P/T limits. Rather, the P/T limits are acceptance limits themselves since they preclude operation in an unanalyzed condition. The RCS P/T limits satts e6 MF PMQ toc. !!D.W (.O (d (iJ O. LCO The two elements of this LCO are:
- a. The limit curves for heatup, cooldown, and ISLH l testing; and
- b. Limits on the rate of change of temperature. ,
l The LCO limits apply to all components of the RCS, except the pressurizer. These limits define allowable operating regions and permit a large number of operating cycles while providing a wide
) margin to nonductile failure.
The limits for the rate of change of temperature control the thermal gradient through the vessel wall and are used as 1 inputs for calculating the heatup, cooldown, and ISLH i testing P/T limit curves. Thus, the LCO for the rate of change of temperature restricts stresses caused by thermal gradients and also ensures the validity of the P/T limit curves. Violating the LCO limits places the reactor vessel outside of the bounds of the stress analyses and can increase stresses in other RCPB components. The consequences depend on several factors, as follows:
- a. The severity of the departure from the allowable operating P/T regime or the severity of the rate of change of temperature;
- b. The length of time the limits were violated (longer violations allow the temperature gradient in the thick vessel walls to become more pronounced); and
) (continued)
M B 3.4-11 Rev GA4 /07AD W hib O k , f. . a n d 3
. .- . .- -- - - = _ . - . _-
i l i l l l l RCS P/T Limits B 3.4.3 BASES LCO c. The existences, sizes, and orientations of flaws in (continued) the vessel material. l l APPLICABILITY The RCS P/T limits Specification provides a definition of acceptable operation for prevention of nonductile failure in accordance with 10 CFR 50, Appendix C (Ref. 2). Although the P/T limits were developed to provide guidance fo operation during heatup or cooldown (MODES 3, 4, ISLH testing, their Applicability is at all times n 5) or keepin 'erc.ap dargd.f va d ha2M m 6dg with the concern for nonductile failure. The limits not gg apply to the pressurizer. g During MODES I and 2, other Technical Specificatio p vi ! l limits for operation that can be more restrictive than or I l can supplement these P/T limits. LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits"; LCO 3.4.2, 'RCS Minimum Temperature for i Criticality"; and Safety Limit 2.1, " Safety Limits," also l provide operational restrictions for pressure and i temperature and maximum pressure. Furthermore, MODES I and 2 are above the temperature range of concern for
, nonductile failure, and stress analyses have been performed l for normal maneuvering profiles, such as power ascension or descent.
, The actions of this LCO consider the premise that a i violation of the limits occurred during normal plant. maneuvering. Severe violations caused by abnormal transients, at times accompanied by equipment failures, may also require additional actions from emergency operating procedures. . ACTIONS A.1 and A.2 1 i Operation outside the P/T limits must be corrected so that l the RCPB is returned to a condition that has been verified by stress analyses. The 30 minute Completion Time reflects the urgency of restoring the parameters to within the analyzed range. Most violations will not be severe, and the activity can be accomplished in this time in a controlled manner. , (continued) bE mL B 3.4-12 Rev V04 /077G I e ( . Ond3 A i
. - . - -- -~ . . . ---. . . -. - .-
t I l l RCS P/T Limits
.B 3.4.3 BASES ACTIONS A.1 and A.2 (continued)
Besides restoring operation to within limits, an evaluation - is required to determine if RCS operation can continue. The evaluation must verify the RCPB integrity remains acceptable and must be completed before continuing operation. Several methods may be used, including comparison with pre-analyzed transients in the stress analyses, new analyses, or inspection of the components. 4 ASME Code, Section XI, Appendix E (Ref. , may be used to
, support the evaluation. However, its use is restricted to evaluation of the vessel beltline, l The 72 hour Completion Time is reasonable to accomplish the evaluation. The evaluation for a mild violation is possible within this time, but more severe violations may require special, event specific stress analyses or inspections. A favorable evaluation must be completed before continuing to operate.
Condition A is modified by a Note requiring Required
)J Action A.2 to be completed whenever the Condition is entered. The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action A.1 is insufficient because higher than analyzed stresses maj have occurrnd and may have affected the RCPB integrity.
B.1 and B.2 If a Required Action and associated Completion Time of Condition A are not met, the plant must be placed in a lower MODE because:
- a. The RCS remained in an unacceptable P/T region for an extended period of increased stress; or
- b. A sufficiently severe event caused entry into an
- unacceptable region.
Either possibility indicates a need for more careful examination of the event, best accomplished with the RCS at i l y (continued) e68'f0 B 3.4-13 Rev(1M4/0V95) WO3 2. i GedD 1 l
I i l RCS P/T Limits B 3.4.3 - BASES ACTIONS B.1 and B.2 (continued) i reduced pressure and temperature. With reduced pressure and i temperature conditions, the possibility of propagation of undetected flaws is decreased. Pressure and temperature are reduced by placing the plant in thin 6 hours and in MODE 5 with RCS pressure ithin 36 hours, et Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly nianner and without challenging plant systems. C.1 and C.2 The actions of this LCO, anytime other than in MODE 1, 2, 3
- or 4, consider the premise that a violation of the limits ,
occurred during normal plant maneuvering. Severe violations > caused by abnormal transients, at times accompanied by ' equipment failures, may also require additional actions from i emergency operating procedures. Operation outside the P/T. i limits must be corrected so that the RCPB is returned to a l condition that has been verified by stress analyses. l The Completion Time of "immediately" reflects the urgency of restoring the parameters to within the analyzed range. Most violations will not be severe, and the activity can be ) accomplished in a short period of time in a controlled ! manner. Besides restoring operation to within limits, an evaluation is required to determine if RCS operation can continue. The evaluation must verify that the RCPB integrity remains acceptable and must be completed before continuing operation. Several methods may be used, including comparison with pre-analyzed transients in the stress analyses, new analyses, or inspection e components. ASME Code, Section XI, Appendix E (Ref. , may be used to i support the evaluation. However, its use is restricted to i evaluation of the vessel beltline. 1 1 ! l (continued) l fridc sto B 3.4-14 Rev ti/04 Inf/9D l Wb i4Ord
'b l'N
m , _ _ . _ __ . _ . - . . __ . _ _ _ _ . _ . _ _ _ . . . - . _ = . _ . . _ . . . _ _ _ . . _ . _ _ . _ _ _ _ _ _ _ t !' 1 i i l 1 l i i ! j l l RCS P/T Limits l B 3.4.3 ) s 1 BASES ACTIONS C.1 and C.2 (continued) The Completion Time of prior to entering MODE 4 forces the evaluation prior to entering a MODE where temperature and pressure can be significantly increased. The evaluation for a mild violation is possible within several days, but more severe violations may require special, event specific stress analyses or inspections. Condition C is modified by a Note requiring Required Action C.2 to be completed whenever the Condition is entered. The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action C.1 ; is insufficient because higher than analyzed stresses may I have occurred and may have affected the RCPB integrity. ] SR 3.4.3.1 SURVEILLANCE REQUIREMENTS / f @ Verification that operation is within@f P/LFlimits is required every 30 minutes when RCS pressure and temperature I
) -
conditions are undergoing planned changes. This Frequency ; is considered reasonable in view of the control room ! indication available to monitor RCS status. Also, since temperature rate of change limits are specified in hourly , increments, 30 minutes permits assessment and correction for . minor deviations within a reasonable time. . 1 Surveillance for heatup, cooldown, or ISLH testing may be discontinued when the definition given in the relevant plant procedure for ending the activity is satisfied. This SR is modified by a Note that requires this SR be performed only during RCS system heatup, cooldown, and ISLH testing. No SR is given for criticality operations because LCO 3.4.2 contains a more restrictive requirement. l l REFERENCES 1. NRC appr ed topical method gy for de port th ining t define P/T 1 s) [e M
. 10 CFR 50, Appendix G.
j i
) (continued)
B 3.4-15 Revd 44/0F/93 l 1
, me i t.a s w
g
i l J 1 i RCS P/T Limits I B 3.4.3 !
)
BASES 1 l REFERENCES h.ASME,BoilerandPressureVesselCode,SectionIII, (continued) Appendix G.
. ASTM E 185-82, July 1982.
- 4. 10 CFR 50, Appendix H.
. ASME, Boiler and Pressure Vessel Code, Section XI, Appendix E.
l j i i i j l l / 4 O , ym B 3.4-16 Revd/4/07AS) ]
?mtc t, O ond 5 @
f-t f
)
l !
- i 1
I I l NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.3 ! l I l l I 1 I - I I I i
i PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS l SPECIFICATION 3.4.3 - RCS Pressure And Temperature (P/I') Limits
- 1. NUREG-1432. .3.4.3. Applicability is at all times. ITS. 3.4.3. !
Applicability is at all times, except when the vessel head is fully detensioned such that the RCS cannot be pressurized. The purpose of the 4 maximum cooldown rates is to prevent the RCS pressure from exceeding the ! corresponding normal operation P-T limit. assuming a concurrent i overpressurization due to the limiting low temperature overpressurization ! transient. Consequently. the cooldown rate and P/T limits are only valid if the RCS is capable of being pressurized. Therefore with the vessel head fully detensioned, the Technical Specification cooldown limits are l not applicable. This specification does not apply for the period of time ; the vessel head is fully detensioned because the RCS cannot be pressurized ) above the static head of water over the vessel in the refueling pit which is negligible compared to the ASME Code Appendix G. P-T limit. PVNGS will continue to use the Applicability as it exists in the ITS. The continued use of ITS, 3.4.3. Applicability is a deviation from NUREG-1432 but is consistent with Palo Verde licensing basis. The Bases has also been revised to be consistent with the LCO.
- 2. NUREG-1432. 3.4.3. locates all plant specific pressure and temperature ,
limits in the PTLR. The PTLR is generated with an NRC approved topical I report that defines the methodology for determining the P/T limits. No such approved topical report exists for CE plants. ITS wi.ll continue to contain such plant specific P/T limits within the LCO. The continued pract-ice of locating such information with the LCO is a deviation from NUREG-1432 but is consistent with Palo Verde-licensing basis. The Bases has also been revised to be consistent with the LCO.
- 3. Grammar and/or editorial changes have been made to enhance clarity. No technical or intent changes to the Specification are made by this change.
- 4. The plant specific titles, nomenclature, number, parameter /value.
reference. system description, system design, operating practices or analysis description was used (additions, deletions, and/or changes are included). Plant specific parameters / values are directly transferred from the CTS to the ITS. PALO VERDE - UNITS 1,2, AND 3 1 IEV.A
..1a_ m W .2 - - AA. .A m 4 PVNGS CTS SPECIFICATION 3.4.3 MARK UP l
1 l l I l I
pke.M c0 3.4,1 I L l l l AA
- b. REACTORCOOLANTSYSTE(D) I (3/4. //8 PRESSURE /I(MPERATURE 4!MI @ D h re ca d (Etr ho Mb%b tR TOR COOLANT STEH [
l l i O f#1Tinn enMITION FOR A ERATI0fA l - (5,'.Jun c.,u - crA L O S.i.D y Reactor Coolant System 'u;;pt the p.es; rn;r) temperature and _ pressure sha'1 be limited in accordance with the limit lines shown on Figures
, QA-2a fr 3.4C1Ad"rino heatup, cooldown, criticality, and inservice leak and hydrostatic ~testingwit g .{
- a. .4-
. Maximum heatup and cooldown rates as specified i,n Table
- b. A maximum temperature change of 10*F in any 1-hour period during inservice hydrostatic testina operations. s APPLICABILITY: At all timehxcept when the reactor vessel head is fully l
detensioned such that the Reactor Coolant System cannot be pressurized. ACTION: s k3 ! (,T A ~ f/Withanyoftheabovelimitsexceeded,restorethetemperatureand/orpressure]' to within the limit within 30 minutes perform an engineering evaluation to (,T, I l t determinetheeffectsoftheout-of-IImitconditiononthestructural 1
- integrity of the Reactor Coclant System; determine that the Reactor Cool .t; stem remains acceotable for continued oDeratio. Asr be in at leas ihmlP. htet TANDBY within the next 6 hours and reduce the RC5 scold and pressure to less than 210*F and 500 psia, respectively, within the following 30 hours.
k,l ! 2-SURVEILLANCE REQUIREMENTS I dormd mb rdM i 3,%3,\ ('.'.C.'.t The Reactor Coolant System temperature and pressure sh>U hal _ Unterm{ nort tn ha b ggdt g en ner 'An m{nntor.4dy'rjng' system
~
an e a hyd sE 4.4.8.1 The reactor essel material tradiation surv llance specime s shall e removed and amined, to det mine changes in aterial prope ies, at ! the ' tervals requir by 10 CFR Par 50 Appendix H i accordance wi tLe se dule in Table 4-5. The resul s of these exami tions shall b used to j' g-( ! u ate Figure 3.4 j l e75pec/a1 TedExcepdon 3.[0.b- - '* I ALO VE DE - U IT51 P S 3/4 4-28 i
- l
. _ . _ . _ - . _ _ __ . _ _ _ _ . _ . . - __ _. . . . _ . . ~_
Wectk$cih'n f O E%5 INSERTS FOR CTS 3.4.8.1 INSERT 1 l --------- --- NOTE . - . - - - - . - - - - - - . - - - - - - - . . . l Required Action A.2 shall be completed whenever this Condition is - i l entered. l I l INSERT 2 ? l
- ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C. ---- N OTE-------- C.1 Initiate action to restore Immediately l Required action C.2 shall parameter (s) to within be completed whenever this limits.
Condition is entered.
. . g l
\ Requirements of LCO not C.2 Detennine RCS is Prior to entering MODE 4. met any time in other than acceptable for continued MODE 1,2,3, or 4. operation. i l l l l l l l i
. .... ._ .... . _ _ __._._ _ ._._.m___ _ _ . _ . . . _ . _ . _ _ . . ..______-,.~._m.._..- . _ _ _ . . .
i 2[_\ \ M ).k. b y- , TABLE M - Maximum Allowable Heatup and Cooldown Rates I'
<8 Effective Full Power Years Heatup Cooldown l
l e" ("F) Rate ( t/NR) 1 " ("f) Rate ( t/MM)
< 128'F 20'F/HR 1 93*F See Figure 3.4-2c 128' - 180'F 30*F/HR 948 - 114*F , 10'F/HR :
, 181' - 230*F 50'F/HR 115'F - 148'F 20*F/HR . l l l
> 230'F 75'F/HR > 148'F 100*F/HR 8-32 Effective Full Power Years i
l Heatup Cooldown , Ig " ("f) Hate ("f/MM) IC" ("P) Rate ( t/hM)
< 116*F 10'F/HR 1 108'F See Figure 3.4-2d 117' - 150*F 20'F/HR 109' - 126*F 10*F/HR l 151' - 199'F 30*F/HR 127'F - 147'F 20*F/HR 200'F - 246*F 50*F/HR 148'F - 162*F 40*F/HR j f > 246'F 75'F/HR > 162*F 100*F/HR l
1 l L
' Indicated Cold Leg Temperature j 3/4 4-28a j 015~EMe_. M -b i 6 M no lio Tc.& 3A.'h-1 k 6 a mm. It s 3.A.% " DOC A.\
Pato Verde - Units 1, 2, 3 4 dumm
,3 - -
D M .h.4,b
. r 1
FIGURE 3.4-2. A.2-t REACTOR COOLANT SYSTEM PRESS LIMITATIONS FOR LESS THAN 8 EFFECTIVEPERA t
. FULL POWER YEARS OF OPERATION i 2500 -
k i
= lEkf-
;4; I
R$ uE _= 0"j {S' E
=
- 2000 7 LOWEST - $F 1 T ~ E t SE RVICE . ' g L-- I
~-
I c -
=
=iD', ==
sErgf[if
- =w
=e h:=- ,
0 c 1500 i 3 1 _ e' -' W tf ' 2 N 'c =s== sp.=.-- : = hIEhgY
=2 Ql
! 6 5 .
_EEE6 g- l l
=-J _5 _EiE_5 5 J '
c - E 1000
!!!!? c
_[i.Ef{gEt g =s - m-- g; == g82
= . -
!:2 E 30*hMR ? I g
~
EHEATUPi _ s(513 PSIA) ~ _i- E 500 - b - -- i (504...P. S. I A. ) - 3 7 COOLDOWN EG J 7 MINIMUM BOLTUPN - i T EMP. 808FF N --- o ion -- zoo soo 4eo see INDICATED RC3 TEMPERATURE ('F) T, - 0.h 6 ya.3A-7-a. %,s v4 4-n 6 nu.md % 1TD kye
- .5 A. b -) . Wnco. T.T')
h A.b DOC k. \ b ckac.Lk u\ t Pato Verde - Units 1,2,3
. _ . ._ .._m. . ._ .._.__ _ __. _ ___ _ ___ _ __ _ .._. _ ..__....__... _._._
DG.D \CfAI)@ b.4 b 3
.. i rIcuRE :.n:. f 4. -
REACTOR COOLANT SYSTEM PRES . M RATURE LIMITATIONS FOR 8 TO 32 EFFECTIVE FULL
' POWER YEARS OF OPERATION 25005 .-
m.---
=== Lowest s eu :-
=y i
=== SERVICE = -
= a-NIi~l
=== TEMP * -
" l
'liiiEE ~
r I-2000 Y gge.. '
?* 1 :-
c _-[ 1 ' \- E
~
_y 5g
-~
.e E =g ,$ =4--
e a 8: , a 2:= 1500 - g '
- $.~= fj_-
^ $
, -~
w
- '1}
i ' Vi l{?l?
-- ~ " ;Q=i!E *.g U .
i: : , . - :
'@p
~
f 1000 c " 5W z ~E!E$:ED U
" == 30*F/HR E E E El 55 2
': r_ g _ E ! Ew
~
- H E ATUP'E 1o E2Ee !EC
,($13 PSIAl--
L ~= I ?kEO 500 - _m ;,; _ g g _ g= -- _;-~
~ ___
.-_w- g 51504 PstAE i
_10'F/NR . : COOLDOWN-_
-="---
MINIMUM BOLTUP - CORE CRITICAL E E TEMP. 80'F. . _
. i.--- --
l __a E -- C 100
=
200 300 '
, 400 [co INDICATED RCS TEMPERATURE ('F)
T, t . M 3/4 4-29a bb bpIO. O'b i Q de fT. 5 Fye SA.6-2.. kbancs .$.6.S toc. A.i 1 i b- ds::c.2:61on i Palo Verde - Units 1,2,3 1
b . i l e s l r ^ t l l F I GURE 3. ' 2c 3A.b-b l MAXIMUM ALLOWABLE C00LD ATES-
< 8 EFPY 1
1 I s
- 10
- .
1
......a....4....1....2......
..................:................a..
l l : : . : i
. . . . . . ' . . . . ..........+..... ...............
g .....+..,....+.....+... C U.NACCEP'i.fABf.E i ! i i. i 1.1. :. :. o .
..........:....+.....+...
. .4.....4.....>.........i.......;.......
LLJ P-= ...r....'..:..... i 4 . i. 4... i.4 . . i&.........v......,.....
. i. !,
i i i AC. CEP.. .TABLE
. . . .t.......
i i ! l
. . . p.....
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...q....4......,.. . . . . . p..... . . . . . . .
.. . . ...... .....g.... .....q...9..t....
. . . . . .......p . .. p......
0 80 90 93 l T-c INDICATED REACTOR COOLANT TEMPERATURE, OF l , -p
- f I
l ( > l 0.Tb Fyc. ) A -f.c. b baan (Tumd+o '1.Tb Fgum 5:4Yb 3 /4 4-29b Mf2.ru:vv.a. 5A.~6 DOC A.i - he chewan ! Palo Verde - Units 1, 2, 3 l
L D(k.C1 S C O m b. Q h t I l I l
-4 l
FIGURE J.4 2d A MAXIMUM ALLOWABLE C00LD W , i 8-32 EFPY I 30 ..p.+ . .y.9.
. . . ..+.p. p.+..
. .p. .+ . . . . 9. 4 9. .t. -- -*1
- t. =1. -4.-*---+.-+.--1.---- t. - 4.-- -
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. . *t. - t. t. - t. - - - + . . - - + --- t. -t. -
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. 9. .T... .+.9. 9. 9. . .. 9. .g. 9. 9. ... .q..
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. . . .. 9. 9. 9. 9. ... 9. .q. . 9. 9. ....q..q..q..u.
. .1 ...p.4 l
. . . . . .. y.... ..
- 7. . .. 7..
- y. .. .... ..7. 7.. p. .
- 7. 7.3 I 7. . .
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Cr .....2... .:.2.2.2....:...:.2....: . . .2....: .:... .. .:.s. . . I 20 .pp..p p .' p p. p p. pp [
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.. ... . .p.lp p p. ..p.p.+.T.p.. . . ..
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. pp p
. .. . .pp.+.+..
...p .a..p.p. ..p.f'.4. ..p.. ..p.p ..p.. ..p.p+.T . ..w.+.+p.. . + . + . .
1 . . . . . . . . . . i . .. . .
. m p y y... I..p..y..p....p..y..I p. ..p.
p ..Ip p p. y . ..y..p..p . . . . . . .T. p.9. .. ..p. . !a. ...p.+. ...+.t.*- y.. ..p. .p..p..p....+ p p.t. ....t. ..p.+..p... . +. . .
- g. gn
...p..
pa. . . .. p . y y.4.
. f .. p .4. ..
l p p.
. .p.
.. p. p .p ..I . .. ..p.t.
9.A. 1 T .. .T.t. . . l .V
.py..y. a y.. . . . y i . 6 .
y.. p p
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y.T.4... i .
...a.+.t....p.... p. .+ .9. 9. 9. . .
- 9. . .
. . . . . . ..I.T..
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. . . . . .g
. t.** .' - *t.
- t. -
y .. y ..y. ..p , . . . , ,.!, pp .6
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. . .. . . . ...p. ...ip p.. .. y. .. .. f..y p.7. .+. ..
s p i
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- y. ..
- y. .... ..y y . ..y.. . .. ..a.. . .
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...p. p. ,
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,. ..y..y . ..... y.1..yyy.
y . .. y. . y.. y. y 0 . 1 . . . 80 90 100 108 l
~
INDI.CATED RCS TEMPERATURE, T',o F e
)
l ' l T b % i e .h A -2 A ha baan uv.x.md% lb bya. b A /A -4 . 44aun:.a. 3 /4 4-29c do % S,{3 h
'PAcNe.cac. . u~t3 1, a a U dem
_ _ _ _ _ _ _ _ . . ______ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ----- --- - - - - - - ' - - - - - - - - - - ~ - - - - - ~~~ ~ ~ ~ ~ ~ ~ ~' -~ TABLE 4.4-5
)
o - REACTOR VESSEL MATERIAL SURV LANCE PROGRAM - WITHDRAWAL SCHEDULE M s CAPSULE
'N \ VESSEL EAD C
e NUMER 's LOCATION FA R WITHDRAWAL TIME (EFPY) h 1 38" 1.0<LF< 8 - 10 2 43' 1.0(LF< 1.5 Standby 3 137' 1.0<LF< 1.5 4- 5 4 142' 1.0<LF< 1.5 St y 5 230* 1.0<tF< 1.5 12 - 15 {
=
6 310' 1.0<LF< 1.5 18 - 24 h O :( i f h B y .
'~
S l kt '
! M 3 h
.a ti-j '
t e ? ' 4 _ -_ m _ _ - _ _ . - . _ _ . . _ _ . _ _ _ . _ - - _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ - _ - _ __- m__ _ u =+ ue e -e+- -e
l
.6pcAchn 3 A.D .
FOR INFORMATION ONLY r-LE 4.4-5 ,, } REACTOR VESSEL MATER SURVEILLANCE PROGRAM - WITHDRAVAL SCHE I CAPSUL VESSEL LEAD NUM LOCATION FACTOR (LF) WITHDRAWAL, E (EFPY) 1 38' 1.0(LF<1.5 Stapdby [g ( ! 2 43" 1.0<LF(1.5 andby 3 137' 1. 'Lf< 4- 6 ! 4 142* p /1.0 <LF<1.5 Standby 5 30' 1.0<LF<1.5 12 - 15 6 310* 1.0<LF<1.5 18 - 24 I f l e l . l PALOVERDE-UNIT >2(3' 3/4 4-30
.n n -- ..a. < = _
p DISCUSSION OF CHANGES SPECIFICATION 3.4.3 I i l l
PALO VERDE ITS CONVERSION DISCUSSION OF CIIANGES L SPECIFICATION 3.4.3 - RCS Pressure And Temperature (PfI') Limits ADMINISTRATIVE CHANGES 4 i A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432. Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station l (PVNGS) Improved Technical Specifications (ITS) should be more readable, and l therefore understandable, by plant operators as well as other users. During , the reformatting and renumbering of the ITS, no technical changes (either l actual or interpretational) to the Current Technical Specifications (CTS) l were made unless they were identified and justified. Editorial rewording (either adding or deleting) is made consistent with l l NUREG-1432. During NUREG-1432 development, certain wording preferences or l English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. l Additional information has also been added to more fully describe each ! subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC adding more detail does not result in a technical change. I A.2 CTS 3.4.8.1. Applicability Footnote, references "See Special Test Exception ! 3.10.5." Cross references are not used in the ITS or NUREG-1432. Removing cross references does not alter the requirements of the referenced l Specification. Also, it should be noted that special test exception 3.10.5 does not exist in CTS. Special test exception 3.10.5 has been deleted by ! previous Technical Specification amendments (Unit 1 #54. Unit 2 #39, and I Unit 3 #27). Therefore, this is an administrative change with no impact on safety. This change is consistent with NUREG-1432. I A.3 CTS 3.4.8.1 ACTION requires an engineering evaluation to be performed to l determine the effects of an out of limits condition on the structural l integrity of the RCS. In addition. CTS 3.4.8.1 ACTION requires a determination that the RCS remains acceptable for continued operations. ITS 3.4.3 Actions A.2 and C.2 require that it be determined if the RCS is acceptable for continued operation if there is an out of limits condition. It is implicit in ITS 3.4.3 Actions A.2 and C.2 that an evaluation of l structural integrity would be performed to determine the acceptability of the RCS for continued operations. since that is the primary concern in the event of exceeding the pressure / temperature limits. ITS Bases 3.4.3 Background states that in the event the LCO limits are exceeded, an evaluation must be performed to determine the effect on the structural integrity of the RCPB components. ITS Bases 3.4.3 Actions A.2 and C.2 states that the evaluation must verify the RCPB integrity remains acceptable and must be completed before continuing operation. Since ITS LCO 3.0.2 allows Actions to be exited if LCO compliance is achieved, ITS 3.4.3. Condition A. adds a note to explicitly require performance of Action A.2. The addition of the note neither adds nor detracts from the intent of CTS and is therefore administrative. This change is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 1 REV.B l l
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES l SPECIFICATION 3.4.3 - RCS Pressure And Temperature (P/F) Limits TECHNICAL CHANGES MORE RESTRICTIVE M.1 The CTS 3.4.8.1 Action associated with violation of the Pressure / Temperature Limits allows 30 minutes to restore temperature and/or pressure to within limits. ITS Action C. Mode 5 and lower applicability, requires that action be initiated immediately to restore temperature and/or pressure to within limits. The ITS requirement to immediately initiate action to restore parameters to within limits is more restrictive than the CTS requirement allowing 30 minutes to restore parameters to within limits, since the action to restore parameters may not begin until well into the 30 minute limit. Further, if the 30 minute requirement in CTS is not met. CTS allows up to 36 hours to reduce pressure, which would not impose the urgency to restore parameters as does the ITS requirement. This change does not detrimentally affect plant safety. This change is consistent with NUREG-1432. l TECHNICAL CHANGES RELOCATIONS LA.1 CTS 3.4.8.1. SR 4.4.8.1.2, addresses the reactor vessel material irradiation Surveillance Requirements. ITS 3.4.3 will not contain this information. Generic Letter 91-01 states that a program for the reactor vessel' material surveillance ensures the availability of data to update the l inservice operating temperature and pressure limits. This program assists in fulfilling the requirements of Appendix H to Part 50 of Title 10 of the Code Federal Regulations to prevent the brittle fracture of the reactor vessel. The relocation of this Surveillance is allowed because section l II.B.3 of Appendix H to 10 CFR Part 50 requires the submittal to, and approval by, the NRC of a proposed withdrawal schedule for material specimens before implementation. Hence, the placement of this schedule in the TS duplicates the controls on changes to this schedule that have been established by Appendix H. Therefore, this information (SR 4.4.8.1.1 and Tables 4.4-5) will be relocated to a Licensee Controlled Document (Technical Requirements Manual (TRM)). Any changes to the TRM will be in accordance with 10 CFR 50.59. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This information is not required to be in the ITS to provide adequate protection of public health and safety. Therefore, relocation of this information to a Licensee Controlled Document is acceptable and is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 2 REV.B l
l j PALO VERDE ITS CONVERSION j DISCUSSION OF CHANGES I SPECIFICATION 3.4.3 - RCS Pressure And Temperature (Pfr) Limits l TECHNICAL CHANGES LESS RESTRICTIVE I l L.1 ITS 3.4.3, Action A.2, allows 72 hours following out of limit parameters to determine that the RCS is acceptable for continued operation (if the parameters are restored to within limits within 30 minutes) prior to l commencing actions to place the plant in Mode 3. CTS 3.4.8.1 requires the i determination to be performed within 6 hours and 30 minutes. In CTS after l the initial 30 minutes to restore pressure and/or temperature within limits is expired. 6 hours is given to complete entry into Mode 3. In ITS, an initial 30 minutes to restore pressure and/or temperature within limits is allowed, plus a concurrent 72 hours is allowed to complete the determination and then 6 hours is given to complete entry into Mode 3. This change is acceptable because 72 hours is a reasonable time to accomplish the determination. This change is consistent with NUREG-1432. I I 1 l PALO VERDE - UNITS 1,2, AND 3 3 REV.A
f l [ i I 1 l NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.4.3 l l I l l l l l l l l
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NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.3 - RCS Pressure and Temperature (Pfr) Limits l ADMINISTRATIVE CHANGES l (ITS 3.4.3 Discussion of Changes Labeled A.1, A.2 and A.3) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, is converting to the ITS as outlined in NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants." The proposed changes ! involve the reformatting, renumbering, rewording of the Technical Specifications (TS) and Bases with no change in intent, and the incorporation of current operating practices consistent with NUREG-1432. These changes, since they do not involve technical changes to the Current TS (CTS), are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows: )
Standard 1.- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432, certain wording preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators af any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or j consequences of an accident previously evaluated. l PALO VERDE - UNITS 1. 2, AND 3 1 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.3 - RCS Pressure and Temperature (Pfl') Limits ADMINISTRATIVE CHANGES (ITS 3.4.3 Discussion of Changes Labeled (A.1, A.2 and A.3) (continued) 1 i Standard 2. Does the proposed change create the possibility of a new or l different kind of accident from any accident previously evaluated? l The proposed changes involve reformatting, renumbering, and rewording of the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or i different kind of accident from any accident previously evaluated. Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? l The proposed changes involve reformatting, renumbering, and rewording of I the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes are administrative in nature and will not involve any , technical changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 2 Rev. A i l
NO SIGNIFICANT HAZARDS CONSIDERATION l ITS Section 3.4.3 - RCS Pressure and Temperature (Pff) Limits l TECHNICAL CHANGES MORE RESTRICTIVE I l (ITS 3.4.3 Discussion of Changes Labeled H.1) l Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. This particular NSHC is for the changes labeled " Technical Changes - More Restrictive" described in the specific Discussion of Changes listed above. The proposed changes incorporate more restrictive changes into the CTS by either making current requirements more stringent or adding new requirements which currently do not exist. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amenoment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of , a new or different kind of accident from any accident previously evaluated; or j
- 3) involve a significant reduction in a margin of safety. A discussion of these ;
standards as they relate to this amendment request follows: l Standard 1. - Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? l The proposed changes provide more stringent requirements than previously existed in the CTS. The more stringent requirements will not result in , operation that will increase the probability of initiating an analyzed l event. If anything, the new requirements may decrease the probability or l consequences of an analyzed event by incorporating the more restrictive j changes discussed in the specific Discussion of Changes listed labove. l These changes will not alter assumptions relative to mitigation of an i accident or transient event. The more restrictive requirements will not alter the operation and will continue to ensure process variables, structures, systems, or components are maintained consistent with safety analyses and licensing basis. These changes have been reviewed to ensure that no previously evaluated accident has been adversely affected. l Therefore, these changes will not involve a significant increase in the j probability or consequences of an accident evaluated. i l PALO VERDE - UNITS 1,2, AND 3 3 Rev. A
1 1 NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.3 - RCS Pressure and Temperature (Pff) Limits l l l TECHNICAL CHANGES - MORE RESTRICTIVE (ITS 3.4.3 Discussion of Changes Labeled H.1) (continued) I 1 l Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? Making existing requirements more restrictive and adding more restrictive requirements to the CTS will not alter the plant configuration (no new or i , different type of equipment will be installed) or change the methods i i governing normal plant operation. These changes do impose different l requirements. However, they are consistent with the assumptions made in the safety analyses licensing basis, and NUREG-1432. Therefore these changes will not create the possibility of a new or different kind of i accident from any accident previously evaluated. 1 Standard 3. Does the proposed change involve a significant reduction in a l l margin of safety? l The proposed changes provide more stringent requirements than previously l existed in the CTS. An evaluation of these changes concluded that adding i these more restrictive requirements either increases or has no impact on l the margin of safety. The changes provide additional restrictions which , l may enhance plant safety. These changes maintain requirements of the l safety analysis, licensing basis, and NUREG-1432. As such, no question of l safety is involved. Therefore. these changes will not involve a l significant reduction in a margin of safety. l l PALO VERDE - UNITS 1,2, AND 3 4 Rev. A
1 NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.3 - RCS Pressure and Temperature (P/F) Limits TECHNICAL CHANGES RELOCATIONS , (ITS 3.4.3 Discussion of Changes Labeled LA.1) l Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS), Units 1. 2, and 3 is converting to the ITS as outlined in NUREG-1432. The ; l proposed changes, since detail is being removed from the CTS to a Licensee ! l Controlled Document, are less restrictive. The descriptions of these changes are l in the Discussion of Changes listed above. The Commission has provided standards for determining whether a significant i hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no signi ficant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. - Does the proposed change involve a significant increase in the l probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee l Controlled Document. These changes do not result in any hardware changes or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee
- Controlled Document containing the relocated requirements will be l maintained using the provisions of 10 CFR 50.59 or other specified control processes and is subject to the change control process in the Administrative Controls Section of the ITS. Since any changes to a l Licensee Controlled Document will be evaluated, no increase in the l probability or consequences of an accident previously evaluated will be allowed. Therefore, these changes will not involve a significant increase
~ in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 5 Rev. A l l 1 i
l NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.3 - RCS Pressure and Temperature (P/I') Limits l TECHNICAL CHANGES RELOCATIONS l (ITS 3.4.3 Discussion of Changes Labeled LA.1) (continued) l Standard 2.- Does the proposed change create the possibility. of a new or different kind of accident from any accident previously evaluated? ) l The proposed changes relocate requirements from the CTS to a Licensee l Controlled Document. These changes will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes will not impose l different requirements and adequate control of information will still be l maintained. These changes will not alter assumptions made in the safety analysis or licensing basis. Therefore, these changes will not create the l possibility of a new or different kind of accident from any accident . previously evaluated. l l Standard 3. Does the proposed change involve a significant reduction in a l l margin of safety? The proposed changes relocate requirements from the CTS to a Licensee l Controlled Document. These changes will not reduce a margin of safety l since they have no impact on any safety analysis a3sumptions. In addition. l the requirements to be transposed from the CTS to the Licensee Controlled Document are the same as the CTS. Since any future changes to this i l Licensee Controlled Document will be evaluated per the requirements of 10 CFR 50.59. or other specified control processes, no reduction (significant or insignificant) in a margin of safety will be allowed. Therefore, these changes will not involve a significant reduction in a margin of safety. l- , The NRC review provides a certain margin of safety, and although this review will no longer be performed prior to submittal. the NRC still inspects the 10 CFR 50.59 process. The proposed changes are consistent l with NUREG-1432 which was approved by the NRC Staff. The change controls I for proposed relocated details and requirements provide an acceptable level l of regulatory authority. Revising the CTS to reflect the approved level l of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore, revising the CTS to reflect the NRC accepted level of detail and requirements ensures no reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 6 Rev. A l
I NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.3 - RCS Pressure and Temperature (Pff) Limits l i TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.3 Discussion of Changes Labeled L.1) l Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the i description of this less restrictive change and the NSHC for the conversion to NUREG 1432. l L.1 ITS 3.4.3. Action A.2, allows 72 hours following out of limit parameters to determine that the RCS is acceptable for continued operation (if the parameters are restored to within limits within 30 minutes) prior to commencing actions to place the plant in Mode 3. CTS 3.4.8.1 requires the determination to be performed within 6 hours and 30 minutes. In CTS. after the initial 30 minutes to restore pressure and/or temperature within limits is expired, 6 hours is given to complete entry into Mode 3. In ITS, an l initial 30 minutes to restore pressure and/or temperature within limits is l allowed, plus a concurrent 72 hours is allowed to complete the 1 determination and then 6 hours is given to complete entry into Mode 3. This , change is acceptable because 72 hours is a reasonable time to accomplish I the determination. This change is consistent with NUREG-1432. l l The Commission has provided standards for determining whether a significant l hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to ! an operating license for a facility involves a no significant hazards l consideration if operation of the facility, in accordance with a proposed i amendment, would not 1) involve a significant increase in the probability or l consequences of an accident previously evaluated: 2) create the possibility of l a new or different kind of accident from any accident previously evaluated; or l 3) involve a significant reduction in a margin of safety. A discussion of these l standards as they relate to this amendment request follows: i j PALO VERDE - UNITS 1,2, AND 3 7 Rev.A
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NO SIGNIFICANT IIAZARDS CONSIDERATION l ITS Section 3.4.3 - RCS Pressure and Temperature (P/T) Limits TECHNICAL CHANGES LESS RESTRICTIVE l (ITS 3.4.3 Discussion of Changes Labeled L.1) (continued) Standard 1.- Does the proposed change involve a significant increase in the j probability or consequences of an accident previously evaluated? 1 l The proposed change will allow 72 hours tc complete a determination that the RCS is acceptable for continued operation following out-of-limit ; parameters, vs. 6 hours 30 minutes in CTS. The 72 hours provides sufficient time to accomplish the determination. A favorable determination must be completed before continuing to operate. The relaxation of the CTS requirements will not result in operation that will increase the probability of initiating an analyzed event. This change does not alter any assumptions relative to mitigation of an accident or transient event. This change has been reviewed to ensure that no previously evaluated accent ' has been adversely affected. Therefore, this change will not involve a significant increase in the probability or consequences of an accident
. evaluated.
Standard 2.-- Does the proposed change create the possibility of a new or ! different kind of accident from any accident previously evaluated? l Allowing 72 hours to determine that the RCS is acceptable for continued l operation does not alter the plant configuration (no new or different type i of equipment will be installed) or change the methods governing normal plant operation. While these changes do relax the requirements of the CTS. l they are consistent with the assumptions made in the safety analyses and I is consistent with NUREG-1432. Therefore, this change will not create the possibility of a new or different kind of accident on any accident previously evaluated. l PALO VERDE - UNITS 1,2, AND 3 8 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.3 - RCS Pressure and Temperature (P/T) Limits TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.3 Discussion of Changes Label / L.1) (continued) Standard 3.-- Does the proposed change involve a significant reduction in a margin of safety?
'The proposed change allows a 72 hour Completion Time to determine that the RCS is acceptable for continued operation following out-of-limit pressure and/or temperature parameters. An evalJation for this change has determined that there is no impact on the margin of safety. This change maintains the requirements of the safety analyses and is consistent with NUREG-1432. As such, no question of safety is involved. Therefore, this change will not involve a significant reduction in a margin of safety.
l l l l 1 1 I PALO VERDE - UNITS 1,2, AND s 9 Rev. A i 4 .
l 1 CE STS I 1 NUREG-1432 REV.1 SPECIFICATION 3.4.4 MARK UP
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_ , . ~ , . .-. . . - . . -. . . . . . . . . . _ -.- . . . . t , / i I l I l 'a l I i !" l l 'l !- 1 j RCS Loops-MODES 1 and 2 3.4.4 I UD . i
) 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.4 RCS Loops-MODES 1 and 2 1 3.4.4 Two RCS loops shall be OPERABLE and in operation.
LCO li.\.h ' LCO APPLICABILITY: MODES I and 2, ACTIONS
. . . CONDITION REQUIRED ACTION COMPLETION TIME 3,$d.\ ACT A. R'equirements of LC0 A.1 Be in MODE 3. 6 hours j not met. 1 i
SURVEILLANCE REQUIREMENTS
)
SURVEILLANCE FREQUENCY
. $.\. \ SR 3.4.4.1 Verify each RCS loop is in operation. 12 hours i
I 1 9
) Pc a - On,b bLS A G -- t 3.4-7 Rev CI7T)4J07/91)
CE STS NUREG-1432 REV.1 ; SPECIFICATION 3.4.4 BASES MARK UP l
2 . ._ . . _- _ . - - . _ . _ . . - _ - - . . . _ . _ _ . _ . _ . _ _ . . . _ _ __ __..- _ . s 1 RCS Loops-MODES I and 2 B 3.4.4
) B 3.4 REACTOR COOLANT SYSTEM (RCS)
B 3.4.4 RCS Loops-MODES I and 2 BASES BACKGROUND The primary function of the RCS is removal of the heat generated in the fuel due to the fission process and transfer of this heat, via the steam generators (SGs), to the secondary plant. The secondary functions of the RCS include:
- a. Moderating the neutron energy level to the thermal i state, to increase the probability of fission; l
- b. Improving the neutron economy by acting as a ,
reflector, . 1
- c. Carrying the soluble neutron poison, boric acid;
- d. Providing a second barrier against fission product l release to the environment; and j l ) e. Removing the heat generated in the fuel due to fission i product decay following a unit shutdown.
I The RCS configuration for heat transport uses two RCS loops. Each RCS loop contains a SG and two/eactor foolantgumps 3 1 (RCPs). An RCP is located in each of the two SG cold legs. l The pump flow rate has been sized to provide core heat l moval with appropriate margin to /eparture from p6cleate iling (DNB) during power operation and for anticipated ransients originating from power operation. This l !- Specification requires two RCS loops with both RCPs in ! operation in each loop. The intent of the Specification is l to require core heat removal with forced flow during power i operation. Specifying two RCS loops provides the minimum necessary paths (two SGs) for heat removal. I APPLICABLE . Safety analyses contain various assumptions for the Design SAFETY ANALYSES' Bases Accident (DBA) initial conditions including RCS pressure, RCS temperature, reactor power level, core parameters, and safety system setpoints. The important I (continued) i O- B 3.4-17 Rev 1, /07/95 b k hnb.kidh
' I
. 1 2
i l I l RCS Loops-MODES 1 and 2 B 3.4.4 I BASES APPLICABLE aspect for this LCO is the reactor coolant forced flow rate, which is represented by the number of RCS loops in service. SAFETY ANALYSES (continued) Both transient and steady state analyses have been performed . to establish the effect of flow on DNB. The transient or ! accident analysis for the plant has been performed assuming four RCPs are in operation. The majority of the plant safety analyses are based on initial conditions at high core power or zero power. The accident analyses that are of most importance to RCP operation are the four pump coastdown, single pump locked rotor, single pump (broken shaft or coastdown), and rod withdrawal events (Ref.1). Steady state DNB analysis had been performed for the (dyfour[ For'%fourYpumpoperation,thestea
- pump combination.
state DNB analysis, which gefibrates the pressure and temperature and Safety Limit (i.e., the departure from
. nucleate boiling ratio (DNBR) limit), assumes a maxh 1n power level of 107% RTP. This is the design overpower condition for four pump operation. The 107% value is the accident analysis setpoint of the nuclear overpower (high flux) trip and is based on an analysis assumption that bour>ds possible instrumentation errors. The DNBR limit defines a locus of pressure and tecperature points that result in a minimum DNBR greater than or equal to the critical heat flux correlation limit.
RCS loops-MODES I an sa Criterlayad 't 4tuiOiB M 'N' )OC SC).hW (.00_G)
-~
LCO The purpose of this LCO is to require adequate forced flow for core heat removal. Flow is represented by having both RCS loops with both RCPs in each loop in operation for removal of heat by the two SGs. To meet safety analysis acceptance criteria for DNB, four pumps are required at rated power. Each OPERABLE loop consists of two RCPs providing forced flow for heat transport to an SG that is OPERABLE in ' accordance with the Steam Generator Tube Surveillance Program. 5G, and hence RCS loop, OPERABILITY with regard to l SG water level is ensured by the Reactor Protection System l A reactor trip places the plant in (RPS) in MODES I and 2. (continued) RevCN D4/07//J5) M B 3.4-18 6 - i ts ,2,3 D
_ _ _. _. . .- . ._m . . . . _ _ ._ ._ _ ._ .. i
\
I e l l 1 1 RCS Loops-MODES I and 2 I B 3.4.4 !
] BASES LaJh gf\p j LCO MODE 3 if any SG 1evel is s as sensed by the RPS. !
(continued) minimum water level to declare the SG OPERABLE is s
.uda.es3s.Shab T#
APPLICABILITY In MODES I and 2, the reactor is critical and thus has the potential to produce maximum THERMAL POWER. Thus, to ensure , that the assumptions of the accident analyses remain valid, , all RCS loops are required to be OPERABLE and in operation ) in these MODES to prevent DNB and core damage. 4 The decay heat production rate is much lower than the full
.. power heat rate. As such, the forced circulation flow and heat sink requirements are reduced for lower, noncritical MODES as indicated by the LCOs for MODES 3, 4, 5, and 6.
Operation in other MODES is covered by: ^ LCO 3.4.5, 'RCS Loops-MODE 3*! LCO 3.4.6, 'RCS Loops-MODE 4*; LCO 3.4.7, 'RCS Loops-MODE 5, Loops filled"; 4 LCO 3.4.8, 'RCS Loops-MODE 5. Loops Not filled";
- LCO 3.9.4, " Shutdown Cooling (SDC) and Coolant
) Circulation-High Water Level" (MODE 6); and LCO 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level" (MODE 6).
ACTIONS Ad If the requirements of the LCO are not met, the Required Action is to reduce power and bring the plant to MODE 3. This lowers power level and thus reduces the core heat 4 removal needs and minimizes the possibility of violating DNB limits. it should be noted that the reactor will trip and place the plant in MODE 3 as soon as the RPS senses less than four RCPs operating. The Completion Time of 6 hours is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging safety systems. l J l
< -y l
# (continued)
En Jr1 - B 3.4-19 Rev 04 @ :
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l i l l l RCS Loops-MODES I and 2 ' l l B 3.4.4 l BASES (continued) m _ i UJC L%
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MWhaT)
~ -
l 1 SR 3.4.4.1 i
/ SURVEILLANCE REQUIREMENTS D / g This SR r uires if cation;every 12 hours A the require l
number of oops n operation". Verification includes flow ~f i rate, temperature, or pump status monitoring, which help to i ensure that forced flow is providing heat removal while i maintaining the margin to DNB. The Frequency of 12 hours ! has been shown by operating practice to be sufficient to l regularly assess degradation and verify operation within I safety analyses assumptions. In addition, control room indication and alarms will normally indicate loop status. l REFERENCES 1. SAR, Section i i l l j l l 1 l l l l ! s M 6JdC,*Orsdbi k[b i Rev CD'D4 /0)Si> Q B 3.4-20 A
NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.4 l l l
~
PALO VERDE ITS CONVERSION l NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.4 - RCS Loops - Modes 1 And 2
- 1. The Bases was revised for consistency with other Bases sections.
- 2. The plant specific titles, nomenclature, number. parameter /value.
reference, system description, system design, operating practices or analysis description was used (additions deletions, and/or changes are included). Plant specific parameters / values are directly transferred from the CTS to the ITS,
- 3. Grammar and/or editorial changes have been made to enhance clarity. No technical or intent changes to the Specification are made by this change.
l l l l l l l l l l PALO VERDE - UNITS 1,2, AND 3 1 REV.A g - . - _ ,
1 1 l I I l 1 l ! 6 i l l l I l l 1 i i 1 1 l i i PVNGS CTS - SPECIFICATION 3.4.4 I MARK UP i i i 4 1 4 l l I I l I i a l i
C' O.OT4.OTio3 d.O . k 1 A.\ 3A f3/a.aT REACTOR COOLANT SYSTE h( D 3,Q 3/a. REACT 0ll' COOLANT LOO /S AND C00LMT CIRCULAf!O _ - D \ qdt NRTUPAND ER OPERATI ] 3 1 (LIMfTING CDffDITION #0R OPER4F10K3 g4 1. .1.1 bothreactorcoolantloops){ngboth f(actor / cool /t pupsfs in e[ch 4eop-shall be in operation.J g APPLICABILITY: MODES 1 and 2". -- - ACTION: gA ! With least HOT16ss than the STANDBY above within % hour.requiredWact# coolant 06mpslin operation, be in at) L C.\ i i SURVEILLANCE REQUIREMENTS i 1&hM.\ 0.0.'rb The above required reactor coolant loops shall be verified to be in operationiapo circylating/eactor/coolapOat least once per 12 hours. hk.7 "5eySpecialTest ception 3. 3. < k.E ! i l i 3/4 4-1 Palo Verde - Units 1, 2, 3
I l DISCUSSION OF CHANGES SPECIFICATION 3.4.4 l 1 i I
PALO VERDE ITS CONVERSION DISCUSSION OF CIIANGES l SPECIFICATION 3.4.4 - RCS Loops - Modes 1 And 2 l ADMINISTRATIVE CHANGES l A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CE0G) Standard Technical Specifications NUREG-1432. , Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station ) (PVNGS) Improved Technical Specifications (ITS) should be more readable. I and therefore understandable, by plant operators as well as other users. l During the reformatting and renumbering of the ITS. no technical changes ! (either actual or interpretational) to the Current Technical Specifications l (CTS) were made unless they were identified and justified. Editorial rewording (either adding or deleting) is made consistent with NUREG-1432. During NUREG-1432 development, certain wording preferences or , English language conventions were adopted which resulted in no technical ! changes (either actual or interpretational) the CTS. Additional information has also been added to more fully describe each ! subsection. This wording is consistent with NUREG-1432. Since the design l 1s already approved by the NRC, adding more detail does not result in a technical change. A.2 CTS 3.4.1.1. Applicability Footnote, references "See Special Test Exception 3.10.3." Cross references are not used in the ITS or NUREG-1432. Removing l cross references does not alter the requirements of the referenced Specification. Therefore, this is an administrative change with no impact on safety. This change is consistent with NUREG-1432. l l TECHNICAL CHANGES - MORE RESTRICTIVE i None l PALO VERDE - UNITS 1,2 AND 3 1 REV.A l
l l PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.4 - RCS Loops - Modes 1 And 2 1 4 l TECHNICAL CHANGES LESS RESTRICTIVE l L.1 CTS 3.4.1.1 requires entry into Mode 3 within 1 hour with less than 2 RCPs operating in each loop. ITS 3.4.4 Action A. requires entry into Mode 3 within 6 hours with less than 2 RCPs operating in each loop. The relaxation of Completion Time to enter Mode 3 constitutes a less restrictive change. The Completion Time of 6 hours is reasonable, based on operating experience, to reach Mode 3 from full power conditions in an orderly manner and without challenging safety concerns. It should be noted that the l reactor will trip and place the plant in Mode 3 as soon as the RPS senses less than four RCPs operating. This change does not detrimentally affect plant safety and is consistent with NUREG-1432. 4 l PALO VERDE - UNITS 1,2, AND 3 3 REV.A
1 l l l l l l l I l l l l NO SIGNIFICANT HAZARDS CONSIDERATION l SPECIFICATION 3.4.4 l l l l l l
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.4 - RCS Loops - Modes 1 And 2 l l ADMINISTRATIVE CHANGES l (ITS 3.4.4 Discussion of Changes Labeled A.1 and A.2) I i Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). ; Units 1. 2. and 3. is converting to the ITS as outlined in NUREG-1432. " Standard , l Technical Specifications. Combustion Engineering Plants." The proposed changes ! l involve the reformatting, renumbering. rewording of the Technical Specifications j i -(TS) and Bases with no change in intent. and the incorporation of current l operating practices consistent with NUREG-1432. These changes, since they do not involve technical changes to the Current TS (CTS) are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this l Section/ Chapter to NUREG-1432. l l The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to l an operating license for a facility involves a no significant hazards consideration if operatics of the facility, in accordance with a proposed i amendment, would not 1) involve a significant increase _in the probability or I consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
-Standard 1. - Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
l The proposed changes involve reformatting, renumbering, and rewording of i the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432. certain wording preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. I PALO VERDE - UNITS 1,2, AND 3 1 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.4 - RCS Loops - Modes 1 And 2 l ADMINISTRATIVE CHANGES (ITS 3.4.4 Discussion of Changes Labeled (A.1 and A.2) (continued) Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes involve reformatting, renumbering and rewording of the CTS along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or change the methods l governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3.-- Does the proposed change involve a significant reduction in a margin of safety? The proposed changes involve reformatting, renumbering, and rewording of the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes are' administrative in nature and will not involve any technical changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. l l PALO VERDE - UNITS 1,2, AND 3 2 Rev. A
i l NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.4 - RCS Loops - Modes 1 And 2 l TECHNICAL CHANGES - RELOCATIONS (ITS 3.4.4 Discussion of Changes Labeled LA.1 and LA.2) Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed changes, since detail is being removed from the CTS to a Licensee Controlled Document, are less restrictive. The descriptions of these changes are in the Discussion of Changes listed above. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to l an operating license for a facility involves a no significant hazards l consideration if operation of the facility, in accordance with a proposed ! amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated; 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes do not result in any hardware changes or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee Controlled Document containing the relocated requirements will be maintained using the provisions of 10 CFR 50.59 or other specified control processes and is subject to the change control process in the Administrative Controls Section of the ITS. Since any changes to a Licensee Controlled Document will be evaluated, no increase in the probability or consequences of an accident previously evaluated will be allowed. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 3 Rev. A
NO SIGNIFICANT IfAZARDS CONSIDERATION ITS Section 3.4.4 - RCS Loops - Modes 1 And 2 TECHNICAL CHANGES RELOCATIONS I (ITS 3.4.4 Discussion of Changes Labeled LA.1 and LA.2) (continued) l 1 Standard 2.- Does the proposed change create the possibility of a new or l different kind of accident from any accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes will not impose ! ! different requirements and adequate control of information will still be I l maintained. These changes will not alter assumptions made in the safety l l analysis or licensing basis. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident i previously evaluated. ! Standard 3.-- Does the proposed change involve a significant reduction in a margin of safety? The proposed changes relocate requirements from the CTS to a Licensee l Controlled Document. These changes will not reduce a margin of safety l since they have no impact on any safety analysis assumptions. In addition, the requirements to be transposed from the CTS to the Licensee Controlled l Document .are the same as the CTS. Since any future changes to this Licensee Controlled Document will be evaluated per the requirements of 10 CFR 50.59. or other specified control processes, no reduction (significant or insignificant) in a margin of safety will be allowed. l Therefore, these changes will not involve a significant reduction in a margin of safety. l The NRC review provides a certain margin of safety a,nd although this review will no longer be performed prior to submittal, the NRC still ) inspects the 10 CFR 50.59 process. The proposed changes are consistent with NUREG-1432. which was approved by the NRC Staff. The change controls for proposed relocated details and requirements provide an acceptable level
- of regulatory authority. Revising the CTS to reflect the approved level of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore, revising the CTS to reflect the NRC accepted level of detail and requirements ensures no
. reduction in a margin of safety. PALO VERDE - UNITS 1.'2, AND 3 4 Rev. A
1 i NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.4 - RCS Loops - Modes 1 And 2 1
- TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.4 Discussion of Changes Labeled L.1)
Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The , proposed change involves making the CTS less restrictive. Below is the ! description of this less restrictive change and the NSHC for the conversion to ! NUREG 1432. L.1 CTS 3.4.1.1 requires entry into Mode 3 within 1 hour with less than 2 RCPs operating in each loop. ITS 3.4.4. Action A. requires entry into Mode 3 l within 6 hours with less than 2 RCPs operating in each loop. The relaxation i of Completion Time to enter Mode 3 constitutes a less restrictive change. I The Completion Time of 6 hours is reasonable, based on operating experience, to reach Mode 3 from full power conditions in an orderly manner j and without challenging safety concerns. It should be noted that the , reactor will trip and place the plant in Mode 3 as soon as the RPS senses less than four RCPs operating. This change does not detrimentally affect i plant safety and is consistent with NUREG-1432. ) i The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A propose ~d amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with 'a proposed
. amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
PALO VERDE - UNITS 1,2, AND 3 5 Rev.A
NO SIGNIFICANT HAZARDS CONSIDERATION l ITS Section 3.4.4 - RCS Loops - Modes 1 And 2 TECHNICAL CHANGES - LESS RESTRICTIVE
-(ITS 3.4.4 Discussion of Changes Labeled L.1) (continued)
Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? l The proposed change relaxes the completion time for the plant to enter Mode 3 with less than 2 RCP's operating in each loop. The CTS 3.4.1.1 l requires the plant to enter Mode 3 within 1 hour with less than 2 RCP's L operating in each loop, where the ITS allows the plant 6 hours to reach ! i Mode 3 with less than 2 RCP's operating in each loop. The completion time
- of 6 hours is reasonable, based upon operating experience, to reach Mode 3 l from full power conditions in an orderly manner and without challenging safety concerns. The current design of the plant has the Reactor .
Protection System initiate a reactor trip placing the plant in Mode 3 as soon as it senses there are less than 4 RCP's operating. Therefore, this I change will not affect the probability of an accident. The consequences of an accident are not significantly affected by this change. The change does not alter assumptions relative to the mitigation of an analyzed event. Therefcre, the change will not involve a significant increase in the probability or consequences of an accident previously evaluated. Standard 2. Does the proposed change create the possibility of a new or l different kind of accident from any accident previously evaluated? The proposed change relaxes the completion time for the plant to enter l Mode 3 with less than 2 RCP's operating in each loop. The CTS 3.4.1.1 requires the plant to enter Mode 3 within 1 hour with less than 2 RCP's operating in each loop, where the ITS allows the plant 6 hours to reach . , Mode 3 with less than 2 RCP's operating in each loop. The completion time l of 6 hours is reasonable, based upon operating experience, to reach Mode 3 ) l from full power conditions in an orderly manner and without challenging l safety concerns. This change will not physically alter the plant ( no new ' or different type of equipment will be installed). This change does not require any new or unusual operator actions. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated. i l l PALO VERDE - UNITS 1,2, AND 3 6 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.4 - RCS Loops - Modes 1 And 2 TECHNICAL CHANGES LESS RESTRICTIVE ! (ITS 3.4.4 Discussion of Changes Labeled L.1) (continued) l Standard 3. Does the proposed change involve a significant reduction in a margin of safety? The proposed change relaxes the completion time for the plant to enter Mode 3 with less than 2 RCP's operating in each loop. The CTS 3.4.1.1 i requires the plant to enter Mode 3 within 1 hour with less than 2 RCP's operating in each loop, where the ITS allows the plant 6 hours to reach l Mode 3 with less than 2 RCP's operating in each loop. The completion time of 6 hours is reasonable, based upon operating experience, to reach Mode 3 l from full power. conditions in an orderly manner and without challenging safety concerns. The margin of safety is not affected by this change. Therefore, this change does not involve a significant reduction in a margin of safety. i I h I l PALO VERDE - UNITS 1,2, AND 3 7 Rev.A L
CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.5 MARK UP i i l 1 l 1 0
. .. . _ . - . . ~- . . - - . ~ . . - - - -. . . . --
r i
~
r i I i
<c@ RCS Loops-MODE 3 3.4.5 l
3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 RCS Loops-MODE 3 ! ( C Q 1 ,k ), E LCO 3.4.5 4Twog RCS loops shall be OPERABLE and one RCS loop shall be in operation.
---- - ---NOTE --------
All reactor coolant pumps may be de-energized for s I hour Oc)(, A,g . per 8 hour period, provided:
- a. No operations are permitted that would cause reduction i (QX M.7-), of the RCS boron concentration; and l
\
gh b. Core outlet temperature is maintained at least 10*F { h.4.\.T. Eh, / below saturation temperature. i l APPLICABILITY: MODE 3. 1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required RCS loop A.1 Restore required RCS 72 hours S
/,N,4,\,2 d a, loop to OPERABLE inoperable.
status. . Required Action and B.1 Be in MODE 4. 12 hours
.4 1.2. M T a. .
associated Completion Time of Condition A , not met. (continued) l f G 3.4 8 Rev C/04/E7,90 O TdC, 'Dr\dD i k lib
l 1 i l' l l l l RCS Loops-MODE 3 3.4.5 l ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME 3,4 l.2, kC,T b. . No RCS locp OPERABLE. C.1 Suspend all Innediately operations involving
.B a reduction of RCS g g y/
Q boron concentration. No RCS loop in y c g ,3 ) 8!g l operation. C.2 Initiate action to Innediately l
. restore ene RCS loop to OPERABLE status i and operation. .
j
$URVEILLANCE REQUIRENENTS ,_
SURVEILLANCE FREQUENCY ,
- l 1
4,k 1,1 SR 3.4.5.1 Verify required RCS loop is in operation. 12 hours d.4. \. 2 ,3 SR 3.4.5.2 Verify seco-dary side water level in each 12 hours' steam generator 24254%. 4,4,1,2, ,i SR 3.4.5.3 Verify correct breaker alignment and 7 days indicated power available to the required pump that is not in operation. i i l l Ne/ A k As (2 4 ( gK, r/5) 3.4-9 Rev 0 A4/qr/93 i-
i r { l I i l l CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.5 BASES MARK UP i l l
~
I i l I I~ 1 1 RCS Loops-MODE 3 I B 3.4.5 )
) B 3.4 REACTOR COOLANT SYSTEM (RCS)
B 3.4.5 RCS Loops-MODE 3 BASES I BACKGROUND The primary function of the reactor coolant in MODE 3 is 1 l r moval of decay heat and transfer of this heat, via the i es enerators (SGs), to the secondary plant fluid. The
, co ary function of the reactor coolant is to act as a arrier for solubl eutton poison, boric acid.
In MODE 3, eactor oolant umps (RCPs) are used to provide ! forced circulation eat removal during heatup and cooldown. i The MODE 3 decay heat removal requirements are low enough I l' that a single RCS loop with one RCP is sufficient to remove core decay heat. However, gtwoKRCS loops are required to be OPERABLE to provide redundant paths for decay heat removal. Only one RCP needs to be OPERABLE to declare the associated RCS loop OPERABLE. Reactor coolant natural circulation is not normally used but J is sufficient for core cooling. However, natural
- circulation does not provide turbulent flow conditions. I Therefore, boron reduction in natural circulation is ) prohibited because mixing to obtain a homogeneous concentration in all portions of the RCS cannot be ensured.
APPLICABLE Analyses have shown that the rod withdrawal event from SAFETY ANALYSES MODE 3 with one RCS loop in operation is bounded by the rod withdrawal initiated from MODE 2. Failure to provide heat removal may result in challenges to
' -a fission product barrier. The RCS loops are part of the primary success path that functions or actuates to prevent or mitigate a Design Basis Accident or transient that either assumes the failure of, or presents a challenge to, the integrity of a fission product barrier.
RCS Loops- sa terian Laf tW Nar Popop W. (. O U f) I Li I. L J & l
) (continued) 56G [ B 3.4-21 Rev EA4/07/99 h YQ.f'dl2,. M b I 2. i h.
RCS Loops-MODES 3 8 3.4.5 BASES (contic 4 LCO The purpose of this LCO is to require Itwo[RCS loops to be available for heat rcmoval, thus providing redundancy. The 6 LCO requires the)(tw loops to be OPERABLE with the intent of requiring bot 6 3Gs o be capable (+.-GMkwater level) of .k W/o d ro%4., transferring heat from t'e n reactnr coolant'at e controlled J rate. Forced reactor coolant flow is the required way to transport heat, although natural circulation flow provides adequate removal. A minimum of one running RCP meets the LCO requirement for one loop in operation. D OC I'A 9[ The Note permits a limited period of operation without RCPs. All RCPs may be de-energized for 51 hour per 8 hour period. 2 This means that natural circulation has been established. When in natur*' circulation, a reduction in boron concentration s prohibited be:ause an even concentrati n gyg ( distribution thioughout the RCS cannot be ensured. ore Sap e q 6 or outlet temperature is to be maintained at least 10*F below b TE0d* the saturation temperature so that no vapor bubble may form d"IN and possibly cause a natural circulation flow obstruction. dge ( 4h P In MODEY 3.-0. .; t is sometimes necessary to stop all k D dW4b RCPs 'shutdj$n coo ing 3 1h" e.a . to crurnge 'operat,fspC) pumpforced ctrfulation/wn from on(SDC traitrto the g(herd Io g rform surveillance or startup testing, W eerfpfm pleJ 3
* (f _ .
cm my, or to avoid operation below the RCP minimum net positive suction head limit). The time period is acceptable because natural circulation is adequate for heat removal, or the reactor 6 coolant temperature can be maintained subcooled and horon stratift af control is not ex e ted. amm An OPE
~
new[r proTitaTng 9 forced flow for heat transport and a G that is OPERABLE in accordance with the Steam Generator Tube Surveillance Program. An RCP is OPERABLE if it is capable of being powered and is able to provide forced flow if required. APPLICABILITY In MODE 3, the heat load is lower than at power; therefore, one RCS loop in operation is adequate for transport and heat reamval . A second RCS loop is required to be OPERABLE but j not in operation for redundant heat removal capability. I l Operation in other MODES is covered by: j (continued) CrRG s(D B 3,4-22 Rev0/04 /07f91b b 9/dt.Oh h2.h l i
1 I RCS Loops-MODES 3 B 3.4.5 BASES APPLICABILITY LCO 3.4.4, 'RCS Loops-MODES I and 2*; (continued) LCO 3.4.6, 'RCS Loops-MODE 4'; LCO 3.4.7, 'RCS Loops-MODE 5, Loops Filled"; LCO 3.4.B. *RCS Loops-MODE 5, Loops Not Filled"; LCO 3.9.4, ' Shutdown rooling (SDC) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level" (MODE 6). ACTIONS AJ If one required RCS loop is inoperable, redundancy for
. forced flow heat removal is lost. The Required Action is restoration of the required RCS loop to OPERABLE status within a Completion Time of 72 hours. This time allowance is a justified period to be without the redundant, nonoperating loop because a single loop in operation has a heat transfer capability greater than that needed to remove the decay heat produced in the reactor core.
) L.1
- If restoration is not possible within 72 hours, the unit q
must be placed in MODE 4 within 12 hours. In MODE 4, the plant may be placed on the SDC System. The Completion Time of 12 hours is compatible with required operation to. achieve cooldown and depressurization from the existing plant conditions in an orderly manner and without challenging plant systems. C.1 and C.2 4(, If no RCSloap'ishn operation,%xesnT3s propeea yoJtoTiry e in tw semu_m all operations involving . reaucuon of RCS boron concentration must be inwnediately suspended. This 7 is necessary because boron dilution requires forced circulation for proper homogenization. Action to restore one RCS loop to OPERABLE status and operation shall be initiated immediatW and continued until one RCS loop is restored to OPERABLE status and operation. The innedtate Completion Times reflect the importance of maintaining operation for decay heat removal.
) (continued)
B 3.4-23 Rev & c4/M /n5) G h Yt/bt.
- N% Nlh
I I i I l l l t i l I ! l ! RCS Loops-MODE 3 l B 3.4.5 I I BASES (continued) N ^ -M
' DX_ L A.C./ g.3rdcirc km3 SURVEILLANCE SR 3.4.5.1 / " g f Q .-
REQUIREMENTS l This SR requires verificatioa every 12 hours tha the i required number of RCS loops are in operation erification includes flow rate, temperature, Apump status monitoring, ,.. @T / which help ensure that forced flow isivv anng neat f* , removal. The 12 hour interval has been shown by operating l practice to be sufficient to regularly assess degradation ! and verify operation within safety analyses assumptions. In J addition, control room indication and alarms will nomally 1 indicate loop status. ' N $R 3.4.5.2 COC. LA,b / e I This SR requires verification every 12 hours that I i secondary adequate SG side water water levellevel in eachinSG is required t5 An is 1 {r t)o have a hea orde 9 sink for removal of the core decay heat from the reacts,r coolant. Tne 12 hour interval has been shown by operating practice to be sufficient to regularly assess degradation and verify operation within the safety analyses assumptions. l , ! SR 3.4.5.3 l l Verification that the required r. umber of RCPs are OPERABLE I l ensures that the single failure criterion is met and that an i additional RCS loop can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power availability to the required RCPs. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. REFERENCES None. 1 GIOG II B 3.4-24 Rev W O4/pfjF3 Rf YO\\ \
I i 1 l i l i I I l NUREG-1432 EXCEPTIONS ! 1 i SPECIFICATION 3.4.5 4 1 1 l l I l l l i l r
PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS 1 SPECIFICATION 3.4.5 - RCS Loops - Mode 3
- 1. Grammar and/or editorial changes have been made to enhance clarity. No technical or intent changes to the Specification are made by this change.
l 2. ITS 3.4.5. LC0 Bases, adds a sentence to clarify the intent of the Note. 4 item (a), in the LCO. Since this Note could be interpreted to stop any activity that has even a remote possibility of affecting RCS boron
. concentration, it was decided to clarify its intent. NUREG-1432 does not clarify intent of the LC0 Note. item (a). Interpreting this Note in the global sense would have profound affects on maintenance activities and
- - limit our ability to respond to plant needs, A sentence that states "The ,
4 intent is to stop any known or direct positive reactivity additions to the j RCS". was added to clarify intent of the Note, item (a). This clarifies
- PVNGS operating practice and is consistent with PVNGS licensing basis.
^
- 3. NUREG-1432. LCO 3.4.5. Bases Section makes reference to Mode 4 and 5 operation. ITS LC0 3.4.5. Bases Section will only reference Mode 3 operation. This Specification is a Mode 3 Applicability and should only reference Mode 3 operations. Though the statement is true for Modes 4 and 5 it adds no value to the information presented. In fact it introduces some confusion as to why a Mode 3 Specification is referencing operations in Modes 4 and 5. The renoval of this information is a deviation from NUREG-1432 but is consistent with PVNGS licensing basis.
- 4. Bases revised for consistency with other Bases Sections.
- 5. ITS 3.4.'5 LC0 Bases removes any references that state it may be necessary to stop SDC pump forced circulation for shifting of SDC trains. or to transition to or from SDC. This is done because PVNGS does not secure SDC forced circulation for any of these evolutions. This change is consistent with PVNGS licensing basis.
- 6. NOT USED 4
EALO VERDE - UNITS 1,2, AND 3 1 REV.B
+
m _ > . _ . _ . ..m.. _ _ _ . _ _ _ _ _ . . . _ _ . _ _ . - . - _ _ _ _ _ _ . . _ _ . _ _ . A
~
PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS l SPECIFICATION 3.4.5 - RCS Loops - Mode 3
- 7. ITS, Actions C. Bases deletes reference to Note l' in the LC0 section.
Location of Note 1 reference implies - that suspension of operations involving a reduction in of RCS boron concentration are not required. This implies that compliance with Note 1 is not required. The bases is trying to emphasize that performance of Required Actions is not required when the l- RCS loops are secured in accordance with Note 1 Compliance with Note 1 is still required; no operations are permitted that would cause reduction of the RCS boron concentration, and core outlet temperature is maintained at least 10 F below saturation temperature. There is no need to reference ' Note 1 in Action C Bases. Note 1 stands alone and its usage is understood. i If no RCS loops are in operation, based on Note 1 usage, it is not l required to perform the Required Actions of Actions A and C. It is only required to comply with the requirements of Note 1. Should failure to meet the requirements of Note 1 occur. entry into Actions A and C is required. This change is consistent with PVNGS licensing basis. ' ! 8. The plant specific titles, nomenclature, number, parameter /value, reference, system description. system design operating practices or analysis description was used (additions, deletions, and/or changes are , included). Plant specific parameters / values are directly transferred from the CTS to the ITS. l 1 l i f ) PALO VERDE - UNITS 1,2, AND 3 2 REV.A , i-
1 1 I I i 1 1 1 I l 1 l l 1 PVNGS CTS I i SPECIFICATION 3.4.5 MARK UP i 1 i i 1 1 1 l l L i i l i i
OxcAcokrn 54.5' ( l A.\ ,
, REACTOR C00LANT SYSTE D)
[ _ A.f m w - Nun 3 (~LIBiflNG C9fiDIT10N RiR OpERAT)6N) .- - J'iuV)
~
3, .1d'2 /rhalreactor coolant loops Q 1 one of these reactor coolant loops sha' shall be OPERABLE and at least 1 be n operation *. 1 !- F
- a. R ctor Coolant Loo 1 and its associa d steam generato and at '
ast one associst reactor coolant , g, g
- b. Reactor Coolant oop 2 and its ass isted steam gene tor and at
(- least one asso ated reactor cool t pump, l f)/ [ APPLICABILITY: MODE 3# D j ACTION: o m q ui p % $ ( % ~4 W> f y Nh lesdhan_ thdbove eduired reJf(tor coednt loop PERABLb g6 3 store the recuired
;GnJiDT,$HuTh" locos to within _thamt 12 OPERABLE ha"'" status within 72 hauemfor K l
C"b ~-- a osp= , X[WithnoreactorcoolantT n operation, uspend all ooerations ! involving a reduction in boron concentrati of the Reactor Coolant l (,,_ - System and immediately initiate corrective etian ta return the l 1 required reactor coolant loop to operation) ~
$URVEILLANCE REQUIREMENTS A 4.1.H/D At least the above required reactor coolant pumps, if not in '
%M.S.'5 operat' on, shall be determined to be OPERABLE once per 7 days ey verifying l correct breaker alignments and indicated power availability.
NO Wa.1.2/27 At least one_ reactor coolant loop shall be verified to be in operation (anyttreula)(ng reacp5r cooWt)at least once per 12 hours. i _ M1.2/33 The required steam generator (s) shall be determined OPERABLE bv LA. (b A,dj,2,, verifying the secondary side water level to be 125%(Tpsicatapfwice/Engel (level at least once per 12 hours.f - r - O.h
$.D reactor cc cur}p vided k (1) no operations are permitted that would cause dilution of the Reactor Coolant System boron concentration, and (2) core outlet temperature is
{ intained at_1 4a a(1)*F bel.ow saturation temperatureg Tg/$pecial/fest EsteptionA.10.W nh I
~
A'P' 4 . 3/4 4-2 .
~
Palo Verde - Units 1, 2, 3 l 4
1 t i l l 1 l DISCUSSION OF CHANGES SPECIFICATION 3.4.5 I l l l i l ?
k PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.5 - RCS Loops - Mode 3 6QM_INISTRATIVE CHANGES A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CE0G) Standard Technical Specifications NUREG-1432. Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station (PVNGS) Improved Technical Specifications (ITS) should be more readable, and therefore understandable, by plant operators as well as other users. During the reformatting and renumbering of the ITS. no technical changes (either actual or interpretational) to the Current Technical Specifications (CTS) were made unless they were identified and justified. Editorial rewording (either adding or deleting) is made consistent with NUREG-1432. During NUREG-1432 development, certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more detail does not result in a technical change. A.2 CTS 3.4.1.2. Applicability Footnote, references "See Special Test Exception 3.10.9." Cross references are not used in the ITS or NUREG-1432. Removing cross references does not alter the requirements of the referenced Specification. Therefore, this is an administrative change with no impact on safety. This change is consistent with NUREG-1432. A.3 CTS 3.4.1.2. Action a does not specifically identify the condition that defines Operable, not in operation, or condition not met. ITS 3.4.5 Actions A and B do define what condition defines inoperable, not in operation, or condition not met (one RCS loop inoperabla). This change will split CTS 3.4.1.2. Action a, into two separate Actions. A and B. in ITS. The splitting of an Action into two separate Actions for clarification constitutes an administrative change. This change is consistent with NUREG-1432. t PALO VERDE - UNITS 1,2, AND 3 1 REV.A
, PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.5 - RCS Loops - Mode 3 TECHNICAL CHANGES HORE RESTRICTIVE M.1 CTS 3.4.1.2. Action b. requires the suspension of all operations involving , a reduction in boron concentration of the RCS when no RCS loop is in 4 operation. The CTS does not provide any Completion Time associated with this Action. ITS 3.4.5. Action C.1 requires suspension of all operations involving a reduction of RCS boron concentration. "immediately." CTS only associates the term "immediately" with Action to return the required RCP loop to operation not with the Action to suspend all operations involving a reduction in boron concentration of the RCS. The addition of
- "immediately" for Completion Time to suspend all operations involving a 1
reduction in toron concentration of the RCS reflects the importance of 2 maintaining operation of decay heat removal. The addition of this requirement constitutes a more restrictive change to PVNGS plant operation. This change is consistent with NUREG-1432. M.2 CTS 3.4.1.2. Footnote *. allows all RCPs to be de-energized for up to one . hour. ITS 3.4.5 LCO Note allows all RCPs to be de-energized for up to 1 hour per 8 hour period. Therefore, the amount of time all RCPs may be
- de-energized has been restricted from less than or equal to one hour, to less than or equal to one hour per eight hour period. CTS would permit l repeated application of the one hour exemption. indefinitely. This i additional restriction on plant operation restricts immediate, repeated
- application of the one-hour allowance, which would circumvent the intent i of the Note. Although not explicitly stated in CTS. PVNGS operating practice complies with the 1 hour per 8 hour period requirement statement in ITS 3.4.5 Note. This change provides explicit wording that clarifies
- PVNGS operating practice in application of this LCO. Placing a limitation on the de-energization of all RCPs will not adversely affect plant safety.
4 Placing additional restrictions on plant operation constitutes a more restrictive change. This change is consistent with NUREG-1432. I l PALO VERDE - UNITS 1,2, AND 3 2 REV.A
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES . SPECIFICATION 3.4.5 - RCS Loops - Mode 3 TECHNICAL CHANGES MORE RESTRICTIVE (continued) M.3 CTS 3.4.1.2. Action b. requirements are imposed only when no reactor coolant loop is in operation. ITS 3.4.5. Action c. contains the same Action requirements as CTS 3.4.1.2 Action b (except as discussed in M.1). but is more restrictive by also imposing the Action requirements when no reactor coolant loops are OPERABLE. This change is acceptable because this will eliminate any ambiguity that could incorrectly result in having two loops inoperable yet one loop in operation for the purposes of compliance with the Actions. This change is consistent with NUREG-1432. TECHNICAL CHANGES RELOCATIONS LA.1 CTS LCO 3.4.1.2 specifies the loop numbers, components making up a loop. l and that one RCP per loop is required. The specific loop numbers exist in l the UFSAR and the components making up a loop and the number of RCPs required per loop is moved to Section 3.4.5 of the ITS Bases. Any changes to the UFSAR will require a 10 CFR 50.59 evaluation. Any changes to the Bases will be in accordance with .ITS Chapter 5.0 Bases l Control Program. This provides an equivalent level of controi and is an administrative change with no impact on the margin of safety. This ; information is not required to be in ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to a Licensee Controlled Document is acceptable and is consistent with I NUREG-1432. LA.2 CTS 4.4.1.2.2 requires the reactor coolant loops to be verified in I operation and " circulating reactor coolant." The requirement to circulate reactor coolant is moved to Section 3.4.5 of the ITS Bases. Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an l administrative change with no impact on the margin of safety. This ) information is not required to be in ITS to provide adequate protection of l l public health and safety. Therefore, relocation of this requirement to a i Licensee Controlled Document is acceptable and is consistent with l
- NUREG-1432.
} } PALO WOE - UNITS 1,2, AND 3 3 REV.A l
l PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES ; I SPECIFICATION 3.4.5 - RCS Loops - Mode 3 TECHNICAL CHANGES - RELOCATIONS (continued) l LA.3 CTS SR 4.4.1.2.3 specifies that " indicated wide range" level is to be used l for verification of SG 1evel. All values in ITS are indicated values. This i information, less the word " indicated". is moved to ITS 3.4.5 Bases l Section. l l l Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases I Control Program. This provides an equivalent level of control and is an i administrative change with no impact on the margin of ' safety. This ! information is not required to be in ITS to provide adequate protection of , public health and safety. Therefore, relocation of this requirement to a 1 Licensee Controlled Document is acceptable and is consistent with i NUREG-1432. l TECHNICAL CHANGES LESS RESTRICTIVE None l l l l l l l l l i . PALO VERDE - UNITS 1,2, AND 3 4 REV.A
I t ! I i l i
)
1 I i l i l NO SIGNIFICANT HAZARDS CONSIDERATION l SPECIFICATION 3.4.5 : 1 i i l ! 1 i < l l 1 1 1 i . l l l i l l l l l 1 J d f
~- .- . - - . - .- _ _ - - -. --
NO SIGNIFICANT HAZARL)S CONSIDERATION ITS Section 3.4.5 - RCS Loops - Mode 3 ADMINISTRATIVE CHANGES (ITS 3.4.5 Discussion of Changes Labeled A.1. n.2 and A.3) Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). o Units 1. 2. and 3. is converting to the ITS as outlined in NUREG-1432. " Standard Technical SpecUications. Combustion Engineering Plants." The proposed changes l involve the reformatting. renumbering, rewording of the Technical Specifications l (TS) and Bases with no change in intent. and the incorporation of current l operating practic.as consistent with NUREG-1432. These changes, since they do not involve technical changes to the Current TS (CTS), are administrative. Below are ! the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards l consideration if operation of the facility, in accordance with a proposed , amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or i 3) involve a significant reduction in a margin of safety. A discussion of these l standards as they relate to this amendment request folic.5: l Standard 1. Does the proposed change involve a significant increase in the l probability or consequences of an accident previously evaluated? l The proposed changes involve reformatting, renumbering, and rewording of I the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432, certain wording preferences or English language conventions were adopted. The proposed I changes to this Section/ Chapter are administrative in nature and do not l impact initiators of any analyzed events. They also do not impact the
- assumed mitigation of accidents or transient events. Therefore, these 1 changes do not involve a significant increase in the probability or j consequences of an accident previously evaluated.
. PALO VERDE - UNITS 1,2, AND 3 1 Rev. A I
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.5 - RCS Loops - Mode 3 i ADMINISTRATIVE CHANGES (ITS 3.4.5 Discussion of Changes Labeled (A.1, A.2 and A.3) (continued) Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3. Does the proposed change involve a significant reduction in a margin of safety? The proposed changes involve reformatting, renumbering, and rewording of the CTS,' along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes are administrative in nature and will not involve any technical. changes. The proposed changes will not reduce a margin of safety-because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. f PALO VERDE - UNITS 1,2, AND 3 2 Rev. A
~
L l NO SIGNIFICANT HAZARDS CONSIDERATION l ITS Section 3.4.5 - RCS Loops - Mode 3 l l l l TECHNICAL CHANGES MORE RESTRICTIVE (ITS 3.4.5 Discussion of Changes Labeled M.1, M.2 and M.3) I Arizona Public Service Company Palo Verde Nuclear Generating Station (PVNGS). Units 1, 2. and 3 is converting to the ITS as outlined in NUREG-1432. This l particular NSHC is for the changes labeled " Technical Changes - More Restrictive" described in the specific Discussion of Changes listed above. The proposed changes incorporate more restrictive changes into the CTS by either making current requirements more stringent or adding new requirements which currently i do not exist. ] l The Commission has provided standards for determining whether a significant i hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to I an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or . consequences of an accident previously evaluated: 2). create the possibility of l a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these '
standards as they relate to this amendment request follows: I Standard 12 Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? l The proposed changes provide more stringent requirements than previously ! existed in the CTS. The more stringent requirements will not result in operation that will increase the probability of initiating an analyzed l event. If anything, the new requirements may decrease the probability or consequences of an analyzed event by incorporating the more restrictive i changes discussed in the specific Discussion of Changes listed above. l These changes will not alter assumptions relative to mitigation of an l accident or transient event. The more restrictive requirements will not alter the operation and will continue to ensuv process variables. structures, systems, or components are maintained consistent with safety analyses and licensing basis. These changes have been reviewed to ensure i that no previously evaluated accident has been adversely affected. l Therefore, these changes will not involve a significant increase in the probability or consequences of an accident evaluated. i PALO VERDE - UNITS 1,2, AND 3 3 Rev.A
. . . . . . . - - - - . - . - . - . . ~. -
l NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.5 - RCS Loops - Mode 3 l TECHNICAL CHANGES HORE RESTRICTIVE (ITS 3.4.5 Discussion of Changes Labeled M.1, M.2 and M.3) (continued) , 1 l Standard 2. - Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? Making existing requirements more restrictive and adding more restrictive l ! requirements to the CTS will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes do impose different I requirements. However, they are consistent with the assumptions made in the safety analyses. licensing basis, and NUREG-1432. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. l Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? The proposed thanges provide more stringent requirements than previously existed in the CTS. An evaluation of these changes concluded that adding these more restrictive requirements either increases or has no impact on l the margin of safety. The changes provide additional restrictions which l may enhance plant safety. These changes maintain requirements of the safety analysis, licensing basis, and NUREG-1432. As such, no question of safety is involved. Therefore, these changes will not involve a l significant reduction in a margin of safety. I i I l i PALO VERDE - UNITS 1,2, AND 3 4 Rev.A 4
i i NO SIGNIFICANT HAZARDS CONSIDERATION i ITS Section 3.4.5 - RCS Loops - Mode 3 TECHNICAL CHANGES RELOCATIONS (ITS 3.4.5 Discussion of Changes Labeled LA.1, LA.2, and LA.3) 4 l l ~ Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). I Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The I , proposed changes, since detail is being removed from the CTS to a Licensee 1 Controlled Document, are less restrictive. The descriptions of these changes are l
- in the Discussion of Changes listed above.
1
- The Commission has provided standards for determining whether a significant I hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to j an operating license for a facility involves a no significant hazards !
consideration if operation of the facility, in accordance with a proposed I j amendment, would not 1) involve a significant increase in the probability or l
- consequences of an accident previously evaluated
- 2) create the possibility of l a new or different kind of accident from any accident previously evaluated; or !
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1.- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes do not result in any hardware changes I or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee ContrPled Document containing the relocated requirements will be I maintained using the provisions of 10 CFR 50.59 or other specified control processes and is subject to the change control process in the Administrative Controls Section of the ITS. Since any changes to a Licensee Controlled Document will be evaluated. no increase in the probability or consequences of an accident previously evaluated will be i allowed. Therefore, these changes will not involve a significant increase l in the probability or consequences of an accident previously evaluated. I i l
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PALO VERDE - UNITS 1,2, AND 3 5 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.5 - RCS Loops - Mode 3 TECHNICAL CHANGES RELOCATIONS (ITS 3.4.5 Discussion of Changes Labeled LA.1, LA.2, and LA.3) (continued) Standard 2.-- Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not alter the plant configuration (no new or different type of equipment will be installed) or change the ; methods governing normal plant operation. These changes will not impose different requirements and adequate control of information will still be maintained. These changes will not alter assumptions made in the safety I analysis or licensing basis. Therefore, these changes will not create the 1 possibility of a new or different kind of accident from any accident ; previously evaluated. Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not reduce a margin of safety since they have no impact on any safety analysis assumptions.' In addition, the requirements to be transposed from the CTS to the Licensee Controlled Document are the same as the CTS. Since any future changes to this Licensee Controlled Document will be evaluated per the requirements of 10 CFR 50.59. or other specified control processes, no reduction (significant or insignificant) in a margin of safety will be allowed. Therefore, these changes will not involve a significant reduction in a margin of safety. The NRC review provides a certain margin of safety, and although this review will no longer be performed prior to submittal the NRC still inspects the 10 CFR 50.59 process. The proposed changes are consictent with NUREG-1432. which was approved by the NRC Staff. The change controls for proposed relocated details and requirements provide an acceptable level of regulatory authority. Revising the CTS to reflect the approved level of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore, revising the CTS to reflect the NRC accepted leve' of detail and requirements ensures no ! reduction in a margin of safety. i ) PALO VERDE - UNITS 1,2, AND 3 '6 Rev. A l
CE STS NUREG-1432 REV. I SPECIFICATION 3.4.6 MARK UP t l l
1 l l 1 I
. I r
ot. RCS Loops-Wt 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 RCS Loops-MODE 4 Two loops or trains consisting of any combination of RCS I LC.O 3.$ .\ D LCO 3.4.6 loops and%hutdown j6oling (SDC) trains shall be OPERABLE and at-1 t one loop or train shall be in operation. 1 Of $ NOTES - l s 1. All eactor dloolant umps (RCPs) and SDC pumps may be
<3,4\h Qdg / de--energized for 5 1 hour per 8 hour period, provided:
- a. No operations are permitted that would cause reduction of the RCS boron concentration; and
- b. Core outlet temperature is maintained at least 10*F below saturation temperature.
- 2. No RCP shall be started with any RCS cold leg temperature 5 'F % n au, oc 6./Prespirize/ water lev /1 is/< [6p; l
%. econdary side water temperature in eat tea 4 generator (50)is<1100J'[aboveeachoftheRCS 2 cold leg temperatures. ,,
~
[ g, _no esere % .; 2 LLfc r^*1 Ve in eprak Ih it.c.s ceI4 to,
+c ye raturs 6 too* A. 90 m.re 4 n t it c fs m a-y 6 e. in APPLICABILITY: MODE 4. o ry ra f,m Jih g C5 cold ley tee.pa yedia te > 2co *f u t 500*g l
l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME i
/ A. One required RCS loop A.1 Initiate action to immediately
-3A,l.1,a, restore a second loop inoperable.
\ or train to OPERABLE AND status.
Two SDC trains inoperable. t. (continued) 1 GrdP., -bh h7. h 6 3.4-10 Rev ar '
i 1 I I I I i l RCS Loops-MODE 4 l 3.4.6 l ' ! 1 ACTIONS (continued) !. CONDITION REQUIRED ACTION COMPLETION TIME
/ ~ '
l N.h4\.h.G
- \
B. One required SDC train inoperable. 8.1 Be in MODE 5. 24 hours l M 1 i Two require;DRCS loops , ! inoperable. ' I - (/* 4. g.3, b. i W C. Cgggureg RCS loop or C.1 Suspend all 1 mediately
- SUL trai Fe71tt3rg. operations involving i reduction of RCS !
O1093 "I boron concentration. No RCS loop or SDC E train in operation. C.2 Initikte action to imediately I restore one loop or train to OPERABLE status and operation. ( ) SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4,4.\ .3 *D SR 3.4.6.1 Verify one RCS loop or SDC train is in 12 hours operation. 44Q ,L SR 3.4.6.2 Verify secondary side water level in 12 hours requiredSG(s)is2k'g. (continued) h ;;;
% -Eb \,1.3 3.4-11 S
Rev ,, C',07,L d
. . - .+.1 . .~ . . . . . . . - - . . ~ . . - . . . ~ . . - . . - ~ - . . . - . _ . ~ . . . . ~ _ .
1 h l l 1 1 RCS Loops-MODE 4 1 3.4.6 ) l l SURVEILLANCE REQUIREMENTS (continued) SURVEILLANCE FREQUENCY r Verify correct breaker alignment and 7 days l N b k .D.\ SR 3.4.6.3 indicated power available to the required pump that is not in operation.
'l 1
1 1 1 (dd. hfi n 7::: :TE 3.4-12 Rev -i ^iMn i !
i 4 l I l l l l l CE STS l NUREG-1432 REV.1 l SPECIFICATION 3.4.6 BASES MARK UP 1
l I l
)
I l RCS Loops-MODE 4 ; B 3.4.6 l 1 B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.6 RCS Loops-MODE 4 4 I BASES D In MODE 4, the primary funftton o the reactor coolant is BACKGROUND g e rempval of decay heat gd trans)r of this heat to the team.4enerators (SGs) or ,,hutdown ;!ooling (SDC) heat l exchan'gers. The secondary function of the reactor coolant is to act as a carrier for soluble neutron poison, boric acid. In MODE 4, either eacto olantyumps (RCPs) or SDC trains can be used for coolant ci culation. The intent of this LCO is to provide forced flow from at least one RCP or one SDC train for decay heat removal and transport. The flow provided by one RCP loop or SDC tiain is adequate for heat removal. The other intent of this LCO is to require that two paths be available to provide redundancy for heat removal.
) APPLICABLE Jn MODE 4, RCS circulation is considered in the SAFETY ANALYSES determination of the time available for mitigation of the i accidental boron dilution event. The RCS cops and SD I trains provide this circulation. pgg ggy RCS Loops-MODE 4 have been identified in une pr. rpaw
@ as important contributors to risk reduction.
100 The purpose of this LCO is to require that at least two loops or trains, RCS or SDC, be OPERABLE in MODE 4 and one of these loops or trains be in operation. The LCO allows the two loops that are required to be OPERABLE to consist of any combination of RCS and SDC System loops. Any ane loop or train in operation provides enough flow to remove the decay heat from the core with forced circulation. An additional loop or train is required to be OPERABLE to ! provide redundancy for heat removal. bn
$ #" M A. careed R.d l
Note 1 permits all RCPs and SDC pumps to be de-energized 4 ,A l s I hour per 8 hour period. This means that natural bc d hwh to circulation G"hmt established using the SGs. The Note es,bh vu&ade. ML e j., o e (continued dMdb -
<)
R< B 3.4- Rev i, /./=/es 5
O r v - b * * * A 5 h ALS Q &e 3 ceshritfL it f of erb '*n no m " &n W Fc '% x.c.s c ig cou sef pry,rdw. 6 zoo c, **d Sa-h % % d ese e,,d hg*,,q l lc) +. emb4re >200'6 Ld f 600*6 L"ill mo d th e n anol355 J 045uey fsavsf o-( % ((ovJ induce d (gesgufp s torf"M b M bri h .bg.Poped*p @,{,y, RCS Loops M B 3.4.6 BASES LCO (continued) prohibits boron dilution when forced flow is stopped beAse an even concentration distribution cannot be ensured.* Core iM @ outlet temperature is to be maintained at least 10*F below saturation temperature so that no vapor bubble may form and N9 g# possibly cause a natural circulation flow obstruction. The # T response of the RCS without the RCPs or SDC pumps depends on m b y oddi e the core decay heat load and the length of time that the pumps are stopped. As decay heat <!!minishes, the effects on ggg,,z RCS temperature and pressure diminish. Without cooling by IW' D UWdl forced flow, higher heat loads will cause the reactor > coolant temperature and pressure to increase at a rate proportional to the decay heat load. Because pressure ca increase, the applicable system pressure limits essure
. mperature(iT)limitsorfow f
Jerature essure O ection (LTOP) limits) must bt rved-4atforced low or heat removal via the SGs must -es Dtatwl- T I prior to reaching the pressure limit. The c tances for stopping both RCPs or SDC pumps are to be limited to situations where:
- a. Pressure and temperature increases can be maintained well within the allowable pressure (P/T limits and LTOP) and 10*F subcooling limits; or
- b. An alternate heatJamoval path through the SGs is in operation. l Note 2 requiresh m . e wner or tm roi sawing wo congmong GPTiTTNTFID before an RCP star w wit L cold leg temperature s F r~ M% or L M O// i nty had , A t
- a. Pre /suriMr wateo/ lev /T is </60ldf-or
-- Zw % e % 'iamg n tra,ca,ro & 1 K econdary sTde water tempefatu'rer trTa 4e % prem
<MhhAt* < 'F above each of the RCS cold leg temperatu p __ _ .w- -
Satis per/J the above conditions will preclude a large pressure surge in the RCS when the F.CP is started.
'An OPERABLE RCS loop consists of at least one OPERABLE RCP and an SG that is OPERABLE in accordance with the Steam Generator Tube Surveillance Program and has the minimum water level specified in SR 3.4.6.2.
Similarly, the SDC System, an OPERABLE SDC train is composed o PERABLE SDC pumpg capable of providing d (continued)
,CDG S B 3.4-26 Rev i C;ie7,55 fdC. MO k 2.h
.. - - _. . . - . - . . . _ - _ . - ~__ - .
i ] s l RCS Loops-MODE 4 8 3.4.6 i a
) BASES i: fee har et M a\
LC0 @ flow to the SDC heat exchanger C s innd SDC i (continued) pumps are OPERABLE if they are capable of being powered and i
- are able to provide flow if required. l APPLICABILITY In MODE 4, this LCO applies because it is possible to remove core decay heat and to provide proper boron mixing with either the RCS loops and SGs or the SDC System.
- Operation in other MODES is covered by
I LCO 3.4.4, 'RCS Loops-MODES I and 2*; < LCO 3.4.5, 'RCS Loops-MODE 3';
- LCO 3.4.7, 'RCS Loops-MODE 5, Loops Filled *;
LCO 3.4.8, 'RCS Loops-MODE 5, Loops Not Filled"; I LCO 3.9.4, ' Shutdown Cooling (SDC) and Coolant Circulation-High Water Level" (MODE 6); and 4 LCO 3.9.5, ' Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level" (MODE 6). l
)
ACTIONS AJ V h If only one< required.RCS loop @ySpt 181s OPERABLE and in operation, redundancy for heat removai is lost. Acti must be initiated immediately to restore a second loop $
@ to OPERABLE status. The immediate Completion Time retiects the importance of maintaining the availability of
- two paths for decay heat removal.
IL1 If only one require 1 SDC train is OPERABLE and in operation, i redundancy for heat removal is lost. The plant must be placed in MODE 5 within the next 24 hours. Placing the plant in MODE 5 is a conservative action with regard to decay heat removal. With only one SDC train OPERABLE, i redundancy for decay heat removal is lost and, in the event of a loss of the remaining SDC train it would be safer to initiate that loss from NODE 5 (s F) rather than MODE 4 ( *F to *F). The Completion 11 of 24 hours is r onable, ase on operating experi nee, to reach MODE 5 9 \ f
) (continued)
" !!! B 3.4-27 Rev 1,.04/G421
\QNQfbQ.~ 0 b \,I.h
. . .- -. ._ - - -- . . . - . ~ _ - -
i 4. I a l i i l
' I 4
J RCS Loops-MODE 1 1 B 3.4.6 1 BASES
- ACTIDNS D.J (continued) j from MODE 4, with only one SDC train operating, in an orderly manner and without challenging plant systems.
i , ) C.1 and C.2 ,
~
if no RCS loops or SDC trains are OPERABLE.or in operation, pt dur< na e6nditions cermitted by Note 1 in th( l_C0 g j (exp(tion./a'l we operations involving reduction of RCS boron I concentration must be suspended and action to restore one i RCS loop or SDC train to OPERABLE status and operation must be initiated. Boron dilution requires forced circulation
. for proper mixing, and the margin to criticality must not be reduced in this type of operation. The immediate Completion 4
Times reflect the importance of decay heat removal. The ' action to restore must continue until one loop or train is restored to operation. I SURVE!LLANCE SR 3.4.6.1 4 REQUIREMENTS
- t
- E ** t. of yeafer !
This SR requires verification every 12 hours that one ! required loop or train is in operatio This ensures forced +hn or eku l ] flow is providing heat removal. Verification includes flow jo 4000 g ] rate, temperature, or pump status monP *ing. The 12 hour ' Frequency has been shown by operating pt.ctice to be sufficient to regularly assess RCS loop status. In addition, control room indication and alarms will normally indicate loop status. l , g 4.i.l.D.2 [ 3.4.6.2 NLU E SR This SR requires verification every 12 hours of secondary M %m sidewaterlevelintherequiredSG(s)21251% An adequate i SG water level is required in order to have a heat sink for 1 removal of the core decay heat from the reactor coolant. l The 12 hour interval has been shown by operating practice to be sufficient to regularly assess degradation and verify operation within safety analyses assumptions. i - i l (continued) y;;oi B 3.4-2B Rev . M /07/ L io\o SMC,- VM D k,E 3
l 1 I I i I RCS Loops-MODE 4 ! B 3.4.6 .~. I BASES SURVEILLANCE SR 3.4.6.3 REQUIREMENTS (continued) Verification that the required pump is OPERABLE ensures that an additional RCS loop or SDC train can be placed in operation, if needed to maintair decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be accept:ble by operating experience. l REFERENCE enene. i N i 1 f Yb5 OgerAdd I, t.en(t A ren menkt 62 3 6, ud N i j b dm k I,1,sint( $j (45fecY M 7 ; o d 6 5$ 6 C sac Y e gf b .S t*[t (yAlu.d[rvt Md* M M 7gli90,
% _J
\\
.c y (Cf.sG S]E) B 3.4-29 Rev 0 / 04/7/ /vs) Vo% NQJE.A. Un% \ glh
i NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.6 1
PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.6 - RCS Loops - Mode 4 1
- 1. Grammar and/or editorial changes have been made to enhance clarity. No technical or intent changes to the Specification are made by this change.
- 2. NUREG-1432 specifies a single temperature as the determinant to place an L-TOP in service or to remove an L-TOP from service. ITS uses two different temperatures, dependent on whether the plant is in a cooldown or heatup evolution, to perform the same function. ITS will continue to apply PVNGS licensing basis and use two specific temperatures to determine when an L-TOP will be placed in service or removed from service. This is acceptable because these temperatures reflect the metallurgical characteristics of the PVNGS reactor vessel. Because of the different thermal / hydraulic stresses applied to the reactor vessel, depending whether a cooldown_ or heatup is occurring, two different tempergtures are used to reflect the transition point from ductile to brittw failure.
Hence, there are two different temperaturec. depending on whether a cooldown or heatup is occurring, where L-TOPS are required to be OPERABLE and in service. The continued use of two separate temperatures for L-TOP use is a deviation from NUREG-1432 but is consistent with PVNGS licensing basis. '
- 3. ITS 3.4,.6. LC0 Bases, adds a sentence to clarify the intent of the Note, item (a), in the LCO. Since this Note could be interpreted to stop any ,
activity that has even a remote possibility of affecting RCS boron ' concentration, it was decided to clarify its intent. NUREG-1432 does not clarify intent of the LC0 Note item (a). Interpreting this Note in the global sense would have profound affects on maintenance activities and limit our ability to respond to plant needs. A sentence that states. "The intent is to stop any known or direct positive reactivity additions to the RCS". was added to clarify intent of the Note, item (a). This clarifies PVNGS operating practice and is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO.
- 4. NUREG-1432 LC0 3.4.6. Note 2. allows the use of either secondary side water temperature p.t pressurizer water level as a condition to preclude RCS pressure surges when starting an RCP in Mode 4. ITS LC0 3.4.6 does not allow the use of pressurizer water level in lieu of secondary water temperature limits to preclude RCS pressure surges when starting an RCP.
The decision not to allow the use of pressurizer water level as a conditional requirement is a deviation from the NUREG-1432 but is consistent with PVNGS licensing basis (CTS 3.4.1.3). The Bases has also been revised to be consistent with the LCO. PALO VERDE - UNITS 1,2, AND 3 1 REV.B
i . PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS
- SPECIFICATION 3.4.6 - RCS Loops - Mode 4 1
- 5. NUREG-1432 3.4.6 Bases states that. " natural circulation has been established using the SGs." ITS 3.4.6 Bases states that. " natural j circulation should be established. after the operating RCP or SDC pump is secured. using SGs." This is done to remove confusion associated with the
- NUREG-1432 statement. NUREG-1432 implies that natural circulation should be established prior to securing the operating RCP or SDC pump. This is i- not possible when a RCP or SDC pump is in operation. therefore, additional ,
information is added to require natural circulation establishment after the operating RCP or SDC pump is secured. Also. ITS 3.4.6 Bases states ; that " Depending on decay heat and current RCS temperature, it may be 1 difficult to establish verifiable natural circulation." This was added
- because NUREG-1432 is silent about conditions of low decay heat load in conjunction with low RCS temperatures. Establishing ideal natural circulation parameter indications in these conditions can be difficult. As
. long as the control room operator can establish temperature control to maintain current RCS temperatures. heat removal is established, therefore. i natural circulation is established. This is a deviation from NUREG-1432 but is consistent with PVNGS licensing basis.
- - 1
! 6. NUREG-1432. Actions A. Bases makes reference to a SDC train in operation. , This Action only addresses a single RCS loop in operation. Therefore. the , i reference to a SDC train in operation is deleted from ITS. Action A, i . Bases. This change is consistent with PVNGS licensing basis. ] l j 7. ITS Actions C. Bases deletes reference to Note 1 o the LC0 section. ' Location of Note 1 reference implies that susper.. 1 of operations ) involving a reduction in of RCS boron concentration are not required. This
- implies that compliance with Note 1 is not required. The bases is trying
! to emphasize that performance of Required Actions is not required when RCS F loops and SDC trains are secured in accordance with Note 1. Compliance with Note 1 is still required: no operations are permitted that would cause reduction of the RCS boron concentration, and core outlet i temperature is maintained at least 10*F below saturation temperature. There is no need to reference Note 1 in Action C Bases. Note 1 stands alone and it:; usage is understood. If no RCS loop or SDC train are in 3 operation, based on Note 1 usage. it is not required to perform the Required Actions of Actions A or B. and C. It is only required to comply with the requirements of Note 1. Should failure to meet the requirements .i of Note 1 occur then entry into Actions A or B. and C is required. This C '6hange is consistent with PVNGS licensing basis. PALO VERDE - UNITS 1,2, AND 3 2 REV.A
PALO VERDE ITS CONVERSION l NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.6 - RCS Loops - Mode 4
- 8. NOT USED
- 9. The plant titles, specific nomenclature, number, parameter / values,
- reference, system description, system design, operating practices or analysis description was used (additions, deletions, and/or changes are included). Plant specific parameters / values are directly transferred from the CTS to the ITS.
- l 4
- 10. The wording of NUREG-1432 LC0 3.4.6, Action C Condition is not consistent with the NUREG Bases or the other LCO 3.4.6 Actions. The original NUREG ;
Condition wording, " Required RCS loop or SDC train inoperable," implies i ! that if any of the two required RCS loops or SDC trains are inoperable. ;
- this Condition would be entered. However, according to the NUREG Bases i i for Actions C.1 and C.2, and CTS 3.4.1.3, this Condition and required I Action applies when no RCS loops or SDC trains are operable or in operation. This revised wording is consistent with the wording used in
- NUREG-1432 (and ITS) LC0 3.4.5 Action Condition C, which is a similar l Condition. This change is consistent with PVNGS licensing basis.
4
- 11. ITS LCO 3.4.6 Not 3 restricts operation of RCPs to no more than 2 RCPs in i operation with RCS cold leg temperature 5 200*F. and no more than 3 RCPs with RCS cold leg temperature > 200*F but 5 500'F. NUREG-1432 LC0 3.4.6 i
does not specify these restrictions. These restrictions are necessary to maintain the analysis assumptions of the flow induced pressure correction factors due to RCP operation, and are consistent with the current licensing basis (CTS 3.4.1.3). The ITS Bases for LC0 3.4.6 and References include the basis for the RCP operating restrictions. This change is
- consistent with PVNGS licensing basis.
4 4 ? i i 1 l 2 PALO VERDE - UNITS 1,2, AND 3 3 REV.B 4
i l I l l PVNGS CTS SPECIFICATION 3.4.6 MARK UP 1 I l 1 l l 1 I l 1 i I
, _ -_ ~ --
&L&W Y' \
/..k g
$ REACTOR COOLANT SYSTEM (dCM "JT ::UT;=;
LIMITING CONDITION FOR OPERATION 3.4.1.5 k(233 % and at least one reactor coolant and/or shutdown cooling peration".
- a. Reactor least olant Loop I and its asso .-
ated steam generator an at U
- b. Rea e associated reactor cool t pump"",
or Coolant Loop 2 and it "k' 1 associated steam generat and at st one associated reactor colant pump **,
- c. 5.sutdown Cooling Train Shutdown Cooling Tra B.
AoPLICABILITY: MODE 4#. b k.i ACTION: 9ae t*tE*d DbPg"ND\'d H # j T <h>
'h',f[Wip less th Rhr* eptagc.f~
the abov/ recuired /eac_t.or cooM nt tndig d hutdow
\roolino los . OPERABLf,4 immediately initiate corrective action toD DD return the required loops to OPERABLE status as soon: as possible Liffth_eZWiisidriilP_f!BH/
COLD SHUTDOWN within 24 hours.
*~
loon fs a shutdown cao11nciloopMe in T i* Mf) +m's ofc RA gx ew g , g. (Wl'th no reactor coolantAor shutdown cooling uspend heturntherecuiredcoolantinneinensrationReactor I on to Coolant N System mE
/&Ywe &rh<
colant pumps an {y{y,*Allreacto l for up to hour provided
)
hutdown cooling pumps may be deenergized' ( ou. .;th , of the Reactor Coolant System boron concentration,.\and CM cor s W tlet temperature is maintained at least 10'F belowemperature. saturation t 2,**A reactor coolant pump shall not be started with one or more of th Coolant System cold leg temperatures less than or equal to 214'F durin G> ture cooldown. or 291'F durino heatup, unless the secondary water temper ((s)(uratit% tempsp'ature pbtrespor) Sing tt/ steam ce6erator afressurAT>o *g steam gold generator is less tnan 100 t above each of the Reactor leo temocratures. . m Coolant Syste j
- J M*
h [S,Reeete'e:':ntPr;eper:tunM'bitetoWomorethang2 ump Reactor &cola [da *1 oolant Pumps 4with RCS cold leg temperature greater than 20 r equal to 500'F. . Reactor t less than [.l
~
#5,( Special Tsit Exception 1/10.9M' /
%h \ ak t ~
f r A.E. Palo Verde - Units 1. 2, 3
1 . b f REACTOR COOLANT SYSTEM 9 } A, l T !"""?* N/
$URVEILLANCE REOUIREMENTS i M,D M)$.bd I ! f.0.1. f I The required .. i.. w determined to be OPERABLE once per.1% i ,, ,(.), if not in operation, shall be lignments and indicated m:r availability.7 days by verifying correct breaker
' ,.4. 4
'k .h,[ .3.2 -- The required steam generator (s) shall be determined OPE'!ABLE byl verifying level at leasttheonce secondary side waterJgyal to be > 211 rinweated s'na r=#1 per 12 hours.J - '
LA. g 3,k h, } 4re.-? . O. ;
'N'~- -
verified to be in operatienjuna ciAt least one reactor coolant or shutdown cooling loo Lgreater than or/soual ta/4000 ana(rcusRing reagr.or coolant pt a flow fatn at least once per iz nours.1 --- % k. ( J ^ w d i I l l l i 3/4 4-4 Palo Verde - Units 1, 2, 3
~a -aA -,
4 x G- ._Ji:. ,-- --,_- $ , t DISCUSSION OF CHANGES SPECIFICATION 3.4.6 i l l l I l
- - - - - - - .- .-. . . . , . - . - . .. . - - - ~ .
PALO VERDE ITS CONVERSION
; DISCUSSION OF CHANGES SPECIFICATION 3.4.6 - RCS Loops - Mode 4 -
ADMINISTRATIVE CHANGES 1 A.1- All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432. . . Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station I (PVNGS) Improved Technical Specifications (ITS) should be more readable, and therefore understandable by plant operators as well as other users. During the reformatting and renumbering of the ITS. no technical changes 3 (either actual or interpretational) to the Current Technical Specifications (CTS) were made unless they were identified and justified. ] : l Editorial rewording (either adding or deleting) is made consistent with '
- NUREG-1432. During NUREG-1432 development, certain wording preferences or i
English language conventions were adopted which resulted in no technical changes (either actual or interpretation 11) the CTS. ' Additional information has also been added to more fully describe each e subsection. This wording is consistent with NUREG-1432. Since the design j is already approved by the NRC adding more detail does not result in a technical change. A.2 CTS 3.4.1.3. Applicability Footnote, references "See Special Test Exception 3.10.9." Cross references are not used in the ITS or NUREG-1432. Removing cross references does not alter the requirements of the referenced
- Specification. Therefore, this is an administrative change with no impact on safety. This change is consistent with NUREG-1432.
. A3 CTS 3.4.1.2. Action b, states, in part. "with no reactor coolant or i' shutdown cooling loop in operation .. " ITS 3.4.6. Action C. adds a Condition of "no RCS loop or SDC train OPERABLE." The addition of this i statement to Action C in ITS provides clarification of intent. In the CTS. because of the wording, there existed some ambiguity with Action b. The i plant could be in Mode 4 with the required RCS loop or SDC train inoperable and only be in CTS Action a. The added wording to ITS Action C clarifies its usage by requiring its performance with the required RCS loop or SDC train inoperable. Although not explicitly stated in CTS PVNGS operating practice complies with the intent of ITS 3.4.6 Action C. This change provides explicit wording that clarifies Palo Verde practice in usage of i ITS 3.4.6 Action C. therefore, this is an administrative change. This change is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 1 REV.A
_-_.______-_.m . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . . _ _ . _ _ _ . _ _ PALO VERDE ITS CONVERSION DISCUSS!ON OF CHANGES SPECIFICATION 3.4.6 - RCS Loops - Mode 4 l ADMINISTRATIVE (,HANGES (continued)- $ A.4 CTS 3.4.1.3. Action a. does not specifically identify the conditions that i define Operable, or not in operation. ITS 3.4.6 Actions A and B do define what conditions define inoperable, or not in operation. This change will . split the CTS 3.4.1.3 Action a. into two separate Actions, A and B. in the ITS. The splitting of an Action into two separate Actions for clarification i constitutes an admini.strative change. This change is consistent with l NUREG-1432. 1 i A.5 CTS LC0 3.4.1.3 Footnote
- discusses the requirements which allows all RCPs j and SDC pumps to be de-energized for a period of time. One requirement is i that no operations be permitted that would cause dilution of the RCS boron concentration. ITS LC0 3.4.6 Note 1 changed the word " dilution" to
- " reduction." Both words are used in the same context; reducing boron
, concentration of the RCS is not acceptable. This change does not alter the LCO intent. Therefore, this is an administrative change with no impact on
, safety. This change is consistent with NUREG-1432.
i TECHNICAL CHANGES HORE RESTRICTIVE ] , M.1 CTS. Action 3.4.1.3.b. requires the suspension of all operations involving
- a reduction in boron concentration of the RCS when no RCS loop is in j operation. The CTS does not provide any Completion Time associated with this Action. ITS 3.4.6, Action C.1 requires suspension of all operations 4
involving a reduction of RCS boron concentration. "immediately." CTS only associates the term "immediately" with action to return the required RCP ! loop to operation, not with the action to suspend all operations involving
- a reduction in boron concentration of the RCS. The adoition of
- "immediately" for Completion Time to suspend all operations involving a reduction in boron concentration of the RCS reflects the importance of i maintaining operation of decay heat removal. The addition of this i requirement constitutes a more restrictive change to PVNGS plant operation.
This change is consistent with NUREG-1432. ] i 4 l1 1 i PALO VERDE - UNITS 1,2, AND 3 2 REV.A
.-.1
- - - -. . .. -..~. - .-. .. . . _ - - - - - . . - -
I PALO VERDE ITS CONVERSION l l DISCUSSION OF CHANGES SPECIFICATION 3.4.6 - RCS Loops - Mode 4
' TECHNICAL CHANGES - MORE RESTRICTIVE (continued)
M.2 CTS 3.4.1.3, Footnote *, allows all RCPs and shutdown cooling pumps to be de-energized for up to one hour. ITS LCO 3.4.6 Note 1 allows all RCPs and , shutdown cooling pumps to be de-energized for up to 1 hour per 8 hour period. Therefore, the amount of time all RCPs and shutdown cooling pumps may be de-energized has been restricted from less than or equal to one j hour, to less than or equal to one hour per eight hour period. CTS would
- permit repeated application of the one hour exemption, indefinitely. This additional restriction on plant operation restricts immediate, repeated application of the one-hour allowance, which would circumvent the intent of the Note. Although not explicitly stated in CTS, PVNGS operating
. practice complies with the 1 hour per 8 hour period requirement statement
- in ITS 3.4.6 Note. This change provides explicit wording that clarifies !
PVNGS operating practice in application of this LCO. Placing a limitation on the de-energization of all RCPs and shutdown cooling pumps will not adversely affect plant safety. Placing additional restrictions on plant operation constitutes a more restrictive change. This change is consistent f with NUREG-1432. M.3 CTS SR 4.4.1.3.1 requires performance only for RCPs not in operation. ITS SR 3.4.6.3 requires performance for both RCPs and SDC pumps not in operation. The additional requirement to perform this Surveillance for the , 4 SDC pump not in operation constitutes a more restrictive change to TS. ' Verification thct the required pump is Operable ensures that an additional RCS loop or SDC train can be placed in operation, if needed, i.o maintain decay heat removal and reactor coolant circulation. Therefore, this change does not detrimentally affect plant safety. This change is consistent with NUREG-1432. TECHNICAL CHANGES RELOCATIONS - 1 j LA.1 NOT USED l I i i l i l PALO VERDE - UNITS 1,2, AND 3 3 REV.B 4
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.6 - RCS Loops - Mode 4 TECHNICAL CHANGES RELOCATIONS (continued) LA.2 CTS SR 4.4.1.3.3 contains a minimum flow rate that SDC must equal or exceed. This information will be relocated to ITS SR 3.4.6.1 Bases. Also. CTS 4.4.1.3.3 requires at least one reactor coolant loop or SDC train be verified in operation and " circulating reactor coolant." The requirement j to circulate reactor coolant is moved to Section SR 3.4.6.1 of the ITS ] Bases. In addition, both pieces of information do not meet the 10 CFR 50.36 (c) (2) (ii) criteria for inclusion in to the ITS and are. therefore, being relocated. Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases Control Program. 4 Any changes to the Bases will be in accordance with Chapter 5.0 Bases Control Program. Any technical changes to plant procedures will be in
- accordance with the PVNGS procedure control process. This provides an j equivalent level of control and is an administrative change with no impact on the margin of safety. This information is not required to be in ITS to provide adequate protection of public health and safety. Therefore.
relocation of this information to a Licensee Controlled Document is acceptable and is consistent with NUREG-1432. 1 s i PALO VERDE - UNITS 1,2, AND 3 4 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.6 - RCS Loops - Mode 4 TECHNICAL CHANGES - RELOCATIONS (continued) LA.3 CTS LCO 3.4.1.3 specifies the loop / train numbers for the reactor coolant loops and SDC train, components making up a reactor coolant loop, and that one RCP per loop is required. This information does not meet the 10 CFR 50.36 (c) (2) (ii) criteria for inclusion in to the ITS and is, therefore, being relocated. The specific reactor coolant loop and SDC train numbers exist in the UFSAR, and the components making up a reactor coolant loop and the number of RCPs required per loop is moved to Section 3.4.6 of the ITS Bases. Any changes to the UFSAR will require a 10 CFR 50 59 evaluation. Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This information is not required to be in ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to a Licensee Controlled document is acceptable and is consistent- with NUREG-1432. LA.4 CTS 3 . ,4 . 6 , Footnote ** contains information that provides guidance determining SG water temperature. Although this information is useful, it is not required to determine the OPERABILITY of a system, component or structure, and is, therefore, relocated to ITS 3.4.6 LC0 Bases. Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an administrative change with no impact on_ the margin of safety. This information is not required to be in ITS to provide adequate protection of public health and safety. Therefore, relocation of this. requirement to a Licensee Controlled document is acceptable and is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 5 REV.A i
l PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.6 - RCS Loops - Mode 4 TECHNICAL CHANGES RELOCATIONS (continued) LA.5 CTS SR 4.4.1.3.2 specifies that " indicated wide range" level is to be used i for verification of SG level. All values in ITS are indicated values. This information, less the word " indicated", is moved to ITS SR 3.4.6.2 Bases section. This information is not required to determine OPERABILITY of a system, component or structure and therefore is being relocated to a Licensee Controlled Document (Bases Section). Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This information is not required to be in ITS to provide adequate protection of ; public health and safety. Therefore, relocation of this requirement to a i Licensee Controlled document is acceptable and is consistent with l NUREG-1432. i TECHNICAL CHANGES LESS RESTRICTIVE None l 1 1 4 PALO VERDE - UNITS 1,2, AND 3 6 REV.B 1
l P I
- NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.4.6 4
l t I i e 4 4
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.6 - RCS Loops - Mode 4 ADMINISTRATIVE CHANGES (ITS 3.4.6 Discussion of Changes Labeled A.1, A.2, A.3, A.4, and A.5) Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3, is converting to the ITS as outlined in NUREG-1432. " Standard Technical Specifications. Combustion Engineering Plants." The proposed changes involve the reformatting, renumbering, rewording of the Technical Specifications (TS) and Bases with no change in intent, and the incorporation of current operating practices consistent with NUREG-1432. These changes since they do not involve technical changes to the Current TS (CTS), are administrative. Below are i the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. 1 i The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility. in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or
- consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
- Standard 1.- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
i The proposed changes involve reformatting, renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432, certain wording . preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. ] PALO VERDE - UNITS 1,2, AND 3 1 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.6 - RCS Loops - Mode 4 J ADMINISTRATIVE CHANGES i . (ITS 3.4.6 Discussion of Changes Labeled (A.1, A.2, A.3, A.4. and A.5)
- (continued) i Standard 2.- Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
l The proposed changes involve reformatting, renumbering. and rewording of a the CTS. along with the incorporation of PVNGS current operating practices and other changes, as discussed in order to be consistent with NUREG-1432. i The proposed changes do not involve a physical alteration of the plant (no i new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or ) different kind of accident from any accident previously evaluated. j Standard 3. Does the proposed change involve a significant reduction in a margin of safety? The proposed changes involve reformatting, renumbering. and rewording of ' , the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. j The proposed chances are administrative in nature and will not involve any technical changes. The proposed changes will not reduce a margin of safety
- because they have no impact on any safety analysis assumptions. Also.
because these changes are administrative in nature, no question of safety } is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. J 1 i I i 1 1 i PALO VERDE - UNITS 1,2, AND 3 2 Rev. A
NO SIGNIFICANT liAZARDS CONSIDERATION ITS Section 3.4.6 - RCS Loops - Mode 4 TECHNICAL CHANGES HORE RESTRICTIVE (ITS 3.4.6 Discussion of Changes Labeled H.1, H.2 and H.3) Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS), l Units 1. 2. and 3 is converting to the ITS as outlined in' NUREG-1432. This particular NSHC is for the changes labeled " Technical Changes - More Restrictive" ! ! described in the specific Discussion of Changes listed above. The proposed ! 1 changes incorporate more restrictive changes into the CTS by either making
- current requirements more stringent or adding new requirements which currently
{ do not exist.
, The Commission has provided standards for determining whether a significant
! hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to ! an operating license for a facility involves a no significant hazards consideration if operation of the facility. in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or . consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these
- standards as they relate to this amendment request follows:
Standard 1. - Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes provide more stringent requirements than previously , s existed in the CTS. The more stringent requirements will not result in ! operation that will increase the probability of initiating an analyzed l event. If anything, the new requirements may decrease the probability or l consequences of an analyzed event by incorporating the more restrictive )
- changes discussed in the specific Discussion of Changes listed above. l These changes will not alter assumptions relative to mitigation of an '
i accident or transient event. The more restrictive requirements will not alter the operation ard will continue to ensure process variables. structures, systems, or components are maintained consistent with safety , analyses and licensing basis. These changes have been reviewed to ensure i
- that no previously evaluated accident has been adversely affected. !
! Therefore, these changes will not involve a significant increase in the probability or consequences of an accident evaluated. - PALO VERDE - UNITS 1,2, AND 3 3 Rev. A a
- - - - - -. - -- ~ . . -
4 NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.6 - RCS Loops - Mode 4 i ~ TECHNICAL CHANGES - MORE RESTRICTIVE 4 (ITS 3.4.6 Discussion of Changes Labeled M.1, H.2 and H.3) (continued) Standard 2.- Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? Making existing requirements more restrictive and adding more restrictive
- requirements to the CTS will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes do impose different I l requirements. However, they are consistent with the assumptions made in !
the safety analyses, licensing basis, and NUREG-1432. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. ! Standard 3. - Does the proposed change involve a significant reduction in a margin of safety? i . The proposed changes provide more stringent requirements than previously existed in the CTS. An evaluation of these changes concluded that adding these more restrictive requirements either increases or has no impact on ; i the margin of safety. The changes provide additional restrictions which . may enhance plant safety. These changes maintain requirements of the l ! safety analysis, licensing basis and NUREG-1432. As such, no question of i safety is involved. Therefore, these changes will not involve a significant reduction in a margin of safety. ] 4 i i l PALO VERDE - UNITS 1,2, AND 3 4 Rev.A
NO SIGNIFICANT HAZARDS CONSIDERATION , ITS Section 3.4.6 - RCS Loops - Mode 4 l TECHNICAL CHANGES - RELOCATIONS (ITS 3.4.6 Discussion of Changes Labeled LA.1, LA.2, LA.3, LA.4 and LA.5) l 1 l Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). l Units 1, 2. and 3 is converting to the ITS as outlined in NUREG-1432. The 1 proposed changes since detail is being removed from the CTS to a Licensee Controlled Document, are less restrictive. The descriptions of these changes are in the Discussion of Changes listed above. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes do not result in any hardware changes or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any anai/ zed event. The Licensee Controlled Document containing the relocated requirements will be maintained using the provisions of 10 CFR 50.59 or other specified control processes and is subject to the change control process in the Administrative Controls Section of the ITS. Since any changes to a Licensee Controlled Document will be evaluated. no increase in the probability or consequences of an accident previously evaluated will be allowed. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 5 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION 1 ITS Section 3.4.6 - RCS Loops - Mode 4 TECHNICAL CHANGES RELOCATIONS (ITS 3.4.6 Discussion of Changes Labeled LA.1, LA.2. LA.3 LA.4 and LA.5) (continued) Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not alter the plant configuratior (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes will not impose different requirements and adequate control of information will still be maintained. These changes will not alter assumptions made in the safety analysis or licensing basis. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. 1 ~ Standard 3. - Does the proposed change involve a significant reduction in a margin of safety? a The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not reduce a margin of safety since they have no impact on any safety analysis assumptions. In addition, , the requirements to be transposed from the CTS to the Licensee Controlled Document are the same as the CTS. Since any future changes to this Licensee Controlled Document will be evaluated per the requirements of 10 CFR 50.59, or other specified control processes, no reduction (significant or insignificant) in a margin of safety will be allowed. j Therefore, these changes will not involve a significant reduction in a margin of safety. The NRC review provides a certain margin of safety, and although this review will no longer be performed prior to submittal, the NRC still inspects the 10 CFR 50.59 process. The proposed changes are consistent with NUREG-1432, which was approved by the NRC Staff. The change controls i for proposed relocated details and requirements provide an acceptable level of regulatory authority. Revising the CTS to reflect the approved level of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore. revising the CTS to reflect tb NRC accepted level of detail and requirements ensures no 4 reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 6 Rev. A
CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.7 MARK UP
I i h RCS Loops-MODE 5, Loops Filled 3.4., l 3.4 REACTOR COOLANT SYSTEM (RCS) i 3.4.7 RCS Loops-MODE 5, Loops Filled j 5,k) k k LC0 3.4.7 One utdown fooling (SDC) train shall be OPERABLE and in
\ operation, and either: )
- a. One additional SDC train shall be OPERABLE; or !
- b. The secondary side water level of each fteam enerator (SG) shall be 2,f25%f.
I
- NOTES------- --
- 1. The SDC pump of the train in operation may be de-energized for s I hour per 8 hour period provided:
- a. No operations are permitted that would cause reduction of the RCS boron concentration; and
- b. Core outlet temperature is maintained at least 10*F below saturation temperature. !
h,4g gM 2. One required SDC train may be inoperable for up to 2 hours for surveillance testing provided that the other 5 1 SDC train is OPERABLE and in operation. .
- 3. No[eactor[colant[ ump (RCP) shall be star d with
- e r more of the RCS cold leg temperatures &nce w % m,. .
- itch *F Angreso (a. /The t/essuririr wate(level /s < f60]%;[oD un\a.2
\. 3 secondary side water temperature n each is
< 11001*F above each of the RCS cold leg em er tures.
i h All SDC trains may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation.
% /Jo Awa f$no., 2 llc Ys P
- y bt is of*rsk +% R.C S c* IJ
\ e , + e n p a r+ h re E 24o * *; . Os ~.ve sm 5 f.ch n y \,s APPLICABILITY: MODE 5 wuiiEBoops filled.
4 p , g Q ,g g yg c q g,gj g,] de Wfere h+1r > T oc*F bi,4 b TDd'6 QfhQ,,-O Dk) M 3.4-13 Rev i, ../C/T., L
-. maa,-a i - - . > . _ . . - - , ,a.:- a s .a s. + - - . - + . s. ~ , . . - a- . m., -i.-a . n. .s --.
I l l l l l l l l I RCS Loops-MODE 5, Loops Filled 3.4.7 j l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME !
)
A. One SDC train A.1 Initiate action to Innediately 3 4\,k\ D g, restore a second SDC inoperable. train to OPERABLE 1 l i M status. l ' i Any SG with secondary B l side water level not - , within limit. A.2 Initiate action to Immediately ! restore SG secondary l side water levels to . l within limits. l l l l Suspend all Immediately l . l14 \.A.\ D b. B. Required SDC train inoperable. B.1 operations involving i reduction in RCS l boron concentration. l M No SDC train in R operation. B.2 Initiate action to immediately restore one SDC train to OPERABLE status and operation. S. I l l' l l I l Pa %de -Und bZ@ A Rev i, 04fei f si-ger, gg 3.4 14
l l l i i 1 i i
)
RCS Loops-MODE 5, Loops Filled 3.4.7 I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY ] 4,4) ,4,\ .t SR 3.4.7.1 Verify one SDC train is in operation. 12 hours 4,4,lke\.k Verify required SG secondary side water j SR 3.4.7.2 12 hours ( levelis2425{1, q J l
% M ,\ SR 3.4.7.3 Verify correct breaker alignment and 7 days l indicated power available to the required ,
l s
- SDC pump that is not in operation. ].
I 1
)
1 l l 1
. i l
l k\/k- N J.; R
\w}
3.4-15 Rev t-- C/;7/;C - , A
r I 1 l
- CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.7 BASES MARK UP l
l l 1 i l l i I l l I
i ! I l l l i L l RCS Loops-MODE 5. Loops Filled B 3.4.7 l B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.7 RCS Loops-MODE 5. Loops Filled l BASES i BACKGROUND in MODE 5 with the RCS loops filled, the primary function of the reactor coolant is the removal of cay heat and 1 l transfer this heat either to the fteam enerator (SG) M i i secoglary sidg, coolant or therf.pmponen oling"Whter via \.') theJhutdown" fooling (SDC)heatexchangers, wnne Ine , principal means for decay heat removal is via the SDC MscA ! System, the SGs are specified as a backup means for a ! redundancy. Even though the SGs cannot produce steam in O l this MODE, they are capable of being a heat sink due to ! their large contained volume of secondary side water. As long as the SG secondary side water is at a lower , temperature than the reactor coolant, heat transfer will 1 occur. The rate of heat transfer is directly proportional to the temperature difference. The secondary function of 1 the reactor coolant is to act as a carrier for soluble neutron poison, boric acid. i In MODE 5 with RCS loops filled, the SDC trains are the prin:1 pal means for decay heat removal. The number of trains in operation can vary to suit the operational needs. I The intent of this LCO is to provide forced flow from at least one SDC train for decay heat removal and transport. The flow provided by one SDC train is adequate for decay
- heat removal. The other intent of this LC0 is to require i that a second path be available to provide redundancy for l decay heat removal.
The LCO provides for redundant paths of decay heat removal capability. The first path can be an SDC train that must be l OPERABLE and in operation. The second path can be another ! OPERABLE SDC train, or through the S0s, eact. having kn adequate water level. APPLICABLE In MODE 5, RCS circulation is considered in the SAFETY ANALYSES determination of the time available for mitigation of the accidental baron dilution event. The SDC trains provide this circulation. (continued) l vu 'i5 B 3.4-30 Rev N b yer -Om o Ub g
l
; i RCS Loops-MODE 5, Loops Filled !
B 3.4.7 j BASES l APPLICABLE RCS Looos-MODE 5 (Loops Filled) have been identified in@ i 2 SAFETY ANALYSES asr eo m v : as im tant contributors to risk i y (continued) reduction. IDM 50.34s (E M 4 j h ! j
<Wb\h\b{
LCO The purpose of this LCO is to require at least er.e of the 8 SDC trains be OPERABLE and in operation with an addisional SDC train OPE BLE or secondary side water level of each SG shall be 212 %.ETn"elDC train provides sufficiert forcedhg ghg circulation 1 erform the safety functions of the reactor coolant under these conditions. The second SDC train is normally maintained OPERABLE as a backup to the operating SDC train to provide redundant paths for decay heat removal. However, if the standby SDC train is not OPERABLE, a sufficient alternate method to provide redundant paths for decay heat rem al s two SGs with their secondary side water levels 2 25 " Should the operating 5U0 train 41 , the SGs could e us to remove the decay heat. 1 Note 1 permits all SDC pumps to be de-energized s I hour per 8 hour period. The circumstances for stopping both SDC trains are to be limited to situations where pressure and
) temperature increases can be maintained well within the allowable pressure (pressure and temperature and low temperature overpressure protection) and 10*F subcooling limits, or an alternate heat removal path through the SG(s) is in operation.
3 < This LCO is modified by a Note that prohibits boron d'ilutio when SDC forced flow is stopped because an eve,n rnimenT ob :Atp " concentration distribution cannot be ensured. FCore outlet N he m- Arad temperature is to be maintained at least 10'F below saturation temperature, so that no vapor bubble would form pomb.m. racx3.Aq wh ({,g and possibly cause a natural circulation flow obstruction. e,y0 ,g - in this MODE, the SG(s) can be used as the backup for SDC h* b bM heat removal. To ensure their availability, the RCS loop flow path is to be maintained with subcooled liquid. In MODE 5, it is sometimes necessary to stop all RCP or SDC forced circulation. This is pemitted to change operation from one SDC train to the other, perfom surveillance or startup testing, perform the transition to and from the SDC, or to avoid operation below the RCP minimum net positive suction head limit. The time period is acceptable because natural circulation is acceptable for decay heat removal,
'} (continued)
CEOG STS B 3.4-31 %t 1, 04/07/95
l
- "Z. ,R.C Fr M M f)e rho /c be 3 h 4 fv5hrick % e/cr f ui O E.l $ cold I*y f ewg6 M /C k MN ##d M Mo{o Man i Ata e n (cs e. a ley bg4 , >zoov A+ s. goo.g, f
% % % a m a a & % ,.,,
Wp%s o Z W % 'mfwea pas, sue3b ear<eeQ t Cuiws due b f CP *F sYcop# ##s-Mout 5. Loops Filled y~ - B 3.4.7 i BASES LCO the reactor coolant temperature can be maintained subcot, led, (continued) and boron stratification affecting reactivity control is not expected. Note 2 allows one SDC train to be inoperable for a period of up to 2 hours pr w ideo that the other SDC train is OPERABLE and in operation. This permits periodic surveillance tests to be performed on the inoperable train during the only time when such testing is safe and possible. Note 3 requires thatetyer-#7 Me fo11 sting te conagens. (De sat % w before an RCP_may be sta e j wp cM d leg temperature s .a r ~u on.or- S CRn* G l _ _
.M h 'Ffdoving%: La MFu% i _ '
Ca/ yrergurizerfater/evelmuftbe((6p%fa k
~
on ar si e water temperature in each'SG must 'be
'F above each of the RCS ol le temperatures.
Satisfy ng :ithe f the above conditio will preclude (tstLdmhysc , low temperature overpressure event due to a thermal % gg3
'< 3 A .\.6,\ % %%e.gg\ /
transient when the RCP is started.
, wss. )
,Not r rovides for an orderly transition from MODE 5 t MODE 4 during a planned heatup by permitting removal of SDC trains from operation when at least one RCP is in operation.
This Note provides for the transition to MODE 4 where an RCP is permitted to be in operation and replaces the RCS circulation function provided by the SDC trains. . An OPERABLE SDC train is composed SDC pum 9.cfyovidacg ses en uvumtw SDClelt exchan ue had two< w go + q,y pero esw.t __ SDC pumps are OP Lt if Weyjartr' capable of being powered and are able to provide flow 4f recuired. An OPERABLE _SG can oerform as a heat sink when itOrrs afr acegerate e n sa4 -m is OPERABLE wi _ .w J ube Surveihlance P (spmk d i n 68. 14.1. 2. . C6 s.rnini even h m -- = T +
--wv-l l APPLICABILITY In MODE 5 with RCS loops filled, this LCO requires force circulation to remove decay heat from the core and to bt#r \
l I provide proper boron mixing. One SDC train provides sufficient circulation for these purposes. 7 (continued) i i
"^*
B 3.4-32 Rev 1, 0;/07/ Z O YP/dQ. 'Unb \ 1 b 1
1 INSERT FOR ITS BASES 3.4.7 ! LCO BASES (Units 1,2, and 3) INSERT 1 l LCO When entering RCS Loops - MODE 5 Loops Filled from RCS Loops - ! 4 MODE 5 Loops not Filled the additional requirement of total gas 1
- concentration must be addressed for SGs to be considered as a heat I sink. A total gas concentration of < 20 cc/kg is required for MODE 5 !
operations. This limit ensures that gases coming out of solution in the SG U-tubes will not adversely affect natural circulation with RCS pressure at atmospheric conditions. Normal operating procedures implement the findings for determination of when RCS loops are i considered filled, which in turn allows for transition from RCS Loops - ; 4 MODE 5 Loops not Filled to RCS Loops - MODE 5 Loops Filled. The ability to feed and the ability to steam SGs is not a requirement. Since RCS temperature is less than 210*F in MODE 5-Loops Filled, no boiling (i.e. loss of SG inventory) will occur, therefore, the ability to feed and the ability to steam SGs is not a requirement. However, a i means to feed and steam the SGs, whenever the Unit is in RCS Loops - MODE 5 Loops Filled, should be provided. Feed sources available are i not limited only to Essential Auxiliary Feedwater Pumps and the Condensate Storage Tank (if. ). Steaming capability is usually via ADVs. Also, the RCS must be intact (ability to pressurize to at least 100 psia) for the SGs to be considered as a heat sink. With the RCS not intact a majority of heat removal, assuming a loss of SDC flow, will be out the vent (Ref. 2). Therefore, with the RCS not intact, transition to
- LCO 3.4.8, RCS Loops - MODE 5 Loops not Filled, is appropriate. '
i i i 4 e 1 2
I l l l I i l I l l RCS Loops-MODE 5, Loops Filled B 3.4.7 i s ( BASES APPLICABILITY Operation in other MODES is covered by: (continued) LCO 3.4.4, "RCS Loops-HODES I and 2*; LCO 3.4.5, 'RCS Loops-MODE 3'; LCO 3.4.6, 'RCS Loops-MODE 4'; LCO 3.4.8, 'RCS Loops-MODE 5, Loops Not Filled"; LCO 3.9.4, " Shutdown Cooling (SDC) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.5, ' Shutdown Cooling (SDC) and Coolant l Circulation-Low Water Level' (MODE 6). ACTION A.1 and A.2 ggg g 5.u A. \ .b(i 3, ,w rea s eb SDC train is ino era e an any ave G 25 Q redundancy for heat sec'ondary removal side Action is lost. water levels must < {be iMtiated immediately to restore a second SDC train to OPERABLE status or to restore t the water level in the required SGs. Either Required Action A.1 or Required Action A.2 will restore redundant decay heat removal paths. The immediate Completion Times reflect the importance of maintaining the availability of l (two paths for decay heat removal. O t DM@nd cr rc +'*' d yq if D tra is n operation,(naspt E oerwTte46SE h
@ all operations involving the reduction of RC5 boron j concentration must be suspended. Action to restore one SDC
! train to OPERABLE status and operation must be initiated. i Boron dilution requires forced circulation for proper mixing and the margin to criticality must not be reduced in this j type of operation. The immediate Completion Times reflect I the importance of maintaining operation for decay heat removal. SR 3.4.7.1 b Ob I' SURVEILLANCE st
- 4tew vue o Z p r..h e r_ Ww e v- epl REQUIREHENTS This SR requires veri ication every 12 hours that one SDC train is in operatio . Verification includes flow rate, -4 Sc ooMm '
temperature, or pump status monitoring, which help ensure that forced flow is providing decay heat removal. The
) (continued)
Rev i-, , vi di-
!"^! P! B 3.4-33
\o w-umb \,za 3 i
l
l l l i l l RCS Loops-MDDE 5, Loops filled B 3.4.7 BASES SURVEILLANCE SR 3.4.7.1 (continued) REQUIREMENTS 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation and verify operation is within safety analyses assumptions. In addition, control room indication and alarms will normally indicate loop status. The SDC flow.is established to ensure that core outlet temperature 19 maintained sufficiently below saturation to allow time for swapover to the standby SDC train should the operating train be lost.
- 3. 4.7. 2 SR 6
Verifying the SGs are OPERABL y ensuring their secondary side water levels are 2 25% nsures that redundant heat t.st removal paths are availab e i the second SDC train is \ inoperable. The Surveillance is required to be performed when the LCO requirement is being met by use of the SGs. If both SDC trains are OPERABLE, this SR is not needed. The 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation and verify operation within safety analyses assumption <. j ($ Mb. .hg/ SR 3.4.7.3 Verification that the second SDC train is OPERABLE ensures that redundant paths for decay heat removal are available. The requirement also ensures that the additional train can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper breaker alignment and power available to the required pumps. The Surveillance is required to be performed when the LCO requirement is being met by one of two SDC trains, e.g., both SGs have < (2Q% water level. The Frequency of 7 days is considered reasonable in view of other administrative controls available and has been shown to be acceptable by operating experience. REFERENCES Nea+ 1.MotgQcf gm
- 2. ceBh>-aso-mo3.4-34 u% 4q04/47./SS-Rev L Me w ~1 eum sa' wm 1,2,3 2.e n .a~n u ,m wo ve, t m se c u . ~...
.,.~.da n s., < w, :ta y,y u, anamow a ~t
200 F but 5 50b F.
NUREG-1432 LC0 3.4.7 does not speci fy these restrictions. These restrictions are necessary to maintain the analysis assumptions of the flow induced pressure correction factors due to RCP operation, and are consistent with the current licensing basis (CTS 3.4.1.4.1). The ITS Bases for LC0 ".4.7 and References include the basis for these RCP operating restrictions. This change is consistent with PVNGS licensing basis. PALO VERDE - UNITS 1,2, AND 3 2 REV.B 1
l 1 l PVNGS CTS . 1 SPECIFICATION 3.4.7 i 1 MARK UP i l j i I l 1 l l i j l l
l __ \ n r a c c;i u \ 3- ,. o
\
1 M b REACTOR COOLANT SYSTEM 4 f
-Col 0 5%W - L^^^C "!!!!O-PC5_-lev - @ -AIDDf 6'LCOPS b -
. LIMITING CONDITION FOR OPERATION 3.4.1.0.- ?.; M .; one shutdown cooling MD o ration *, and either: , shall be OPERABLE and in
- a.
' One additional shutdown cooling loop shall be OPERABLE #, or gggy
- b. The secondary side water level of at least two steam cenerators shall be greater than 25%(fr)dicated/ wide rapgJeev/p /
) g
~ APPLICABILITY: MODE 5 with reacto oolant loops f_illedN. '_ _
ACTION: py DC _ 0 _ oQN .hMk@%gv %w1:hma
- ' K. NiK less tMn the ob~ e requi~rpfffoiips~0PEMQiLT~ir'/rith r less than I
{k t tKe reauirs6 steam _ rator urtL/famediately initiate corrective action to return the required loops to OPERABLE status er to restare he reautred level me annn ma neasible / g gg K. no shutdown cooling loop in operation,
~
spend all o~peraH ons yb involving a reduction in boron concentratio the Reactor Coolant System and ismediately initiate corrective ac on to return the cuired shutdown coolino Inno to eneration. / I . SURVEILLANCE REQUIREMENTS
- Ifhmcid -
%. s' '
' O.0.1.0.1.1 The secondary side water level of both steam generators when Q,1 tenuired shall be determined te he within limits at least once ner 12 hours. 3 4.4.1.0.1.2 At 1_e85.1_pDe shutdown coolino lopp_shall be detersined E W n_) 4 Dg$ g g onerationfand #1rcula';ido reactor do ant at a/ flow rate sT areateor than er
~
! (equer to 3780/nos C east once per 12 hours %Mdy Y jW g-
'; Ql.Theshutdowncoolingpum$fmaybedeenergizedforuptoIhour&provided1 (1) no operations are permitted that would cause di kt'04 cf the Reactor Coolant System boron concentration, and (2) core outlet \ temperature is maintained at least 10' saturation temperature. C ne shutdown cooling . , ==y be inoperable for up to 2 hours for [
Q@l surveillance testing provided the other shutdown cooling and in operation. is CPERABLE ei M hAreactorcoolantpumpshallnotbestartedwithoneormoreoftbReactor b Coolant System cold leg temperatures less than or equal to 214'F during cooldown, or 291'F during heatup, unless the secondary water temperature tsatgration AemneratMe~c_orMsf6hdinar to steTVoeneratosr cressurn,of each
*k steam cold leggenerator temperatures. is less than 100'F above each of the Reactor Coolaht System g
i p, ee r-+ -- c 13 r* g - r - = + 4 a- <-
-'* d tL No more thang 2 Fesctor Coolant ^
! nicag be uno ia with RCS cold leg temperature less than 'er equal to 200*F.dReactor __ l
*/**b.
i ( or eaual to 500'F. Coolant 70Hih'Ywith RCS cold leg temperature greater than 200'F A*lbut less tha h .<e j j ton dung pim Nowyto M4 b cd hd M 3/4 4-5
- e. % ,n w Lt Palo Verde - Units 1, 2, 3 i
4
l l INSERT FOR CTS 3.4.1.4.1 SURVEILLANCE REQUIREMENTS (Units 1,2, and 3) INSERT 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.7.3 Verify correct breaker alignment and indicated power 7 days available to the required SDC pump that is not in operation. l { i
/
I l l
l DISCUSSION OF CHANGES SPECIFICATION 3.4.7 1 J l I l 1 I I I i 1
PALO VERDE ITS CONVERSION ; DISCUSSION OF CHANGES l SPECIFICATION 3.4.7 - RCS Loops - Mode 5, Loops Filled I l ADMINISTRATIVE CHANGES A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432. l Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station (PVNGS) Improved Technical Specifications (ITS) should be more readable. and therefore understandable, by plant operators as well as other users. During the ' reformatting and renumbering of the ITS. no technical changes 4 (either actual or interpretational) to the Current Technical Specificai. ions l (CTS) were made unless they were identified and justified. $ Editorial rewording (either addir cr deleting) is made consistent with NUREG-1432. During NUREG-1432 deve apment, certain wording preferences or ! English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. 1 l Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more detail does not result in a technical change. l ! A.2 CTS LCO 3.4.1.4.1 Footnote
- discusses the requirements which allow all RCPs and SDC pumps to be de-energized for a period of time. One requirement is that no operations be permitted that would cause dilution of the RCS
! boron concentration. ITS LC0 3.4.7 LCO Note 1 changed the word " dilution" to " reduction." Both words are used in the same context; reducing boron 3 concentration of the RCS is not acceptable. This change does not alter the LCO intent. Therefore, this is an administrative change with no impact on safety. This change is consistent with NUREG-1432. A.3 CTS 3.4.1.4.1. Action b, states, in part. "with no shutdown cooling loop in operation . . " ITS 3.4.7. Action B. adds a Condition of " required SDC i train inoperable." The addition of this statement to Action B in ITS provides clarification of intent. In the CTS. because of the wording, there
- existed some ambiguity with Action b. The plant could be in Mode 5 with the 3
required RCS loop or SDC train inoperable and only be in CTS Action a. The 4 added wording to ITS Action B clarifies its usage by requiring its performance with the required SDC train inoperable. Although not explicitly stated in CTS. PVNGS operating practice complies with the intent of ITS i 3.4.7 Action B. This change provides explicit wording that clarifies Palo 4 Verde practice in usage of ITS 3.4.7 Action B. therefore, this is an
! administrative change. This change is consistent with NUREG-1432.
PALO VERDE - UNITS 1,2, AND 3 1 FEV. A
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.7 - RCS Loops - Mode 5, Loops Filled ADMINISTRATIVECHANGES(continued) A.4 CTS 3.4.1.4.1. Action a. does not specifically identify the conditions that define Operable, or not in operation. ITS 3.4.7 Actions A and B do define I what conditions define inoperable, or not in operation. This change provides clarification of CTS 3.4.1.4.1. Action a. Providing clarification constitutes an administrative change. This change is consistent with NUREG-1432. TECHNICAL CHANGES - MORE RESTRICTIVE M.1 ITS SR 3.4.7.3 has been added which requires verification of correct breaker alignment and indicated power available to the required SDC pump that is not in operation. CTS 3.4.1.4.1 does not contain this requirement. , Verification that the required pump is Operable ensures that an additional ! SDC train can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. The addition of this SR. for the SDC pump not in operation, constitutes a more restrictive change to PVNGS plant operation. This change is consistent with NUREG-1432. M.2 CTS 3.4.1.4.1. Footnote *, allows all shutdown cooling pumps to be I de-energized for up to one hour. ITS 3.4.7 LC0 Note 1 allows all shutdown cooling pumps to be de-energized for up to 1 hour per 8 hour period. Therefore, the amount of time all shutdown cooling pumps may be de-energized has been restricted from less than or equal to one hour, to less than or equal to one hour per eight hour period. CTS would permit repeated application of' the one hour exemption, indefinitely. This additional restriction on plant operation restricts immediate, repeated application of the one-hour allowance, which would circumvent the intent of the NOTE. Although not explicitly stated in CTS. PVNGS operating practice complies with the 1 hour per 8 hour period requirement statement in ITS 3.4.7 NOTE. This change provides explicit wording that clarifies i PVNGS operating practice in application of this LCO. Placing a limitation on the de-energization of all shutdown cooling pumps will not adversely affect plant safety. Placing additional restrictions on plant operation ! constitutes a more restrictive change to PVNGS operating practice. This I change is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 2 REV.A
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.7 - RCS Loops - Mode 5, Loops Filled TECHNICAL CHANGES MORE RESTRICTIVE (continued) M.3 CTS 3.4.1.4.1. Action b, requires the suspension of all operations i involving a reduction in boron concentration of the RCS when no SDC loop is in operation. The CTS does not provide any Completion Time associated with this Action. ITS 3.4.7. Action B.1 requires suspension of all
- operations involving a reduction of RCS boron concentration, "immediately."
! CTS only associates the term "immediately" with Action to return the l required SDC loop to operation, not with the Action to suspend all operations involving a reduction in boron concentration of the RCS. The addition of "immediately" for Completion Time to suspend all operations involving a reduction in boron concentration of the RCS reflects the importance of maintaining operation of decay heat removal. The addition of this requirement constitutes a more restrictive change to PVNGS plant ; operation. This change is consistent with NUREG-1432. ' i TECHNICAL CHANGES RELOCATIONS LA.1 NOT USED , l PALO VERDE - UNITS 1,2, AND 3 3 REV.B
l PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.7 - RCS Loops - Mode 5, Loops Filled TECHNICAL CHANGES - RELOCATIONS (continued) 1 LA.2 CTS SR 4.4.1.4.1.2 contains a minimum flow rate that SDC must equal or exceed. This information will be relocated to ITS SR 3.4.7.1 Bases. Also. CTS 4.4.1.4.1.2 requires at least one SDC train be verified in operation and " circulating reactor coolant." The requirement to circulate reactor coolant is moved to Section SR 3.4.7.1 of the ITS Bases. In addition, both pieces of information do not meet the 10 CFR 50.36 (c) (2) (ii) criteria . for inclusion in to the ITS and are, therefore, being relocated. Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This information is not required to be in ITS to provide adequate protection of public health and safety. Therefore, relocation of this information to a Licensee Controlled document (Bases) is acceptable and is consistent with 3 NUREG-1432. 4 LA.3 CTS LCO 3.4.1.4.1.b specifies that " indicated wide range" level is to be used for verification of SG 1evel. All values in ITS are indicated values. This information. less the word " indicated", is moved to ITS 3.4.7 Bases
- Section. This information is not required to determine OPERABILITY of a system, component or structure and therefore is being relocated to a Licensee Controlled Document (Bases Section).
Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This information is not required to be in ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to a Licensee Controlled document is acceptable and is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 4 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.7 - RCS Loops - Mode 5, Loops Filled TECHNICAL CHANGES RELOCATIONS (continued) LA.4 CTS 3.4.7, Footnote ##, contains information that provides guidance determining SG water temperature. Although this information is useful, it is not required to determine the OPERABILITY of a system, component or structure, and is therefore being relocated to ITS 3.4.7 LCO Bases. Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This information is not required to be in ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to a Licensee Controlled document is acceptable and is consistent with NUREG-1432. TECHNICAL CHANGES LESS RESTRICTIVE L.1 ITS 3.4.7 LC0 Note 5 allows all SDC trains to be removed from operation during a planned heatup to Mode 4 when at least one RCS loop is in operation. CTS has no such allowance for transition into Mode 4. The addition of this information to the LC0 provides for an orderly transition from Mode 5 to Mode 4 during a planned heatup. This provides for the I transition to Mode 4 where an RCP is permitted to be in operation and replaces the RCS circulation function provided by the SDC trains. ; Therefore, this change does not detrimentally affect plant safety. This change is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 5 REV.B
- m -
1 NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.4.7
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.7 - RCS Loops - Mode 5, Loops Filled ADMINISTRATIVE CHANGES (ITS 3.4.7 Discussion of Changes Labeled A.1, A.2, A.3 and A.4) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS). l Units 1, 2, and 3. is converting to the ITS as outlined in NUREG-1432. " Standard i Technical Specifications, Combustion Engineering Plants." The proposed changes
- involve the reformatting, renumbering, rewording of the Technical Specifications (TS) and Bases with no change in intent, and the incorporation of current i
- operating practices consistent with NUREG-1432. These changes, since they do not involve technical changes to the Current TS (CTS), are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432.
1 The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to I an operating license for a facility involves a no significant hazards
- consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or
, consequences of an accident previously evaluated: 2) create the possibility of j l a new or different kind of accident from any accident previously evaluated; or l
- 3) involve a significant reduction in a marg'n of safety. A discussion of these l standards as they relate to this amendment request follows:
l Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
- 1
, The proposed changes involve reformatting, renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating ! practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. ' j Specifically, there will be no change in the requirements imposed on PVNGS s due to these changes. During development of NUREG-1432, certain wording preferences or English language conventions were adopted. The proposed
- changes to this Section/ Chapter are administrative in nature and do not i impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
4 PALO VERDE - UNITS 1,2, AND 3 1 Rev. A i
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.7 - RCS Loops - Mode 5, Loops Filled ADMINISTRATIVE CHANGES (ITS 3.4.7 Discussion of Changes Labeled (A.1, A.2, A.3 and A.4) (continued) Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3. Does the proposed change involve a significant reduction in a margin of safety? 1 The proposed changes involve reformatting, renumbering, and rewording of the CTS. along with the incorporation of PVNGS current operating practices 1 and other changes, as discussed, in order to be consistent with NUREG-1432. ' The proposed changes are administrative in nature and will not involve any technical changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 2 Rev. A
. . - __ . =-. . . . . .
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.7 - RCS Loops - Mode 5 Loops Filled 1 TECHNICAL CHANGES - MORE RESTRICTIVE (ITS 3.4.7 Discussion of Changes Labeled M.1, M.2 and M.3) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. This particular NSHC is for the changes labeled " Technical Changes - More Restrictive" described in the specific Discussion of Changes listed above. The proposed changes incorporate more restrictive changes into the CTS by either making current requirements more stringent or adding new requirements which currently do not exist. The Commission has provided standards for determining whether a significant )
- hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards ;
consideration if operation of the facility. in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the. possibility of j a new or different kind of accident from any accident previously evaluated: or )
- 3) involve a significant reduction in a margin of safety. A discussion of these l
- standards as they relate to this amendment request follows:
Standard 1.-- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes provide more stringent requirements than previously i' existed in the CTS. The more stringent requirements will not result in operation that will increase the probability of initiating an analyzed event. If anything. the new requirements may decrease the probability or consequences of an analyzed event by incorporating the more restrictive changes discussed in the specific Discussion of Changes listed above. These changes will not alter assumptions relative to mitigation of an j accident or transient event. The more restrictive requirements will not alter the operation and will continue to ensure process variables, structures, systems, or components are maintained consistent with safety analyses and licensing basis. These change.s have been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident evaluated. PALO VERDE - UNITS 1,2, AND 3 3 Rev.A
NO SIGNIFICANT HAZARDS CONSIDERATION , ITS Section 3.4.7 - RCS Loops - Mode 5, Loops Filled l 4 TECHNICAL CHANGES - MORE RESTRICTIVE (ITS 3.4.7 Discussion of Changes Labeled H.1, M.2 and H.3) (continued) I l Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? l Making existing requirements more restrictive and adding more restrictive requirements to the CTS will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes do impose different requirements. However, they are consistent with the assumptions made in the safety analyses, licensing basis, and NUREG-1432. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? The proposed changes provide more stringent requirements than previously existed in the CTS. An evaluation of these changes concluded that adding these more restrictive requirements either increases or has no impact on the margin of safety. The changes provide additional restrictions which ! may enhance plant safety. These changes maintain requirements of the I safety analysis, licensing basis, and NUREG-1432. As such, no question of safety is involved. Therefore, these changes will not involve a significant reduction in a margin of safety. d i -f PALO VERDE - UNITS 1,2, AND 3 4 Rev.A
l l NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.7 - RCS Loops - Mode 5, Loops Filled l TECHNICAL CHANGES - RELOCATIONS (ITS 3.4.7 Discussion of Changes Labeled LA.1, LA.2, LA.3 and LA.4) J Arizona Public Service Company Palo Verde Nuclear Generating Station (PVNGS). i Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The ! proposed changes, since detail is being removed from the CTS to a Licensee Controlled Document, are less restrictive. The descriptions of these changes are in the Discussion of Changes listed above. j The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards j consideration if operation of the facility, in accordance with a proposed amendment would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows: ,
Standard 1.- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee ; Controlled Document. These changes do not result in any hardware changes or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee Controlled Document containing the relocated ?quirements will be < maintained using the provisions of 10 CFR 50.59 o. .ther specified control processes and is subject to the change control process in the Administrative Controls Section of the ITS. Since any changes to a Licensee Controlled Document will be evaluated, no increase in the probability or consequences of an accident previously evaluated will be allowed. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 5 Rev. A
i i NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.7 - RCS Loops - Mode 5, Loops Filled TECHNICAL CHANGES RELOCATIONS (ITS 3.4.7 Discussion of Changes Labeled LA.1, LA.2. LA.3 and LA.4) (continued) i Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? l The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes will not impose different requirements and adequate control of information will still be maintained. These changes will not alter assumptions made in the safety analysis or licensing basis. Therefore, these changes will not create the ! possibility of a new or different kind of accident from any accident previously evaluated. 1 Standard 3. Does the proposed change involve a significant reduction in a i margin of safety? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not reduce a margin of safety since they have no impact on any safety analysis assumptions. In addition, the requirements to be transposed from the CTS to the Licensee Controlled Document are the same as the CTS. Since any future changes to this Licensee Controlled Document will be evaluated per the requirements of 10 CFR 50.59. or other specified control processes, no reduction (significant or insignificant) in a margin of safety will be allowed. < Therefore, these changes will not involve a significant reduction in a l margin of safety. ! The NRC review provides a certain margin of safety, and although this review will no longer be performed prior to submittal, the NRC still l inspects the 10 CFR 50.59 process. The proposed changes are consistent l with NUREG-1432. which was approved by the NRC Staff. The change controls
- for proposed relocated details and requirements provide an acceptable level of regulatory authority. Revising the CTS to reflect the approved level of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore, revising the CTS to reflect the NRC accepted level of detail and requirements ensures no j reduction in a margin of safety.
PALO VERDE - UNITS 1,2, AND 3 6 Rev. A
i NO SIGNIFICANT HAZARDS CONSIDERATION l ITS Section 3.4.7 - RCS Loops - Mode 5, Loops Filled i TECHNICAL CHANGES LESS RESTRICTIVE l (ITS 3.4.7 Discussion of Changes Labeled L.1) l l Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the description of this less restrictive change and the NSHC for.the conversion to l NUREG 1432. L.1 ITS 3.4.7 LCO Note 4 allows all SDC trains to be removed from operation during a planned heatup to Mode 4 when at least one RCS loop is in l operation. CTS has no such allowance for transition into Mode 4. The addition of this information to the LCO provides for an orderly transition from Mode 5 to Mode 4 during a planned heatup. This provides for the transition to Mode 4 where an RCP is permitted to be in operation and replaces the RCS circulation function provided by the SDC trains. l Therefore this change does not detrimentally affect plant safety. This , l change is consistent with NUREG-1432. l l The Commission has provided standards for determining whether a significant , ! hazards consideration exists as . stated in 10 CFR 50.92. A proposed amendment to : an operating license for a facility involves a no significant hazards l consideration if operation of the facility, ir. accordance with a proposed amendment. would not 1) involve a significant increase in the probability or l consequences of an accident previously evaluated: 2) create the possibility of , a new or different kind of accident from any accident previously evaluated; or l
- 3) involve a significant reduction in a margin of safety. A discussion of these l standards as they relate to this amendment request follows:
l 1 I i I
- l 1 l PALO VERDE - UNITS 1,2, AND 3 7 Rev. A I
\
1 NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.7 - RCS Loops - Mode 5, Loops Filled i TECHNICAL CHANGES - LESS RESTRICTIVE I (ITS 3.4.7 Discussion of Changes Labeled L.1) (continued) l I Standard 1.- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change provides a Note that permits all SDC trains to be removed from service during a planned heatup to Mode 4 when at least one RCS loop is in operation. The CTS has no such allowance for transition to l Mode 4. This change provides for an orderly transition from Mode 5 to Mode 4 during a heatup. This change will not result in operation that will ! increase the probability of initiating an analyzed event. In addition, this change does not alter assumptions relative to mitigation of an accident or transient event. This change has been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. Standard 2. - Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? 1 Allowing all SDC trains to be removed from operation during a planned heatup to Mode 4 when at least one RCS loop is in operation does not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. This change relaxes the requirements of the CTS by allowing the SDC trains to be inoperable with one RCS loop in operation, however, it is consistent with the assumptions made in the safety analyses, licensing basis, and consistent with NUREG-1432. Therefore, this change will not create the l possibility of a new or different kind of accident from any accident previously evaluated. Standard 3. Does the proposed change involve a significant redaction in a ; margin of safety? l l The proposed change provides a relation for SDC trains being inoperable l during a planned heatup to Mode 4 with one RCS loop in operation. An ' i evaluation of this change concluded that there is no impact on the margin l of safety. The change maintains requirements of the safety analysis. (' licensing basis, and consistent with NUREG-1432. As such, no question of safety is involved. Therefore. this change will not involve a significant reduction in a margin of safety. PALO VEP_DE - UNITS 1,2, AND 3 8 Rev. A i
l 1 i CE STS ; NUREG-1432 RE'/.1 SPECIFICATION 3.4.8 MARK UP l i l l 1 i l
RCS Loops-it3DE 5, Loops Not Filled 3.4.8 3.4 REACTOR COOLANT SYSTEK (RCS) l 3.4.8 RCS Loops-MODE 5, Loops Not Filled [@ 3,kl,$2,,, LCO 3.4.8 woIutdownIooling (SDC) trains shall be OPERABLE an SDC train shall be in operation. one N l hoLr
-- a --<
W E W WPbJ g5 --------- NOTES--- -- , <.h. 4 .\ .k 2 U n3QZ / 1. All SDC oumos may be de-energized for s mis 0tes e h ] (wit; King ffomptie } rain pu angn43)provided (b,4,\$.d [dde,5) a. The core outlet temperature is belowsaturationtemperature;(. maintained >10*F 3 A,( A .l Qde.," b. No operations are pe".ditt d that would cause 'a' reduction of the P'.S boron t.% centration; and
- c. No d-dr.ino coth tions to further reduce the RCS l
4E M) water voluine are permitted. Q'4,j,Q Qd") 2. One SDC train may be inoperable for s 2 hours for surveillance testing provided the other SDC train is OPERABLE and in operation. APPLICABILITY: MODE 5 with RCS loops not filled. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME imediately ! (D h A. One SDC train inoperable, A.1 Initiate action to restore SDC train to , ! OPERABLE status. l 1 l (continued) l l y:T;- m.,
, -u m u 3.4-16 Rev b Es3 a' '" 'M i
t l l I
- I RCS Loops-MODE 5 Loops Not Filled f 3.4.8 .
i r ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
/ Suspend all Imediately
)
%g B. Required SDC trains inoperable.
B.1 operations involving reduction of RCS E boron concentration. No SDC train in AtiQ operation. B.2 Initiate action to Immediately restore one SDC train to OPERABLE stetus and operation, i l l SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.4.\ 4, SR 3.4.8.1 Verify one SDC train is in operation. 12 hours I h M. SR 3.4.8.2 Verify correct breaker alignment and indicated power available to the required 7 days SDC pump that is not in operation. l I I I i i t I ! 3.4-17 Rev 1, "t,; f;5 Mfdt. OMD 11 l
l l CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.8 BASES MARK UP l l l I i t
- . - -~ . , - - . _ _- .
1 i RCS Loops-MODE S Loops Not Filled B 3.4.8 i i B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.B' RCS Loops-MOCE 5, Loops Not Filled BASES BACKGROUND In MODE 5 with the RCS loops not filled, the primary 1 I function of the reactor coolant is the rempal of decay heat andtransferofthisheattothe'fhutdownfooling(SDC) heat exchangers. Theefteamfenerators(SGs)arenotavailableas a heat sink when the loops are not filled. The secondary function of the reactor coolant is to act as a carrier for ! the soluble neutron poison, boric acid. In MODE 5 with loops not filled, only the SDC Systes can be used for coolant circulation. The number of , rains in operation can vary to suit the operational r .eds. The intent of this LCO is to provide forced flev from at least I one SDC train for decay heat removal and
- ansport and to require that two paths be available to p' avide redundancy for heat removal.
.) APPLICABLE - In MODE 5, RCS circulation is cons # red in determining SAFETY ANALYSES the time available for mitigation of the accidental boron dilution event. The SDC trains provide this circulation.
The flow provided by one SDC train is adequate for decay heat removal and for boron mixing. RCS loops-MODE 5 (lo not filled) have been identified in Gre WE PolRy Sta an ibutors to risk 10CTA g.al.o (flC2. h f h LCO The purpose of this LCO is to require a minimum of two SDC trains be OPERABLE and one of these trains be in operation. An OPERABLE train is one that is capable of transferring heat from the reactor coolant at a controlled rate. Heat cannot be removed via the SDC System unless forced flow is used. A minimum of one running SDC pump meets the LCO requirement for one train in operation. An additional SDC train is required to be OPERABLE to meet the single failure criterion. .) (continued)
"" T B 3.4-35 Rev ,fv,j n h k,0b NDbD kL2h
j 1 l l l l l 1
- 1 i
I i , l l l l RCS Loops-MODE 5 Loops Not Filled
- 3. 8 i
! N BASES _,,
l i % ts I h=rp6 hcqpan O l LCO Note I permits 1 SDC pumps to be de-energized foril~ (continued) G A mwes -wb(n swi)<hing t4m pne train io ar/Jt . The ; circumstances for stopping potn suL pumps a to be limited ' to situations when the outage time is short nd the core 4 outlet temp ature is maintained > 10'F bel saturation i temperatur The Note prohibits boron dilution or draining operations en SDC forced flow is stopped. Note 2 allows one SDC train to be inoperable for a period of l 2 hours provided that the other train is OPERABLE and in operation. This permits periodic surveillance tests to be k performed on the inoperable train during the only time when these tests e f fm fad ssible. { I ee ham raen.= l An OPERAB tTain is composed of, _ ERABLE SDC pum D or D 1 i capable 9rovidino 4eeeed- flow to sa_ uVtmet+1SDC heat e-- - exchange //along with e appropriatf flow and te,pfperature b (instrumep(ation for ntrol, proteefion, and in$feation. T 4 SUL pumps are UFt.KABLL if they are capable of being powered and are able to provide flow,)f required. Rducesh
~ _-
Eat.b d I APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the SDC System. Operation in other MODES is ccvered by: LCO 3.4.4, 'RCS Loops-MDDES 1 and 2'; l LCO 3.4.5, 'RCS Loops-MODE 3'; LCO 3.4.6, 'RCS Loops-MODE 4'; LCO 3.4.7, "RCS Loops-HODE 5, Loops Filled"; LCO 3.9.4, ' Shutdown Cooling (EDC) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.5, ' Shutdown Cooling (SDC) and Coolant l Circulation-Low Water Level" (MODE 6). l ACTIONS Ad g If OfPFequyespSDC train is inoperable, redundancy for heat removal is lost. Action must be initiated immediately to restore a second train to OPERABLE status. The Completion Time reflects the importance of maintaining the availability of two paths for heat removal (continued) 0"^t ~ B 3.4-36 Rev ' ^t/^7/M _ h D h ~ N '> \s2 0
- - . - . . ~ - . - - - - - - . _ . . - - . .. -.- ~. ~.. - _ . - -.
I l I. I l- ) ! 1 l \ I ! ! i ! l l- RCS Loops-MODE 5, Loops Not Filled l B 3.4.8 BASES ACTIONS B.1 and B.2 l- (continued) . If no SDC train-is OPERABLE or in operation, except as t provided in Note 1, all operations involving the reduction ! of RCS boron concentration must be suspended. Action to l , restore one SDC train to OPERABLE status and operation must be initiated iemediately. Boron dilution requires forced circulation for pr.oper mixing and the margin to criticality must not be reduced in this type of operation. The
-immediate Completion Time reflects the importance of l
maintaining operation for decay heat removal. SURVEILLANCE SR 3.4.8.1 g dd. f t REQUIREMENTS This SR requires veri ication every I'2 hours that one SDC l train is in operatio Verification includes flow rate, l temperature, or pump status monitoring, which help ensure ! that forced flow is providing decay heat removal. The i 12 hour Frequency has been shown by operating practice to be sufficient to regularly assess degradation and verify operation is within safety analyses assumptions. SR 3.4.8.2 , , Verification that the required number of trains are OPERABLE l ensures that redundant paths for heat removal are available ' and that additional trains can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. Verification is performed by verifying proper l breaker alignment and indicated power available to the ! required pumps. The Frequency of 7 days is considered i reasonable in view of other administrative controls available and has been shown to be acceptable by operating - experience. l REFERENCES None. i l
. .)
i CEOG STS B 3.4-37 Rev 1, ""/0?/95 0
J & l NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.8 l 4 l l 1 i i I I i l i I
t PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS ; l SPECIFICATION 3.4.8 - RCS Loops - Mode 5, Loops Not Filled l l
- 1. Grammar and/or editorial changes have been made to enhance clarity. No technical intent changes to the Specification are made by this change.
J
- 2. ITS 3.4.8 LC0 Bases contains information that, identifies a SDC pump as either a Containment Spray pump (CS) or a low Pressure Safety Injection !
pump (LPSI). NUREG-1432 does not identify which pumps can be used as a l SDC pump. PVNGS has the capability to use either a LPSI or CS pump to I perform SDC. The information added to the LCO Bases emphasizes this fact. When used for SDC either pump (CS or LPSI) must meet the requirements as ! outlined in the SRs to be considered an Operable SDC pump. The decision to use this information is a deviation from the NUREG-1432 but is consistent with Palo Verde licensing basis.
- 3. NUREG-1432 LC0 3.4.8 allows de-energization of SDC pumps for 515 minutes only for the purpose of switching one train to another. ITS 3.4.8 will l allow de-energization of all SDC pumps for 51 hour per 8 hour period with no stipulation on the reason for SDC pump de-energization. This allows de-energization of all SDC pumps for 51 hour to support plant operations.
This does not lessen the impact or the concern associated with de-energization of all SDC pumps in this condit. ion, it allows more j flexibility in supporting plant operations. The requirement to maintain ; core outlet temperature > 10 F below saturation temperature is still i applicable. It is this requirement that ensures adequate core cooling is I taking place. As long as core outlet temperature is maintained > 10"F below saturation temperature for the time period that flow is secured, the time period with no SDC flow, though relevant, is of no consequence. This also maintains consistency with other similar NUREG Specifications (3.4.5. 3.4.6 and 3.4.7). The removal of the restrictions for stopping all SDC pumps is a deviation from NUREG-1432 but is consistent with Palo Verde ! licensing basis. The Bases has also been revised to be consistent with the LCO.
- 4. Bases revised for consistency with other Bases Sections.
- 5. NOT USED
- 6. NOT USED PALO VERDE - UNITS 1,2, AND 3 1 REV.B
I l i i l l l l l l l l l I PVNGS CTS - 1 SPECIFICATION 3.4.8 I l MARK UP l l l l l l l l l l l I 1 l 1 l
Mumon sAz i A.\ REACTOR COOLANT SYSTEM kI ww . .- .e LOOPS NOT FILLED D /w.h6 n LIMITING CONDITICN FOR OPERATION b,4.% 0. 0.1. 0. Two shutdown cooling loops shall be OPERABLE! and at least one shutdown canlina 1aan shall he in naaratiana . i ( APPLICABILITY: MDDE II loops not filled. ACTION: y. Wth les/ action than thi abovethe76eviredAoops reevired loops to QRRABLEdiamediately initiate } gg corrective con as nossible. I to return OPERABLE status as l f. (6 no shutdown cooling loop in operation, uspend all operations involving a reduction in boron concentratio of the Reactor Coolant
.a D ion T(System requiredand immediately shutdown coolinainitiateloop to coecee44*e operation. a to return the
,, hikdd M -
$URVEILLANCE REQUIREMENTS i I 0.t.1.0.0 At least one shutdown cooling loop shall be determined to be in l operationtapa circuiappa reactarreaniant at a new a ate at nematar than
.'Or Aval tef 3780 aps Atfleast once per 12 hours. ~
j,1 Q*}
=
g2
/
l h ne shutdown cooling loop may be inoperable for b 2 hours for surveillance l testino provided the other shutdown coolina loop is OPERABLE and in eneration. I gM shutdown operations coolingt may are permitted pum@ be deenergized hat would cause for ; t: dM':: 1 5::eof rovided the Re tor Coolant 6 Systemboronconcentration,and(44oreoutletkeeperature s maintained at gA least 10'F below saturation tempers",ure. \ m* 1
=-
p % Ke bh tvirinon "*_*~_**P** l (,,% RbA b%asqreaaca . l wahr vtArm crt. Had A.E v4 4-6 IM l } Palo Verde - Units 1, 2, 3 l
I INSERT FOR CTS 3.4.1.4.2 SURVEILLANCE REQUIREMENTS l (Units 1,2, and 3) INSERT 1 SURVEILLANCE REQUIREMENTS l SURVEILLANCE FREQUENCY SR 3.4.8.2 Verify correct breaker alignment and indicated power 7 days available to the required SDC pump that is not in operation. l l
l
]
DISCUSSION OF CHANGES l SPECIFICATION 3.4.8 i l I 1
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.8 - RCS Loops - Mode 5, Loops Not Filled ADMINISTRATIVE CHANGES A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432. Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station (PVNGS) Improved Technical Specifications (ITS) should be more readable, and therefore understandable, by plant operators as well as other users. During the reformatting and renumbering of the ITS. no technical changes (either actual or interpretational) to the Current Technical Specifications (CTS) were made unless they were identified and justified. Editorial rewording (either adding or deleting) is made consistent with NUREG-1432. During NUREG-1432 development, certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. , l Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design I is already approved by the NRC, adding more detail does not result in a ! technical change. I A.2 CTS LCO 3.4.1.4.2 Footnote
- discusses the requirements whigh allow all SDC l pumps to be de-energized for a period of time. One requirement is that no operations be permitted that would cause dilution of the RCS boron concentration. ITS LC0 3,4.8. Note Ib. changed the word " dilution" to
. " reduction." Both words are used in the same context: reducing boron concentration of the RCS is not acceptable. This change does not alter the LCO intent. Therefore, this is an administrative change with no impact on safety. This change is consistent with NUREG-1432. A.3 NOT USED PALO VERDE - UNITS 1,2, AND 3 1 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CIIANGES SPECIFICATION 3.4.8 - RCS Loops - Mode 5, Loops Not Filled l TECHNICAL CHANGES - HORE RESTRICTIVE M.1 ITS 3.4.8 introduces an additional requirement to the LC0 Note that allows the SDC loops to be de-energized. The restriction added disallows all , draining operations that would further reduce the RCS water volume. CTS I 3.4.1.4.2 has no such additional restriction. This additional restriction ensures that while no forced circulation is taking place, the water volume remains stable. The water volume is the only mechanism of heat dissipation while both shutdown cooling trains are secured. The addition of restrictions constitute a'more restrictive change. This change will not have any adverse affects on plant safety. This change is consistent with NUREG-1432. 1 M.2 ITS SR 3.4.8.2 has been added which requires verification of correct breaker alignment and indicated power available to the required SDC pump l that is not in operation. CTS 3.4.1.4.2 does not contain this requirement. ! Verification that the required pump is Operable ensures that an additional ! SDC train can be placed in operation, if needed, to maintain decay heat removal and reactor coolant circulation. The addition of this SR, for the SDC pump not in operation, constitutes a more restrictive change to PVNGS plant operation. This change is consistent with NUREG-1432. M.3 CTS 3.4.1.4.2. Action b. requires the suspension of all operations involving a reduction in boron concentration of the RCS when no SDC loop i is in operation. The CTS does not provide any Completion Time associated with this Action. ITS 3.4.8. Action B.1 requires suspension of all operations involving a reduction of RCS boron concentration. "immediately." CTS only associates the term "immediately" with Action to return the required SDC loop to operation, not with the Action to suspend all J operations involving a reduction in boron concentration of the RCS. The addition of "immediately" for Completion Time to suspend all operations involving a reduction in boron concentration of the RCS reflects the importance of maintaining operation of decay heat removal. The addition of this requirement constitutes a more restrictive change to PVNGS plant operation. This change is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 2 REV.A
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.8 - RCS Loops - Mode 5, Loops Not Filled TECHNICAL CHANGES - MORE RESTRICTIVE (continued) M.4 CTS 3.4.1.4.2. Footnote *. allows all shutdown cooling pumps to be de-energized for up to one hour. ITS 3.4.8 LC0 Note 1 allows all shutdown cooling pumps to be de-energized for up to 1 hour per 8 hour period. Therefore, the amount of time all shutdown cooling pumps may be
- de-energized has been restricted from less than or equal to one hour to less than or equal to one hour per eight hour period. CTS would permit repeated application of the one hour exemption, indefinitely. This additional restriction on plant operation restricts immediate, repeated application of the one-hour allowance, which would circumvent the intent of the NOTE. Although not explicitly stated in CTS PVNGS operating
; practice complies with the 1 hour per 8 hour period requirement statement in ITS 3.4.8 NOTE. This change provides explicit wording that clarifies ~
PVNGS operating practice in application of this LCO. Placing a limitation on the de-energization of all shutdown cooling pumps will not adversely I affect' plant safety. Placing additional restrictions on plant operation constitutes a more restrictive change to PVNGS operating practice. This ! change is consistent with NUREG-1432. M.5 CTS 3.4.1.4.2. Action b. requires suspension of all operations involving a reduction in boron concentration of the RCS when no SDC loop is in operation. The CTS does not specify an Action if a SDC loop is in ' operation but both loops are not OPERABLE (i.e.. do not meet SRs). ITS 3.4.8. Action B. requires suspension of all operations involving reduction of RCS boron concentration when either no SDC loop is in
; operation @ when the two required SDC trains are inoperable. The addition of this requirement constitutes a more restrictive change to PVNGS plant operation. This change is consistent with NUREG-1432.
TECHNICAL CHANGES RELOCATIONS 4 LA.1 CTS SR 4.4.1.4.2 contains a minimum flow rate that SDC must equal or . exceed. This information is a minimum SDC flow limit and is. therefore, more suitably located in the ITS Bases. Also. CTS 4.4.1.4.2 requires at least one SDC train be verified in operation and " circulating reactor coolant." The requirement to circulate reactor coolant is moved to Section 3.4.8 of the ITS Bases. In addition, both pieces of information do not meet the 10 CFR 50.36 (c) (2) (ii) criteria for inclusion in to the ITS and are, therefore, relocated. PALO VERDE - UNITS 1,2, AND 3 3 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.8 - RCS Loops - Mode 5, Loops Not Filled TECHNICAL CHANGES - RELOCATIONS (continued) Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases Control Program. Any technical changes to the plant procedures will be in accordance with the PVNGS procedure control process. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This information is not required to be in ITS to provide adequate protection of public health and safety. Therefore, relocation of this information to a Licensee Controlled document is acceptable and is consistent with NUREG-1432. TECHNICAL CHANGES LESS RESTRICTIVE None I 1 l l l l l PALO VERDE - UNIT 31,2, AND 3 4 REV,A
i I i 1 1 NO SIGNIFICANT HAZARDS CONSIDERATION , SPECIFICATION 3.4.8 , 1 1
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.8 - RCS Loops - Mode 5, Loops Not Filled ADMINISTRATIVE CHANGES (ITS 3.4.8 Discussion of Changes Labeled A.1. A.2 and A.3) Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3. is converting to the ITS as outlined in NUREG-1432. " Standard Technical Specifications. Combustion Engineering Plants." The proposed changes involve the reformatting, renumbering, rewording of the Technical Specifications (TS) and Bases with no change in intent, and the incorporation of current operating practices consistent with NUREG-1432. These changes, since they do not involve technical changes to the Current TS (CTS), are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. - Does the proposed change involve a significant increase in the I probability or consequences of an accident previously evaluated? The proposed changes involve reformatting. renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above. involves no technical changes to the CTS. Specifically. there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432. certain wording preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 i Rev.A
1 NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.8 - RCS Loops - Mode 5, Loops Not Filled 1 ADMINISTRATIVE CHANGES (ITS 3.4.8 Discussion of Changes Labeled (A.1, A.2 and A.3) (continued) l Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes do not involve a physical alteration of the plant (no i new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or ! different kind of accident from any accident previously evaluated. 4 i Standard 3. Does the proposed change involve a significant reduction in a margin of safety? i
- The proposed changes involve reformatting, renumbering, and rewording of the CTS. along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432.
The proposed changes are administrative in nature and will not involve any technical changes. The proposed changes will not reduce a margin of safety , because they have no impact on any safety analysis assumptions. Also. because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. d 4 e i PALO VERDE - UNITS 1,2, AND 3 2 Rev.A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.8 - RCS Loops - Mode 5, Loops Not Filled TECHNICAL CHANGES MORE RESTRICTIVE (ITS 3.4.8 Discussion of Changes Labeled H.1, M.2, H.3 and M.4) Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). l Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. This particular NSHC is for the changes labeled " Technical Changes - More Restrictive" described in the specific Discussion of Changes listed above. The proposed changes incorporate more restrictive changes into the CTS by either making current requirements more stringent or adding new requirements which currently do not exist. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards l consideration if operation of the facility, in accordance with a proposed ' amendment, would not 1) involve a significant increase in the probability or i consequences of an accident previously evaluated: 2) create the possibility of , a new or different kind of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes provide more stringent requirements than previously existed in the CTS. The more stringent requirements will not result in operation that will increase the probability of initiating an analyzed event. If anything, the new requirements may decrease the probability or consequences of an analyzed event by incorporating the more restrictive changes discussed in the specific Discussion of Changes listed above. These changes will not alter assumptions relative to mitigation of an accident or transient event. The more restrictive requirements will not alter the operation and will continue to ensure process variables, structures, systems, or components are maintained consistent with safety analyses and licensing basis. These changes have been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident evaluated. PALO VERDE - UNITS 1,2, AND 3 3 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.8 - RCS Loops - Mode 5, Loops Not Filled l TECHNICAL CHANGES MORE RESTRICTIVE (ITS 3.4.8 Discussion of Changes Labeled H.1, H.2, M.3 and M.4) (continued) i Standard 2. Does the proposed change create the possibility of a new or l different kind of accident from any accident previously evaluated? ' Making existing requirements more restrictive and adding more restrictive requirements to the CTS will not alter the plant configuration (no new or ) different type of equipment will be installed) or change the methods governing normal plant operation. These changes do impose different requirements. However, they are consistent with the assumptions made in the safety analyses, licensing basis, and NUREG-1432. Therefore, these changes will not create the possibility of a new or different kind of . accident from any accident previously evaluated. I Standard 3. - Does the proposed change involve a significant reduction in a l margin of safety? The proposed changes provide more stringent requirements than previously existed in the CTS. An evaluation of these changes concluded that adding these more restrictive requirements either increases or has no impact on the margin of safety. The changes provide additional restrictions which may enhance plant safety. These changes maintain requirements of the safety analysis, licensing basis, and NUREG-1432. As such, no question of safety is involved. Therefore, these changes will not involve a significant reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 4 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.8 - RCS Loops - Mode 5, Loops Not Filled l l TECHNICAL CHANGES RELOCATIONS (ITS 3.4.8 Discussion of Changes Labeled LA.1) i 1 Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed changes, since detail is being removed from the CTS to a Licensee ; j Controlled Document. are less restrictive. The descriptions of these changes are ' in the Discussion of Changes listed above. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to i I an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed I amendment, would not 1) involve a significant increase in the probability or , consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these I standards as they relate to this amendment request follows: !
Standard 1.- Does the proposed change involve a signif'icant increase in the ! probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes do not result in any hardware changes or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee ' Controlled Document containing the relocated requirements will be maintained using the provisions of 10 CFR 50.59 or other specified control processes and is subject to the change control process in the Administrative Controls Section of the ITS. Since any changes to a Licensee Controlled Document will be evaluated. no increase in the probability or consequences of an accident previously evaluated will be allowed. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 5 Rev. A
. ~ _ - . .. - . . .-
NO SIGNIFICANT HAZARDS CONSIDERATION , ITS Section 3.4.8 - RCS Loops - Mode 5, Loops Not Filled ~ TECHNICAL CHANGES - RELOCATIONS (ITS 3.4.8 Discussion of Changes Labeled LA.1) (continued) Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? 4 The p oposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not alter the plant configuration (no new or different type of equipment will be installed) or change the ; methods governing normal plant operation. These changes will not impose different requirements and adequate control of information will still be , maintained. These changes will not alter assumptions made in the safety . analysis or licensing basis. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? l l The proposed changes relocate requirements from the CTS to a Licensee l Controlled Document. These changes will not reduce a margin of safety ' since they have no impact on any safety analysis assumptions. In addition, the requirements to be transposed from the CTS to the Licensee Controlled Document. are the same as the CTS. Since any future changes to this Licensee Controlled Document will be evaluated per the requirements of 10 CFR 50.59, or other specified control processes. no reduction (significant or insignificant) in a margin of safety will be allowed. Therefore, these changes will not involve a significant reduction in a-margin of safety. The NRC review provides a certain margin of safety, and although t;1is review will no longer be performed prior to submittal, the NRC still inspects the 10 CFR 50.59 process. The proposed changes are consistent with NUREG-1432 which was approved by the NRC Staff. The change controls for proposed relocated details and requirements provide an acceptable level of regulatory authority. Revising the CTS to reflect the approved level of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore, revising the CTS to reflect the NRC accepted level of detail and requirements ensures no reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 6 Rev. A
A--- - - - J 4m.4e - , m.= +- J d i 4 C I CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.9 4 MARK UP i i l l 1
]
I , 1 l 1 a l l et
- f 1
I J l j i l I Pressurizer 3.4.9 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.9 Pressurizer 2 cT190 O O L S o*lO l ng3,%,h LCO 3.4.9 The pressurizer shall be OPERABLE wit : 1 i
- a. Pressurizer water level 4 30;%,.nd[
I l b. Two groups of pressurizer heaters OPERABLE with the i capacity of each group 2 MG3- kW Kand capable of lici.;g powered from an emergene owersupp1(. APPLICABILITY: MODES 1, 2, and 3. 4
^ --
t1' l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ) i .d.b,l.b A. Pressurizer water A.1 Be n MODE 3 with 6 hours l level not within reactor trip breakers open. limit. l 8 A.2 Be in MODE 4. {l2 I I
.3.4.D.I.CkACI)B. One required group of B.1 Restore required 72 hours i pressurizer heaters group of pressurizer inoperable. heaters to OPERABLE l status.
! a h 3,3, \,a C. Required Action and associated Completion C.1 Be in MODE 3. 6 hours i I . Time of condition B E i C.2 Be in MODE 4. [12 rs f bE6_- un.ts, \.2.s _;_; .:: 3.4-18 S Rev 4. ^,,ivi m I f
R i l INSERT FOR ITS 3.4.9 APPLICABILITY NOTE , (Units 1,2, and 3) INSERT 1
---- ---- -- NOTE -.
The pressurizer water level limit does not apply during: i a. THERMAL POWER ramp > 5% RTP per minute; or l b. THERMAL POWER step >10% RTP. l i i l . 4 k i I
. - - . . . - . - - . _ - . ~ . ~ . - _- . = -
i I i l ( i i I , l Pressurizer 3.4.9 l I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY d.d,D.I. k SR 3.4.9.1 12 hours Verifyhessurizer d5TCLZs water %*level 11k. Aqg SR 3.4.9.2 Verify capacity of each required group of 92 days 9.71 b pressurizer heaters 2 4444} kW. { l b_ SR 3.4.9 Verify require ressurizer heater re .[18] mon , capable of ng powered from an ergency i s - power sup .
~
I l 1
% cat- nhs \, L 5 A cieG 3i5- 3.4-19 Rev 2, - ,0'/95
l l I I 1 l l 1 CE STS ; NUREG-1432 REV.1 SPECIFICATION 3.4.9 BASES MARK UP j l j 1 l l l i i .
l
)
i i Pressurizer ! B 3.4.9 b l l B 3.4 REACTOR COOLANT SYSTEMS (RCS) LI.O b.O "irmA2.u dr.[e.b %du -
' ^
B 3.4.9 Pressurizer BASES j BACKGROUND The pressurizer provides a point in the RCS where liquid and vapor are maintained in equilibrium under saturated conditions for pressure control purposes to prevent bulk l boiling in the remainder of the RCS. Key functions include maintaining required primary system pressure during steady l state operation and limiting the pressure changes caused by l I reactor coolant thermal expansion and contraction dur ng normal load transients. , g g,g )7 The pressure control compone ts adifressed by this LCO include the pressurizer wat level, the required heaters (s i i and their backup heater con rols, and emergency power - verd6 l supplies. Pressurizer saf y valves and pressurizer I [p c6Dersted rem'et urves (rsaw are addressed by LCO 3.4. O, i i
" Pressurizer Safety Valvesy n CO 3.4.)(gPressuri r )
b ocasd N " " N et (PQMUJ respectively. P (, l i The maximum w has been established to ensure that a liquid to vapor interface exists to permit RCS pressure control, using the sprays and heaters during normal operation and proper pressure response for anticipated , design basis transients. Th water level limit serves two l hu,,1, a#ra - m ._ .- e Pressure control during normal operation maintains a. subcooled reactor coolant in the loops and thus in the l preferred state for heat transport; and ' b. By restricting the level to a maximum, expected I transient reactor coolant volume increases (pressurizer insurge) will not cause excessive level l changes that could result in degraded ability for 1-l \ pressure rontrnt - 5 0,h,b,\j ' ~ 's; h l
' The maximu wa er we mit permits pressure control equipment to function as designed. The limit preserves the steam space during normal operation, thus, both sprays and heaters can operate to maintain the design operating pressure. The level limit also prevents filling the pressurizer (water solid) for anticipated design basis transients, thus ensuring that pressure relief devices (continued)
Rev 4.r-e+teffG4 (
~ ^^
^T^ B 3.4-38
% w on M z# g
l l f l M m nirn>m :Aeody .sbh. c.m4.r W.41 in 4(s. pra wrw-osems ym.xim, hamre, deh s l Ort r esb SO OChtton.OY , rest % f(Gw/L Pressurizer i CMrok (trhath Coueted OM&r"b putMbt, l 6,ch wJf act.ur d Ake. %r.%rs were.orsnytab
) BASES BACKGROUND (80lk-op pressurizer safety valves) can control pressure by (continued) steam relief rather than water relief. If the level limits were exceeded prior to a transient that creates a large pressurizer insurge volume leading to water relief, the l maximum RCS pressure might exceed the Safety Limit of
! 750 psi o, The requirement to have two groups of pressurizer heaters ensures that RCS pressure can be maintained. The pressurizer heaters maintain RCS pressure to keep the reactor coolant subcooled. Inability to control RCS pressure during natural circulation flow could result in loss of single phase flow and decreased capability to remove ! core decay heat. l APPLICABLE in MODES 1, 2, and 3, the LCO requirement for a steam bubble SAFETY ANALYSES is reflected implicitly in the accident analyses. No safety analyses are performed in lower MODES. All analyses I perfemed from a critical reactor condition assume the exiswee of a steam bubble and saturated conditions in the l prest rizer. In making this assumption, the analyses I negl..; the small fraction of nonco ensable gases nonnally present, g i Safety analyses presented in th SAR do not take credit for pressurizer heater operation; however, an implicit initial condition assumption of the safety analyses is that the RCS l is operating at normal pressure. Altaough the heaters are not specifically used in accident analysis, the need to maintain subcooling in the long term during loss of offsite power, as indicated in NUREG-0737 (Re'. 1), is the reason for their inclusion. The requirement for emergency power supplies is based on l P'.JREG-0737 (Ref.1). The intent is to keep the reactor I coolant in a subcooled condition with natural circulation at hot, high pressure conditions for an undefined, but t l extended, time period after a loss of offsite power. While loss of offsite power is a coincident occurrence assumed in the accident analyses, maintaining hot, high pressure conditions over an extended time period is not evaluated in the accident analyses. (continued) t
'N m B 3.4-39 Rev Ir-M/07/L OO\ O0C.,
- 0k% \), h h
I i ! I l l l l I l i l i I . I i- Pressurizer l B 3.4.9 l BASES l l APPLICABLE The pressurizer satisfies Criterion 2 and Criterion 3 of(SP SAFETY ANALYSES (_pKL Fo}fi"y Ma tysnerI bGK f*C.'fdo (,C.l(2T. ( u,,,3, 5
! (continued) l Z) o ond f 54% (, l LCO The LC0 requiremen r e zer o be OPERABLE with water level +f4eM ensures that a steam bubble exists.
Limiting the maximum operating water level preserves the ! steam space for pressure control. The LCO has been established to minimize the consequences of potential overpressure transients. Requiring the presence of a steam bubble is alco consistent w tr.sbnal 'ytical assumptions. 4 The LCO requires two groupsp RABLE pressurizer heaters, e' ,h with a capacity it -{460 kW and capable of being l powered from an emergency power supplyg. The minimum heater l capacity required is sufficient to maintain the RCS near i normal operating pressure when accounting for heat losses l through the pressurizer insulation. By maintaining the 1 pressure near the operating conditions, a wide subcooling marnin to saturation can be obtained in the inces. ct d' sign lue f [1 ) kW s riv f m e se f hea rs r ed 12. kW e n. Ihc amo t ed d t int n pr sur is d ende o the mbi nt ea lo se i APPLICABILITY The need for pressure control is most pertinent when core l heat can cause the greatest effect on RCS temperature resulting in the greatest effect on pressurizer level and RCS pressure control. Thus, Applicability has been designated for MODES I and 2. The Applicability is also provided for MODE 3. .The purpose is to prevent solid water RCS operation during heatup and cooldown to avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup. The LCO does not b apply to MODE 5 (Loops Filled) because LCO 3.4.LP- 'I ~ l
- Temperature Overpressure Protection (LTOP) System," applies I The LC0 do not acolv to fiOQ Q_5 and A wit .u.t_ial loop r
4 operation bo,o %9e h23 e oddadl)o edea. % te e paarsee 6 s encyA us,aa.dsdmo t*uthem_ opetoked + w ow4.ho* a WUJML ltMLA In MODES , , and 3, there is tne need to maintain t e ran9 merans et 7 5'lo per availability of pressurizer heaters capable of being power ,v4e. e, oTgAmh.faser from an emergency power supply. In the event of a loss of ,N ,mj p g pp, offsite power, the initial conditions of these MODES gives (continuid) g,y g n,,m,u
-Son sTt B 3.4-40
' bed 4.,,- O M b (2,$
Pressurizer B 3.4.9 5 BASES APPLICABILITY the greatest demand for maintaining the RCS in a hot (continued) pressurized condition with loop subcooling for an extended period. ForH005S,5,or6,itisnotnecessarytocontrol pressure (by heattrs) to ensure loop subcooling for heat transfer when the Shutdown Cooling System is in service and therefore the LCO is not applicable. ACTIONS A.] and A.2 With pressurizer water level not within the limit, action must be taken to restore the plant to operation within the bounds of the safety analyses. To achieve this status, the unit must be brought to MODE 3, with the reactor trip breakers open, within 6 hours and to MODE 4 within O(, X12Y hours. This takes the plant out of the applicable MODE 3 and restores the plant to operation within the bounds of the safety analyses. Six hours is reasonable, based on operating experience, to reach MODE 3 from full power in an orderly manner and without cha11engin.g plant systems. Further pressure and
) temperature reduction to MODE 4 brings the plant to a H0DE -
where the LCO is not applicable. The 12 hour time to reach the nonapplicable MODE is reasonable based on operating axperience for that evolution. IL1 If one required group of pressurizer heaters is inoperable, restoration is required within 72 hours. The Completion Time of 72 hours is reasonable considering that a demand caused by loss c' offsite power would be unlikely in this period. Pressure control may be maintained during this time using normal station powered heaters. C.1 and C.2 If one required group of pressurizer heaters is inoperable and cannot be restored within the allowed Completion Time of Required Action B.1, the plant must be brought to a MODE in l which the LCO does not apply. To achieve this status, the l l plant must be brought to MODE 3 within 6 hours and to MODE 4 I
) (continued) r B 3.4-41 Rev 17 v*/wi/ n
% vcede -onk tg A
i i i i Pressurizer B 3.4.9 , BASES ACTIONS C.1 and C.2 (continued) 12Khours. The Completion Time of 6 . hours is within(ble, reasona based on operating experience, to reach MODE 3 j from full power in an orderly manner and without challonging gafety systems. Similarly, the Completion Time of 4 112),hoursisreasonable,basedonoperatingexperience,to I reach MODE 4 from full power in an orderly manner and without challenging plant systems. i l SURVEILLANCE SR 3.4.9.1 , R(QUIREMENTS This Surveillance ensures that during steady state CbC. LA.E.) operation, pressurizer water level is maintained below the nominal upper limit to provide a minimum space for a steam bubble. The Surveillance is performed by observing the indicated level. The 12 hour interval has been shown by d operating practice to be sufficient to regularly assess the level for any deviation and verify that operation is within 4 safety analyses assumptions. Alarms are also available for f early detection of abnormal level indications. I i I SR 3.4.9.2 , L- l The Surveillance is satisfied when the power supplies are demonstrated to be capable of producing the minimum power and the associated pressurizer heaters are verified to be at their design rating.. (This may be done by testing the power supply output and by performing an electrical check on heater element continuity and resistance.) The Frequency of - 92 days is considered adequate to detect heater degradation and has been shown by operating experience to be acceptable.
/R 3.4.9.3 ly This SR is no pp11 cable if the aters are perman a powered by power supplies. \ l This S veillance demonstr es that the heat , can be ;
man ly transferred to d energized by e rgency power j s lies. The Freau y of (18] months based on a f (continued) B 3.4-42 Rev ;, M/0'/91 "O" "?!-
% bde. -Onno \,23 A
l l i l Pressurizer B 3.4.9 l 5 BASES l SURVEILLANCE S/3.4.9.3 (cont ued) / ' REQUIREMENTS ./
/typicalfuelc e and industry ccepted practice This is {
consistent w similar verif ations of emerce y power, a REFERENCES 1. NUREG-0737. November 1980. N
)
t i I w o 63c 4_-t a., -s -,, N te l,2i b
-- B 3.4-43 b
Rev 0, 0:,;7,-, I
4 l 4 1 1 1 1 i I NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.9 i l
PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.9 - Pressurizer L i 1. Performance of NUREG-1432 SR 3.4.9.3, as outlined in the NUREG Bases, is , not required because PVNGS pressurizer heaters are permanently powered by 1E power supplies. This change is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO.
- 2. NUREG-1432. 3.4.9. makes no reference to pressurizer minimum level in the Bases. ITS 3.4.9 will use the Bases from CTS 3.4.3.1 that discusses I
pressurizer minimum level. This is to be done since pressurizer minimum l water level is part of the LCO. The use of the CTS Bases discussion about 1 minimum pressurizer level is consistent with PVNGS licensing basis. The ,
- Bases has also been revised to be consistent with the LCO.
- 3. NUREG-1432. LCO 3.4.9 Bases, discusses the design characteristics of the pressurizer heaters. The discussion will be deleted in ITS 3.4.9 Bases since the description is not applicable to PVNGS pressurizer heaters. The removal of the discussion concerning pressurizer heater design is a 4 deviation from NUREG-1432 but is consistent with PVNGS licensing basis.
- 4. ITS 3.4.9 Applicability contains a Note that clarifies when pressurizer level is applicable. The use of this Note serves to eliminate unnecessary l entry into this LC0 when pressurizer level is transitory due to plant '
evolutions. NUREG-1432. SR 3.4.9.1 requires verification of pressurizer level at steady-state conditions (Bases SR 3.4.9.1). Use of a Note in the l Applicability of ITS 3.4.9 that excludes pressurizer level limits based on
- transient conditions maintains consistency between the SR and i
Applicability. The pressurizer pressure LC0 3.4.1 contains the same 4 exclusion for similar reasons. A power change > 5% RTP per minute or a a step change > 10% RTP already defined in NUREG-1432 LC0 3.4.1 as a short term operational transient. serves as the transition point for pressurizer level Applicability. The addition of this information is a deviation from l NUREG-1432 but is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO. ! 5. Grammar and/or editorial changes have been made to enhance clarity. No : technical or intent changes to the Specification are made by this change.
- 6. De plant specific titles, nomenclature, number, parameter /value, refarence, system description, system design, operating practices or e.alysis description was used (additions, deletions, and/or changes are included). Plant Specific parameters / values were directly transferred from the CTS to the ITS. PVNGS does not have PORVs.
- 7. Bases revised for consistency with other Bases Sections.
PALO VERDE - UNITS 1,2, AND 3 1 REV.A
t l PVNGS CTS SPECIFICATION 3.4.9 MARK UP i l
\C.Ciki(_:>rs b ,4.9 j
REACTOR COOLANT SYSTEM hD) A'\ , 3,4 94-4-9 PRESSURIZER V st::ennt:
' "??!M 00 O!T!0" F04-OPERATION- E ' LChhA.Q N
f.O0. 0.1The pressur level of* greater r shall be OPERABLE with a sinimum et tatewater) ' maximum :t:::y . t: water level of less tn or equal to 27% 4'"--t:0 kni (d 5 ::th-feeQ and a
't,00 c tic feet) and at least two groups of or equal to 565 7 4*d4eeta he 4
l
,7 being powered r
' - ~ " '- - e a essurizer heaters acable of APPLICABILITY:
c m ex"Au % c having &Jinimus acit of 5 kW.
, an EL9 Y -
ACTION: - caer . [k,) Wi G uniy-one group T3 -
- AOL;, restore ...; ete n re M re; pressuriger heaters 318d, W:72hours /or be in at N;;t t.;e_grouptto_0PJRAB1E_Ltatus within.
gin NOT $HUTDOWN within eastthe HOT STANDBY followinc within/ the next 6 hours and 3 6 hours. -- g g With the pressurizer :th:-.; ::n:;; nth, restore the pressurizer to r ' CPERABLE reactor trip breakers status op .;i Mr. 'M within 6 hours and in NOT SHUT WN within
, he following 6 hours. I ~
$URVEILLANCE REQUIREMENTS R\
h S A R \ i.t.imits .1.1 k idd)
- at least once per 12 hours.The pressurizer water volume shall be :tedh: to be within t-%M _/
0.0.^,.1.2- The capacity of th: NN1 hall be verified to_be at least 125 kW1 at 1 ast once_cer 92 days.:::"l required group k.4.3.1.3 The emergency power suppl demonstrated OPERABLE at le e pr'essurizer heaters shall be ) Engineered Safety F e per 18 months by verifying that on an offsite pow - Actuation test signal concurrent with a of-K The pressurizer heaters are auto i power sources, and y shed from the emergency g
' .I K The pre y from er theheaters controlcan room.be' rec'onnected to their te ve buses 3/4 4-9 Palo Verde - Units 1, 2, 3
l INSERT FOR CTS 3.4.3.1 i APPLICABILITY NOTE i (Units 1,2, and 3) INSERT 1
]
1 NOTE . . The pressurizer water level limit does not apply during: 1 J
- a. THERMAL POWER ramp > 5% RTP per minute; or
- b. THERMAL POWER step >10% RTP.
.l 9
h i DISCUSSION OF CHANGES SPECIFICATION 3.4.9 I i j i a a 4 1 s d t 1
PALO VERDE ITS CONVERSION 1 DISCUSSION OF CHANGES 1 SPECIFICATION 3.4.9 - Pressurizer i ADMINISTRATIVE CHANGES i A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432 Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station { 1
.(PVNGS) Improved Technical Specifications (ITS) should be more readable. I and therefore understandable. by plant operators as well as other users. I During the reformatting and renumbering of the ITS. no technical changes l (either actual or interpretational) to the Current Technical Specifications !
(CTS) were made unless they were identified and justified.
)
Editorial rewording (either adding or deleting) is made consistent with NUREG-1432. During NUREG-1432 development, certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. Additional- information has also been added to more fully describe each l subsection. This wording is consistent with NUREG-1432. Since the design ! is already approved by the NRC. adding more detail does not result in a , technical dange. I A.2 CTS 3.4.3.1 specifies minimum and maximum pressurizer steady state water i levels. ITS LC0 3.4.9 specifies minimum and maximum pressurizer water levels with a Note stating that the pressurizer water level limit does not apply during: e THERMAL POWER ramp > 5% RTP per minute: or e THERMAL POWER step > 10% RTP. The Note in ITS LC0 3.4.9 clarifies the transient (or non-steady state) conditions when the pressurizer water level limit does not apply, which is consistent with CTS 3.4.3.1 which specifies the steady state water level limits. The use of this Note in ITS serves to eliminate unnecessary entry into the ACTIONS of this LC0 when pressurizer water level is transitory due to plant evolutions. This is consistent with CTS 3.4.3.1 which specifies steady state water levels and thus eliminates unnecessary entry into the LCO ACTIONS when pressurizer water level is transitory due to plant evolutions. NUREG-1432. SR 3.4.9.1 requires verification of pressurizer level at steady-state conditions (Bases SR 3.4.9.1). Use of a Note in the Applicability of ITS 3.4.9 that excludes pressurizer level limits based on transient conditions maintains consistency between the SR and Applicability. The pressurizer pressure ITS LCO 3.4.1 contains the same exclusion for similar reasons. A power change > 5% RTP per minute or a step change > 10% RTP, already defined in NUREG-1432 LCO 3.4.1 as a short term operational transient, serves as the transition point for pressurizer level Applicability. The addition of the clarifying Note in ITS LCO 3.4.9 is consistent with PVNGS licensing basis (CTS). PALO VERDE - UNITS 1,2, AND 3 1 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.9 - Pressurizer TECHNICAL CHANGES MORE RESTRICTIVE M.1 CTS 3.4.3.1 Action b allows 1 hour to restore pressurizer level and then, i if pressurizer level is not restored within 1 hour, an additional 6 hours
; to reach Mode 3. ITS 3.4.9. Action A allows a Completion Time of 6 hours 4
to reach Mode 3. Removal of the of the 1 hour allowance to restore , pressurizer level constitutes a more restrictive change to PVNGS plant ! operation. This is acceptable because ITS LCO 3.0.2 states, "If the LC0 is met or is no longer applicable prior to expiration of the specified Completion Time (s), completion of the Required Action (s) is not required, I unless otherwise stated." This allows pressurizer level to be restored, if i possible, anytime during the Completion Time, which would allow LCO exit. i
- This change is consistent with NUREG-1432.
l TECHNICAL CHANGES - RELOCATIONS LA.1 CTS SR 4.4.3.1.3 tests the emergency power supply for the class pressurizer : heaters. NUREG SR 3.4.9.3 only requires the class heater power emergency ! power supply to be tested if they are not permanently powered by 1E power l i supplies. PVNGS class pressurizer heaters are permanently powered by 1E l
- power. therefore, this Surveillance is relocated. This surveillance is not l
! required to determine the Operability of a system, component or structure, l
- and therefore is being relocated to a Licensee Controlled Document j (Technical Requirements Manual [TRM]). l l Any changes to the TRM will be in accordance with 10 CFR 50.59. This l provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This requirement is not required 1
- to be in ITS to provide adequate protection of public health and safety.
Therefore, relocation of this requirement to a Licensee Controlled Document
- is acceptable and is consistent with NUREG-1432.
c 4 7
- PALO VERDE - UNITS 1,2, AND 3 2 REV.B
Q PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.9 - Pressurizer i TECHNICAL CHANGES - RELOCATIONS (continued) ! LA.2 CTS 3.4.3.1 uses the phrase " steady state" in the LC0 for pressurizer level. The use of this phrase serves to eliminate unnecessary entry into this LC0 when pressurizer level is transitory due to_ piant evolutions. NUREG-1432, SR 3.4.9.1 requires verification of pressurizer level at steady-state conditions (Bases SR 3.4.9.1). This information will be placed
- in the associated Bases Sections to provide clarification. This terminology
, maintains consistency between the SR and Applicability. This information i details the specifics of when this LC0 is applicable. This information is i relocated to a Licensee Controlled Document (i.e. Bases Section). ! l i Any changes to the Bases will be in accordance with Chapter 5.0 Bases ! i Control Program. This provides an equivalent level of control and is an . administrative change with no impact' on the margin of safety. This I requirement is not required to be in ITS to provide adequate protection of ; public health and safety. Therefore relocation of this requirement to a ; Licensee Controlled Document is acceptable and is consistent with H s NUREG-1432. LA.3 CTS LCO 3.4.3.1 specifies that " indicated level" when defining pressurizer Operability as it pertains to pressurizer level. All val,ues in ITS are indicated values unless otherwise specified. This information, less the word " indicated" is moved to ITS 3.4.9 Bases Section. i Any changes to the Bases will be in accordance with ITS Chapter 5.0 Bases i Control Program. This provides an equivalent level of control and is an > administrative change with no impact on the margin of safety. This infrrmation is not required to be in ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to a Licensee Controlled Document is acceptable and is consistent with NUREG-1432. TECHNICAL CHANGES - LESS RESTRICTIVE None s PALO VERDE - UNITS 1,2, AND 3 3 REV.B
e NO SIGNIFICANT HAZARDS CONSIDERATION , SPECIFICATION 3.4.9 l 1 I
NO SIGNIFICANT HAZARDS CONSIDERATION 9 ITS Section 3.4.9 - Pressurizer 1 l
@MINISTRATIVE CHANGES I (ITS 3.4.9 Discussion of Changes Labeled A.1) j i
Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3. is converting to the ITS as outlined in NUREG-1432. " Standard Technical Specifications. Combustion Engineering Plants." The proposed changes involve the reformatting. renumbering rewording of the Technical Specifications (TS) and Bases with no change in intent. and the incorporation of current operating practices consistent with NUREG-1432. These changes since they do not involve technical changes to the Current TS (CTS), are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment. would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1.- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432. certain wording preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 1 Rev.A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.9 - Pressurizer ADMINISTRATIVE CHANGES S (ITS 3.4.9 Discussion of Changes Labeled A.1) (continued) i
- Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
I
- The proposed changes involve reformatting. renumbering, and rewording of the CTS. along with the incorporation of PVNGS current operating practices and other changes. as discussed, in order to be consistent with NUREG-1432.
The proposed changes do not involve a. physical alteration of the plant (no new or different type of equipment will be installed) or change the methods
- governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. ,
Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3. - Does the proposed change involve a significant reduction in a
- margin of safety?
a The proposed changes involve reformatting, renumbering, and rewording of the CTS along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes are administrative in nature and will not involve any. technical changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. i PALO VERDE - UNITS 1,2, AND 3 2 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION l ITS Section 3.4.9 - Pressurizer I l TECHNICAL CHANGES - MORE RESTRICTIVE l (ITS 3.4.9 Discussion of Changes Labeled M.1) i I Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS), ) Units 1, 2, and 3 is converting to the ITS as outlined in NUREG-1432. This : particular NSHC is for the changes labeled " Technical Changes - More Restrictive" described in the specific Discussion of Changes listed above. The proposed changes incorporate more restrictive changes into the CTS by either making current requirements more stringent or adding new requirements which currently do not exist. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to i an operating license for a facility involves a no significant hazards I consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or i consequences of an accident previously evaluated: 2) create the possibility of i a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard _Lf - Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes provide more stringent requirements than previously existed in the CTS. The more stringent requirements will not result in operation that will increase the probability of initiating an analyzed event. If anything, the new requirements may decrease the probability or consequences of an analyzed event by incorporating the more restrictive changes discussed in the specific Discussion of Changes listed above. These changes will not alter assumptions relative to mitigation of an i accident or transient event. The more restrictive requirements will not alter the operation and will continue to ensure process variables, structures, systems, or components are maintained consistent with safety analyses and licensing basis. These changes have been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident evaluated. PALO VERDE - UNITS 1,2, AND 3 3 Rev. A y
_ - . . _ _ _ _ _ .. . _ . _. ~ _ _ _ _ _ NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.9 - Pressurizer TECHNICAL CHANGES HORE RESTRICTIVE (ITS 3.4.9 Discussion of Changes Labeled H.1) (continued) , Randard 2.- Does the proposed change create the possibility of a new or
- different kind of accident from any accident previously evaluated?
1 l
- Making existing requirements more restrictive and adding more restrictive i recuirements to the CTS will not alter the plant configuration (no new or !
different type of equipment will be installed) or change the methods l governing normal plant operation. These changes do impose different i requirements. However, they.are consistent with the assumptions made in the safety analyses. licensing basis and NUREG-1432. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
- Standard 3. Does the proposed change involve a significant reduction in a margin of safety?
- The proposed changes provide more stringent requirements than previously i existed in the CTS. An evaluation of these changes concluded that adding
! these more restrictive requirements either increases or has no impact on the margin of safety. The changes provide additional restrictions which may enhance plant safety. These changes maintain requirements of the
- safety analysis, licensing basis, and NUREG-1432. As such, no question of a safety is involved. Therefore, these changes will not involve a significant reduction in'a margin of safety.
l PALO VERDE - UNITS 1,2, AND 3 4 Rev. A
- . .- . - . - - =- . - - . . . -.
NO SIGNIFICANT IIAZARDS CONSIDERATION ITS Section 3.4.9 - Pressurizer TECHNICAL CHANGES RELOCATIONS
- (ITS 3.4.9 Discussion of Changes Labeled LA.1. LA.2, and LA.3) i Ar4 zona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS),
Units 1, 2. and 3 is converting to the ITS as outlined in NUREG-1432. The
- proposed changes, since detail is being removed from the_ CTS to a Licensee Controlled Document, are less restrictive. The descriptions of these changes are in the Discussion of Changes listed above.
The Commission has provided standards for determining whether a significant j hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed , amendment, would not 1) involve a significant increase in the probability or , consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or . 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows: Standard 1. - Does the proposed change involve a signif'icant increase in the probability or consequences of an accident previously evaluated?
- The proposed changes relocate requirements from the CTS to a Licensee
. Controlled Document. These changes do not result in any hardware changes or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee Controlled ' Document containing the relocated requirements will be maintained using the provisions of 10 CFR 50.59 or other specified control processes and is subject to the change control process in the ] Administrative Controls Section of the ITS. Since any changes to a Licensee Controlled Document will be evaluated, no increase in the probability or consequences of an accident previously evaluated will be allowed. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. 4 PALO VERDE - UNITS 1,2, AND 3 5 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.9 - Pressurizer TECHNICAL CHANGES - RELOCATIONS (ITS 3.4.9 Discussion of Changes Labeled LA.1, LA.2, and LA.3) (continued) Standard 2.-- Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? 4 The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes will not impose different requirements and adequate control of information will still be maintained. These changes will not alter assumptions made in the safety analysis or licensing basis. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3. Does the proposed change involve a significant reduction in a margin of safety? : The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not reduce a margin of safety l since they have no impact on any safety analysis assumptions. In addition. 1 the requirements to be transposed from the CTS to the Licensee Controlled , Document are the same as the CTS. Since any future changes to this i Licensee Controlled Document will be evaluated per the requirements of 10 CFR 50.59, or other specified control processes, no reduction (significant or insignificant) in a margin of safety will be allowed. Therefore, these changes will not involve a significant reduction in a margin of safety. The NRC review provides a certain margin of safety, and although this review will no longer be performed prior to submittal, the NRC still inspects the 10 CFR 50.59 process. The proposed changes are consistent with NUREG-1432, which was approved by the NRC Staff. The change controls for proposed relocated details and requirements provide an acceptable level of regulatory authority. Revising the CTS to reflect the approved level of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore, revising the CTS to reflect the NRC accepted level of detail and requirements ensures no reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 6 Rev.A sT
CE STS .: NUREG-1432 REV.1 . I SPECIFICATION 3.4.10 MARK UP 1 I i I 4 l i l l
1 1 h . Pressurizer Safety W1 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Pressurizer Safety Valve -M6CE.b I . C. c^d ~6 LCO 3.4.30 press er safety valves shall be OPERABLE with lift 9 M g,,2\,/ sett ngs ;t psia and < 5. psia. y 22549.2b t
/
APPLICABILITY: MODES 1 2 and 3 (RODETwhkgrNJ col (leg femperatilresT/285)*Tj
-----------------------------NOTE--- ---- = - --------------
The lift settings are not required to be within LCO limits . I during MODES 3 and 4 for the purpose of setting the s d \/ t r pressurizer safety valves under ambient (hot) conditions. ours following entry This exception is allowed for JJ6 into MODE 3 provided a preliminary cold setting was made prior to heatup. g -_ .- ............ . ACTIONS
, CONDITION REQUIRED ACTION COMPLETION TIME One pressurizer safety A.1 Restore valve to 15 minutes 3.4.2.2. ACT' A.
valve inoperable. OPERABLE status.
\
Required Action and B.1 Be in MODE 3. 6 hours
,4 Z ,2 g B. \ associated Completion Time not met. AM g
B.2 inMODE4[with 11' (12)( hours ( Q L,) ) 9.B Twofor,more pressurizer safety t eratu s
<s 285]' . ,
, ; h valves inoperable.
3.4-20 Rev ', 0 !07/:--
"~C: !5 h C(dP-b'D k2b t
\ i 1
. Pressurizer Safety Valves-//[pge },jg3 l
- 3. 4.10y.
I SURVEILLANCE REOUIREMENTS SURVEILLANCE FREQUENCY
/4A,4 .7 SR 3.4.10.1 Verify each pressurizer safety valve is In accordance N '
OPERABLE in accordance with the Inservice with the Testing Program. Following testing, lift inservice settings shall be within i 1%. Testing Program l ! I i l ? ) l l l I l l l l l l
.) lo ur& -Und* I,2,S 3.4-21 g
Rev L o4/ntfog_ I
1 l , i i CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.10 BASES MARK UP i 1 1 t I l l 1
i 4 Pressurizer Safety Valve - M CF,.bl,2.pd 3 l B 3.4.10 I B 3.4 REACTOR COOLANT SYSTEM (RCS) i B 3.4.10 Pressurizer Safety Valves BASES h The purpose of the prino loaded pressurizer safety 4 BACKGROUND valves is to provide RCS overpressure protection. Oper ting ' c. in conjunction with the Reactor Protection System, h valves are used to ensure that the Safety Limit (SL) o 3 2750 psia is not exceeded for analyzed transients durino etc. anA D 5 operation in MODES 1,+a4 2.t he*For safety valves
- W used ~or th; ; cid:r :f MT. i.
M ? M pc-tf: : E MCDE 4.~ MODE 5, and H0DE 6 with the head on, overpressure protection 5 is provided by operating procedures and the LCO 3.4.:H[g:" Low A Temperature Overoressure Protection (LTOP) System.*fror rs,0 7 (tt)(se MSME1 condit/bns, recu(rementsAmerifan ar# satisfiesSocietf with oneof Mechanifal s/fety val ./ ' Engin IOCf Ah The self actuated pressurizer safety valves are designed in 206 i' accordance with the requirements set forth in the ASME. The Boiler and Pressure Vessel Code /Section III (Ref.1). *M.
- do required lift pressure is t%GTsia e-W.Nhe sately vaives discharge steam from the pressurizer to a quench tank The discharge flow is indicated located in the containment.
by an increase in temperature downstream of the safety valves and by an increase in the quench tank temperature and level. upper d lower Aressurefimits Fe based /on the / T
=
"I i %-tol e nce renuArement (Itef.1) Ier lifth eresfureM psig.J The lift setting is for the ambient 1 ove 10 This requires l onditions associated with MODES 1, 2, and 3.
either that the valves be set hot or that a correlation between hot and cold settings be established. The pressurizer safety valves are part of the primary success path and mitigate the effects of postulated accidents. OPERABILITY c.f the safety valves ensures that the RCS pressure will be limited to 110% of design pressure. The consequences of exceeding the ASME pressure limit (Ref.1) could include damage to RCS components, increased leakage, or a requirement to perform additional stress analyses prior to resumption of reactor operation. (continued) Rev i, w,j , m S "+ B 3.4-a4 l ab Wede tNtd 1,2.3 g l l
(UD ( $$ pg
~ h' .g. 3 ofo Pressurizer Safety Valve -
B 3.4.10 ord LASES (continued) APPLICABLE All accident analyses in t e SAR hat require safety valve SAFETY ANALYSES actuation assume operation of pressurizer safety valves to limit increasing reactor coolant pressure. The - pressure protection analysis is also based on operation , o safety valves and assume _s that the valves ope t the hiah rance of-the setting @fDO-pr.a sygem cepign re;eGre fus M These valves mw. ncommoane pressurizer insurges that could occur during a startup, rod withdrawal, feedwater lineejected rod, loss break accident. Theof mai @naccident feedwater, or main b af W A The . . d A*Tep establishestheminimumsafetyva(lvecapacity. accident is assumed to occur at ) j(et oower. Single ai gr of a safety valve is neither assumed'in the accident ' icu analysis nor required to be addressed by the ASME Code. Compliance with this specification is required to ensure T that the accident analysis and design basis calculations remain valid. The pressurizer safety valves satisfy Criterion 3 of l r<hv rt
' LCO Y'I M @___@
s The c,~ pressurizer safety valves are set to open we -- Fa* p } and within the ASME N D , p atCA ) RCS specifieddesign pressur M'to avoid exceeding the maximum RCS tolerance design pressure SL, to maintain accident analysis assumptions, and to comply with ASME Code reauirements. Th uppe ano io r pressu tolerancf limits afe based fn the ! I tolera e requir ents (Reff 1) for 1/fting or(ssures 2 i ab ve IQp0 sig e limit prot cted by this specification I is Ine reactor poolant fressure oundary (RCPB L of 11 of design pressure. Inoperabil ty of ore or alves could result in exceeding the SL if a transient were to occur. The consecuences of exceeding the ASME pressure limit could include damage to one or more RCS components, increased leakage, or additional stress analysis being required prior to resumption of reactor operation. APPLICABILIT In _ MODES 1, 2, and 3, Can(poxme c w e ahne ate t)6depr- b i cremr'er,at Fr0 OPERABILITY of famofvalves is required because the combined capacity is required to keep reactor coolant pressure below 110% o_f its desien value during certain accidents. MODE 3 qw perpfns sf WDEX er@ conservatively j (continued) 0C ^^'- B 3.4-45 Rev i us / vi j & G"b % de.- U n h b ?- @ A
-~ _. . __ _. . ._. -
- _-m _ _ _ _ ._ _ .
t l l Pressurizer Safety Valve .h(QQ$ \J.Ardb B 3.4.10 t I l BASES included, although the listed accidents may not require APPLICABILITY (continued) safety valves for protection. The C0 is r t applic le in M E 4 whe all RCS e d leg ' cause LT re,4sdf /rv t>.peratur are s [2 51*L an MODE 5 otectio is provid d.' Over ressure rotectio is not k
$14 /e equired n MODE 6 ith_th g attor J tl head d etaas g /
The Note allows entry into MODES 3 and 4 with the lift 1 ja crfkar Mous m settings outside the LCO limits. This permits testing and ) l C#"'d by LCD s 3 N.I$ examination of the safety valves at high pressure and i temperature near their normal operating range, but only The l 4/f,59hter b4th after the valves have had a preliminary cold setting. i w t a s - M O) t at," a n d cold setting gives assurance that the valves are OPERABLE b l near their design condition. Only one valve at, a time will 1_2
- 1. V. / 3 " L-fo / S y 3 /< es , 4 e
be removed from service for testing. The fiHir}7our f
- _ exception is based on 18 hour outage time for each of the two valves. The 18 hour period is derived from operating l J l experience that hot testing can be performed within this I
timeframe. l ACTIONS L,1 With one pressurizer safety valve inoperable, restoration must take place within 15 minutes. The Completion Time of 15 minutes reflects the importance of maintaining the RCS overpressure protection system. An inoperable safety valve coincident with an RCS overpressure event could challenge l tha integrity of the RCPB. I' r B.1 and B.2 - l- If the Required Action cannot be met within the required ; l Completion Tima or if two or more pressurizer safety valves l' i are inoperabit se plant must be brought to a MODE in which l the requiremen. does not apply. To achieve this status, the ' plant must be breucht to at least MODE 3 within 6 hours The and , to MODE 4 Cat # belo/f 2BFf'F7within Alz%nour_s. l 6 hours allowed is reasonable, based on operaung 5 experience, to reach MODE 3 from full power wit.hours ut challenging plant systems. Similarly,theK1 allowed is reasonable, based on operating expe ience. to reach MODE 4 without challenging plant systems. (7/ or > Glow)(---- (continued) Rev 4, N ,-;;,;;- b C 070- B 3.4-46 05 0 - M *:) h 2 3 l i
. I
. . ~ .. .-
i I l Pressurizer Safety Valve -M(Mi>1,2. Grd2) ,, ! B 3.4.10 j BASES I ACTIONS B.1 and B.2 (continued) j d255FF, Aerpregure pr@tetien/s proviMd by LJ0P.'T7he change from MODE I, Z, or 3 to MODE 4 reduces the RCS energy (core power and pressure), lowers the potential for large ! pressurizer insurges, and thereby removes the need for overpressure protection by ressurizer safety valves. SURVEILLANCE SR 3.4.10.1 I REQUIREMENTS l SRs are specified in the Inservice Testing Program. Pressurizer safety valves are to be tested in accordance , with the requirements of Section XI of the ASME Code i (Ref.1), which provides the activities and the Frequency l necessary to satisfy the SRs. No addition uirement_s are specified. g, .g oj, r 4, The pressurizer safety valve setpoint _i t tett for /
~
OPERABILITY;however,thevalvesarepater to 1% durin W the Survefilance tp allow for dr@hf 4 .se Hig pressar< shall (.corresfonel += aMn+ cowddhans of .tke volyg. g4 non,% g ] opera 4iq REFERENCES 1. ASME, Boiler and Pressure Vessel Code, Section Ill, +"Fera 4d 4 Section XI. *
- A p re ssurg. ,
s-g , f\/ 9 G S Oprah'y Lic'esee Apenlous.) nos, 7% Ci sa 4 7 ( br %ks \> 1: *t d 3, (*5p a h be y l,& R s s o e< L & # 4 0 (L C s u f Q c n % 4 1 u dda my a,liW. A_ J EE0; sis B 3.4-47 Rev 1, C'./ 7/ M
&ve -% u3 1 1
i i I l ; i 1 l I l l l j l l
- NUREG-1432 EXCEPTIONS l SPECIFICATION 3.4.10 I r
I l 1 i . l l l l l l t I i 1 i l ? i l l
- -- - - _ - . - . . - - - . - - . - -- . _ . . = -
1
- PALO VERDE ITS CONVERSION 3
NUREG-1432 EXCEPTIONS
- SPECIFICATION 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3
- 1. NUREG-1432 uses one Specification to address Modes 1. 2. 3 and 4. ITS
' splits this Specification into two separate Specifications. ITS Specification 3.4.10 will address Modes 1. 2. and 3: ITS 3.4.11 will address Mode 4. This was necessary because the number of pressurizer safety valves required in Modes 1-4 by NUREG-1432 are the same, whereas at I j PVNGS a different number of pressure safety valves are required dependent !
on whether the plant is in Modes 1-3 or Mode 4. Keeping the pressurizer i safety valve Specification as one Specification at PVNGS would have made 1
- the Actions Table confusing. Therefore, two separate Specifications are l used to address pressurizer safety valves. The use of two Specifications I i is consistent with PVNGS CTS. The Bases has also been revised to be
, consistent with the LCO. 5 l
- 2. NUREG-1432 Bases makes reference to upper and lower pressure tolerances !
being based on the i 1% requirements of ASME. Boiler and Pressure Vessel Code for pressures above 1000 psig. ITS uses 1% to set pressurizer safety valves and +3. -1% for "as found" OPERABILITY determination. This was approved for PVNGS in TS Amendment #75 (Unit 1). #61 (Unit 2). #47 (Unit 3). This is consistent with PVNGS licensing basis.
- 3. NUREG-1432. Bases 3.4.10. Applicable Safety Analysis, states that the startup accident establishes the minimum safety valve capacity. ITS. Bases 3.4.10. Applicable Safety Analysis will state that the Loss of Load with delayed Reactor Trip establishes the minimum safety valve capacity. This is acceptable because PVNGS safety analysis shows this event to be the most limiting. This change is consistent with PVNGS licensing basis.
- 4. NUREG-1432. Bases 3.4.10. contains a statement that says. "For these conditions. American society of Mechanical engineers (ASME) requirements are satisfied with one safety valve." ITS 3.4.10 Bases does not contain '
this statement. There is no Technical Specification requirement that requires one pressurizer safety valve to be Operable in Modes 5 or 6. This change is consistent with PVNGS licensing basis.
- 5. The plant specific titles. nomenclature, number, parameter /value.
reference, system description, system design. operating practices or analysis dc=ription was used (additions, deletions, and/or changes are included). Plant Specific parameters / values are directly transferred from the CTS to the ITS. PALO VERDE - UNITS 1,2, AND 3 1 REV.A i
i I PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 l
- 6. Grammar and/or editorial changes have been made to enhance clarity. No l intent or technical changes to the Specification are made by this change.
- 7. Bases section deleted because the associated Specification / Surveillance was deleted.
- 8. NUREG-1432 Bases 3.4.10 Applicability provides an unnecessarily complex level of detail to describe when LCO 3.4.10 is not applicable. ITS Bases 3.4.10 uses a more simple approach used elsewhere in the NUREG Bases (e.g. ,
3.9.4 and 3.9.5 Bases) to describe that the requirements for overpressure protection in other MODES are covered by LCOs 3.4.11 and 3.4.13.
- 9. ITS Bases SR 3.4.10.1 contains maintenance information concerning the l approved method for setting PSV lift setpoints from CTS LC0 3.4.2.2.
i Footnote *. NUREG-1432 Bases do not contain this information. This is l consistent with the PVNGS licensing bases. ) l l l l ( i l l l l l l PALO VERDE - UNITS 1,2, AND 3 2 REV.B l l
a 4 9 2 4 PVNGS CTS SPECIFICATION 3.4.10 MARK UP
%rMC4k)Df\ 3.i.10
.~.2. _n
- 3. REACTOR COOLANT SYSTE V hh. \O fI E ITING EDNDITIQif FOR OBfRATIO M (f,0 bh,\Q .2/23 pressurizer code safety valves shall be OPERABLE with a lift]
etting o 2475 osia +3. -1%*.1 APPLICABILITY: MODES 1, 2, and 3. ACTION: ' With one pressurizer code safety valve inoperable, either restore thel __ noperable valve to OPERABLE status wuthin 15 m'nutes ir be in at least HOT
~
STANDBY within 6 hours and in HOT SHU"DOWN w' th' n the followino 6 hours i shutdown cyfling system f/ction l' ne re / ef valves aM erpressure Fotection for Abe Reactor Coc/ ant System./ gned to profide / ('3 SURVElllANCE RE0VIREMENTS
@NJi 'dd !d" 7""'" "'T """ '""/"'" '" "f '"' "' % M \D.\ enti ec.h Pe-na-Nusts in AE cm a n mah bevic.c4dng9 . E3 mes ,
ler mhncp M6. wah.n I t %.
*The settin p ssure shal va at nomina orrespondtodmbientcondt[nsofthe t perating t erature and f essure. j 3 PALO VERDE - UNIT 31,C.,b 3/4 4-8 s
- . . .- . _ . . - . . ~ . . . . .. - - . - . _ - . - _ . _ . . . . . - - . .
1
,. i INSERT FOR CTS 3.4.2.2 l
- APPLICABILITY NOTE (Units 1. 2, and 3)
- INSERT 1
. .--NOTE ---. -.--.--.-----.------
4 The lift settings are not required to be within LCO limits during MODES - 3 and 4 for the purpose of setting the pressurizer safety valves under
- ambient (hot) conditions. This exception is allowed for 72 hours following entry into MODE 3 provided a preliminary cold setting was made prior to l
i heatup. ]- . . . . . . . . . 3 l 1 4 3 i e I i i
1 l
' INSERT FOR CTS '3.4.2.2 ACTION B i (Units 1,2, and 3) )
INSERT 2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 6 hours associated Completion g Time not met. B.2 Be in MODE 4. 12 hours Two or more pressurizer safety valves inoperable. I j l
a b DISCUSSION OF CHANGES SPECIFICATION 3.4.10 e
i PALO VERDE ITS CONVERSION - DISCUSSION OF CHANGES SPECIFICATION 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 i ADMINISTRATIVE CHANGES A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432. Rev.1 (NUREG-1432) As a result. the Palo Verde Nuclear Generating Station . (PVNGS) Improved Technical Specifications (ITS) should be more readable. I and therefore understandable, by plant operators as well as other users. ; During the reformatting and renumbering of the ITS. no technical changes ! (either actual or interpretational) to the Current Technical Specifications ! (CTS) were made unless they were identified and justified. ! Editorial rewording (either adding or deleting) is made consistent with NUREG-1432. During NUREG-1432 development, certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more detail does not result in a technical change. l A.2 CTS SR 4.4.2.2 states that pressurizer safety valve Operability is 1 determined by Specification 4.0.5 which includes Inservice Testing ASME Code Class 1. 2. and 3 pumps and valves. ITS SR 3.4.10.1 requires pressurizer safety valve OPERABILITY in accordance with Inservice Testing Program. These two requirements are the same. ITS SR 3.4.10.1 does not add any additional requirements or delete any existing requirements. Therefore. addition of this information is administrative in nature. This change is consistent with NUREG-1432. TECHNICAL CHANGES MORE RESTRICTIVE None PALO VERDE - UNITS 1,2, AND 3 1 REV.A
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 TECHNICAL CHANGES - RELOCATIONS LA.1 CTS LCO 3.4.2.2 footnote *, contains maintenance information concerning the approved method for setting pressurizer safety valve lift setpoints. ITS does not contain this information. This information is not required to determine OPERABILITY of a system, component or structure and therefore is being relocated to a Licensee Controlled Document (Bases Section SR 3.4.10-1: In addition, this information does not meet criteria of 10 CFR 50.36 (c) (2) (ii) for inclusion in to the ITS and is therefore relocated. Any changes to the Bases will be in accordance with Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This requirement is not required to be in ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to a Licensee Controlled Document is acceptable and is consistent with NUREG-1432. LA.2 NOT USED . PALO VERDE - UNITS 1,2, AND 3 2 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 TECHNICAL CHANGES - LESS RESTRICTIVE I t L.1 CTS does not address the condition where two or more pressurizer safety 4 valves are not Operable. This would require simultaneous entry into CTS 3.4.2.2 and 3.0.3. ITS does address the condition where two or more , pressurizer safety valves are not Operable. ITS 3.4.10 requires performance of Action B with two or more pressurizer safety valves inoperable. This prevents unnecessary entry into 3.0.3. Not requiring entry into 3.0.3 is 1 a less restrictive change. This change is acceptable because the Actions contained in the pressurizer safety valve Specification adequately address
- this condition. This change is consistent with NUREG-1432.
L.2 ITS 3.4.10 contains a Note that allows pressurizer safety valve settings to be outside the limits of the LC0 for 72 hours following entry into Mode 3 for the purpose of setting the pressurizer safety valve lift settings under ambient conditions. provided a preliminary cold setting was made ! prior to heatup. CTS 3.4.2.2 has no such exclusion. Allowing entry into Mode 3 by temporarily suspending LCO requirements to allow pressurizer
- safety valve testing constitutes a less restrictive change. This permits testing and examination of the pressurizer safety valves at high pressure and temperature near their normal operating range. but only after the valves have had a preliminary cold setting. This change is acceptable because the cold setting gives assurance that the valves are Operable near their design condition. The 72 hour exception is based on 18 hour outage time for each of the vaices. The 18 hour period is derived from operating l experience that hot testing can be performed within this time frame. This l change is consistent with NUREG-1432.
- L.3 CTS 3.4.2.2 is in conflict with CTS 3.4.2.1 when more than one but not I all. pressurizer safety valves (PSVs) are OPERABLE. CTS 3.4.2.1 would allow indefinite continued operation in MODE 4 with a minimum of one
, OPERABLE PSV. whereas CTS 3.4.2.2 would require the plant to be in MODE 4 with the additional restriction of the shutdown cooling system suction line .' relief valves aligned to provide overpressure protection for the RCS if not all PSVs are OPERABLE. Since the relief capacity of a single PSV is adequate to relieve any overpressure condition which could occur in MODE 4 above LTOP system temperatures. it is appropriate to use CTS 3.4.2.1 for ITS 3.4.10 and 3.4.11 to allow operation in MODE 4 with one or more PSVs OPERABLE. Although this is a Less Restrictive change with respect to CTS 3.4.2.2. it is consistent with CTS 3.4.2.1. NUREG-1432 does not contain a unique LC0 for MODE 4 above LTOP temperatures. PALO VERDE - UNITS 1,2, AND 3 3 IEV. B
i I A NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.4.10 l 1 I
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3
@MINISTRATIVE CHANGES I (ITS 3.4.10 Discussion of Changes Labeled A.1 and A.2)
Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS), t Units 1, 2, and 3, is converting to the ITS as outlined in NUREG-1432. " Standard l Technical Specifications Combustion Engineering Plants." The proposed changes involve the reformatting, renumbering, rewording of the Technical Specifications l (TS) and Bases with no change in intent, and the incorporation of current I operating practices consistent with NUREG-1432. These changes, since they do not l involve technical changes to the Current TS (CTS), are administrative. Below are
- the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. l The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards
consideration if operation of the facility, in accordance with a proposed i amendment, would not 1) involve a significant increase in the probability or I consequences of an accident previously evaluated: 2) create the possibility of l a new or different kind of accident from any accident previously evaluated; or )
- 3) involve ' -ignificant reduction in a margin of safety. A discussion of these !
standards as they relate to this amendment request follows: l Standard 1.-- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432, certain wording preferences or English language conventions were adopted. The proposed i changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 1 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 ADMINISTRATIVE CHANGES (ITS 3.4.10 Discussion of Changes Labeled (A.1 and A.2) (continued) Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes do not involve a physical alteration of the plaat (no new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? The proposed changes involve reformatting, renumbering, and rewording of the CTS, along with the incorporation of PVNGS current operating practices and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes are administrative in nature and will not involve any technical. changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature, no question of safety is involved. Therefore. these changes do not involve a significant reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 2 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3
- TECHNICAL CHANGES RELOCATIONS (ITS 3.4.10 Discussion of Changes Labeled LA.1 and LA.2)
Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1, 2. and 3 is converting to the ITS as outlined in NUREG-1432. The i proposed changes, since detail is being removed from the CTS to a Licensee l , Controlled Document, are less restrictive. The descriptions of these changes are in the Discussion of Changes listed above. The Commission has provided standards for determining whether a significant i
- hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated
- 2) create the possibility of a new or different kind of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. - Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes do not result in any hardware ctanges or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee Controlled Document containing the relocated requirements will be maintained using the provisions of 10 CFR 50.59 or other specified control processes and is subject to the change control process in the Administrative Controls Sec' tion of the ITS. Since any changes to a Licensee Controlled Document will be evaluated, no increase in the probability or consequences of an accident previously evaluated will be allowed. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 3 Rev. A
I NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes ],2 and 3 TECHNICAL CHANGES RELOCATIONS . (ITS 3.4.10 Discussion of Changes Labeled LA.1 and LA.2) (continued) i Standard 2.- Does the proposed change create the possibility of a new or different kind of accident from rny accident previously evaluated? The proposed changes relocate rege' aments from the CTS to a Licensee l Controlled Document. These changes <ill not alter the p ant configuration ; (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes will not impose 4 different requirements and adequate control of information will still be maintained. These changes will not alter assumptions made in the safety
- analysis or licensing basis. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? i The proposed changes relocate requirements from the CTS to a Licensee ] Controlled Document. These changes will not reduce a margin of safety ; since they have no impact on any safety analysis assumptions. In addition. l the requirements to be transposed from the CTS to the Licensee Controlled i 4 Document are the same as the CTS. Since any future changes to this l Licensee Controlled Document will be evaluated per the requirements of l 10 CFR 50.59, or other specified control processes, no reduction (significant or insignificant) in a margin of safety will be allowed. Therefore, these changes will not involve a significant reduction in a margir, of safety. , The NRC review provides a certain margin of safety. and although this review will no longer be performed prior to submittal, the NRC still
- inspects the 10 CFR 50.59 process. The proposed changes are consistent i
with NUREG-1432, which was approved by the NRC Staff. The change controls for proposed relocated details and requirements provide an acceptable level
- of regulatory authority. Revising the CTS to reflect the approved level of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore, revising the CTS to reflect the NRC accepted level of detail and requirements ensures no i reduction in a margin of safety, i
PALO VERDE - UNITS 1,2, AND 3 4 Rev.A
E NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 l TECHNICAL CHANGES LESS RESTRICTIVE i (ITS 3.4.10 Discussion of Changes Labeled L.1) ! 4 Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). , Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The l proposed change involves making the CTS less restrictive. Below is the description of this less restrictive change and the NSHC for the conversion to NUREG 1432. L.1 CTS does not address the condition where two or more pressurizer safety valves are not Operable. This would require simultaneous entry into CTS 3.4.2.2 and 3.0.3. ITS does address the condition where two or more i pressurizer safety valves are not Operable. ITS 3.4.10 requires performance of Action B with two or more pressurizer safety valves inoperable. This prevents unnecessary entry into 3.0.3. Not requiring entry into 3.0.3 is a less restrictive change. This change is acceptable because the Actions ; contained in the pressurizer safety valve Specification adequately address ! this condition. This change is consistent with NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration _ if operation of the facility. in accordance with a proposed ) amendment, would not 1) involve a significant increase in the probability or I consequences of an accident previously evaluated: 2) create the possibility of ; a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
PALO VERDE - UNITS 1,2, AND 3 5 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.10 Discussion of Changes Labeled L.1) (continued) Standard 1. Does the proposed change involve a significant increase in the . probability or consequences of an accident previously evaluated? The proposed change provides specific requirements to enter Action B for the condition when two or more pressurizer safety valves are not Operable. Action B requires the plant to be in Mode 3 within 6 hours and on to Mode 4.. The CTS does not provide any guidance when two or more pressurizer safety valves are inoperable. Therefore, the plant would enter the Actions of 3.0.3. Placing the plant in Mode 3 within 6 hours and then to Mode 4 is less restrictive than required by the CTS. Both Specifications still require the plant to shutdown, however, the proposed change will present a less likelihood of unnecessarily cycling the plant or possible transient that might occur during entering 3.0.3. This change will not alter assumptions relative to mitigation of an accident or transient event. This change has been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. Standard 2.-- Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed change provides specific requirements to enter Action B for the condition when two or more pressurizer safety valves are not Operable. Action B requires the plant to be in Mode 3 within 6 hours and on to Mode 4. The CTS does not provide any guidance when two or more pressurizer safety valves are inoperable.' Therefore, the plant would enter the Actions of 3.0.3. Placing the plant in Mode 3 within 6 hours and then to Mode 4 is less restrictive than required by the CTS still requiring the plant to shutdown, however, relaxing the requirement to enter 3.0.3 by allowing the plant to be in Mode 3 within 6 hours and then to Mode 4. does not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal pant operation. This i change, while still requiring a plant shutdown, however. relaxing the Mode of shutdown is consistent with the assumptions made in the safety analyses l and NUREG-1432. Therefore this change will not create the possibility of a new or different kind of accident from any accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 6 Rev. A
- . = , - - . .- , -. . . _ . . - - .. --
1 NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.10 Discussion of Changes Labeled L.1) (continued) i 1 l Standard 3. Does the proposed change involve a significant reduction in a i margin of safety? The proposed change provides relaxation in plant shutdown requirements. l An evaluation of this change concluded that there is no impact on the margin of safety. The change maintains the requirements of the safety , analysis, licensing basis, and NUREG-1432. As such, no question of safety is involved. Therefore, these changes will not involve a significant reduction in a margin of safety. 1 l PALO VERDE - UNITS 1,2, AND 3 7 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.10 Discussion of Changes Labeled L.2) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2 and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the description of this less restrictive change and the NSHC for conversion to NUREG-1432. L.2 ITS 3.4.10 contains a Note that allows pressurizer safety valve settings to be outside the limits of the LCO for 72 hours following entry into Mode 3 for the purpose of setting the pressurizer safety valve lift settings under ambient conditions, provided a preliminary cold setting was made prior to heatup. CTS 3.4.2.2 has no such exclusion. Allowing entry into Mode 3 by temporarily suspending LC0 requirements to allow pressurizer safety valve testing constitutes a less restrictive change. This permits testing and examination of the pressurizer safety valves at high pressure and temperature near their normal operating range, but only after the valves have had a preliminary cold setting. This change is acceptable because the cold setting gives assurance that the valves are Operable near their design condition. The 72 hour exception is based on 18 hour outage time for each of the valves. The 18 hour period is deiived from operating experience that hot testing can be performed within this time frame. This change is consistent with NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to 1 an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a'significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
1 I PALO VERDE - UNITS 1,2, AND 3 8 Rev. A i I
1 NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.10 Discussion of Changes Labeled L.2) (continued) 4 l Standard 1.-- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? l The proposed change provides a Note that allows the pressurizer safety I valve settings to be outside the limits for 72 hours following entry into
- Mode 3 for the purpose of setting the pressurizer safety valve lift settings under ambient conditions, provided a preliminary cold setting was
- made prior to heatup. The CTS does not provide this allowance. The 72 hour exception is based on 18 hour outage time for each of the valves. The 18 hour period is derived from operating experience that hot testing can be performed within the time frame. This change does not result in
< operation that will increase the probability of initiating an analyzed i event This change will not alter assumptions relative to mitigation of
, an accident or transient event. This change has been reviewed to ensure I that no previously evaluated accident has been adversely affected. I
- Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. i 1
Standard 2. Does the proposed change create the possibility of a new or I different kind of accident from any accident previously evaluated? 1 4 Allowing the 72 hours following entry into Mode 3 for the purpose of setting the pressurizer safety valve setting does not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. This change provides i relaxation by allowing a 72 hour grace period to set the safety valves, however, this is consistent with the assumption made in the safety analyses, licensing basis, and NUREG-1432. Therefore, this change will not i create the possibility of a new or different kind of accident from any accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 9 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.10 - Pressurizer Safety Valves - Modes 1,2 and 3 r TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.10 Discussion of Changes Labeled L.2) (continued) Standard 3. Does the proposed change involve a significant reduction in a margin of safety? l The proposed change provides relaxation by allowing 72 hours after entering l Mode 3 to set the pressurizer safety valve setting. An evaluation of this l change has been performed and concluded that there is no impact on the ! margin of safety. The change maintains the requirement of the safety
- analyses, licensing basis, and NUREG-1432. As such, n question of safety in involved. Therefore, this change will not involve a significant reduction in a margin os safety.
I l l l l I l l l l PALO VERDE - UNITS 1,2. AND 3 10 Rev. A
CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.11 MARK UP 4 l I i l l l l d 1
*4 Db
[6 Pressurizer Safety Valves 3.4.
)
COE k 3.4 ACTOR COOLANT SYSTEM (RCS) 3.4. Pressurizer Safety Valves 4
.3,4 E,\ LCO 3.4 pressurizer safety valve's shall be OPERABLE with lift settin9(2 psia and 5 psia.
, Q $p I"f4O3 f APPLICABILITY: 1/z. amr 3 4 4 with all RCS cold leg temperatures > *F ____ceotd e ,or
~ '
NOTE .
-- The lift settings are not required to be within LCO limits 9 during MODES 3 and 4 for the purpose of setting the N s pressurizer safety valves under ambient (hot) conditions.
LZ. I f i This exception is allowed for ours following entry into MODE 3 provided a preliminary 1 tting was made prior to heatup. gq f \ ME. us%ch Gd \og4Whaa%fv asqQ CONDITION REQUIRED ACTION COMPLETION TIME
.i .Z.\ AC. A. pressurizer safety A.1 Re ore valve to 15 min es
\ / valve inoperable. O RABLE status.
< E r -~
B. Re ired Action d B.1 Be in MODE 3 6 ours a ociated Comp tion me not met. N Q3 - Be in MODE 4'with M
'RC5 Id leg TM immedidly k Two [or mor ]
pressurize safety rature > 4 valves in perable. 285]*F. /J os %tAwn tahg enx.W \u 7
& vAve. m % M A Q
- 3. Rev i, 0 ;-
9
INSERT FOR ITS 3.4.11 ACTION A and B , (Units 1,2, and 3) INSERT 1 s i ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME AND ; l A.2 Perform SR 3.4.11.2 and Immediately SR 3.4.11.3 for the required Shutdown l Cooling System suction line relief valve to comply with Action A.I. i AND l A.3 Be in Mode 4 with all 8 hours ; RCS cold leg temperatures 5 214'F l during cooldown or l l 5 291*F during heatup. e } i i 1
I i Pressurizer Safety Valves 3.4[
) SURVEILLANCE REOUIREMENTS f {
SURVEILLANCE [ FREQUENCY r
+k r~smNb kk(,k SR 3.4.h.1 Verify a press izer safety valve is In accordance l \ q OPERABL n accordance with the Inservice with the l Testing Program. Following testing, lift Inservice settings shall be within 1%. Testing Program A l s
u \- 4 7 B J l I l 1 i ( - j l l 1
) r A Tb k,2.ib l
~ - - , Rev 1, ::j;7j;;
i I i
J
- INSERT FOR ITS 3.4.11 SURVEILLANCE REQUIREMENTS 1
(Units 1,2, and 3) INSERT 1 ! SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.2 . .
--N OTE-------.----- .-.----
4 Only required to be performed when a Shutdown Cooling ] System suction line relief valve is being used for overpressure protection. , , Verify the required Shutdown Cooling System suction 12 hours for , line relief valve aligned to provide overpressure protection unlocked, not for the RCS. sealed, or otherwise l not secured open ;
- pathway vent valve (s)
- AND i 31 days for locked, -
sealed, or otherwise , secured open
- pathway vent valve (s).
SR 3.4.11.3 Verify the required Shutdown Cooling System suction In accordance with l line relief valve OPERABLE with the required setpoint. the Inservice
- Testing Program 1
4 1 4 1 4 4 i
F-CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.11 BASES MARK UP
r I Pressurizer Safety Valve DE N B 3.4. u B 3.4 ACTOR COOLANT SYSTEM (RCS) B 3.4. Pressurizer Safety Valves MODf:.4 i BASES h The purpose of th spring loaded pressurizer safety BACKGROUND 7 ! valves is to provide RCS overpressure protectionJ peratin actor Protec on syste two
~
'in c junction )th the val s are us to ensu that the ty Limit SL) of {
psia is ot exte ed for anal d transin s dur' n J $ g 27 tration MODES 1 nd ? h afety valver ace-usna ror ou q i i O astD portions of iG 4. or the remainder of MODE 4, MDE 5, and MODE 6 with the head on, overpressure prot c a is provided by operati.g, procedures and the LCO 3.4. , " tow Temperature Overoressurt Protection (LTOP) System." r h condit s, Amer n Society f Mechani 1 Engine rs / j n reoui ments ar satisfied ith one s ety valv f i The self actuated pressurizer safety valves are designed in 7A73 accordance with the requirements set forth in the ASME. 9 Boiler and Pressure Vessel to Section III (Ref. 1). The ~* Ib required lift pressure is sia t-%7 The safety valves discharge steam from the pressurizer to a quench tank located in the containment. The discharge flow is indicated ', by an increase in temperature downstream of the safety valves and by an increase in the quench tank temperature and ' level.
~
(Th upper a 'T6ser/pressurf limits /are Dagree on spe 7m
) i 5-tole ce readirement/JDef.16 for 1/ftino VessurIsA L ove 10 osia,_J The lift so ting is for the ambient d
conditions associated with l*L ES 1, 2, and 3. This requires either that the valves be set hot or that a correlation between hot and cold settings be established. J The pressurizer safety valves are part of the primary success path and mitigate the effects of postulated accidents. OPERABILITY of the safety valves ensures that the RCS pressure will be limited to 110% of design pressure. The consequences of exceeding the ASME pressure limit (Ref.1) could include damage to RCS components, increased leakage, or a requirement to perform additional stress analyses prior to resumption of reactor operation. { AsoA i f ( '"" "" ) m - om u a
. , . 0 ., ,
B 3.4-44 Rev ; 00/07/ % /
1 l INSERT FOR ITS BASES 3.4.11 BACKGROUND SECTION ; (Units 1,2, and 3) l INSERT I BASES i BACKGROUND Pressurizer Safety Valve Reauirements I The pressurizer code safety valves operate to prevent the RCS from i being pressurized above its Safety Limit pL) of 2750 psia. Each safety valve is designed to relieve a minimum of 460,000 lb per hour of saturated steam at valve setpoint. The relief capacity of a single safety valve is adequate to relieve any overpressure condition which could occur during shutdown above L-TOP System temperatures. Shutdown Cooline System Suction Line Relief Valve Reauirements A single Shutdown Cooling system suction line relief valve provides : overpressure relief capability and will prevent RCS overpressurization in the event that no pressurizer safety valves are OPERABLE. i I i
. ~ _ _ _ _ - _ _ ..___._._- _ . _ _- _ _ _ _ . _. - . _.. _ .- m._
hb Pressurizer Safety Valves 4 (pMSIm + 56/o B 3.4.yf i BASES (continued) @
'I APPLICABLE All accident analyses in he F at require safety valve i SAFETY ANALYSES actuation assume operation of pressurizer safety valves j to limit increasing reactor coolant pressure. The '
T erpressure protection analysis is also based on operation o safety valves and assumes that the val _ves open_ at the high range of the settin @-ps#n sysste desftn)
; dFresacre passAzu These va ves must accommodate 5 l i
pressurizer insurges that could occur during a startup, r withdrawal, ejected rod, loss of main fee water. or main feedwater line break accident. The establishes the minimum safety ccident apacity. The g"deQ2 h g Qw , accident is assumed to occur at ower. Single failure M i of a safety valve is neither ass ~in the accident analysis nor re:luired to be addressed by the ASME Code. Compliance with this specification is required to ensure
- that the accident analysis and design basis calculations )
j y9 remain valid. LTDC. Ah / The oressurizer safet v lves sat f riferion 1 of Q
-s ycms poeq e r safety valves are set to open et :pa.n )
r* LC0 3 The' p ssur .. RCS design pressure CTaptr gegand within the ASME g specified tolerance to avoid exceeding the maximum RCS D4 design pressure SL, to maintain accident analysis , assumptions, and to comply with ASME Code recuirements A
-]
'up and lowe pressurf tolerancflimits ape basedfh the require 4ents (Reff 1) for 1/fting orAssures['\
5 - . i toleran ve 1000 ig.f The limit protected by this specification mis sne7eactor of design 7oolant pressure. fressurefoundary Inoperability of gm er(RCPB) SL of 110%, b 0) wr,rvaives could result in exceeding the SL if a transient were to occur. The consequences of exceeding the ASME pressure limit could include damage to one or more RCS components, i increased leakage, or additional stress analysis being required prior to resumption of reactor operation. L-APPLICABILITY In 990fES 1/2, af 3, E ffd toe 4 above the LTOP sm temoerawrert vtuluiT of G.eMalveg is requiredJbeca el rthe omb1n p sure ow 110%
~
capacity s requ its d d to keelb&eactor foola gn valuedurina cett3 1n ; < 10
)
ident MODE 3 d port _ ns of#iODE < :?rvatively j (continued) ; B 3.4-45 v /", Rev ; C7 w - ec,sA A ,or v cv
#awoen 4.s m% with !
. . - . ~ - - _-. _ - .. . - - - .
- \\ Pressurizer Safety Valves M 4 Theva ivems<rft 4,over r,3m,E re ' f cf '$Q-C +1'
- r f 5 *d in ia
- low Lrof h54. s -re s g , w ,,3
,,ggg
- a~e a g. .u.'Aobcr av d t t 0 s
. ,. % , .M,,. o<_ m r m .s m .s_ o y , ,
13 "_L ro p % sh - -
%A 4
APPLICABILITY included, although the listed accidents may not require (continued) safety valve ( for protection. MODE 4 whe all RCS cold ll NiLCOisn t eratur applicable are 5 (285)* and MODE 5 ecause LTOP not [(s. ' (V , otectio is provided. Overpressur protection i ensioned s) Qquired n MODE 6 wit the reactor vessel _h_ead d The Note allows entry into MODES 3 and 4 with the lift settings outside the LCO limits. This permits testing and examination of the safety valves at high pressure and temperature near their normal operating range, but only after the valves have had a preliminary cold setting. The cold setting gives assurance that the valves are OPERABLE near their design condition. Only one valve a time be removed from service for testing. The hour exception is based on 18 hour outage time for each of fme- ;M valves. The 18 hour period is derived from operating experience that hot testing can be performed within this timeframe. ACTIONS A,.1 10 With on pressurizer sa ty valve inop able, restor ion I must e place withi 15 minutes. T Completion Teme RCS of i 2. 15 e utes reflects e importance o maintaining ove ressure protee on system. An inoperable sa ty valve
- co cident with an CS overpressur event could allenge e integrity of he RCPB. >
'I pa so %EsWl a I tie Requfed Act/in cannh be me( with% the /eouired) he safetv vaivat moletion/ Time er/ff Wo of mo/ehoressur '
1 are inoperable, the plant must' be' brought tlP a MODE' in which ! the reouirement does not apoly.__90 achieve is st uspt ll urs'a G st be brou t to at lailst MODE 3 w hin 6 he W
.{ plant to M 4 at or ow 385)*F within (12' ours, l 8
- fkC* M 6h rs allowed s reasonab e, based on perati C- l (4 h / e rience, t reach MODE from full . w r wi out I Similarly the ;l hour allenging ant system sed on oper ting e erien , to /
bW'l 11 owed is asonable, reach MOD 4 without c 11enging p nt sys ms. orplow
.A
/
r (continued) doYc/th.-0 wm b B 3.4-46 Rev ', v,i07/05
i l l j INSERT FOR ITS BASES 3.4.11 ACTIONS SECTION (Units 1,2, and 3) l INSERTla . BASES I ACTIONS A.1. A.2 and A.3 To achieve this status, one Shutdown Cooling System suction line relief must be placed in service immediately, then the plant must be brought to at least MODE 4 with all RCS cold leg temperatures s 214*F during cooldown or s 291'F during heatup. within 8 hours, so that LCO 3.4.12 (LTOP System) would apply. It is reasonable to pursue the ACTION to place a shutdown , cooling system suction relef valve in service immediately (without delay) because the plant is already within the shutdown cooling system entry temperature of less than 350 F. The Completion Time of immediately requires that the required action be pursued without delay and in a controlled manner, and , reflects the importance of maintaining the RCS overprotection system. The 8 hours allowed to be in MODE 4 with all RCS temperatures s 214*F during cooldown or s 291 F during heatup is reasonable, based on operating experience, to reach this condition without challenging plant systems. i b
Pressurizer Safety Valve - A B 3.4. i BASES ACTIONS 1 an .2 (continued) [285)'F, overpressure rotection is pro ded by LTOP. he D chan from MODE 1, , or 3 to MODE 4 educes the RCS nergy I (co power and pr ssure), lowers th potential for rge 1 i p ssurizer insu es, and thereby r ves the need or verpressure pr ectiqn by -{two} essurizer safe valves. , _ i M4 v I M k ! i SURVEILLANCE SR 3.4. '
.1 (p REQUIREMENTS I SRs are specified in the Inservice Testing Program. j Pressurizer safety valves are to be tested in accordance with the requirements of Section XI of the ASME Code } l (Ref.1), which provides the activities and the Frequency The Off 9 09 as rs 4 I necessary to satisfy the SRs. No additio 1 e uirements ,
are specified.
, ,g.g q !
f a d 8d' The pressurizer safety va ve poin is for I of . V^ " "h' OPERABILITY; however, the valves are eset to i 1% during
^* "' N*l**J , the SurveillancLto _ allow for drift. p l hi \'i- l V<7ssbt ~-
7 ' REFERENCES 1. ASME, Boiler and Pressure Vessel Code, Section Ill, vn- -- _ - - > 4 (), V N (n S ' O f tr* Lit.ense Amendnd floS* 75'[bI **4 47 u u a ,,e . a m . s .,,, a w (J(Lt. G d. b E vo M4'% c(cdc.d My Si H W-i Y GLtcN ~ h \.l. 0 usu 8 B 3.4-47 Rev 1, 04/07/;L
INSERT FOR ITS BASES 3.4.11 ACTIONS SECTION (Units 1,2, and 3) , INSERT 1 BASES i ACTIONS A.l. A.2 and A.3 l For the Shutdown Cooling System suction line relief valve that is required to be in service in accordance with Required Action A.1, SR 3.4.11.2 and SR 3.4.11.3 must be performed or verified performed within 12 hours. This ensures that the required Shutdown Cooling System suction line relief vdve is OPERABLE. A Shutdown Cooling System suction line reli f valve is OPERABLE when its isolation valves are open, its lift setpoint is set at 467 psig or less, and testing has proven its ability to open at that setpoint. If the Required Actions and associated Completion Times are not met, overpressurization is possible. The 8 hours Completion Time to be in MODE 4 with all RCS cold leg temperatures $ 214*F during cooldown or $ 291 F during heatup places the unit in a condition where the LCO does not apply. l 1
i INSERT FOR ITS BASES 3.4.11 SURVEILLANCE SECTION ! (Units 1,2, and 3) l INSERT 1 BASES SURVEILLANCE SR 3.4.11.2 REQUIREMENTS SR 3.4.11.2 requires that the required Shutdown Cooling System } suction line relief valve is OPERABLE by verifying its open pathway condition either: ,
- a. Once every 12 hours for a valve that is unlocked, not sealed, or otherwise not secured open in the vent pathway, or
- b. Once every 31 days for a valve that is locked, sealed, or ;
otherwise secured open in the vent pathway. The SR has been modified by a Note that requires performance only if a l Shutdown Cooling System suction line relief valve is being used for i overpressure protection. The Frequencies consider operating experience l with the mispositioning of unlocked and locked pathway vent valves. SR 3.4.11.3 SRs are specified in the Inservice Testing Program. Shutdown Cooling System suction line reliefvalves are to be tested in accordance with the requirements of Section XI of the ASME code (Ref. 2), which provides the activities and the Frequency necessary to satisfy the SRs. Shutdown Cooling System suction line relief valve setpoint is 467 psig. I 1
1
)
1 i 1 l l l 1 i 1 1 NUREG-1432 EXCEPTIONS l 1 SPECIFICATION 3.4.11 ! I l I l l l l l i 4
PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.11 - Pressurizer Safety Valves - Mode 4
- 1. Grammar and/or editorial changes have been made to enhance clarity. No intent or technical changes to the Specification are made by this change.
- 2. NUREG-1432 uses one Specification to address Modes 1, 2, 3 and 4. ITS splits this Specification into two separate Specifications. ITS Specification 3.4.10 will address Modes 1, 2. and 3: ITS 3.4.11 will address Mode 4. This was necessary because the number of pressurizer safety valves required in Modes 1-4 by NUREG-1432 are the same, whereas at PVNGS a different number of pressurizer safety valves are required dependent on whether the plant is in Modes 1-3 or Mode 4. Along with this appropriate wording changes have been made to the bases to incorporate information about PVNGS pressurizer safety valves. Keeping the pressurizer safety valve Specification as one Specification at PVNGS would have made the Actions table confusing. Therefore, two separate Specifications are used to address pressurizer safety valves. The use of two Specifications is consistent with PVNGS CTS. The Bases has also been revised to be consistent with the LCO.
- 3. NUREG-1432 Bases makes reference to upper and lower pressure tolerances being based on the i 1% requirements of ASME Boiler and Pressure Vessel Code for pressures above 1000 psig. ITS uses 1% to set pressurizer safety valves and +3. -1% for "as found" OPERABILITY determination. This was approved for PVNGS in TS Amendment #75 (Unit 1). #61 (Unit 2). #47 (Unit 3). This is consistent with PVNGS licensing basis.
- 4. ITS 3.4.11 ACTION A.1 requires the plant be placed in MODE 4 with one shutdown cooling system suction line relief valve in service if all PSVs are inoperable in order to prevent RCS overpressurization (ITS Bases 3.4.11. Background). This is consistent with CTS 3.4.2.1 ACTION a that requires an operable shutdown cooling loop placed in operation if all PSVs are inoperable, which. according to CTS Bases 3.4.4.2. provides overpressure relief capability and will prevent RCS overpressurization.
NUREG-1432 LC0 3.4.10 ACTION B.2 (the model for ITS 3.4.11. ACTION A.1) specifies that the plant be brought to MODE 4 with all RCS cold leg temperatures s [285] F if the PSVs are inoperable. NUREG Bases 3.4.10 ACTION B.1 states that at or below [285] F. overpressure protection is provided by LTOP. ITS 3.4.11 ACTION A.1 provides the overpressure protection in event of inoperable PSVs that NUREG-1432 3.4.10 ACTION B.1 would provide. ITS 3.4.11 ACTION A.1 is also consistent with the current licensing basis (CTS 3.4.2.1. ACTION a.2)
- 5. NUREG-1432. Bases 3.4.11, Applicable Safety Analysis, states that the startup accident establishes the minimum safety valve capacity. ITS Bases l 3.4.11. Applicable Safety Analysis will state that the Loss of Load with delayed Reactor Trip establishes the minimum safety valve capacity. This is acceptable because PVNGS safety analysis shows this event to be the most limiting. This change is consistent with PVNGS licensing basis.
PALO VERDE - UNITS 1,2, AND 3 1 IEV. B
i l PALO VERDE ITS CONVERSION I NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.11 - Pressurizer Safety Valves - Mode 4 1
- 6. ITS 3.4.11 adds Action A.3 which requires the plant to be in MODE 4 s 214 F during cooldown or s 291 F during heatup within 8 hours. This change is consistent with NUREG-1432. LC0 3.4.10. Action B.2. but utilizes PVNGS-specific values for LTOP temperatures (CTS 3.4.8.3) and completion time. The Bases has also been revised to be consistent with the LCO. See also DOC M.2.
- 7. ITS 3.4.11 adds SRs 3.4.11.2 and 3.4.11.3. NUREG-1432 has no equivalent SRs for the pressurizer safety valve LCO. ITS 3.4.11 uses a single Shutdown Cooling System suction line relief valve as a substitute when all pressurizer safety valves are inoperable in Mode 4. Addition of SRs that pertain to the required Shutdown Cooling System suction line relief valve are acceptable because any component, system. or structure being relied upon by Technical Specification Actions must meet their associated operability requirements (SRs) to be considered Operable. ITS SRs 3.4.11.2 and 3.4.11.3 are the same SRs used in ITS 3.4.13. L-TOP System. This change is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the Surveillance.
- 8. NUREG-1432. Bases 3.4.11. contains a statement that says. "For these conditions. American society of Mechanical engineers (ASME) requirements are satisfied with one safety valve." ITS 3.4.11 Bases does not contain this statement. There is no Technical Specification requirement that ;
requires one pressurizer safety valve to be Operable in Modes 5 or 6. This ! change is consistent with PVNGS licensing basis.
- 9. The plant specific titles. nomenclature, number, parameter /value.
reference, system description. system design, operating practices or analysis description was used to reflect PVNGS (additions, deletions, and/or changes are included). Plant specific parameters / values are l directly transferred from the CTS to the ITS.
- 10. Bases section deleted becaus'e the associated Specification / Surveillance was deleted.
- 11. NUREG-1432 Bases 3.4.10 Applicability provides an unnecessarily complex level of detail to describe when LC0 3.4.10 is not applicable. ITS Bases 3.4.11 (developed from NUREG Bases 3.4.10) uses a more simple approach used elsewhere in the NUREG Bases (e.g. 3.9.4 and 3.9.5 Bases) to describe that the requirements for overpressure protection in other modes are covered by LCOs 3.4.10 and 3.4.13.
- 12. ITS Bases SR 3.4.11.1 contains maintenance information concerning the approved method for setting PSV lift setpoints from CTS LCO 3.4.2.1.
Footnote *. NUREG-1432 Bases do not contain this information. This is consistent with the PVNGS licensing bases. PALO VERDE - UNITS 1,2, AND 3 2 IGV. B
a PVNGS CTS SPECIFICATION 3.4.11 MARK UP 1 i 1 1 l 1
Uw b $.\\ I j . , _ . . . . . 3.4 EAC10R 00 ANT SYSTEM , 34.\\ N4.4/23SAFETYVALVES{_- V SHUTDOWN (LIMfTING CONBlTION F084PERAT10JV) LO.D .h [4.OMinimM 7ne pressurizer code safety valve shall i,e OPERABLE with) a lift settino of 2475 osia +3. -1%*.j [,
- APPLICABILITY: MODE wdn o\ D cn\d ag hprL6 > NT N.cg coo \ dun , or
,[ ACTION [ @ py a big M4
@ (\.111 operations invol<...a t esitive reactivity chances /and placeTanWithL.\ no pressurizer c
}k p f0PERABLE shutdown cooling loop into operation. J hfTheprovisionsofSpecificationJ.0.4maybesuspendedforupto or r_urcos hours for entering into and during operation in MODE I L .7,,,
( of settingprovided conditions the pressurizer a preliminarycode safetywas cold setting valves made under prior to am lent (HOT 2 v eatup. j eA SuavElttAN b 15 _ MiD h Nd (T, b ((4A V) No additional Surveillance Requirements other than those required by 7 (Soecil' cation 4.0.5. ) M , 2. i M .3 4.n.) b .\. A f,Z k. pressures)/Ilcorrespc/toambient/onditions/fthe C*Th[liftsetti y(lve at nos a operatin VtemperatureA nd pressure / / _ PALO VERDE - UNITSl i f.,1 3/4 4-7 s
i i l l' INSERT FOR CTS 3.4.2.1 APPLICABILITY NOTE i (Units 1,2, and 3) ) INSERT 1 , l
... .-NOTE ---------.. - - - . - - - - . 1 The lift settings are not required to be within LCO limits during MODES l 3 and 4 for the purpose of setting the pressurizer safety valves under i ambient (hot) conditions. This exception is allowed for 72 hours following entry into MODE 3 provided a preliminary cold setting was made prior to heatup.-
1
._ __ _. ._ .- . _ . ~ . . _ _ . . . . _
I l l INSERT FOR CTS 3.4.2.1 ACTION A and B , (Units 1,2, and 3) j INSERT 2 i ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. All pressurizer safety A.1 Be in MODE 4 with one Immediately valves inoperable Shutdown Cooling System suction line relief valve in service. AND A.2 Perform SR 3.4.11.2 and Immediately ]' SR 3.4.11.3 for the required Shutdown l Cooling System suction line relief valve to comply with Action A.I. l AND A.3 Be in Mode 4 with all 8 hours RCS cold leg temperatures 5 214'F during cooldown or 5 291'F during heatup. 1 a f
. INSERT FOR CTS 3.4.2.1 SURVEILLANCE REQUIREMENTS ; (Units 1,2, and 3) 1 INSERT 3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
; SR 3.4.11.1 Verify the required pressurizer safety valve is In accordance with -
OPERABLE in accordance with the Inservice Testing the Inservice
- Program. Following testing, lift settings shall be within Testing Program. !
1%. SR 3.4.11.2 - - - - - - - - - - - - - - -
-----N OTE----- - --
- Only required to be performed when a Shutdown Coo
- ,
System suction line relief valve is being used for
- ' overpressure protection.
. . . +
Verify the required Shutdown Cooling System suction 12 hours for line relief valve aligned to provide overpressure protection unlocked, not j for the RCS. sealed, or otherwise not secured open , , pathway vent valve (s) AND l I 31 days for locked,
- sealed, or otherwise l secured open pathway vent
, valve (s). )
SR 3.4.11.3 Verify the required Shutdown Cooling System suction In accordance with line relief valve OPERABLE with the required setpoint. the Inservice Testing Program
DISCUSSION OF CHANGES SPECIFICATION 3.4.11 I l I ) 1
PALO VERDE ITS CONVERSION DISCUSSION OF CIIANGES SPECIFICATION 3.4.11 - Pressurizer Safety Valves - Mode 4 ADMINISTRATIVE CHANGES A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432, Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station (PVNGS) Improved Technical Specifications (ITS) should be more readable, and therefore understandable, by plant operators as well as other users. During the reformatting and renumbering of the ITS. no technical changes (either actual or interpretational) to the Current Technical Specifications (CTS) were made unless they were identified and justified. Editorial rewording (either adding or deleting) is made consistent with NUREG-1432. During NUREG-1432 development certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC, adding more detail does not result in a technical change. A.2 CTS SR 4.4.2.1 states that pressurizer safety valve operability is determined by Specification 4.0.5 which includes Inservice Testing ASME Code Class 1. 2, and 3 pumps and valves. ITS SR 3.4.11.1 requires pressurizer safety valve OPERABILITY in accordance with Inservice Testing Program. These two requirements are the same. ITS SR 3.4.11.1 does not add any additional requirements or delete any existing requirements. Therefore, addition of this information is administrative in nature. This change is consistent with NUREG-1432. TECHNICAL CHANGES - MORE RESTRICTIVE M.1 ITS includes two additional SRs that ensure the required Shutdown Cooling System suction line relief valve is Operable. The addition of these additional SRs constitutes'a more restrictive change to plant operating 3ractices. This is acceptable because any component, system, or structure 3eing relied upon by Technical Specification Actions must meet its associated operability requirements (SRs) to be considered Operable. This change is consistent with NUREG-1432. M.2 ITS 3.4.11 ACTION A.3 requires the plant be placed in MODE 4 with all RCS cold leg temperatures s 214*F during cooldown or s 291 F during heatup within 8 hours of all PSVs inoperable. This is more restrictive than CTS 3.4.2.1. which only requires being in MODE 4 and placing an operable shutdown cooling loop into operation (addressed by ITS 3.4.11 ACTION A.1), and does not require further cooling to s 214 F during cooldown or s 291*F during heatup. This change is consistent with NUREG-1432 LC0 3.4.10 (model for ITS 3.4.11), and is consistent with the objective to require completion of the final ACTION to result in the plant being out of this LCO and under the APPLICABILITY of another LCO, in this case ITS 3.4.13 l PALO VERDE - UNITS 1,2, AND 3 1 REV.B I
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.11 - Pressurizer Safety Valves - Mode 4 TECHNICAL CHANGES - RELOCATIONS LA.1 CTS 3.4.2.1, footnote *, contains maintenance information concerning the approved method for setting pressurizer safety valve lift setpoints. ITS does not contain this information. This information is not required to determine Operability of a system, component or structure and therefore is being relocated to a Licensee Controlled Document (Bases Section SR 3.4.11-1). In addition, this information does not meet criteria of 10 CFR 50.36 (c) (2) (ii) for inclusion in to the ITS and is therefore relocated. Any changes to the Bases will be in accordance with Chapter 5.0 Bases
- Control Program. This provides an equivalent level of control and is an 4
administrative change with no impact on the margin of safety. This requirement is not required to be in ITS to provide adequate protectior of public health and safety. Therefore, relocation of this requirement ta a
- Licensee Controlled Document, (Bases Section) is acceptable and is l consistent with NUREG-1432.
TECHNICAL CHANGES - LESS RESTRICTIVE 4 L.1 CTS 3.4.2.1. Action a, requires immediate suspension of all operatio1s 4 involving positive reactivity changes and to place an Operable shutdoun cooling loop into operation. ITS requires immediate entry into Mode 4 with one Shutdown Cooling System suction line relief valve.in service, or the unit is placed in a condition where the LCO does not apply. Removing the j requirement to suspend all operations involving positive reactivity i constitutes a less restrictive change. The requirement to suspend all operations involving positive reactivity changes is not needed for this LC0
- ACTION and could conflict with the required ACTION to plece a shutdown cooling system suction relief valve in service and go to LTOP entry ;
, conditions. This requirement is not needed because positive reactivity ,
changes (such as cooling the RCS when MTC is negative) without achieving ! criticality will not cause a condition that would be detrimental if the PSVs were inoperable. Cooling the RCS would result in lowering RCS pressure and may i;e necessary to enable compliance with the ACTIONS to place a shutdown cooling system suction relief valve in service and go to LTOP entry conditions. Compliance with other Technical Specifications ' ensure that criticality is not achieved in MODE 4. The reactivity condition of the plant in MODE 4 is required to be maintained with K,,, less then 0.99 in accordance with ITS Table 1.1-1. Also. ITS 3.1.1 and 3.1.2 contain requirements for shutdown margin. In addition. ITS 3.4.2 does not allow criticality unless RCS temperatures a 545 F in MODES 1 and 2 only. PALO VERDE - UNITS 1,2, AND 3 2 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.11 - Pressurizer Safety Valves - Mode 4 TECHNICAL CHANGES - LESS RESTRICTIVE (continued) 4 L.2 CTS 3.4.2.1, Action b, contains a statement allowing the suspension of Specification 3.0.4 for up to 12 hours for entry into Mode 4. ITS 3.4.11 contains a NOTE that allows pressurizer safety valve settings to be outside the limits of the LCO in Modes 3 and 4, and for 72 hours following entry into Mode 3, for the purpose of setting the pressurizer safety valve lift settings under ambient conditions, provided a preliminary cold setting was made prior to heatup. Allowing entry into Mode 3 by temporarily suspending LCO requirements for 72 hours to allow pressurizer safety valve testing constitutes a less restrictive change. This permits testing and examination of the pressurizer safety valves at high pressure and temperature near their normal operating range, but only after the valves have had a , preliminary cold setting. This change is acceptable because the cold 1 setting gives assurance that the valves are OPERABLE near their design condition. The 72 hour exception is based on 18 hour outage time for each of the valves. The 18 hour period is derived from operating experience that hot testing can be performed within this time frame. This change is consistent with NUREG-1432. L.3 CTS 3.4.2.1 uses Mode 4 Applicability. ITS 3.4.11 Applicability uses Mode 4 with all RCS cold leg temperature > 214 F during cooldown and Mode 4 with all RCS cold leg temperature > 291 F during heatup. ~Not requiring Applicability throughout Mode 4 constitutes a less restrictive change. This change is acceptable because the LTOP System provides overpressure protection in Mode 4 with all RCS cold leg temperature s 214*F during cooldown and Mode 4 with all RCS cold leg temperature s 291 F during heatup. This change is consistent with NUREG-1432. j l l PALO VERDE - UNITS 1,2, AND 3 3 REV.A i
- +_ .-
NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.4.11 ! l 4 r e
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 ADMINISTRATIVE CHANGES (ITS 3.4.11 Discussion of Changes Labeled A.1 and A.2) 4 Arizona Public Service Company Palo Verde Nuclear Generating Station (PVNGS). . Units 1. 2 and 3. is converting to the ITS as outlined in NUREG-1432. " Standard l Technical Specifications. Combustion Engineering Plants." The proposed changes involve the reformatting, renumbering, rewording of the Technical Specifications (TS) and Bases with no change in intent, and the incorporation of current operating practices consistent with NUREG-1432. These changes, since they do not involve technical changes to the Current TS (CTS), are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard _L.- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432. certain wording preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 1 Rev. A
i l NO SIGNIFICANT HAZARDS CONSIDERATION : ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 l ADMINISTRATIVE CHANGES (ITS 3.4.11 Discussion of Changes Labeled (A.1 and A.2) (continuad) l l Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? ' l The proposed changes involve reformatting, renumbering, and rewording of the CTS, along with the incorporation of PVNGS current operating practices 1 and other changes, as discussed, in order to be consistent with NUREG-1432. l The proposed changes do not involve a physical alteration of the plant (no new or di Uerent type of equipment will be installed) or change the methods l governir.g liormal plant operation. The proposed changes will not impose any , new or different requirements or eliminate any existing requirements. I Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. l Standard 3. Does the proposed change involve a significant reduction in a l margin of safety? I The proposed changes involve reformatting, renumber'ing, and rewording of the CTS, along with the incorporation of PVNGS current operating practices i and other changes, as discussed, in order to be consistent with NUREG-1432. ) The proposed changes are administrative in nature and will not involve any technical changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. I
~
PALO VERDE - UNITS 1,2, AND 3 2 Rev.A
l NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 l TECHNICAL CHANGES - HORE RESTRICTIVE , (ITS 3.4.11 Discussion of Changes Labeled H.1) i Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). l Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. This particular NSHC is for the changes labeled " Technical Changes - More Restrictive" described in the specific Discussion of Changes listed above. The proposed changes incorporate more restrictive changes into the CTS by either making current requirements more stringent or adding new requirements which currently do not exist. i i The Commission has provided standards for determining whether a significant ! hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to j an operating license for a facility involves a no significant hazards l consideration if operation of the facility. in accordance with a proposed j amendment would not 1) involve a significant increase in the probability or i consequences of an accident previously evaluated: 2) create the possibility of a new or different kinc of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
1 Standard 1.-- Does the proposed change involve a significant increase in the 1 4 probability or consequences of an accident previously evaluated? l The proposed changes provide more stringent requirements than previously existed in the CTS. The more stringent requirements will not result in
- operation that will increase the probability of initiating an analyzed i event. If anything, the new requirements may decrease the probability or j consequences of an analyzed, event by incorporating the more restrictive l changes discussed in the specific Discussion of Changes listed above.
1 These changes will not alter assumptions relative to mitigation of an i accident or transient event. The more restrictive requirements will not alter the operation and will continue to ensure process variables. structures, systems, or components are maintained consistent with safety 1- analyses and licensing basis. These changes have been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, these changes will not involve a significant increase in the 4 probability or consequences of an accident evaluated. ' PALO VERDE - UNITS 1,2, AND 3 3 Rev. A
l l NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 1 TECHNICAL CHANGES MORE RESTRICTIVE (ITS 3.4.11 Discussion of Changes Labeled M.1) (continued) Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? Making existing requirements more restrictive and adding more restrictive requirements to the CTS will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes do impose different , requirements. However they are consistent with the assumptions made in the safety analyses. licensing basis, and NUREG-1432. Therefore these 1 changes will not create the possibility of a new or different kind of l accident from any accident previously evaluated. j Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? l The proposed changes provide more stringent requirements than previously i existed in the CTS. An evaluation of these changes concluded that adding these more restrictive requirements either increases or has no impact on the margin of safety. The changes provide additional restrictions which ) may enhance plant safety. These changes maintain requirements of the safety analysis, licensing basis and NUREG-1432. As such. no question of safety is involved. Therefore, these changes will not involve a significant reduction in a margin of safety. j PALO VERDE - UNITS 1,2, AND 3 4 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 TECHNICAL CHANGES RELOCATIONS (ITS 3.4.11 Discussion of Changes Labeled LA.1) Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed changes, since detail is being removed from the CTS to a Licensee Controlled Document, are less restrictive. The descriptions of these changes are in the Discussion of Changes listed above. The Commission has provided staridards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these stan.dards as they relate to this amendment request follows:
Standard 1, Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes do not result in any hardware changes or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee Controlled Document containing the relocated requirements will be j maintained using the provisions of 10 CFR 50.59 or other specified control l processes and is subject, to the change control process in the Administrative Controls Section of the ITS. Since any changes to a Licensee Controlled Document will be evaluated, no increase in the probability or consequences of an accident previously evaluated will be allowed. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. l l l PALO VERDE - UNITS 1,2, AND 3 5 Rev. A l s l
NO SIGNIFICANT HAZARDS CONSIDERATION ,' ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 1 TECHNICAL CHANGES - RELOCATIONS (ITS 3.4.11 Discussion of Changes Labeled LA.1) (continued) Standard 2. - Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee
, Controlled Document. These changes will not alter the plant configuration j
(no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes will not impose , different requirements and adequate control of information will still be s maintained. These changes will not alter assumptions made in the safety l analysis or licensing basis. Therefore, these changes will not create the,.
! possibility of a new or different kind of accident from any accident previously evaluated.
Standard 3.- Does the proposed change involve a significant reduction in a l margin of safety? i l The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not reduce a margin of safety since they have no impact on any safety analysis assumptions. In addition. } the requirements to be transposed from the CTS to the Licensee Controlled Document .are the same as the CTS. Since any future changes to this , Licensee Controlled Document will be evaluated per the requirements of j 10 CFR 50.59, or other specified control processes, no reduction
- (significant or insignificant) in a margin of safety will be allowed.
. Therefore, these changes will not involve a significant reduction in a
- margin of safety. ,
The NRC review provides a certain margin of safety. and although this , review will no longer be performed prior to submittal, the NRC still l inspects the 10 CFR 50.59 process. The proposed changes are consistent J with NUREG-1432, which was approved by the NRC Staff. The change controls for proposed relocated details and requirements provide an acceptable level
- of regulatory authority. Revising the CTS to reflect the approved level i
of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore, revising the CTS i; to reflect the NRC accepted level of detail and requirements ensures no reduction in a margin of safety. l PALO VERDE - UNITS 1,2, AND 3 6 Rev. A
\
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 TECHNICAL CHANGES LESS RESTRICTIVE '
- l. (ITS 3.4.11- Discussion of Changes Labeled L.1) :
Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS). l Units 1, 2, and 3 is converting to the ITS as outlined in NUREG-1432. The ! l proposed change involves making the CTS less restrictive. Below is the ; description of.this less restrictive change and the NSHC for the conversion to i NUREG 1432. i L.1 CTS 3.4.2.1, Action a, requires immediate suspension of all operations i involving positive reactivity changes and to place an Operable shutdown ! cooling loop into operation. ITS requires entry into Mode 4 with one Shutdown Cooling System suction line relief valve in service, or the unit f is placed in a condition where the LC0 does not apply. Removing the ! i requirement to suspend all operations involving positive reactivity l constitutes a less restrictive change. This is acceptable because (1) there l are no credible accidents in Mode 4 above L-TOP System enable temperatures : i that require the operation of more than one pressurizer safety valve for ; event mitigation (2) in Mode 4 above L-TOP enable temperatures a Shutdown ! Cooling System suction line relief valve in service provides overpressure l protection in the event that no pressurizer safety valves are Operable. (3) l if no pressurizer safety valves or Shutdown Cooling System suction line i relief valves are Operable the unit is placed in a condition where the LC0 : does not apply. This change is consistent with NUREG-1432. . The Commission has provided standards for determining whether a significant , l hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or l consequences of an accident previorsly evaluated: 2) create the possibility of I a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
1 1 I I PALO VERDE - UNITF !!2, AND 3 7 Rev. A ! l
NO SIGNIFICANT IIAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.11 Discussion of Changes Labeled L.1) (continued) Standard 1. - Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change relaxes the requirement to immediately suspend all operation involving positive reactivity changes and place the operable shutdown cooling loop into operation. The ITS only requires entry into Mode 4 with all RCS cold leg temperatures < 214 F during cooldown or Mode 4 with all RCS cold leg temperature < 291 F during heatup. This is acceptable since there is no credible accidents in Mode 4 that require the operation of more than one pressurizer safety valve for event mitigation. Implementation of this change will not result in operation that will increase the probability of initiating an analyzed event. This change will not alter assumptions relative to mitigation of an accident or transient event. This change has been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore. this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. Standard 2. Does tho proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? Relaxing the requirement of suspending operation involving positive reactivity changes and place an operable shutdown cooling loop into operation does not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. This change relaxes CTS requirements however, this is still consistent with the safety analyses, licensing basis, and NUREG-1432. Therefore, this change will to create the possibility of a new or different ! kind of accident from any accident previously evaluated. i PALO VERDE - UNITS 1,2, AND 3 8 Rev. A
NO SIGNIFICANT IIAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 l TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.11 Discussion of Changes Labeled L.1) (continued) Stendard 23 -- Does the proposed change involve a significant reduction in a i margin of safety? , The proposed change provides relaxation from the CTS by not requiring the suspension of all operations involving positive reactivity changes and l placing an operable shutdown cooling loop into operation. An evaluation of this change concluded that the is no impact on the margin of safety. ! The change maintains the requirements of the safety analysis, licensing i basis, and consistent with NUREG-1432. As such, no question of safety is ! involved. Therefore, this change will not involve a significant reduction in a margin of safety. I i i I l l l l l l l 3 PALO VERDE - UNITS 1,2, AND 3 9 Rev. A f
l
- NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.11 Discussion of Changes Labeled L.2) i Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS).
Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the description of this less restrictive change and the NSHC for conversion to ) NUREG-1432. L.2 CTS 3.4.2.1. Action b contains a statement allowing the suspension of Specification 3.0.4 for up to 12 hours for entry into Mode 4. ITS 3.4.11 ; contains a NOTE that allows pressurizer safety valve settings to be outside the limits of the LC0 in Modes 3 and 4. and for 72 hours following entry l into Mode 3. for the purpose of setting the pressurizer safety valve lift ! settings under ambient conditions, provided a preliminary cold setting was l made prior to heatup, Allowing entry into Mode 3 by temporarily suspending LC0 requirements for 72 hours to allow pressurizer safety valve testing constitutes a less restrictive change. This permits testing and examination of the pressurizer safety valves at high pressure and temperature near - their normal operating range, but only after the valves have had a ; preliminary cold setting. This change is acceptable because the cold i setting gives assurance that the valves are OPERABLE near their design l condition. The 72 hour exception is based on 18 hour outage time for each 1 of the valves. The 18 hour period is derived from operating experience that hot testing can be performed within this time frame. This change is consistent with NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility. in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
PALO VERDE - UNITS 1,2, AND 3 10 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.11 Discussion of Changes Labeled L.2) (continued) Standard 1.-- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change provides a Note that allows the pressurizer safety valve setting to be outside the limits for 72 hours following entry into Mode 3 for the purpose of setting the pressurizer safety valve lift settings under ambient conditions, provided a preliminary clod setting was made prior to heatup. The CTS does not provide this allowance. The 72 hour exception is based on 18 hour outage time for each of the valves. The 18 hour period is derived from operating experience that hot testing can be performed within the time frame. This change does not result in I operation that will increase the probability of initiating an analyzed l event This change will not alter assumptions relative to mitigation of I an accident or transient event. This change has been reviewed to ensure : that no previously evaluated accident has been adversely affected. l Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluated. Standard 2.-- Does the proposed change create the possibility of a new or ) different kind of accident from any accident previously evaluated? 1 Allowing the 72 hours following entry into Mode 3 for the purpose of setting the pressurizer safety valve setting does not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. This change provides relaxation by allowing a 72, hour grace period to set the safety valves, however, this is consistent with the assumption made in the safety analyses, licensing basis, and NUREG-1432. Therefore, this change well not create the possibility of a new or different kind of accident from any l accident previously evaluated. < l l i i PALO VERDE - UNITS 1,2, AND 3 11 Rev.A
._ - - - - - ..~ . --- ~ - - .. . .- - _ _-- ..
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 L TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.11 Discussion of Changes Labeled L.2) (continued) Standard 3. Does the proposed change involve a significant reduction in a margin of safety? j The proposed change provides relaxation by allowing 72 hours after entering l Mode 3 to set the pressurizer safety valve setting. An evaluation of this ! change has been performed and concluded that there is no impact on the margin of safety. The change maintains the requirement of the safety analyses. licensing basis, and NUREG-1432. As such, n question of safety in involved. Therefore, this change will not involve a significant reduction in a margin of safety. l i l l l l 4 PALO VERDE - UNITS 1,2, AND 3 12 Rev.A l
NO SIGNIFICANT HAZARDS CONSIDERATION 1 ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.11 Discussion of Changes Labeled L.3) Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the description of this less restrictive change and the NSHC for conversion to NUREG-1432.
- L.3 CTS 3.4.2.1 uses Mode 4 Applicability. ITS 3.4.11 Applicability uses Mode 4 with all RCS cold leg temperature > 214 F during cooldown and Mode 4 with all RCS cold leg temperature > 291 F during heatup. Not requiring Applicability throughout Mode 4 constitutes a less restrictive change. This change is acceptable because the LTOP System provides overpressure protection in Mode 4 with all RCS cold leg temperature s 214 F during i cooldown and Mode 4 with all RCS cold leg temperature s 291 F during heatup.
This change is consistent with NUREG-1432. The Commission has provided standards for deteripining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility. in accordance with a proposed amendment, would not 1) involve a significant increase in the' probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change relaxes the requirements for entry into Mode 4 by allowing RCS cold leg temperature 214 F during cooldown and Mode 4 with RCS cold leg temperature > 291 F during heatup. Relaxing the CTS requirements will not result in operation that will increase the probability of initiating an analyzed event. This change will not alter assumptions relative to mitigation of an accident or transient event. This change has been reviewed to ensure that no previously evaluated accident have been adversely affected. Therefore this change will n involve a significant increase in the probability or consequence of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 13 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.11 - Pressurizer Safety Valves - Mode 4 i TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.11 Discussion of Changes Labeled L.3) (continued) i Standard 2. Does the proposed change create the possibility of a new or l different kind of accident from any accident previously evaluated? l Relaxing the requirement for Mode 4 operations will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal pant operation. This change is consistent with assumptions made in the safety analyses, licensing basis, l and NUREG-1432. Therefore. this change will not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3. Does the proposed change involve a significant reduction in a margin i of safety? The proposed change relaxes Mode 4 requirements which will not result in operation that will increase the probability of initiating an analyzed event. This change will not alter assumptions relative to mitigation of an accident or transient event. This change has been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, this change will not involve a significant increase in the probability or consequences of an accident evaluated. PALO VERDE - UNITS 1,2, AND 3 14 Rev. A
1 I I l l CE STS i NUREG-1432 REV.1 SPECIFICATION 3.4.12 MARK UP i
] ' Vents ' Pressurizer 3.4 (ad 3.4 REACTOR COOLANT SYSTEM (RCS) - Ytnk.S ' Pressurizer F;ur ^;:--t:d ..::f ";' .;; '"^"";; -
- 3.4.
0 , ,iL.C_O 3.4. tc0 3.4. aOvfe. -f M$$wi2.tr
; r d e. r':t:d VCeth 'h'f k0a' shall be OPERABLE. % 1(
APPLICABILITY: MODES 1, 2,
- ca n d h
DDC. E1) ACTIONS
~
4
%:..._ :a=-__a._.=_. ..... . .. ... ._., ._. .__n_ _ _ .. _...__._..--NOT
.. - .. E S -/---------------
n, 4 --.-,..uu Q., i e._ _ ,c _______ __.:::_:::_ ._.. ___. __ .______......____...__ ___ __ _ ______ __.J CONDITION REQUIRED ACTION COMPLETION TIME
/
i e or more PORVs A.1 C se and maintain I hour 1 'jir,' inoperable and pable er to associated l lock valve. of being manua y cycled. l I Ih r J. ^.ari Z inoperable. [B3 lose associst block valve. ad ::t 5p 2 - ~ being mua13y-cyc4ed, l CTIO N 4 .2 Remov power from I hou i b h 9tulpreu.ro g asso ated block ht pu h rab p r W v W Restore to 72 hours l OPERABLE status. g,f (continued) b (U - ONib Q h 3.4-22 Rev +, e,,^,7/; L
, 00 ;!;-
- .~. . _ _
i Pressurizer 3.47 ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME i 8 . _ . ._ bE l - ' - . inoperable. r) C. ace associa in manual e PORV ol. 1h l p
/
OcTtod b pressori th onc. i Restore h hours l N4f [ _ y to OPERABLE status. Required Action and 1 Be in MODE 3. 6 hours kCTiedOL associated Completio I ggb Time of Condition AtQ A or not met. g hours g 2 Be in MODE P1" 9 PSG-
/
E. Two RVs inoperable E.1 Close asso lated I hour and at capable of block vai es. be g manually cyc1 . AE 1 ' E.2 Re e power from 1 our as ciated block v ves. i A!Q E.3 Be in MODE 3. 6 hours E.4- Be in MODE . [12]ho s More than one b k F.1 Place sociated I ho valve inoperable. PORVs i nual control. J (continued N
- 3. t.-13 Rev iD7/o;~
- . - - . . - . - . . ~ . . -. - - - . . . . . . ~ . ~ . . ~ . . - - - . . - . ~ ... -. -.... -... ... - . ~
i i l i i-4 Vani5 ! i-Pressurizer /g f 3.4.h 4 b ACTIONS ! COMPLETION TIME i CONDITION llEQUIRED ACTION l. F.2 Restore at least e 2 hours ) W conti ued) block valve to l PERABLE status.
\ <
s l . y Be in E 3. 6 urs
. Required Actio and G.1
- I associated Comp tion
' Time of Condition AllQ t met. {12)hou G.2 Be in MODE
\ .
SURVEILLANCE REQUIREMENTS FREQUENCY SURVEILLANCE
- 3. 11.1 - ------------ NOT E---------- --------
Not equired to be rformed with ock valv closed in acco ance with the Requi d Actions of t s LCO. complete cycle each block [92 days) Perform valve. ths h q,q ,go , g / SR 2-3 . . Perfom a conolete evels of amehM. CerEssa n w vm i val *' Y
)(1
~ l ~
g<_
' n d ::'.; 11BJmonths SR 3 4. .K P:r'; =: ---1:t: : '
/
air trol valve andf:'" ck valve on[n" /\
/} air er h +--- " .... ;ntn! :;- .
/$t{.10. C, J'
~ m
-\ L _
(continued) YvlI[y tmh a
-[l5.s d V N 04 N fritsurtZ*r) f -
boM 'UND [ 3.4-24 Rev m ' / 07 /^2
l l l
- 1
- Pressurizer 3.4.[h
^
ShVEILLANCEREQUIRE TS (continued)\ \ J
\ VEILLANCE
\ kEQUENCY i SR 3. 11.4 Verify PORVs d block valve (s) re capable [18) mo hs of being powere from an emergene power ,
supply. 1 i N N j i i i . l 1 5 . ! l i 1 i J i i l 1 i i i e I i j I 7 i 1 4 1
- k\eV_irde.-VmNb\ glib k
.cc. : L 3.4-25 Rev 1. ^^!^7/^s' i
a 4
CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.12 BASES MARK UP I l l
l2rab Pressurizer PORVs ~ B 3.4 B 3.4 OR COOLANT SYSTEM (RCS)
\ h B 3.4 ressurizer4w ^-- :S' R:lhf Wh:: 'P^RW )
% ES / / pV BACKGROUND The pressurizer is equipped th two types of devices fo pressure relief: pressu ter safety valves and PORVs./The ' PORV is an air operated Ive that is automatically op'ened at a specific set pres, re when the pressurizer pressure increases and is automatically closed on decreasing pressure. The PORV'may also be manually operated using controls insta11ed' in the control room.
/
An electric, motor operated, normally open, lock valve is
/ installed between the pressurizer and the#0RV. The rtM 1 function of'the block valve is to isola}e' the PORV. Block i
valve closure is accomplished manually /using controls in the controlhoom and may be used to isolate a leaking PORV to. permiVcontinued power operation. ost importantly, the block valve is used to isolate a uck open PORV to isolate the'resulting small break loss coolant accident (LOCA). l Ciosure terminates the RCS de essurization and coolant
/inventoryloss.
The PORY and its block v ve controls are powered fro j normal power supplies. heir controls are also cap le of being powered from e gency supplies. Power sup ies for , the PORV are separa from those for the block v ve. Power J supply requiremen are defined in NUREG-0737, -
/ Paragraph III, G (Ref.1).
/ The PORY set int is above the high press e reactor trip
/
setpoint and'below the opening setpoint or the pressurizer safety vaWes as required by Reference . The purpose of the relaytienship of these setpoints to limit the number of transient pressure increase chal nges that might open the BORY, which, if opened, could all in the open position. The/90RV setpoint thus limits t frequency of challenges fr6m transients and limits the ossibility of a small break , OCA from a failed open PORV Placing the setpoint below ! the pressurizer safety valv opening setpoint reduces the frequency of challenges t the safety valves, which, un ke the PORV, cannot be iso ted if they were to fail to en. The primary purpose of this LCO is to ensure that e PORV, its setpoint, and e block valve are operating rrectly so (continued) J
, / a (f Rev 1. ** C fZ -Gu B 3.4-48 Gbkfdo-M Ch13
Pressurizer B 3.4. - e Y BASES
/ / )
BACKGROUND he potential for a small b ak LOCA through the PORY (continued) pathway is minimized, or i a small break LOCA were to Accur throu h a failed open PO , the block valve could be / manua ly operated to i ate the path. The PORY may be man ly operated to depressurizp'the RCS as deemed necessary b the operator in response to/nomal or abnormal transie s. The PORY may be used for/ depressurizatio when the pressurizer spray As not available, a ndition that may be encountered during loss of offsite power. Operators can manually'open the PORVs to reduce RCS ressure in the event of a steam generator tube rupture GTR) with offsite power unava'ilable. 4 / j~ The P(/V may also be used for feedjnd bleed core cooling in the se of multiple equipment fajiure events that are not 3 wi in the design basis, such as/a total loss of feedwater.
/
he PORV functions as an automatic overpressure device and limits challenges to the safety valves. Although the P0 acts as an overpressure device for operational purposes safety analyses [do not ,take credit for PORY actuatio , but] do take credit for the safety valves. J / The PORV also provide's low temperature overpressu protection (LTOP) .during heatup and cooldown. 0 3.4.12.
" Low Temperaturef0verpressure Protection (LTOP System,"
addresses thisyfunction.
- / /
The PORY small break LOCA break size i bounded by the i ' APPLICABLE SAFETY ANALYSES spectrum' of piping breaks analyzed f plant licensing. Because the PORV small break LOCA i located at the top of the pressurizer, the RCS response haracteristics are different from RCS loop piping b enks; analyses have been performed to investigate these haracteristics.
~ The possibility of a small eak LOCA through the PORV is reduced when the PORV fio path is OPERABLE and the POR opening setpoint is esta ished to be reasonably remot from expected transient cha enges. The possibility is e imized if the flow path is i lated.
The PORY opening point has been established i accordance with Reference 2 It has been set so expected CS pressure j (continued) u / / 5 B 3.4-49 Rev 1, 00/07/;, hYefdt.-VMO h2.3
Pressurizer B3.4 g l BASES APPLICABLE increases from anticipated ansients will not challenge t SAFETY ANALYS PORV, minimizing the possi lity of small break LOCA thropgh (continue the PORV. Overpressure protecti credit is provided by safety valves analyses do not tak for the PORV opening for/and accident mitigatio . Pressurizer P0 s satisfy Criterion 3 of the N Policy Statement. LC0 The LC ouires the PORV and its asso ated block valve to be OP LE. The block valve is reo red to be OPERABLE so it y be used to isolate the flow ath if the PORV is not OP LE. PORV setpoint is correct. , alve OPERABILITY also means t j ing setpoint is correct, the By PORV ensuring is notthat the PORV subject to fre op nt challenges from possible s, and therefore the possibi ty pressure increase of a small break LOCA t transieough a failed open PORV is an frequent event. In MODES 1, 2, 3, the PORV and its block lve are AP ICABILITY for a small required to be PERABLE to limit the potent break LOCA t ough the flow path. A likel cause for PORV small brea OCA is a result of pressure nerease transients in the energy that caus the PORV to open. Imbalanc output the core and heat removal b the secondary system can ca e the RCS pressure to incre e to the PORY opening setp nt. Pressure increase trans nts can occur any time th steam generators are used fo eat removal. The most her operating power and r id increases will occur at and 2. ressure conditions of MODES Pressure increases are les prominent in MODE 3 because t core input energy is red ed but the RCS pressure is h The . Therefore, this LCO is plicable in MODES 1, 2, and 3 core LCO is not applicable n MODE 4 when both pressure a and the pressure surges become uch energy are decrease he PORV setpoint is reduced f LTOP in less significant, I (continued)
/ / Y B 3.4-50 Rev 1, 04/;'/X, - iv Me - Oesp , z.. A @
1-i, Pressurizer B3.4.[ s/ i l BASES [ j I
- APPLICABILITY MODES 4, 5, and 6 with the r ctor vessel head in place.
j (continued) LC0 3.4.12 addresses the P0 requirements in these MODES. I
- -ACTIONS L1
, The ACTIONS are ified by two Notes. Note 1 e rifies
,' that all pressu zer PORVs are treated as separ e entities, each with sep te Completion Times (i.e., th Completion ( Time is on a omponent basis). Note 2 is a exception to
- LCO 3.0.4. he exception for LCO 3.0.4 p its entry into i MODES 1 , and 3 to perform cycling of e PORY or block
- valve t verify their OPERABLE status, esting is typically
, not p formed in lower MODES. Wi the PORV inoperable and capa e of being manually cled, either the PORY must be estored or the flow path i- solated within I hour. The b ek valve should be closed , j but power must be maintained o the associated block valv , ; since removal of power woul render the block valve ; j inoperable. Although the RV may be designated inope ble, I it may be able to be ma ally opened and closed and this , !' manner can be used to erform its function. -PORY ' inoperability may be ue to seat leakage, instr tation a problems, automati control problems, or other uses that j -do not prevent al use and do not create a ssibility ! for a small bre LOCA. For.these reasons, e block valve ! ! may be closed ut the Action requires power maintained to 4 the valve. is Condition is only intend to permit !' operation the plant for a limited per od of time not to i exceed t next refueling outage (MOD ) so that . ! mainte ce can be performed on the Vs to eliminate the z. probl condition. The PORVs shou normally be available 4 for utomatic mitigation of overp ssure events and should be eturned to OPERABLE status ior to entering startup E 2). 4 j Quick access to the PORY f pressure control can be made
- when power remains on th losed block valve. The Completion Time of I ho is based on plant operatin experience that minor roblems can be corrected or c sure can be accomplished this time period.
j (continued)
/ / J
"^C !!C B 3.4-51 Rev M 4/n11 E b QdC.
- On85 k ,N
Pressuriz r b8ASES. / [ / [ B.1. B.2J and B.3 /
/ '
ACTIONS (continue ./ If one PORV is inoperapie and not capable of being manua y cycled, it must eith be isolated, by closing the associated block va e and removing the power from t block valve, or restore o OPERABLE status. The Complet)en Time of I hour is re onable, based on challenges to the' PORVs during this ti period, and provides the operator adequate time to corr t the situation. If the inoperabie valve cannot be stored to OPERABLE status, it must be isolated within t specified time. Because there i.s' at least one PORV th remains OPERABLE, an additional A2 hours is provi d to restore the inoperable PORY o OPERADLE status.
.1 and C.2 l
i If one block valve is inoperabl , then it must be restored ! to OPERABLE status, or the as ciated PORV placed in manual i control. The prime importa e for the capability to close ' the block valve is to isol e a stuck open PORV. Therefor , it the block valve cannoy'be restored to OPERACLE status within 1 hour, the Req fred Action is to place the POR in manual control to pre ude its automatic opening for n overpressure event d to avoid the potential for a 1e. tuck The open PORV at a ti that the block valve is inope Completion Times f 1 hour are reasonable based the small . potential for allenges to the system during is time t the-l l period and pr vide the operator time to corr OPERABLE, the situation. ecause at least one PORY remai operator permitted a Completion Time o 72 hours to restore he inoperable block valve to OP BLE status. The time owed to restore the block valv .is based upon the CompM tion Time for restoring an ino rable PORV in to ition B since the PORVs are no capable of mitigating an erpressure event when placed in anual control. If the ' lock valve is restored within e Completion Time of 72 hours, the power will be r cred and the PORV restored to OPERABLE status. D.1 and 0.2 If the Required Acti cannot be met within the a ociated Completion Time, t plant must be brought to a DE in which the requir nt does not apply. To achi e this (continued)
/ /-
Rev 1, ^^'^ /;; B 3.4-52
"^C ~
NYG1 = Nb
Pressuriz r - BASES [ ,,/ ACTIONS D.1 and D.2 (continued) status, the plant must b brought to at least MODE 3 wit n 6 hours and to MODE 4 thin 12 hours. The allowed Completion Times are asonable, based on operating experience, to rene the required plant conditions om full power conditions i an orderly manner and without challenging plan systems. E.1. E.2. E and E.4 If more an one PORV is inoperable and t capable of being
. manual' cycled, it is necessary to ei er restore at least I hour or isolate one v ve within the Completion Time the low path by closing and removi the power to the
, a ociated block valves. ~ The Comp tion Time of I hour is asonable based on the small po ntial for challenges to the system during this time and rovides the operator time to correct the situation. If ne PORV is restored and one PORV remains inoperable, th the plant will be in Condition B with the time ock started at the original declaration of having tw ORVs inoperable. If no PORVs re
' restored within the to etion Time, then the plant aus be brought to a MODE in ich the LCO does not apply. T achieve this status he plant must be brought to at east MODE 3 within 6 ho s and to MODE 4 within 12 hour The Completion Time 6 hours is reasonable, based operating experience, to ach MODE 3 from full power in orderly manner and wi out challenging plant systems, imilarly, the Completi n Time of 12 hours to reach MOD 4 is reasonable considering that a plant can c down within that ti frame on one safety system trai . In MODES 4 and 5, intaining PORV OPERABILITY may e required. See LCO 3 .12.
l F and F.2 If more than one block valve inoperable, it is necessary 1 to either restore the block lves within the Completio: 4 Time of I hour or place th associated PORVs in manual 1 control and restore at 1 t one block valve to OPERABL status within 2 hours a the remaining block valve in 72 hours. The Comple on Time of I hour to either r tore f [ the block valves or ace the associated PORVs in ual j (continued)
/ /
6 B 3.4-53 Rev 1, 0 /07/% - bONQtba - WND NE.h
l l-ED Pressurizer . i B 3.4.n l I BASES -/ / ACTIONS F.1 and F.2 (continued) i l control is reasonable b ed on the small potential for challenges to the syst during this time and provides ! operator time to cor et the situation. G.1 and G.2 If the Requi d Actions and associated Comple n Times of Condition or F are not met, then the plant st be brought to a MOD in which the LC0 does not apply. he plant must be bro t to at least MODE 3 within 6 ho s and to MODE 4
.withi 12 hours. The Completion Time o 6 hours is l nable, based on operating experi ce, to reach MODE 3 l
rea fr full power in an orderly manner nd without challenging l fety systems. Similarly, the C letion Time of 12 hours l to reach MODE 4 is reasonable co idering that a plant can cool down within that time fr on one safety system train, l 'In MODES 4 and 5. maintaining V OPERABILITY may be j - required. See LCO 3.4.12. l
/
SURVEJLLANCE SR 3.4.11.1 REQUIREMENTS
-' Block valve cycli verifies that it can be clos if
/ necessary. The sis for the Frequency of [92 ys)is l' If the block valve is clos to isolate a
'/ ASME XI (Ref. .
PORY that is apable of being manually cyc1 , the ' / OPERABILIT of the block valve is of impor nee because opening block valve is necessary to rett the PORV to ! be used or manual control of reactor essure. If the j block alve is closed to isolate an o erwise inoperable PORV the maximum Completion Time t restore the PORY and l l op the block valve is 72 hours, ich is well within the owable limit's (25%) to exten he block valve , urveillance interval of [92 d s]. Furthermore, these test l requirements would be comple d by the reopening of a recently closed block valv pon restoration of the PORV t OPERABLE status (i.e., c lation of the Required Action fulfills the SR). The Note modifies th SR by stating that this SR is ot required to be per reed with the block valve clos in l accordance with Required Actions of this LCO (continued)
, J 1
[ B 3.4-54 Rev I, 01/07/ S hw W NO YCNta= 0Rb b \1b
.- . . ... - .~ - -- - .- - - - .. ~.~ -.
l 1 l l l e.n j l l Pressurizer . 1 B 3.4,44. BASES l
- l l $ EILLANCE SR 3.4.11.2 l QUIREMENTS (continued) SR 3.4.11.2 rea es complete cycling of each PORY. RV cycling demon ates its function. The Frequency I
[18) months)t based on a typical refueling cyc1 and industry epted practice, l SR .4.11.3 I - erating the solenoid air control y ves and check valves on the air accumulators ensures thp'PORV control system l actuates properly when called upo6. The Frequency of [18] months is based on a typi refueling cycle and the Frequency of the other surv lances used to demonstrate PORV OPERABILITY. SR 3.4.11.4 i This Surveillan is not required for plants with rmanent IE power supp s to the valves. The test demor rates that emergency p r can be provided and is perfo by I transferr power from the nomal supply t he emergency supply cycling the valves. The Frequ y of [18) months l is ba on a typical refueling cycle a industry accepted ! pra ice. REFERENCES 1. NUREG-0737, Paragraph !! C.I. November 1980, 1 f 2. Inspection and Enfor nt (IE) Bulletin 79-05B, April I
/ 21, 1979. ! ,
a l
- 3. ASME, Boiler a Pressure Vessel Code, Section XI i i
/ -
Y / / b i l B 3.4-55 Rev i " ' ^ ~ ' " l Sb bac - UnA::, b?-O h
. 1
/NStLT 1--
Pressurizer Vents
/#5(t r /bt. IT$ 3 N.17. B 3.4.12 BMES ' \
s . I ! B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4.12 Pressurizer Vents-BASES I
- BACKGROUND The pressurizer vent is 3 art of the reactor coolant gas vent system (RCGVS) as descri)ed in UFSAR 18.II.B.1 (Ref.1). The pressurizer can be vented remotely from the control room
- through the following'four paths (see UFSAR Figure 18.II.B-1)
i From the pressurizer vent through SOV HV-103, then i 1. { through SOV HV-105 to the reactor drain tank (RTO). I i' 2. From the pressurizer vent through SOV HV-103, then i through SOV HV-106 directly to.the containment i atmosphere.
- 3. From the 3ressurizer vent through SOVs HV-108 and i HV-109. tien through S0V HV-105 to the reactor drain i- tank (RTD).
I 4. From the 3ressurizer vent through SOVs HV-108 and HV-109, tien through SOV HV-106 directly.to the containment atmosphere. The RCGVS also includes the reactor head vent..which can be used along with'the pressurizer vent to remotely vent gases that could inhibit natural circulation core cooling during post accident situations. -However, this function does not j meet the criteria of 10 CFR 50.36(c)(2)(ii) to require a I Technical Specification LCO, and therefore the reactor head i vent is not included in these Technical Specifications. l (continued) PALO VERDE UNITS 1.2.3. B 3.4.12-1 REV. B
Pressurizer Vents . 3.4.12 A BASES APPLICABLE The requirement for pre.ssurizer path vent path to be SAFETY ANALYSES OPERABLE is based on the st2am generator tube rupture (SGTR) . with loss of offsite power (LOP) and a single failure safety
- analysis, as described in UFSAR 15.6.3 (Ref. 4). It is assumed that the auxiliary pressurizer spray system (APSS) is not available for this event. Instead RCS depressurization is performed. 2 hours after the initial 5
SGTR, by venting the RCS via a pressurizer vent path and throttling HPSI flow. The analysis also incorporates an additional failure by assuming that only the smallest of the four available 3ressurizer vent paths is used. This is identified as tie orificed flow path to the RDT. The results of the analysis for steam generator tube rupture with a loss of offsite power and a fully stuck open ADV using the pressurizer vent system, forwarded to the NRC in Reference 3. states that the analysis assumes that the APSS is inoperable and the pressurizer gas vent system 3erforms the functions of RCS dearessurization. The staff las reviewed and accepted t1e results of the analysis and the design of the pressurizer gas vent system. The staff's detailed evaluation has been reported in Supplement No. 9 to PVNGS SER (Ref. 2). The 3ressurizer vent paths satisfy Criterion 3 of 10 C R 50.36 (c)(2)(ii). LCO The LCO requires four pressurizer vent paths be OPERABLE. The four vent paths are:
- 1. From the pressurizer vent through SOV HV-103, then through S0V HV-105 to tt.e reactor drain tank (RTD).
- 2. From the pressurizer vent through S0V HV-103. then through SOV HV-106 directly to the containment atmosphere.
- 3. From the 3ressurizer vent through SOVs HV-108 and HV-109. tien through SOV HV-105 to the reactor drain tank (RTD).
- 4. From the Jressurizer vent through SOVs HV-108 and HV-109. tien through SOV HV-106 directly to the containment atmosphere.
(continued) PALO VERDE UNITS 1,2.3 B 3.4.12-2 REV. B
Pressurizer Vents 3.4.12 BASES LCO A vent path is flow capability from the pressurizer to the (continued RDT or from the pressurizer to containment atmosphere. Loss of any single valve in the pressurizer vent system will causo two flow paths to become inoperable. A pressurizer vent path is required to depressurize the RCS in a SGTR design basis event which assumes LOP and APPS unavailable. APPLICABILITY In MODES 1, 2. 3. and MODE 4 with RCS pressure 2 385 psia ; the four pressurizer vent paths are required to be OPERABLE. l The safety analysis for the SGTR with LOP and a Single Failure (loss of APSS) credits a pressurizer vent path to : reduce RCS pressure. In MODES 1. 2. 3. and MODE 4 with RCS pressure 2 385 psia the SGs are the primary means of heat removal in the RCS. until shutdown cooling can be initiated. In MODES 1. 2. 3. and MODE 4 with RCS pressure 2 385 psia, assuming the APSS is not available. the pressurizer vent paths are the credited means to depressurize the RCS to Shutdown Cooling , System entry conditions. Further depressurization into MODE 5 requires use of the pressurizer vent paths. In MODE 5 with i the reactor vessel head in place, temperature requirements of MODE 5 (< 210 F) ensure the RCS remains depressurized. In MODE 6 the RCS is depressurized. ACTIONS A.1 If two or three pressurizer vent paths are inoperable, they must be restored to OPERABLE status. Loss of any single valve in the pressurizer vent system will cause two flow paths to become inoperable. Any vent path that provides flow capability from the pressurizer to the RDT or to the containment atmosphere, independent of which train is powering the valves in the flow path, can be considered an operable vent path. The Completion Time of 72 hours is reasonable because there is at least one pressurizer vent ; path that remains OPERABLE. ' 4 (continued) PALO VERDE UNITS 1.2.3 B 3.4.12-3 REV. B
Pressurizer Vents 3.4.12 i BASES , 4 l B.1 If all pressurizer vent paths are inoperable, then restore at least one pressurizer vent path to OPERABLE status. The Completion Time of 6 hours is reasonable to allow time to i correct the situation, yet emphasize the im]ortance of restoring at least one pressurizer vent pat 1 If at least one pressurizer vent path is not restored to OPERABLE within , the Completion Time, then Action C is entered. Cl If the recuired Actions. A and B. cannot be met within the associatec Completion Times. the plant must be brought to a , MODE in which the requirement does not apply. To achieve ; 4 this status. the plant must be brought to at least MODE O : within 6 hours. and to MODE 4 with RCS pressure < 385 psia ; 4 within 24 hours. The allowed Completion Times are ' reasonable. based on operating experience. to reach the recuired plant conditions from full power conditions in an orcerly manner without challenging plant systems. i SURVEILLANCE SR 3.4.12.1 REQUIREMENTS SR 3.4.12.1 requires complete cycling of each pressurizer ! vent path valve. The vent valves must be cycled from the 1 control room to demonstrate their operability. Pressurizer 1 vent path valve cycling demonstrates its function. The frequency of 18 months is based on a typical refueling cycle and industry accepted practice. This surveillance test must be performed in. Mode 5 or Mode 6. SR 3.4.12.2 3 SR 3.4.12.2 requires verification of flow through each ! pressurizer vent path. Verification of pressurizer vent l patn flow demonstrates its function. The frequency of 18 months is based on a typical refueling cycle and industry , accepted practice. This surveillance test must be performed ' in Mode 5 or Mode 6. 4 4 (continued) i PALO VERDE UNITS 1.2.3 B 3.4.12-4 REV. B
Pressurizer Vents 3.4.12 l L BASES l REFERENCES 1. UFSAR Section 18.
- 2. NUREG-0857. initial issue. November 1981 through Supplement 12. November 1987.
L 3 Letter from Arizona Nuclear Power Project to NRC (ANPP-33905) dated November 4. 1985. "Information , Concerning the PVNGS Auxiliary Pressurizer Spray."
- 4. UFSAR. Section 15.
l l I f l l J PALO VERDE UNITS 1.2.3 B 3.4.12-5 REV. B J w
samaA i 4 NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.12 4 4 4 l
PALO VERDE ITS CONVERSION j NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.12 - Pressurizer Vents
- 1. ITS retains requirements associated with pressurizer pathway vents in I Specification 3.412. NUREG-1432 has no Specification associated with i pressurizer pathway vents. PVNGS. credits the pressurizer pathway vents as the depressurization method for the Steam Generator Tube Rupture (SGTR) design basis event. This Specification will be retained thus meeting criterion 3 of 10 CFR 50.36 (c) (2) (ii). This change is consistent with PVNGS licensing basis.
- 2. Grammar and/or editorial changes have been made to enhance clarity. No l technical or intent changes to the Specification are made by this change. l i
- 3. The plant specific titles, nomenclature, number. parameter /value, I reference, system description, system design, operating practices or analysis description was used (additions, deletions, and/or changes are included). Plant specific parameters / values are directly transferred from ,
the CTS to the ITS. l l I l l I l l i PALO VERDE - UNITS 1,2, AND 3 1 REV.B
PVNGS CTS SPECIFICATION 3.4.12 , MARK UP I i i l
b&OR b.$. \l
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-haut eye" VENTS 4?""!NO COM !'!0M TOS Or C'T 0N k,3
!._b,1!, Both,r;3_:_*g _ gg' p y:t
_. -, .... ... vent paths shall be operable er.d :i: d at-gg a. Reactor vessel head, and j Db 3A.lt XW APPL!CABillTY: MODES 1, 2, 3 and 4 whn M.e pooeurs A SttTgo. ug ACTION: h( [ Vith only one of the above required r paths OPERABLE, fr= :!th: ': n t:... ,estore or coolant system vent both naths at that M*{
] location to OPERABLE status within 72 hoursfor be in at. least H077
~
TANDBY within the next 6 hours and in HOT 5 HUT 00WN(f within the followino 6 hours # - gM m <gId
- f. I h none of the above required r ~
ent pat OPERABLE, fr= :ith:r '.:nti: 6 tore at least one path at that .b f C. cation to 0PERABLE status within the nart 6 hours 4 r be in at least HOT STANDBY within the next 6 hours and in HDT SHUTDOWH e. j ithin the followino I hoursf - _ - - -- SURVEILLANCE REQUIREHENTS h\. \ MiE, hS N _3 AL2. t least once cedbenths rwnen ivM00Evs ne%3bv-Each Reactor lab Coolant S F [. fying all the open nual isola) ion valves % each ventW5ath are lor /eDC ition.f [g,g VC "" 'ac _ vent valve throuch at least one eggplete cycle b ^^ th ? b M. [ _Verifying flow through the reactor coolant system vent paths LAf. r durino ventino. ] { 1 l 1 3/4 4 35 i Palo Verde - Units 1, 2, 3
1 i DISCUSSION OF CHANGES SPECIFICATION 3.4.12 I l ? i 1
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.12 - Pressurizer Vents ADMINISTRATIVE CHANGES A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432. i Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station (PVNGS) Improved Technical Specifications (ITS) should be more readable, and therefore understandable, by plant operators as well as other users. : During the reformatting and renumbering of the ITS. no technical changes I (either actual or interpretational) to the Current Technical Specifications (CTS) were made unless they were identified and justified. l l Editorial rewording (either adding or deleting) is made consistent with NUREG-1432. During NUREG-1432 development, certain wording preferences or i English language conventions were adopted which resulted in no technical ' changes (either actual or interpretational) the CTS. l i Additional information has also been added to more fully describe each l subsection. This wordirig is consistent with NUREG-1432. Since the design i is already approved by the NRC, adding more detail does not result in a ! technical change. A.2 CTS 3.4.10. Actions a and b. require the RCS vent function from both the pressurizer vent and reactor vessel head vents to be Operable. As discussed in the Split Report. the reactor vessel head vent requirements are being relocated from the ITS. Portions of the CTS LCO. Actions, and Surveillances that relate to having both vent locations within the TS (e.g. , "from either location"), are being editorially revised. Therefore the removal of this information from ITS 3.4.12 is administrative in nature and consistent with NUREG-1432. A.3 CTS LC0 3.4.10 requires the pressurizer vent paths to be " operable and closed." ITS 3.4.12 requires pressurizer vent paths to be Operable, but does not detail "and closed." The CTS 3.4.10 requirement for the pressurizer vent valves to be closed is not required to mitigate the SGTR with LOP design basis accident, does not fall under the criterion of 10 CFR 50.36(c)(2)(ii). and is therefore not required to be included in ITS LCO 3.4.12. Since the necessity for the closed vent paths is adequately addressed in the ITS LC0 for "RCS LEAKAGE." this specific detail is not needed in ITS 3.4.12. Pressurizer Vents. Any open vent path would result in excessive RCS LEAKAGE. Duplicating requirements in multiple Specifications is not necessary or consistent with NUREG-1432 philosophy. Therefore the removal of this information from ITS 3.4.12 is administrative in nature. This change is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 1 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.12 - Pressurizer Vents TECHNICAL CHANGES MORE RESTRICTIVE M.1 CTS 3.4.10 (Reactor Coolant System Vents) LCO is specified as applicable in MODES 1. 2, 3, and 4. However, the ACTIONS for CTS 3.4.10 require an end-state of MODE 4, which would not put the plant in a mode where the LCO is not applicable. This anomaly in CTS results in the need to justify the new ITS 3.4.12 (Pressurizer Vents) APPLICABILITY of Mode 1, 2, 3, and 4 with RCS pressure 2385 psia as a less restrictive change to CTS, and the new ITS ACTION end-state of Mode 4 with RCS pressure <385 psia as a more restrictive change to CTS. The more restrictive change to the ACTIONS is discussed below, and the less restrictive change to the APPLICABILITY is discussed in DOC Section L.1. The change to the required ACTION end-state mode in ITS 3.4.12 (Pressurizer Vents) of MODE 4 with RCS pressure <385 psia is more restrictive than the CTS 3.4.10 (RCS Vents) ACTION end-state of MODE 4. This change is acceptable because the ITS ACTION end-state to reduce RCS pressure to less than 385 psia would ensure that the plant is in a condition where the LCO is no longer applicable and the SGTR safety analysis requirement for pressurizer vent is no longer applicable. If the plant were only required to go to the CTS end-state of MODE 4. the RCS pressure may still be at or above 385 psia which would be above shutdown cooling entry. conditions and not consistent with the SGTR safety analysis. The increase of 12 hours allowed to get to the new end-state of MODE 4 with RCS pressure less than 385 psia in ITS is consistent with the end-state change since the additional time is needed to perform an orderly cooldown and depressurization to the more restrictive end state (lower pressure) without challenging plant systems. PALO VERDE - UNITS 1,2, AND 3 2 REV,A i 1
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.12 - Pressurizer Vents TECHNICAL CHANGES - RELOCATIONS LA.1 CTS SR 4.4.10.a requires the verification of all manual isolation valves in the pressurizer vent path to be locked in the open position, while the ITS 3.4.12 does not specifically retain this Surveillance. This requirement is not required to determine the Operability of a system, component or structure and therefore is being relocated to a Licensee Controlled Document (Technical Requirements Manual [TRM]). The CTS 4.4.10 surveillance requirement to verify all manual isolation valves in each vent pathway are locked in the open position every 18 months is not required to mitigate the SGTR with LOP design basis accident. does not fall under the criterion of 10 CFR 50.36(c)(2)(ii), and is therefore not required to be included in ITS LCO 3.4.12. Maintaining the pressurizer vent path manual isolations open is an implicit requirement for Operability of the flow path, and is directly confirmed during the ITS SR 3.4.12.2 (same as CTS SR 4.4.10.c). which requires verifying flow through the pressurizer vent path. The requirement to " lock" the pressurizer vent path manual isolation valves is adequately controlled by plant procedures. This specific detail can be relocated from the Specification for pressurizer vent path Operability. Any changes to the TRM will be in accordance with 10 CFR 50.59. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This requirement is not required to be in the ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to a Licensee Controlled Document is acceptable and is consistent with NUREG-1432. LA.2 CTS SR 4.4.10.b details that the method for cycling each vent valve be "from the control room." The ITS SRs do not typically detail methods for performing Surveillances. This information is not required to determine the ; OPERABILITY of a system, component or structure and therefore is being ' relocated to a Licensee Controlled Document (Bases Section). In addition, i this requirement does not meet the criterion of 10 CFR 50.36 (c) (2) (ii) ' for inclusion into ITS. Any changes to the Bases will be in accordance with Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This requirement is not required to be in the ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to i a Licensee Controlled Document is acceptable and is consistent with i NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 3 REV.B
E PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES
! SPECIFICATION 3.4.12 - Pressurizer Vents TECHNICAL CHANGES RELOCATIONS (continued)
- LA.3 CTS SR 4.4.10 requires vent path Surveillances be performed "when in MODES 5 or 6." The ITS SRs do not detail any restrictions for performance of the Surveillances. This requirement is not required to determine the OPERABILITY of a system, component or structure and therefore is being i
I relocated to a Licensee Controlled Document (Bases Section). This limitation is not necessary to ensure the OPERABILITY of the pressurizer vent paths, and can be adequately controlled in a Licensee Controlled ' Document. In addition, this requirement does not meet the criterion of 10 CFR 50.36 (c) (2) (ii) for inclusion into ITS. Any changes to the Bases will be in accordance with Chapter 5.0 Bases Control Program. This provides an equivalent level of control and is an , administrative change with no impact on the margin of safety. This requirement is not required to be in the ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to a Licensee Controlled Document is acceptable and is consistent with j NUREG-1432. TECHNICAL CHANGES LESS RESTRICTIVE L.1 CTS 3.4.10 (Reactor Coolant System Vents) LC0 is specified as applicable in MODES 1. 2. 3. and 4. However, the ACTIONS for CTS 3.4.10 require an end-state of MODE 4 which would not put the plant in a mode where the LCO is not applicable. This anomaly in CTS results in the need to justify the new ITS 3.4.12 (Pressurizer Vents) APPLICABILITY of Mode 1. 2. 3. and 4 4 with RCS pressure 2385 psia as a less restrictive change to CTS. and the new ITS ACTION end-state of Mode 4 with RCS pressure <385 psia as a more restrictive change to CTS. The less restrictive change to the APPLICABILITY is discussed below, and the more restrictive change to the ACTIONS is discussed in DOC Section M.1. The change to the pressurizer vent path LCO APPLICABILITY in ITS 3.4.12 will require the pressurizer vent path LCO to be APPLICABLE in Modes 1, 2.
- 3. and 4 with RCS pressure 2385 psia. This is less restrictive than the CTS requirement for RCS vent paths to be OPERABLE in MODES 1, 2. 3. and 4.
since the new ITS would not require RCS vent paths to be OPERABLE in MODE 4 below 385 psia. This change is acceptable since the safety analysis that credits the pressurizer vents for RCS depressurization (SGTR with LOP and i failure of the APSS) considers the SGTR event terminated when shutdown cooling entry conditions are reached, which is in Mode 4 with RCS pressure
<385 psia. This change does not impact safety and is consistent with the PVNGS safety analysis.
4 PALO VERDE - UNITS 1,2, AND 3 4 REV.B 5
J NO SIGNIFICANT HAZARDS CONSIDERATION SPECIFICATION 3.4.12 f
)
NO SIGNIFICANT HAZARDS CONSIDERATION l ITS Section 3.4.12 - Pressurizer Vents ADMINISTRATIVE CHANGES (ITS 3.4.12 Discussion of Changes Labeled A.1. A.2 and A.3) l Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1, 2. and 3. is converting to the ITS as outlined in NUREG-1432. " Standard Technical Specifications. Combustion Engineering Plants." The proposed changes involve the reformatting, renumbering. rewording of the Technical Specifications i (TS) and Bases with no change in intent, and the incorporation of current operating practices consistent with NUREG-1432. These changes since they do not involve technical changes to the Current TS (CTS). are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to 4 an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed l amendment, would not 1) involve a significant increase in the probability or ' consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1.- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes involve reformatting renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific : Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the , other changes listed above. involves no technical changes to the CTS. Specifically. there will be no change in the requirements imposed on PVNGS ) due to these changes. During development of NUREG-1432. certain wording preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. li ALO VERDE - UNITS 1,2, AND 3 1 Rev. A 4
NO SIGNIFICANT HAZ S CONSIDERATION ITS Section 3.4 - Pressurizer Vents i ADMINISTRATIVE CHANGES (ITS 3.4.12 Discussion of Changes Labeled (A.1. A.2 and A.3) (continued) i Standard 2.- Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes involve reformatting, renumbering, and rewording of . the CTS. along with the incorporation of PVNGS current operating practices I and other changes, as discussed, in order to be consistent with NUREG-1432. The proposed changes do not involve a physical alteration of the plant (no new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? The proposed changes involve reformatting, renumbering, and rewording of the CTS. along with the incorporation of PVNGS current operating practices ! and other changes, as discussed. in order to be consistent with NUREG-1432, The proposed changes are administrative in nature and will not involve any technical changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also. ) because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. l I l PALO VERDE - UNITS 1,2, AND 3 2 Rev.A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.12 - Pressurizer Vents a TECHNICAL CHANGES - MORE RESTRICTIVE (ITS 3.4.12 Discussion of Changes Labeled M.1) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS).
- Units 1, 2, and 3 is converting to the ITS as outlined in NUREG-1432. This particular NSHC is for the changes labeled " Technical Changes - More Restrictive" described in the specific Discussion of Changes listed above. The proposed changes incorporate more restrictive changes into the CTS by either making i current requirements more stringent or adding new requirements which currently )
do not exist. The Commission has provided standards for determining whether a significant i hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes provide more stringent requirements than previously existed in the CTS. The more stringent requirements will not result in operation that will increase the probability of initiating an analyzed event. If anything, the new requirements may decrease the probability or consequences of an analyzed, event by incorporating the more restrictive changes discussed in the specific Discussion of Changes listed above. These changes will not alter assumptions relative to mitigation of an accident or transient event. The more restrictive requirements will not alter the operation and will continue to ensure process variables, structures, systems, or components are maintained consistent with safety analyses and licensing basis. These changes have been reviewed to ensure that no previously evaluated accident has been adversely affected. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident evaluated. PALO VERDE - UNITS 1,2, AND 3 3 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.12 - Pressurizer Vents TECHNICAL CHANGES - HORE RESTRICTIVE i (ITS 3.4.12 Discussion of Changes Labeled M.1) (continued) i I , l Standard 2.-- Does the proposed change create the possibility of a new or ; different kind of accident from any accident previously evaluated? Making existing requirements more restrictive and adding more restrictive requirements to the CTS will not alter the plant configuration (no new or ; different type of equipment will be installed) or change the methods I i governing normal plant operation. These- changes do impose different requirements. However, they are consistent with the assumptions made in the safety analyses, licensing basis, and NUREG-1432. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. ) Standard 3. Does the proposed change involve a significant reduction in a l margin of safety? The proposed changes provide more stringent requirements than previously existed in the CTS. An evaluation of these changes concluded that adding these more restrictive requirements either increases or has no impact on the margin of safety. The changes provide additional restrictions which may enhance plant safety. These changes maintain requirements of the safety analysis, licensing basis, and NUREG-1432. As such, no question of safety is involved. Therefore, these changes will not involve a significant reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 4 Rev. A
l l NO SIGNIFICANT IIAZARDS CONSIDERATION I ITS Section 3.4.12 - Pressurizer Vents ! TECHNICAL CHANGES RELOCATIONS (ITS 3.4.12 Discussion of Changes Labeled LA.1, LA.2, and LA.3) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS). I i Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The ! proposed changes, since detail is being removed from the CTS to a Licensee j Controlled Document, are less restrictive. The descriptions of these changes are ! j in the Discussion of Changes listed above. l l The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards i consideration if operation of the facility, in accordance with a proposed ; amendment, would not 1) involve a significant increase in the probebility or ! consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these ,
standards as they relate to this amendment request follows: l 1 Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee , Controlled Document. These changes do not result in any hardware changes ! or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee ' Controlled Document containing the relocated requirements will be maintained using the provisions of 10 CFR 50.59 or other specified control processes and is subject, to the change control process in the Administrative Controls Section of the ITS. Since any changes to a Licensee Controlled Document will be evaluated, no increase in the probability or consequences of an accident previously evaluated will be allowed. Threfore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 5 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.12 - Pressurizer Vents TECHNICAL CHANGES RELOCATIONS (ITS 3.4.12 Discussion of Changes Labeled LA.1, LA.2, and LA.3) (continued) Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes will not impose different requirements and adequate control of information will still be maintained. These changes will not alter assumptions made in the safety analysis or licensing basis. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated. Standard 3.-- Does the proposed change involve a significant reduction in a margin of safety? The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not reduce a margin of safety since they have no impact on any safety analysis assumptions. In addition. l the requirements to be transposed from the CTS to the Licensee Controlled Document are the same as the CTS. Since any future changes to this Licensee Controlled Document will be evaluated per the requirements of 10 CFR 50.59. or other specified control processes, no reduction (significant or insignificant) in a margin of safety will be allowed. Therefore. these changes will not involve a significant reduction in a margin of safety. The NRC review provides a certain margin of safety and although this review will no longer be performed prior to submittal. the NRC still inspect:; the 10 CFR 50.59 process. The proposed changes are consistent with NUREG-1432. which was approved by the NRC Staff. The change controls for proposed relocated details and requirements provide an acceptable level of regulatory authority. Revising the CTS to reflect the approved level of detail per NUREG-1432 reinforces the conclusion that there ;s not a significant reduction in the margin of safety. Therefore, revising the CTS to reflect the NRC accepted level of detail and requirements ensures no reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 6 Rev. A
I NO SIGNIFICANT HAZARDS CONSIDERATION 1-ITS Section 3.4.12 - Pressurizer Vents i . TECHNICAL CHANGES LESS RESTRICTIVE l (ITS 3.4.12 Discussion of Changes Labeled L.1) a Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). ~ Units 1, 2, and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the l description of this less restrictive change and the NSHC for the conversion to NUREG 1432. L.1 CTS 3.4.10. (Reactor Coolant System Vents) LCO is specified as applicabh in MODES 1. 2. 3 and 4. However, the ACTIONS for CTS 3.4.10 require an end-state of MODE 4, which would not put the plant in a mode where the LC0 is not applicable. This anomaly in CTS results in the need to justify the new ITS 3.4.12 (Pressurizer Vents) APPLICABILITY of Mode 1. 2, 3. and 4 with RCS pressure 2385 psia as a less restrictive change to CTS. and the ; new ITS ACTION end-state of Mode 4 with RCS pressure <385 psia as a more
- restrictive change to CTS. The less restrictive change to the
- APPLICABILITY is discussed below, and the more restrictive change to the ACTIONS is discussed in DOC Section M.1.
1 The change to the pressurizer vent path LCO APPLICABILITY in ITS 3.4.12 will require the pressurizer vent path LC0 to be APPLICABLE in Modes 1. 2, 3 and 4 with RCS pressure 2385 psia. This is less restrictive.than the CTS requirement for RCS vent paths to be OPERABLE in MODES 1. 2. 3 and 4. since the new ITS would not require RCS vent paths to be OPERABLE in MODE 4 below 385 psia. This change is acceptable since the safety analysis that i , credits the pressurizer vents for RCS depressurization (SGTR with LOP and failure of the APSS) considers the SGTR event terminated when shutdown i cooling entry conditions are reached, which is in Mode 4 with RCS pressure
<385 psia. This change does not impact safety and is consistent with the PVNGS safety analysis.
The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
PALO VERDE - UNITS 1,2, AND 3 7 Rev. A
I NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.12 - Pressurizer Vents i TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.12 Discussion of Changes Labeled L.1) (continued) Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed change will reduce the applicability of the requirement to have operable RCS pressurizer vent paths from Modes 1. 2. 3. and 4. in CTS. to Modes 1, 2. 3. and 4 with RCS pressure >385 psia in ITS. This change would not impact safety since it would make the TS requirement consistent with the safety analysis. The requirement to maintain operable pressurizer ; vent paths is based on the safety analysis for SGTR with LOP and failure of the APSS. The SGTR safety analysis considers the SGTR event terminated when shutdown cooling entry conditions are reached, which is in Mode 4 with j RCS pressure <385 psia. Therefore, the pressurizer vent paths are no longer credited in the safety analysis when the plant is in Mode 4 with RCS pressure <385 psia. ! l This change does not impact safety and is consistent with the PVNGS safety analysis. This change will not alter assumptions in the safety analysis or licensing basis. Therefore this change will not involve a significant i increase in the probability or consequences of an accident previously evaluated. i
~
Standard 2. Does the proposed change create the possibility of a new or l different kind of accident from any accident previously evaluated? ' The proposed change will reduce the applicability of the requirement to have operable RCS pressurizer vent paths from Modes 1. 2. 3. and 4. in CTS, to Modes 1. 2, 3. and 4 with RCS pressure >385 psia in ITS. This change would not impact safety since it would make the TS requirement consistent with the safety analysis. The requirement to maintain operable pressurizer vent paths is based on the safety analysis for SGTR with LOP and failure of the APSS. The SGTR safety analysis considers the SGTR event terminated when shutdown cooling entry conditions are reached, which is in Mode 4 with RCS pressure <385 psia. Therefore the pressurizer vent paths are no longer credited in the safety analysis when the plant is in Mode 4 with RCS pressure <385 psia. This change does not impact safety and is consistent with the PVNGS safety analysis. This change will not alter assumptions in the safety analysis or licensing basis. Therefore, this change will not create the possibility of a new or different kind of accident from any previously evaluated. PALO VERDE - UNITS 1,2, AND 3 8 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.12 - Pressurizer Vents TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.12 Discussion of Changes Labeled L.1) (continued) Standard 3.-- Does the proposed change involve a significant reduction in a margin of safety? The proposed change will reduce the applicability of the requirement to have operable RCS pressurizer vent paths from Modes 1. 2. 3. and 4. in CTS. to Modes 1, 2. 3. and 4 with RCS pressure >385 psia in ITS. This change would not impact safety since it would make the TS requirement consistent with the safety analysis. The requirement to maintain operable pressurizer vent paths is based on the safety analysis for SGTR with LOP and failure of the APSS. The SGTR safety analysis considers the SGTR event terminated when shutdown cooling entry conditions are reached, which is in Mode 4 with RCS pressure <385 psia. Therefore, the pressurizer vent paths are no longer credited in the safety analysis when the plant is in Mode 4 with RCS pressure <385 psia. This change does not impact safety and is consistent with the PVNGS safety analysis. This change will not alter assumptions in the safety analysis or licensing basis. Therefore, this change will not involve a significant reduction in the margin of safety. PALO VERDE - UNITS 1,2, AND 3 9 Rev. A 1
1 1 1 l 1 i l l l 1 1 l l CE STS ; NUREG-1432 REV.1 SPECIFICATION 3.4.13 MARK UP 1 l l l
., . _ . - - .. _ _ _ _ - -.~.-. .- - -- . _ _ _ . - . . -
d b i LTOP
'(CTS) 3.4 REACTOR COOLANT SYSTEM (RCS) 3 I
3.4. L Temperature Overpressure Protection (LTOP) System I Ib 1 _ 9 piMg [ 5 An LTOP System shall be OPERABLE wit maxi ' of one gh
'(,Q 3,4,$,
LCO 3.4.J[ rpresfbre safety / Injection'( Si p and on harging ump , ; 3 ca le of inj ting into RCS a the sa ty inje ion i
<t ks (SITS) olat d. a -
g g 4 l
- a. Two OPERABLE 4ourwoperaevd7e3 va ( sJwit lift settings s psi i
T > e, m a yo+bL onpu.wes. prd 6 & ar
- b. The RCS depressu and 6 iht Act I i
- 2 . sgu s.
i 9 l Inwr4 2 -- 3 Albuc_4 ulc3 om M is a 04*rtA,,g n,Mng ! APPLICABILITY: ru m * ..... why na coin's ss ' duri hdY l MODE 5 MODE 6 when the reactor vessel head is on./ _ i r..........._... TE-------- ----------- ----- l ' SIT solation s only requ ed when SIT ressure is eater th or equal o the maxi RCS pressu for the ex sting ,
- loved by the P/T limit c ves w R cold leg emperature l l 1 rovided in he PTLR.
1 ... . ........... ............ .......... ... .... _, ACTIONS REQUIRED ACTION COMPLETION TIME ; i CONDITION i .e Two o more HPSI p A.1. Initi e action to diately A. cap le of injecti ver y a maximum of 1 2 i o the RCS. on HPSI pump capable o injecting into t ( 4 C5. J l (continued) { n h \i?.s'b Rev-2, nd/^7'n' CEOC :T5 3.4-26
-. . . - - . . . _ . - - _.-. .--. -.- -.-. . - . ~ - . - . . . . - .
i l l l INSERT FOR ITS 3.4.13 APPLICABILITY NOTE , (Units 1,2, and 3) INSERT 1 NOTE- - When one or more cold legs reach 214'F, this LCO remains applicable during periods of steady state temperature conditions until all RCS cold leg temperatures reach 291*F. If a cooldown is terminated prior to reaching 214'F and a heatup d l is commenced, this LCO is applicable until all RCS cold leg temperatures reach 291*F. t 1-LCO NOTE INSERT 2 NOTE - - No RCP shall be started unless the secondary side water i temperature in each steam generator (SG) is <100'F above L each of the RCS cold leg temperatures. e l l
,,~ , - , . -. . - , . . - - , -
LTOP System 3.4.J2'h
) ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. Two or more arging ------ - -- TE------------- pumps capa e of Two charg< g pumps may be injecting nto the capable injecting into the RCS. RCS dur ng pump swap opera on for s 15 minutes. B Initiate action t Immediately verify a maxi of one charging p capable of i ecting
' / into the RC p
r- 1 C. A SIT n isolated C. Isolate affected T. I hour when pressure is grea r than or equal to e maximum RCS ' { pr sure for existing
; d leg temperature 110wed in the PTLR j
'D. Required Ac on and associated ompletion D.1 crease RCS cold leg emperature to [2 hours )
Time of C dition C > [175)*F. not met. CB D. Depressurize affe ed 12 hours SIT to less than he maximum RCS pre ure for existing c d leg temperature al owed
/ in the PTLR. ;
Y ic ? $ *5 ! 5 :!f DN7 days One required @ 33 $a inoperable in MOCE 4. E.1 - nestore requirea rvR. to OPERAB'.E status, fewh $, J ' continued) kk.% lis e a ek 3.4-27 Rev ,, y,fv,f u l
% Vcede - Vn % \ i 7 3 I
_.. - - . . .- .~ . - ~ - _. - . . _ _ _ _ . - . . . . . . _ . - . --- i 4 LTOP
%ftdoon Op%rn oxbohN. rdtef W, e, ACTIONS (continued)
I COMPLETION TIME l REQUIRED ACTION p CONDITION One required Restorerequiredh. 24 hours l 3.4%3 hCt' b) inoperable in MODE F to OPERABLE status. or 6. _m b , , / kW 3.4.%2.2 ACT h X. Two required V Depressurize RCS and 8 hours i 31 estab'ish RCS vent of inoperable. 2G square ; inches. q
$ O I
Required Action and bkEh C h associated Completio ghbrw 4 l f hAI'D D b) Time of Condition A ot 7 ^ 3 4.%.h AC.T c y 1B,}(D,4. 4 met. { W sm h ru tt2.\. st rg
~
MVd 5 operable for an .ason other - \
<IXX. L. ) >
D, r 4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify ximum of HPSI p is hour SR .4.12.1 into the / I capabl of injecti . e e charging op is d2 hours f SR/3.4.12.7/ Verify maximum of into the G capab of injecti
/
(continued) 3.4-28 Rev i, M/07/M qu e v e-b 4
l r I l i LTOP Syste.. - 3.4g i SURVEILLANCE REQUIREMENTS (continued) J SURVEILLANCE FREQUENCY SR .4.12.3 ----- ------------NOT E- ----------------- Reg red to be performe when complying wit LC0 3.4.12b. T ' erify each S!T isgsolated. 12 hour
, Eq $
3.4,%,b k.T h SR 3.4 M.K Verify RCS vent 2 square n 12 hours fo,
\ open. ,(b w so c- '
unlockeddqpe ve,4 m a%r$*.a. nch -~ = ' 'D - 01'b SR .4.12.5 rify PORV bl k valve is o n for each d2 hours required POR . t SR 3.4. .6 - - - - - - - - - - - ----NOT E ------- --------- Not require o be performed u il [12) hours fter decreasing R cold leg , temperatu A to5[285)*F. /
---.---- --- ---... - . --- ------------- A Perfo CHANNEL FUNCTIONA TEST on each '31 days requ ed PORY, excluding ctuation.
L SR 3.4.12.7 Pe fom CHANNEL C IBRATION on th [18) months r quired PORY a untion channe . (
)
(\ b
.ba.rt 1
.)
\4
" ' ' " ^ ^ ~
a car eve 3.4-29 Rev ' ,-,i n l
1 i l INSERT FOR ITS 3.4.13 SURVEILLANCE REQUIREMENTS (Units 1,2, and 3) INSERT 1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY i SR 3.4.13.2 Verify each Shutdown Cooling System suction line relief 12 hours for valve aligned to provide overpressure protection for the unlocked, not RCS. sealed, or otherwise not secured open ; pathway vent valve (s) AND 31 days for locked, sealed, or otherwise ! secured open pathway vent valve (s). SR 3.4.13.3 Verify each Shutdown Cooling System suction line relief in accordance with valve OPERABLE with the required setpoint. the Inservice i Testing Program l J l l
i l CE STS l 4 NUREG-1432 REV.1 SPECIFICATION 3.4.13 BASES MARK UP 1 l l l
l l l l l l l l I l l i l 4 LTOP System B 3.4.
]
B 3.4 REACTOR COOLANT SYSTEM (RCS) B 3.4 [ Low Temperature Overpressure Protection (LTOP) System B i BASES N BACKGROUND The LTOP System controJs RCS essure at low temperatures so the integrity of the peactor olantfressureboundary (RCPB) is not compromised by iolating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G (Ref.1). The reactor vessel is the lietting RCPB component for demonstrating such protection. LCO 3.4.3, 'RCS Pressure and , Temperature (P/T) Limits,' provides the allowable l' combinations for operational pressure and teniperature during cooldown, shutdown, and heatup to keep from violating the Reference I requirements during the LTOP MODES. The reactor vessel material is less tough at low temperatures than at normal operating temperatures. As the vessel neutron exposure accumulates, the material toughness decreases and becomes less resistant to pressure stress at low temperatures (Ref. 2). RCS pressure, therefore, is maintained low at low temperatures and is increased only as temperature is increased. The potential for vessel overpressurization is most acute ; when the RCS is water solid, occurring only while shutdown; a pressure fluctuation can occur more quickly than an operator can react to relieve the condition. Exceeding the RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel. LCO 3.4.3 requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the P/T limits. This LC0 provides RCS overpressure protection by havina +- gninisdtn coopant irect capaevi' v ame hmnal$indecuate nressure relief capacity. 5 Li iting coola t input c pability requ' es all but ne high pr ssure safety injectio (HPSI) i pum and one ch ging pump capable of njection nio the s pc and holati g ,the_ safet _injectinn_ nLs_(SIT L.,,/The elief capacity requires either two OPERABLE redundan er operAed rerief v/Ives trwsijor the R depressuriZeo ano an KLb vent oT EuTIluent 5120. One l or the RCS vent is the overpressure protection device that acts to terminate an increasing pressure event. y n bg D d2Lrn fiac. m knQ,. rdc YM (dcaor\ _ % M A/n M oc.f$$rAegcontinued) b l i m - --- -__ .~ C ; ;;3 8 3.4-56 Rev ;, 0"/C7/Z O NQSblL ~ UN \ 0 \
)
i i l l I l LTOP System l B 3.4g l5 l BASES BACKGROUND F Wi mini coolant iput ca ility, he abi ity to (continued) ovide re coolan additio is res icted. The LCO oes not re ire the m eup cont I syst deacti ated or he safe - injection SI) act ion cir uits bl ked. D e to the ower pres res in tt L10P M ES and i e expec d core d ay heat le 15, the keup sys em can p ovide a quate ow via the c.akeup co .rol valv If cor itions equire the use of ore than ie [HFI o chargi pump f makeup in the ev t of loss f invent y, then umps ce be made m um (1 m h1 thrannh = ..i s 1 met 4 e, dit;W m b M rdd V!kdd.6 The LT P ystem foi pressure relief consists of two fyth reduced ifrt setperggor an RCS vent of suffici@ent sue. Iwo reliar vaives are required for redundancy. One , has adequate relieving capability to prevent ' overpressurization for the required coolant in ut urs(tr$lry3 b b 6' \U6hNL(dC Recu rement - - F As de gned for the TOP System, e h PORV is sig ledto7
;) open if the RCS pr ssure approach s a limit dete ined by the TOP actuati logic. The tuation logic onitors RCS pr ssure and de reines when t LTOP overpre ure setting i approach 2d. If the indica d pressure me s or exceeds he calculat value, a PORV is signaled to pen.
The LCO pr ents the PORY etpoints for L P. The setpoints are norma y staggered s only one valve pens during a low / g tempera re overpressur transient. Ha ng the setpoints f N , both v ves within the imits of the L ensures the P/T ! limit will not be e eeded in any an yzed event. l Whe a PORV is oper d in an increas g pressure transi nt, l th release of co ant causes the essure increase slow a reverse. As he PORV release coolant, the sys m essure decrea s until a reset ressure is reach and the alve is signa}td to close. Th pressure continu decrease beloV the reset press e as the valve c)ps oses.to _) l l w- - /. ,
. W< ;
i
) (continued)
G uo r- B 3.4-57 Rev 1, '"/C7/ 5 Obgjbk-UrdjaS n Q i
- INSERT FOR BASES 3.4.13
- BACKGROUND SECTION !
(Units 1,2, and 3) i INSERT 1 BACKGROUND Shutdown Coolino System Suction Line Relief Valve Requirements As designed for the LTOP System, each Shutdown Cooling System suction line relief valve is designed to lift and relieve RCS pressure if RCS pressure approaches : the Shutdown Cooling System suction line relief valve , lift setpoint. , Each Shutdown Cooling System suction line relief valve is designed to protect the reactor vessel given a single : failure in addition to a failure that initiated the pressure l transient. No single failure of a Shutdown Cooling system suction line relief valve isolation valve (SI-651, 652,653, or 654) will prevent one Shutdown Cooling - System suction line relief valve from performing its ' intended function (Ref. 7). The OPERABILITY of two Shutdown Cooling System suction line relief valves, while maintaining the limits imposed on the RCS heatup and cooldown rates, ensures i that the RCS will be protected from analyzed pressure i transients. Either Shutdown Cooling System suction line relief valve provides overpressure protection for the RCS ) due to the most limiting transients initiated by a single l operator or equipment failure, i
- a. The start of an idle RCP with secondary water temperature of the SG s 100*F above RCS cold leg i temperatures
- b. 'An inadvertent SIAS with two HPSI pumps injecting into a water solid RCS, three charging pumps injecting, and letdown isolated.
These events are the most limiting energy and mass addition transients, respectively, when the RCS is at low , temperatures (Refs. 7,8, and 9). When a Shutdown Cooling System suction line relief valve lifts due to an increasing pressure trarsient, the ; release of coolant causes the pressure incre.ase to slow l and reverse. As the Shutdown Cooling System suction i
I BASES i l BACKGROUND Shutdown Cooline System Suction Line Relief Valve i (continued) Requirements ' line relief valve releases coolant. the system pressure decreases until valve rescat pressure is reached and the Shutdown Cooling system suction line relief valve closes. ! At low temperatures with the Shutdown Cooling System ) suction line relief valves aligned to the RCS, it is
; necessary to restrict heatup and cooldown rates to assure 1 i that P-T limits arc not exceeded. These P-T limits are usually applicable to a finite time period such a one cycle, ] , 5 EI '
c, and are based upon irradiation damage i pred. uon by the end of the period. Accordingly, each time P-T limits change, the LTOP System needs to be re- l analyzed and modified, if necessary, to continue its function. i l l 1 I 5 2
l l l LTOP Syste B 3.4 BASES : I BACKGROUND RCS Vent Raouirements i (continued) l Once the RCS is depressurized, a vent exposed to the containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the relieving requirements of the transient do not exceed the j capabilities of the vent. Thur, the vent path must be capable of relieving the flow resulting from the limiting LTOP mass or heat input transient and maintaining pressure below the P/T limits. The required vent capacity may be provided by one re vent p 't For an RCS vent B ' meet the specified flow apacity, it h ; j reauires removina pressurizer safety val J rykovin ; V's ternals/ and difablina/its blocE valvr in h% t 7-a op ] siti ,[or cimilarly establishing a vent by openin lan CS ) ent alvel. The vent path (s) must be above the leve of reactor coolant, so as not to drain t h en [ ; l n ny- t\ dQdongg nAA, Urs u 23W{ dsg*M { APPLICABLE Safety analyses (Ref. 3 deironstrathiractor vessel SAFETY ANALYSES is adequately protected against exceeding the Reference 1 P/T limits during shutdown. In MODES 1, 2, and 3, 1 MODE 4 with any RCS cold leg temperature exceeding ( 2s the pressurizer safety valves prevent RCS pr exceeding the Reference I limits. At about q'S and g belos, overpressure prevention falls to the LE T^^W '. [ Jor to a depressurized RCS and a sufficient sized RCS ventf. Elch of thes h imit ve , capability, g g @\g .
/
-_v- -
The actual temperature at w the pressure in the P/T limit curve falls below the pressurizer safety valve A setpoir.t increases as the reactor vessel material toughness decreases due to neutron embrittlement. Each time the P/T limit curves are revised, the LTOP System will be re-evaluated to ensure unctional requirements can still be satisfied using the , method or the depressurized and venteo RCS condition. , Reference 3 contains ce imits t at satis y e LTOP requirements. Any change to the RCS must be evaluated against these analyses to detennine the impact of the change o nq % (continued) y' B 3.4-58 Rev h- S'/07/%
^Vo NCS O,% \1 D
. .-. . - - - -. . . ._~ .- - - -, .. . . . . . - . _ _ _ -
1 l 4 f I s LTOP System B3.4g D i BASES i APPLICABLE Transients that are capable of overpressurizing the RCS are SAFETY ANALYSES categorized as either mass or heat input transients, (continued) examples of which follow: Mass Inout Tvoe Transients i
- a. Inadvertent safety injection; or
- b. Charging / letdown flow mismatch.
Heat Inout Tvoe Transients
- a. Inadvertent actuation of pressurizer heaters;
- b. Loss of shutdown cooling (SOC); or j
- c. Reactor coolant pump (RCP) startup with temperature asymmetry within the RCS or between the RCS and steam
-generators.
T followin are requir d during the OP MODES to nsure at mass a heat inpu transients d not occur, ich
. ither of e LTOP ove pressure prot tion means c nnot I handle:
- a. Re ering all c rging pump t one HPSI p capable of i ection; and
, and all bu one ( l
- b. activating he SIT discha e isolation alves in f their closed asitions. ~
-4he Referenc63 d iinalyses demonstrate that either one(TWhilari'7,S 19 the RCS vent can maintain RCS pressure below limitsfithen ] gh "on one HPSI mp and one char ng pump are ac ated, i y T s, the LCO llows only one SI pump and on charging $*gJ.* <
ap OPERABL during the LTOP DES. Since ne ther the PORV or the RCS ent can handle e pressure tran ient produced from accu ator injection, hen RCS tempera re is low, the , n LC0 also equires the SITS solation when a umulator 3 C. . pressur is greater than equal to the a imum RCS ! pressu for the existin RCS cold leg te erature allowed ! in t PTLR. Th isolated SIT + mu have their disch ge valves clos a the valve power upply breakers fi d in their oper ositions. The ann yses show the eff t of SIT disch ge is ;
) \ w (continued) r^r "% B 3.4-59 Rev ', S'/Gi,,
Db YQr62 - Ond li2 d
1 , INSERT FOR BASES 3.4.13 l APPLICABLE SAFETY ANALYSIS SECTION (Units 1,2, and 3) INSERT 1 for the two most limiting analyzed events: l
- a. The start of an idle RCP with secondary water temperature of the SG < 100'F above RCS cold leg temperatures
- b. An inadvertent SIAS with two HPSI pumps injecting into j a water solid RCS, three charging pumps injecting, and letdown isolated.
d
1 ) INSERT FOR BASES 3.4.13 I i APPLICABLE SAFETY ANALYSIS SECTION (Units 1,2, and 3) ;
,l INSERT 1 J ,
for the two most limiting analyzed events:
- a. The start of an idle RCP with secondary water <
temperature of the SG s 100'F above RCS cold leg temperatures
- b. An inadvertent SIAS with two HPSI pumps injecting into !
a water solid RCS, three charging pumps injecting, and , letdown isolated. ' e I I
.O
LTOP System 8 3.4 @ BASES APPLICABLE Heat Inout Tvoe Transients (continued) SAFETY ANALYSES h o e O n o Fracture mechanics ana established the temper tu LTOP Applicability at F and belowg Above _% temperatur(Dthe pressurtzer safety valves provide the reactor vesTel pressure protection. The vessel materials were assumed to have a neutron irradiation accumulation 1E eq a t effective fu I w y r fo ati n
,. %7_am 6,c.7vi eMEpa kcho - in WasMf, The os ue ce o smalT breakloss cooTanr acciden 5
(LOCA) in LTOP MODE 4 conform to 10 CFR 50.46 and 10 CFR 50, _ Appendix K (Refs. 4 and 5)f equirem s by havi g a max um T of ne HP5Vpump and one c rging p OPERAB nd SI is tuttionAnabled/ Tor th e pumps. _f D ' erforman N
.%J' JA i Wm bhs (chd cNJ ev 3e r1 P The fracture mechan an e o a prote ed when the are set to open at or below o A psig. The setpoint is derived by modeling the p(rformance of the LTOP System, assumino the limitino U allowed LTOP transientfof one $1 pump nd one c rging M b pump njettin ifto t e RCS. hese an yses con der pre sure ove hoot a d under oot beyo d the P0 opening an closin setpoin s. re u ino from sional or ca uino a Ive str e timet The setpoints at or below the derived limit ensure the n@e erence 1 limits will be met, he setpoints will be re-evaluated for compliance when the evised P/T limits conflict with the LTOP analysis l limits. The P/T limits are periodically modified as the 1 reactor vessel material toughness decreases due to embrittlement caused by neutron irradiation. Revised P/T limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens. The Bases for j LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits,"
discuss %, u6nm b\ina_ rc33.d MWw k The are cons active components. Thus, tfie failure of on represents the worst case, single active failure.
$ N b b [ p h en n r2nas \n t (d d w \JE.
h on ue i~~ - B 3.4-60 Rev i, e,fvii d bQ Y4rda.- O n @ \ d,
. . . _ . _ _ _. .. . _m._ _ _ _ . _ . _ _ . . . ..
1 l l l l I LTOP System, ' l B 3.4.J T l'8)
) BASES :
APPLICABLE RCS Vent Performance SAFETY ANALYSES (continued) With the RCS depressurized, analyses show a vent size of 1 square inches is capable of mitigating the limiting i allowed LTOP overpressure transient. In that event his size vent maintains RCS pressure less than t RCS pressure on the P/T limit curve. The RCS vent size will also be re-evaluated for compliance / l each time the P/T limit curves are revised based on the i results of the vessel material surveillance, j The RCS vent is passive and is not subject to active l failure. I LTOP S st a atisfies Criter 2 (M Nac Po4Ted
' O C. M .M OU.MU b' LCO This LCO is required to ensure that the LTOP System is !
OPERABLE. The LTOP System is OPERABLE when the C. < Met 1wut-me pressure relief capabilities are OPERABLE.
)- V101ation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference I limits as a result of an operational transient 7Toligftthecools one SI pump and ne chargi input cap ility, the 0 requires pump capabl ofinjectin o y int the RCS an the SITS i lated when a cumulator pr sure i greater tha or equal t the maximum S pressure r the isting RCS Id leg tem rature allo d in the PTL .
The elements of the LCO that provide ov essure mitigation through pressure relief ar - ckson %gh%rn W "-::u:.v q.,r i w as a.' Two OPERABLE o
- b. .The depressurh e C nd a RCS vent i h Akaon M g h st - e u h t ec3 e yo c_
s OPE BLE for P when dd@ 9MO 8 Kl e s wve n open, ts lift setpoint is set at psig or less and testing has proven its ability to open at that setpointL na mouve p sa lable to two valv nd thei trol ( 4 [) (continued) goa B 3.4-61 Rev : ;;/;7/;; IO Verda.. Ondo (2..b
= _.
For an RCS vent to meet the specified flow capacity. it 7 requires removing all pressurizer safety valves, or i similarly establishing a vent by opening the 3resSurizer manway (Ref. 11). The vent path (s) must be a>ove the level d of reactor coolant. so as not to drain the RCS when open. / c - J LTOP System B3.4g BASES LCO An RCS vent is OPERABLE when open with an area (continued) 2 square inches. 4 Ea these methods of overpressure prevention is capable of mitigating the limitir:g LTOP transient. r'Le d & -n - n ~_ ~
-~
2K0; L,'n '
- n or i GN APPLICABILITY This LCO is applicable in we te emperature o any RCS cold leg is s in MODE 5, and in MODE 6 when the reactor vessel head is on. The pressurizer safety valves #
g provide overpressure nrntactinn tbt meets the Reference 1 ( P/T limits ab [25]*f rd M';;dWhen the reactor vessel _f' head is offg ver ressurization cannot necur
= hwa ~ 'Qt% dgi -
T he. reg t r* *b b )\ LCO 3.4.3 prov es t op or all MODE . I C 3.4.10, ' ressur uer 5 ety vaives, requires t e over/rersare PecMn i 0 RABILITY f the press izer safety lves that rovide M NO Wi lt **4g, verpressu protection uring MODES , 2, and 3 and MO 4
% J g pao % 't d 'V' bove {28 ' f ._ = --
L.Tof6Y5fu"4'*[" Low temperature overpressure prevention is most critical we cew ,, A k y L. during shutdown when the RCS is water solid, and a mass or 3 , y, f,' " /r e sa r s c.e e" heat input transient can cause a very rapid increase in RCS gy,, . gogs pressure when little or no time allows oper Q t
., . . ea Lco
" 9" I WT _4 TheApplicabilityismodifiedbyaNote}statingthat IT 3 Y' g g' ,, po sp r ne / FsoTatio is only requ red when the SI pressure is reater k{,h Wlvti ' f than o equal to the CS pressure for the existing tempe ature, as all ed by the P/T mit curves p ovided in s O D g y' ..
the TLR. This No permits the 5 discharge lve jN /{ su eillance perf d only under hese pressu and mperature con tions. , ,/ ACTIONS A.1 and 9.f With t or more HPSI pump capable of injectin into the RCS, erpressurization i possible. l J
- j. Th immediate Completi Time to initiate a ions to restore r stricted coolant i ut capability to th CS reflects the
' mportance of main ining overpressure p tection of the I RCS. l F (continued) B 3.4-62 Rev 1, ^ ^ ~L7/Z b
i d l INSERT FOR BASES 3.4.13 l APPLICABILITY SECTION - l- (Units 1,2, and 3) ! l INSERT l . I stating when one or more cold legs reach 214*F, this LCO remains applicable during periods of steady state temperature conditions until all RCS cold leg temperatures reach 291'F. Also, if a cooldown is terminated prior to reaching 214 F and a heatup is commenced, this LCO is applicable until all RCS cold leg temperatures reach 291*F. This Note provides clarification about Applicability intent. Since PVNGS uses two different temperatures at which the Shutdown Cooling System suction line relief valves must be placed in service there is some possibility of confusion. This Note clarifies those ; circumstances where the Shutdown Cooling System suction line relief valves must be placed in service. 4 LCO SECTION INSERT 2 Note 2 requires that, before an RCP may be started, the secondary side water temperature (saturation temperature corresponding to SG pressure) in each SG is <100 F above each of the RCS cold leg temperatures. Satisfying this condition will preclude a large pressure surge in the RCS when I the RCP is started. i l I l
i l l i i l B 3 4. s 1 BASES i ACTIONS [ A.] Ind B.1 (conti ed) [ quired Action is modified by .40te that perm s two l harging pumps pable of RCS inje ion for 5 15 m' utes to ; allow for pump waps. i P C.1. D.1. and D.F ] An unisolated T requires isolati n within I hour. Thi is , only required hen the SIT press e is greater than or 2 to the maxi RCS pressure for he existing cold leg temperatur allowed in the PTLR ual
.' l If isola on is needed and ca tit be accomplished wi in I hour, equired Action D.1 id Required Action D.2 rovide j two o ions, either of whic must be performed with 12 h rs. By increasing t RCS temperature to > 75)*F,a SIT ressure of [600] psig carinot exceed the LTOP imits if th tanks are fully injec d. Depressurizing the SIT below e LTOP limit ' stated in he PTLR also protects gainst such n event.
' The Completion Times a based on operating e erience that these activities can act;omplished in thes time periods and on engineering e luations indicating t t an event requiring LTOP is n likt:ly in the allowed' times, j lb I _ _
hmf , 5 ffamarAAgk rdM vD\vaa fin NOUE 4 when n 5 ol'd leg empiFrature is s es n or
& y, s/e/ ACN _with onenPORV-inoperable, two must be restored to .fi. 5 I5 M*g 'g gV . . OPERABLE status within a Completion Time of 7 days. Two valves are required te seet the LCO requirement and to dp"E dr 3 '
pot,_ 9(af
- thf provide low temperatu7e overpressure mitigation while wit lur ponent.
LC O 3.0.4 's1 M5 gy se on f acts that only one49RV-
"(( ^Q Th is required to mitigate an overpressure transient and that
- - - the likelihood of an active failure of the remaining valve path during this ttme period is very low.
(continued) y3 B 3.4-63 Rev t, O'./0?/ 5 exsEEEED @ i
1 l I l i l l i l LTOP System B 3.4 BASES ACTIONS (continued) The consequences of operational events that will overpressure the RCS are more sovere at lower temperature (Ref. 6). Thui one reauir2 @ inoperable in MODE 5 or E in MODE 6 ith the head on, the Completion Time to restor ,copyc,h al BLE stnut ho e __ % Am . Q. r \M CN The 74 hour Tomp e to restore _two WPERABLE in MODE 5 or in HODE 6 when the vessel head is on is a reasonable types of ount of time to investigate and repair several f ilures without exposure to a lengthy period 4
- with only n OPERABLE to prote st overp essure events. g gg t4 If two requiredh are inoperable, or if a Required h
~
Action and the associated Comoletion Time of Condition A.tB, p joy 3, g l C. E. r " are not met / or iffthe LTOPfaystem/fs in (fof anyheason/other Ehan Condition AAhrouoY Condw,oprabl I ' ien F S4 k W N.'#8g% Ihe RCS must be depressurized and a vent established with'in 8 hours. The vent must be sized at least tt- E souare ( 4 jtt.$ cow ),) inches to ensure the flow capacity is greater tRan that 4 byf r Abre M required for the worst case mass input transient reasonable during the applicable MODES. This action protects the RCPB b, reduced 40 les$ from a low temperature overpressure event and a possible
. Oan 200*4 f 5 *# brittlefailureofthereactorvessel.g b 'T The Completion Time of 8 hours to depressurize and vent the '\ RCS is based on the time required to place the plant in this condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements.
SURVEILLANCE SR 3.4 2.1. SR 3.4.12.2!andSR 3.4.12 REQUIREMENTS To mi inize the potenti for a low temp ature overpressu > s even by limiting the ass input capabi ty, only one HPS T pum and all but [on charging pump a verified OPERAB
- wi the other pump iocked out with wer removed and e l 5 discharge inc able of injecting nto the RCS. Th PI) pump [s] an chargingpump[s] e rendered incap le l J i t (continued) i B 3.4-64 Rev i, e,je7/33
,f5
LTOP System B3.4 [ 3 s BASES SURVEILLANCE SR 3.4.12.1. A 3.4.12.2. and SR[3.4.12.3 (continue REQUIREMENTS / of injectin into the RCS throu . removing the power rom the pumps b racking the break s out under administ ative control. n alternate method f LTOP control may b employed sing at least two dependent means to pr vent a / pump st t such that a sing failure or single ac ton will 7 not re it in an injection nto the RCS. This ma be ace ished through the mp control switch bei placed in (pul to lock) and at le t one valve in the di harge flow pat being closed. T e 12 hour interval e nsiders operating prac ice to ~ egularly assess pote tial degradation and t verify
< peration within the afety analysis.
ts SM o- nroh C.W.acA>m M A M h m 3.4.18. Wi d '"' I' ' * ' *
*v.. ~ 9 W '
e SR ~ SR 3.4 3 k equirek vert ing that the RCS vent is open l(o 2 . square inches is proven OPERABLE by verifying its - o en c o either: bbb'$ whm rddt4ve
. 0 2 hour for a valve that is unlockedyope ; m%.w.dt g )
*Y .or ob%)s*XL Nfd%'M x on %a ,
- b. r e that is lockegopen entv3 q Th pas ly be openA o be. = -
Q /g OPERABLE. gTh+t Surveillanc eed only be performed if the QA ute vent 4,,being used to satis the requirements of this L i The Frei;uencies consider operatino expertence with b9 mispositioning of un]ocked and lockedTve oF %.dd I 1.2m n.c h hen.ed d
\@8 \ q YWWYWy-_ *'
F l g SR 3A.12.5 The ORV block valve must be verified ope every 72 hours to Q pr ide the flow pa for each required RV to perform its j f etion when actu ed. The valve can remotely verifie w en in the main ntrol room. The block valve is a remotely contro ed, motor operate valve. The pow to the valve motor operator is not re ired to be remove and the manual actu or is not required J I
') (continued)
CEOG STS B 3.4-65 Rev 1. 04/07/95
INSERT FOR BASES 3.4.13 l SURVEILLANCE REQUIREMENTS SECTION (Units 1,2, and 3) INSERT 1 RCS Vent i
- a. Once every 12 hours for a vent pathway that is unlocked, not sealed, or otherwise not secured open, or
- b. Once every 31 days for a vent pathway that is lockeu, sealed, or otherwise secured open.
For an RCS vent to meet the specified flow capacity, it requires removing all pressurizer safety valves, or similarly establishing a vent by opening the pressurizer manway (Ref. I1). The vent path (s) must be above the level of reactor coolant, so as not to drain the RCS when open. L
- . . - . - - - . . . . - . .. . - - _- ~ - --
l l t l LTOP System B 3.4. h ' BASES SURVEILLANCE SR 3.4.12/5 (continued) REQUIREMENTS locked the inactive post on. Thus, the bio k valve can be clo d in the event the ORV develops exceJ ive leakage or do not close (sticks pen) after relievi g an over essure event. Th 72 hour Frequency e isiders operating perience witt, cidental movement of alves having remo control and osition indication c abilities availab where easily monitored. These co iderations includ the administrati e controls over main ntrol room access nd equipment control. )
" SR 3.4.12.(
Performa e of a CHANNEL F CTIONAL TEST is re ired every 31 days o verify and, as ecessary, adjust t PORV open 4 setpoi s. The CHANNEL F NCTIONAL TEST will erify on a monthl basis that the P V lift setpoints e within the LCO 1 mit. PORV actuat n could depressuri e the RCS and is not equired. The 31 y Frequency consid rs experience wit equipment reliabi ity. A ote has been adde' indicating this S is required to be rformed [12) hour' after decreasing RCS cold leg emperature to s 5)*F. The test capnot be performed / until the RCS is the LTOP MODES when the PORV lift setpoint can be r uced to the LTOP ptting. ThetestmuIt be performed wit n 12 hours after e,ntering the LTOP MODES. , F D SR 3.4.12.7
- Perfo ance of a CHANNEL C IBRATION on each requir PORV actu ton channel is requ ed every [18) months to djust the hole channel so tha it responds and the val e. opens wi in the required LTO range and with accuracy to known i ut.
he [18] month Freque cy considers operating perience with equipment reliabilit and matches the typica refueling outage schedule. y l _ l b#r 2 p @ ! (continued) CEOG STS B 3.4-66 Rev1,04/07/95
- 1. t l
[ ! INSERT FOR BASES 3.4.13 4 I l SURVEILLANCE REQUIREMENTS SECTION l (Units 1,2, and 3) INSERT 2 SR 3.4.13.3 SRs are specified in the Inservice testing Program. Shutdown Cooling System suction line relief valves are to be tested in accordance with the requirements of Section XI of the ASME Code (Ref.10), which provides the activities and Frequency necessary to satisfy the SRs. The Shutdown Cooling System suction line relief valve set point is 467 psig. l l l i 4 4
. _ - . ._ ._ z . . _ _ _ _ . _ _ - - - - .. . . .
d i LTOP System B 3.4 /3
. s' BASES (continued)
REFERENCES 1. 10 CFR 50, Appendix G. l
- 2. Generic Letter 88-11.
I FSAR,Section/15{.
- 4. 10 CFR 50.46.
f
- 5. 10 CFR 50, Appendix K,
-$AR A,m R. V-?:W ocA hua.(owde Amiq3e '^'rv j
- 4. V.%X o\O ,Mos i %< sura. ArowaA m VaW S$b k2>
. xsmE., %Au ord % usa. YS\ CcAa-s en4u M- 4 j
\\. 6*C.CD Ah- h on W ueVe:d % % b V.S. 'D9hi 6Md.u.an .
CEOG STS B 3.4-67 Rev 1, 04/07/95
I J l l l l 1 l i i I NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.13 l
_ . ~ _ _ . . _ _ ._ _ _. I PALO VERDE ITS CONVERSION l NUREG-1432 EXCEPTIONS l ! SPECIFICATION 3.4.13 - Low Temperature Overpressure Protection (LTOP) System ) ? 1
- 1. Grammar and/or editorial changes have been made to enhance clarity. No technical or intent changes to the Specification are made by this change.
- 2. NUREG-1432, 3.4.13 has various restrictions on operation of HPSI pumps, l charging pumps, and SITS to prevent exceeding the relief capacity of the l LTOP System and, thus, overpressurize the RCS. ITS 3.4.13 has no such restrictions. The only limitation concerns cold leg temperature versus SG temperature for RCP operation which is restricted by the note under ITS '
LCO 3.4.13 (as described in Exception No.13). UFSAR Section 5.2 provides the analysis that supports these statements. This is acceptable because ' operation of this equipment is either controlled via plant ; procedures (Licensee Controlled Document) or within the design relief I capacity of the PVNGS LTOP System. Plant procedures contain direction to remove from service both HPSI pumps in Mode 5. restrict RCP operation I based on cold leg temperature versus SG temperature differential, and to depressurize and isolate the SITS. ; References in ITS 3.4.13 in the LCO, Applicadility Note. Actions SRs. and Bases to HPSI pumps, charging pumps, or SITS that are not applicable to PVNGS based on the preceding discussion have been have been removed. This change is consistent with PVNGS licensing basis. The bases has also been revised to be consistent with the LCO.
- 3. ITS 3.4.13 contains additional information stating that the Shutdown Cooling System suction line relief valves must be aligned to provide overpressure protection for the RCS. This additional requirement does not exist in NUREG-1432. In NUREG-1432 low temperature overpressure protection is provided by PORVs with reduced settings that have no isolation valves from the RCS. At PVNGS this function is performed by Shutdown Cooling System suction relief valves that are isolable from the RCS via valves SI-651. 652. 653, and 654. Therefore, for the Shutdown Cooling System suction line relief valves to be OPERABLE they must also be aligned to provide overpressure protection for the RCS as well as having lift setting 5 467 psig. This change is consistent with PVNGS licensing bases. The bases has also been revised to be consistent with the LC0.
l l PALO VERDE - UNITS 1,2, AND 3 1 REV.B l
l l PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS SPECIFICATION 3,4.13 - Low Temperature Overpressure Protection (LTOP) System ! l 4. NUREG-1432, 3.4.13 specifically references PORVs throughout the Specification. ITS 3.4.13 makes no references to PORVs because PVNGS does not have PORVs. PVNGS uses Shutdown Cooling System suction line relief valves to perform the function of low temperature overpressure protection. The Shutdown Cooling System suction line relief valves are spring-loaded liquid relief valves that are isolable from the RCS via SI-651, 652, 653. and 654. ITS 3.4.13 is modified throughout (LCO, Actions, SRs. and Bases) to reflect PVNGS licensing basis. This change is consistent with PVNGS licensing basis. The bases has also been revised to be consistent with the LCO.
- 5. NUREG-1432, 3.4.13 uses Mode 4 when any RCS temperature is s [285]*F as part of the Applicability. ITS 3.4.13 uses Mode 4 when any RCS cold leg temperature 5 214 F during cooldown and MODE 4 when any RCS cold leg temperature 5 291 F during heatup as part of the Applicability. This change is acceptable because PVNGS uses two temperatures for LTOP System Applicability in MODE 4 dependent on whether a cooldown or heatup was in progress. This is acceptable because these temperatures reflect the metallurgical characteristics of the PVNGS reactor . vessel. Because of the different thermal / hydraulic stresses applied to the reactor vessel, depending whether a cooldown or heatup is occurring. two different temperatures are used to reflect the transition point from ductile to brittle failure. Hence, there are two different temperatures, depending whether a cooldown or heatup is occurring, where L-TOPS are required to be OPERABLE and in service. This change provides plant specific information that is dependent on reactor vessel neutron embrittlement. This change is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO. )
i
- 6. ITS SRs 3.4.13.1 and 3.4.13.2 provide additional descriptive information. l "not sealed, or otherwise not secured", about the " vent pathway" that more clearly defines intent of the surveillance. This information does not exist in the NUREG-1432. The additional information serves to clarify the intent of the SR by emphasizing the importance of an open pathway in order to provide overpressure protection for the RCS. This is especially important for Shutdown Cooling System suction line relief valves because they can be physically isolated from the RCS via valves SI-651, 652. 653, and 654. This change is consistent with PVNGS licensing basis. The Bases has also been revised to be ccasistent with the LCO.
PALO VERDE - UNITS 1,2, AND 3 2 REV.A
PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS j SPECIFICATION 3.4.13 - Low Temperature Overpressure Protection (LTOP) System
- 7. The plant specific titles, nomenclature, number, parameter /value, reference, system description, system design, operating practices or i analysis description was used (additions, deletions, and/or changes are
- included). Plant specific parameters / values are directly transferred from the CTS to the ITS.
l
- 8. NUREG-1432. 3.4.13 Bases states that for an RCS vent to meet the specified I
- flow capacity, it requires removing a pressurizer safety valve, removing a PORV's internals and disabling its block valve in the open position, or similarly establishing a vent by opening an RCS vent valve. ITS 3.4.13 requires the removal of all four pressurizer safety valves or removal of the pressurizer manway to meet the required 16 sq. in. RCS vent requirement. Calculation and Sensitivity Study on Pressurizer Vent Daths ;
vs. Days Post Shutdown and Hot Leg Path FME Device Requirements, provide ! l this plant specific information. This change is consistent with PVNGS , licensing basis. I
- 9. ITS 3.4.13 uses an Applicability Note that clarifies usage and intent of Mode 4 Applicability. NUREG-1432, 3.4.13 has no such Note. Because PVNGS uses two different temperatures to place the Shutdown Cooling System suction line relief valves in service, there exists the possibility of confusion in interpreting Mode 4 Applicability. This Note clarifies those circumstances where the Shutdown Cooling System suction line relief valves must be placed in service. This change is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO.
- 10. NOT USED
- 11. NUREG-1432. 3.4.13. uses an Action that states. "LTOP System inoperable l for any reason other than Condition ..." ITS 3.4.13 does not use this i
Action. Realistically, there are no conditions where this Action will be of use to PVNGS. PVNGS uses mechanical relief valves rather than PORVs l that have electronically modified setpoints. PVNGS Shutdown Cooling System i suction line relief valves are adequately addressed by ITS 3.4.13 Actions. This change is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO. I 12. ITS SR 3.4.13.1 removes all references to " valves" in the SR and l Surveillance Bases. The RCS vent path used at PVNGS has no valves in the l vent pathway. Instead the Surveillance requires. that the vent pathway be ! checked open. This is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO. 1 4 PALO VERDE - UNITS 1,2, AND 3 3 IGV. B l
l ! l l PALO VERDE ITS CONVERSION l NUREG-1432 EXCEPTIONS l SPECIFICATION 3.4.13 - Low Temperature Overpressure Protection (LTOP) System ) l 13. ITS LC0 3.4.13 Applicability Note 2 specifies that no RCP shall be started ! I unless the secondary side water temperature in each steam generator is
< 100 F above each of the RCS cold leg temperatures. NUREG-1432 does not contain this restriction. This restriction is necessary to preclude a large pressure surge in the RCS when the RCP is started. This restriction is in CTS 3.4.8.3. Actions a. b. and c. and is consistent with the !
restrictions in ITS 3.4.6, Note 2. and 3.4.7, Note 3. The Bases has also been revised to be consistent with this note. The requirement in this Note is consistent with the PVNGS licensing basis.
- 14. ITS 3.4.13 Action C.1 Bases contains guidance to reduce RCS cold leg temperature to less than 200 F prior to venting for personnel safety considerations. NUREG-1432 does not contain this guidance. This is relocated from CTS 3.4.8.3. actions b and c. as addressed in the Discussion of Changes (DOC) for ITS 3.4.13. LA.2. This is consistent with I PVNGS licensing basis. !
- 15. NUREG-1432 Bases 3.4.12 Applicability provides an unnecessarily complex level of detail to describe when LC0 3.4.12 is not applicable. ITS Bases 3.4.13 (developed from NUREG Bases 3.4.]?) uses a more simple approach used elsewhere in the NUREG Bases (e.g. 3.9.4 and 3.9.5 Bases) to describe that the requiremerts for overpressure protection in other MODES i are covered by LCOs 3.4.10 and 3.4.11.
- 16. ITS 3.4.13 Action A.1 contains a Note stating that LC0 3.04 is not applicable. NUREG-1432 (source for ITS 3.4.13) does not contain this exception. This exception is included in CTS 3.4.8.3. Action f. and is therefore consistent with PVNGS licensing basis.
f PALO VERDE - UNITS 1,2, AND 3 4 REV.B
PVNGS CTS 1 SPECIFICATION 3.4.13 MARK UP t 4 J 4 . ? i 1 4 ^l J 4 1 l i 4 1 l 1
. .- .. e s v. .i, i
%r%rsr%R, _,-mp W.t.%, UDPb\ :.:P D(bh # l r6t$
- Q m pEACTOD COOLANT SYSTE51MCf
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- 4.0.; Both snutdown cooling system (SC5) suction line relief valves witn '
I l(lif t settings of less than or equal to 467 psig shall be OFERABLE and aligned I33$. S t m.
& %:. to m e ur u .o & on ):.J ar,the RealtjLrf oolsv k D 1Wpg.oxc. meras ;
APPLICABILITYfk J ntheregtorvesse/headis/installedandpetemperafu_s) Q{d*g) i j
~ 40.fJne,.or._ pore of he.RCS c/1d legs i Lless_thak or e ua. ,
Tkw ' @ 7 r~If k_.5 9 @ F 5; % D r ts I ( ny ?( : la-add 444s^nt::sM% one or more cold legs reach 214*F, this LCO remains 3 i
/ yN applicable during periods of steady state temperature conditions until all RCS
% , sT l cold legs reach 291*F. If a cooldown is terminated prior to reaching 214*F and ,
. k. d / .
a heatup is commenced, this LCO is applicable until all PCS Cold legs reach \d I i291*F. 2 1 ACTION: f.,[WithoneSCSreliefvalveinoperableinMODE4,restorethe] (m)O A /tincoerable valve to OPERABLE statu.s within 7 days >or cepressurize an j vent the RCS thro _ ugh at leaspl6 square inch vent (s) within the c next 8 hours. O c:t ;t;rt . reactor c60lant pum_pM the steam ' l
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g,enef ator witer JenttAtxt is ""'*-- e;,100*V_above any RCS cold ' [4,Y) t, i
, @C -- _P_*** 1es. tem:erature_) @ (mu w <+=< +e s Jes, Q.
j ! k1 )(. q,testore jWith one the SCSinoperable reliefvalve valve inoperablestatus to OPERABLE in NCDES within 24 S hours or 6, oeither (1)]r LA2 a -reduce ',y p venting of thi'RCS~tlife' to-less-than-200*f-and;fcomplete Ugh at leiT! a guaredepressurization inch vent (s) - } w%. . , , g% n %. within a total of 32 hours./ 0: :t :te-* : reactor coolant pump
~
"a l* 5 8 j
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! v n c 1 ea 'k ) M c3 Mdlith both SCS relief y.Ahts. Jn0Atuble3 7;d.;; E :: 1 ;;; _t h;_:< . lkl I
' C00" e..d Aepressurize and vent the RCS throughTgreater ,than E g
gg qual to 16 squa-e inch vent (s).,wlthin 21ght hours) "- - " -* "* ' N reactor coolant pump the steam generator secondary water O ' emperature is % e 100*F above any RC / g *y)' can ms surm n o ,g > _S _ cold leg temperature /N J M )(. p.tt tM 000 ....t;d at least once ;;r per *CI:0NC 31 days, when t, ;r :.the verify the':vent pathway ; rtid:dpathway by : :1::';' k MM 4+4-1s locked, sealed, or otherwise secured in the open position; 4 u therwise. verify the vent cathway every 12 hours. Lk 3/4 4-32 Palo Verde - Units 1, 2, 3
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- 16 L 4. 6 . !
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m 5.M e. In the event either the SCS suction line relief valves or ar, RCS ~ l vent (s) are used to mitigate an RCS pressure transient, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6,9.2 within 30 days. The report shall describe the circumstances initiating the transient, the effect of the SCS suction line relief valves or RCS vent (s) on the transient and any corrective
~1D S LON action necessary to prevent recurrence.
2bO ff. The provisions of Specification 3.0.4 are not applicable ] _ SURVElltANCE RE0VfDEWENTS A.3 4.,.0.0.; Each SCS suction line relief valve shall be verified to be aligned ' MM.\b ,E., to provide overpressure protection for the RCS at least once per 31 days when , the pathway is provided by a valve (s) that is locked, sealed, or otherwise ) tescuron in ten e-on entitien- nthetwise_ verify aligagent every 12 hours. ) 1 4.4.0.2.0 The SCS suction line relief valves shall be verified OPERABLE with '
'N the recuired setrointGK least ence/er IShentaA 2
,. , r~f5 mr in ac.L.orbanta. wN,ha $tsaa l Te4. ?< 0 1 l
l I l l 3/4 4-33 Palo Verde - Units 1, 2, 3 -
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--m DISCUSSION OF CHANGES SPECIFICATION 3.4.13 s,
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.13 - Low Temperature Overpressure Protection (LTOP) System f ADMINISTRATIVE CHANGES A.1 All reformatting and renumbering is in accordance with Combustion Engineering Plant (CEOG) Standard Technical Specifications NUREG-1432. Rev.1 (NUREG-1432). As a result, the Palo Verde Nuclear Generating Station (PVNGS) Improved Technical Specifications (ITS) should be more readable, and therefore understandable, by plant operators as well as other users.
.During the reformatting and renumbering of the ITS. no technical changes (either actual or interpretational) to the Current Technical Specifications (CTS) were made unless they were identified and justified. ;
Editorial rewording (either adding or deleting) is made consistent with NUREG-1432. During NUREG-1432 development, certain wording preferences or English language conventions were adopted which resulted in no technical changes (either actual or interpretational) the CTS. Additional information has also been added to more fully describe each subsection. This wording is consistent with NUREG-1432. Since the design is already approved by the NRC adding more detail does not result in a . technical change. A.2 CTS 3.4'.8.3 uses two different temperatures to place the Shutdown Cooling System suction line relief valves in service, therefore, there exists the possibility of confusion in interpreting Mode 4 Applicability. CTS 3.4.8.3 clarifies those circumstances of when the Shutdown Cooling System suction line relief valves must be placed in service with additional information in the Applicability Statement. ITS 3.4.13 will retain this information in the format of a Note. This information does not add any additional i requirements or delete any existing requirements. Therefore, addition of this information in the format of a Note to ITS 3.4.13 is administrative in nature. This is consistent with PVNGS licensing basis. A.3 CTS 3.4.8.3 states that the provisions of 3.0.4 are not applicable to this Specification. ITS has no such statement in 3.4.13. ITS 3.0.4 has an exclusion that states Mode 5 and Mode 6 are not applicable. CTS 3.0.4 has l no such exclusion within its definition. CTS 3.0.4 is applicable in all Modes unless specifically excluded within the LC0 (e.g. CTS 3.4.8.3) itself. Therefore, it is not necessary to state 3.0.4 exclusion in ITS 3.4.13 since, within the definition of ITS 3.0.4. Mode 5 and Mode 6 are excluded. This change is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 1 REV.A
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.13 - Low Temperature Overpressure Protection (LTOP) System ADMINISTRATIVE CHANGES (continued) A.4 CTS 3.4.8.3 Actions a. b and c prohibit starting an RCP if the SG secondary water temperature is greater than 100 F above any RCS cold leg temperature. This requirement is specified in ITS 3.4.12 LCO Note with editorial rewording to be consistent with NUREG-1432 wording preferences and Notes for ITS LC0 3.4.6 and 3.4.7. This is consistent with the PVNGS licensing basis. TECHNICAL CHANGES - MORE RESTRICTIVE None TECHNICAL CHANGES - RELOCATIONS LA.1 NOT USED LA.2 CTS 3.4.8.3. Actions b and c. states that with one Shutdown Cooling System suction line relief valve not Operable in Modes 5 or 6. either (1) restore the valve to Operable status within 24 hours or reduce cold leg temperature to less than 200*F. and complete depressurization and venting the RCS through at least 16 sq. in. vent (s) within a total of 32 hours. ITS does not include the requirement to reduce cold leg temperature below 200 F. This requirement is a personnel safety issue rather than directly relating to any safety analysis. This requirement is not required to determine the Operability of a system, component or structure and therefore is being relocated to the ITS Bases 3.4.13. Action C.1. In addition, this information does not meet the 10 CFR 50.36 (c) (2) (ii) criterion for inclusion in the ITS. Any changes to the Bases Section will be in accordance with ITS Bases Control Program. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This ; requirement is not required to be in the ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to i a Licensee Controlled Document is acceptable and is consistent with . NUREG-1432. l PALO VERDE - UNITS 1,2, AND 3 2 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.13 - Low Temperature Overpressure Protection (LTOP) System TECHNICAL CHANGES - RELOCATIONS (continued) LA.3 CTS 3.4.8.3 requires that the Shutdown Cooling System suction line relief valves be verified Operable every 18 months. ITS 3.4.13 requires that Operability be verified in accordance with the Inservice Testing Program. Information concerning Frequency performance for this type of valve is better located in the Inservice Testing Program. Other safety valves, pressurizer safety valves and main steam safety valves, have their frequencies located in the Inservice Testing Program as well. Frequency : performance is not required to determine the OPERABILITY of a system, component or structure and therefore is being relocated to a Licensee Controlled Document (Inservice Test Program). Any technical changes to the Inservice Test Program will be in accordance with the 10 CFR 50.55a. This provides an equivalent level of control and is an administrative change with no impact on the margin of safety. This requirement is not required to be in the ITS to provide adequate protection of public health and safety. Therefore, relocation of this requirement to a Licensee Controlled Document is acceptable and is consistent with NUREG-1432. TECHNICAL CHANGES LESS RESTRICTIVE L.1 CTS does not address the fact that there are no valves in the RCS vent pathway. CTS requires verification of the RCS vent pathway every 12 hours if the pathway is not provided by a valve that is locked, sealed, or otherwise secured in the open position. ITS 3.4.13 would require that the < vent pathway be locked, sealed, or otherwise secured in the open position. This allows compliance with ITS SR 3.4.13.1 on a 31 day Frequency vs. 12 ! hour Frequency. This is not possible in CTS because there do not exist any valves in the RCS vent pathway, hence, the SR is performed on a 12 hour Frequency. The 12 hour Frequency is based on operating experience with mispositioning of unlocked vent valves. As stated earlier, PVNGS has no valves in the RCS vent pathway. Allowing the RCS vent pathway to be locked, sealed, or otherwise secured in the open position is a less restrictive , change. This change is acceptable because the intent is to verify an RCS i vent pathway open to atmosphere for overpressure protection. Whether there is a valve open in the vent pathway or the vent pathway is unobstructed the result is the same. Also, the SR frequencies are the same as though a valve ! existed in the vent pathway. This change is consistent with NUREG-1432. PALO VERDE - UNITS 1,2, AND 3 3 REV.B
PALO VERDE ITS CONVERSION DISCUSSION OF CHANGES SPECIFICATION 3.4.13 - Low Temperature Overpressure Protection (LTOP) System TECHNICAL CHANGES LESS RESTRICTIVE (continued) L.2 The purpose of CTS LC0 3.4.8.3, according to CTS Bases 3/4.4.8. is to ensure that the RCS will be protected from pressure transients which could exceed the limits of 10 CFR 50. Appendix G. " Fracture Toughness Requirements." Although CTS 3.4.8.3 does not have the provision for a depressurized RCS and a 16 square-inch vent in the LCO CTS 3.4.8.3 ACTIONS
- a. b, and c result in relying on a depressurized and vented RCS for overpressure prevention with SCS relief valve (s) inoperable. ITS LCO 3.4.13 ACTION C.1 also results in relying on a depressurized and vented RCS for overpressure prevention with SCS relief valve (s) inoperable. As stated in ITS Bases B3.4.13. LCO. this overpressure prevention is provided by either the SCS suction line relief valves or a depressurized RCS with a 16 square-inch RCS vent. By including the provision for a depressurized RCS with a 16 square-inch RCS vent in ITS LCO 3.4.13 compliance with the ACTIONS when the SCS relief valves are inoperable will result in a plant condit' ion where the plant is in compliance with the TS, without requiring the unnecessary removal of the reactor vessel head. Also, including the provision for a depressurized RCS with a 16 square-inch RCS vent in ITS LC0 3.4.13 will allow entry into a MODE of Applicability of ITS LCO 3.4.13 with one or more SCS relief valves inoperable, as long as the RCS is depressurized and the required vent is established. This is acceptable because the depressurized and vented RCS (in accordance with the ITS LCO) will be prevented from exceeding P/T limits. This change is consistent with NUREG-1432.
l PALO VERDE - UNITS 1,2, AND 3 4 REV.B
\
4 l NO SIGNIFICANT HAZARDS CONSIDERATION i l SPECIFICATION 3.4.13 1 l l I l l l
- - = . .. . . _ _ - -
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.13 - Low Temperature Overpressure Protection (LTOP) System ADMINISTRATIVE CHANGES (ITS 3.4.13 Discussion of Changes Labeled A.1, A.2 and A.3) Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS). Units 1. 2. and 3. is converting to the ITS as outlined in NUREG-1432. " Standard Technical Specifications. Combustion Engineering Plants." The proposed changes involve the reformatting, renumbering, rewording of the Technical Specifications (TS) and Bases with no change in intent, and the incorporation of current operating practices consistent with NUREG-1432. These changes, since they do not involve technical changes to the Current TS (CTS), are administrative. Below are the No Significant Hazards Consideration (NSHC) for the conversion of this Section/ Chapter to NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to ! an operating license for a facility involves a no significant hazards I consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
Standard 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes involve reformatting. renumbering, and rewording of the CTS and Bases along with incorporation of PVNGS current operating practices and other changes to the CTS as discussed in the specific Discussion of Changes listed above in order to be consistent with NUREG-1432. The reformatting, renumbering, and rewording along with the other changes listed above, involves no technical changes to the CTS. Specifically, there will be no change in the requirements imposed on PVNGS due to these changes. During development of NUREG-1432 certain wording preferences or English language conventions were adopted. The proposed changes to this Section/ Chapter are administrative in nature and do not impact initiators of any analyzed events. They also do not impact the assumed mitigation of accidents or transient events. Therefore, these changes do not involve a significant increase in the probat;ility or consequences of an accident previously evaluated. PALO VERDE - UNITS 1,2, AND 3 1 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION 1 ITS Section 3.4.13 - Low Temperature Overpressure Protection (LTOP) System l ADMINISTRATIVE CHANGES l (ITS 3.4.13 Discussion of Changes Labeled (A.1, A.2 and A.3) (continued) 1 ; l Standard _1 Does the proposed change create the possibility of a new or ! different kind of accident from any accident previously evaluated?
]
The proposed changes involve reformatting, renumbering, and rewording of i the CTS, along with the incorporation of PVNGS current operating practices I and other changes, as discussed, in order to be consistent with NUREG-1432. I i The proposed changes do not involve a physical alteration of the plant (no j new or different type of equipment will be installed) or change the methods governing normal plant operation. The proposed changes will not impose any new or different requirements or eliminate any existing requirements. Therefore, these changes do not create the possibility of a new or 3 different kind of accident from any accident previously evaluated. Standard 3. Does the proposed change involve a significant reduction in a margin of safety? The proposed changes involve reformatting, renumbering, and rewording of the CTS, along with the incorporation of PVNGS current operating practices I and other changes, as discussed, in order to be consistent with NUREG-1432. l The proposed changes are administrative in nature and will not involve any technical changes. The proposed changes will not reduce a margin of safety because they have no impact on any safety analysis assumptions. Also, because these changes are administrative in nature, no question of safety is involved. Therefore, these changes do not involve a significant reduction in a margin of safety. , i i i PALO VERDE - UNITS 1,2, AND 3 2 Rev. A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.13 - Low Temperature Overpressure Protection (LTOP) System ! l TECHNICAL CHANGES - RELOCATIONS (ITS 3.4.13 Discussion of Changes Labeled LA.2, and LA.3) Arizona Public Service Company, Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3 is converting to the ITS as outlined in NUREG-1432. The proposed changes. since detail is being removed from the CTS to a Licensee Controlled Document, are less restrictive. The descriptions of these changes are in the Discussion of Changes listed above. The Commission has provided standards for determining whether a significant j hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to ' an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or l consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these
- standards as they relate to this amendment request follows
Standard 1.-- Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed changes relocate requirements from the CTS to' a Licensee Controlled Document. These changes do not result in any hardware changes l or changes to plant operating practices. The details being relocated are not assumed to be an initiator of any analyzed event. The Licensee i Controlled Document containing the relocated requirements will be
- maintained using the provisions of 10 CFR 50.59 or other specified control l processes and is subject to the change control process in the Admi;estrative Controls Section of the ITS. Since any changes to a Li ct. 30 Conalled Document will be evaluated, no increase in the i probebility or consequences of an accident previously evaluated will be allowed. Therefore, these changes will not involve a significant increase in the probability or consequences of an accident previously evaluated.
I l 1 i PALO VERDE - UNITS 1,2, AND 3 3 Rev.B
NO SIGNIFICANT IIAZARDS CONSIDERATION ITS Section 3.4.13 - Low Temperature Overpressure Protection (LTOP) System l TECHNICAL CHANGES RELOCATIONS i (ITS 3.4.13 Discussion of Changes Labeled LA.2, and LA.3) (continued) l Standard 2.- Does the proposed change create the possibility of a new or
- different kind of accident from any accident previously evaluated?
The proposed changes relocate requirements from the CTS to a Licensee Controlled Document. These changes will not alter the plant configuration (no new or different type of equipment will be installed) or change the methods governing normal plant operation. These changes will not impose different requirements and adequate control of information will still be maintained. These changes will not alter assumptions made in the safety analysis or licensing basis. Therefore. these changes will not create the possibility of a new or different kind of accident from any accident 1 previously evaluated. l Standard 3.-- Does the proposed change involve a significant reduction in a
- margin of safety?
The proposed changes relocate requirements from the CTS to a Licensee
- Controlled Document. These changes will not rcouce a margin of safety l since they have no impact on any safety analysis assumptions. In addition. l'
; the requirements to be transposed from the CTS to the Licensee Controlled Document are the same as the CTS. Since any future changes to this Licensee Controlled Document will be evaluated per the requirements of
, 10 CFR 50.59. or other specified control processes, no reduction 2 (significant or insignificant) in a margin of safety will be allowed. i Therefore, these changes will not involve a significant reduction in a margin of safety. The NRC review provides a certain margin of safety. and although this review will no longer be performed prior to submittal, the NRC still inspects the 10 CFR 50.59 process. The proposed changes are consistent with NUREG-1432, which was approved by the NRC Staff. The change controls for proposed relocated details and requirements provide an acceptable level of regulatory authority. Revising the CTS to reflect the approved level of detail per NUREG-1432 reinforces the conclusion that there is not a significant reduction in the margin of safety. Therefore, revising the CTS to reflect the NRC accepted level of detail and requirements ensures no reduction in a margin of safety. PALO VERDE - UNITS 1,2, AND 3 4 Rev B
I NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.I3 - Low Temperature Overpressure Protection (LTOP) System TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.13 Discussion of Changes Labeled L.1)
; Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS).
i Units 1. 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the
- description of this less restrictive change and the NSHC for the conversion to NUREG 1432.
L.1 CTS does not address the fact that there are no valves in the RCS vent pathway. CTS requires verification of the RCS vent pathway every 12 hours ; ^ if the pathway is not provided by a valve that is locked sealed, or i otherwise secured in the open position. ITS 3.4.13 would require that the ) vent pathway be locked, sealed, or otherwise secured in the open position. This allows compliance with ITS SR 3.4.13.1 on a 31 day Frequency vs.12 hour Frequency. This is not possible in CTS because there do not exist any
- valves in the RCS vent pathway, hence the SR is performed on a 12 hour I Frequency. The 12 hour Frequency is based on operating experieve with mispositioning of unlocked vent valves. As stated earlier PVNGS has no valves in the RCS vent pathway. Allowing the RCS vent pathway to be locked, sealed, or otherwise secured in the open position is a less restrictive
- change. This change is acceptable because the intent is to verify an RCS
- vent pathway open to atmosphere for overpressure protection. Whether there
. is a valve open in the vent pathway or the vent pathway is unobstructed the result is the same. Also, the SR frequencies are the same as though a valve existed in the vent pathway. This change is consistent with NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards j consideration if operation of the facility, in . accordance with a proposed i amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated: or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
i 4 4 PALO VERDE - UNITS 1,2, AND 3 5 Rev. A
- . . .. . . _ - .--. -- . - ~
l I NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.13 - Low Temperature Overpressure Protection (LTOP) System TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.13 Discussion of Changes Labeled L.1) (continued) I Standard 1.-- Does the proposed change involve a significant increase in the i probability or consequences of an accident previously evaluated? ) , l . The proposed change allows the verification that the RCS vent pathway is l secured in the open position as opposed to verifying that a vent valve is secured in the open position. The opening must be greater than or equal to 16 square inches to ensure that the RCS is protected from over pressurization. This change does not alter the verification that the RCS will be vented adequately. This change does not affect the probability of an accident. This change does not alter assumptions relative to mitigation of an accident or transient event. This change does not impact an
- initiator of any analyzed event. The consequences of an accident are not significantly affected by this change. Therefore, this change will not
, involve a significant increase in the probability or consequence of an accident previously evaluated. Standard 2. - Does the proposed change create the pos'sibility of a new or i different kind of accident from any accident previously evaluated? l The proposed change allows the verification that the RCS vent pathway is secured in the open position as opposed to verifying that a vent valve is secured in the open position. The opening must be greater than or equal i to 16 square inches to ensure that the RCS is protected from over ' pressurization. This change does not alter the verification that the RCS will be vented adequately. This change does not physically alter the plant , and there is no new or different type of equipment installed. The change does not require any new or unusual operator actions. Therefore, this change does not create the possibility of a new or different kind of accident from any accident previously evaluated. i' PALO VERDE - UNITS 1,2, AND 3 6 Rev. A 4 1
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.13 - Low Temperature Overpressure Protection (LTOP) System TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.13 Discussion of Changes Labeled L.1) (continued) a Standard 3. - Does the proposed change involve a significant reduction in a margin of safety? 4 The proposed change allows the verification that the RCS vent pathway is j secured in the open position as opposed to verifying that a vent valve is secured.in the open position. The opening must be greater than or equal to 16 square inches to ensure that the RCS is protected from over pressurization. The margin of safety is not affected by this change.
- Therefore. the change does not involve a significant reduction in a margin of safety.
i I + I 4 [ t i PALO VERDE - UNITS 1,2, AND 3 7 Rev.A
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.13 - Law Temperature Overpressure Protection (LTOP) System I l TECHNICAL CHANGES LESS RESTRICTIVE i (ITS 3.4.13 Discussion of Changes Labeled L,2) l Arizona Public Service Company. Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2. and 3 is converting to the ITS as outlined in NUREG-1432. The proposed change involves making the CTS less restrictive. Below is the description of this less restrictive change and the NSHC for the conversion to NUREG 1432. L.2 The purpose of CTS LCO 3.4.8.3, according to CTS Bases 3/4.4.8, is to ensure that the RCS will be protected from pressure transients which could exceed the limits of 10 CFR 50. Appendix G. " Fracture Toughness Requirements." Although CTS 3.4.8.3 does not have the provision for a depressurized RCS and a 16 square-inch vent in the LCO CTS 3.4.8.3 ACTIONS a, b. and c result in relying on a depressurized and vented RCS for overpressure prevention with SCS relief valve (s) inoperable. ITS LC0 3.4.13 ACTION C.1 also results in relying on a depressurized and vented RCS for overpressure prevention with SCS relief valve (s) inoperable. As stated in ITS Bases B3.4.13 LCO, this overpressure prevention is provided by either the SCS suction line relief valves or a depressurized RCS with a 16 square-inch RCS vent. By including the provi'sion for a depressurized RCS with a 16 square-inch RCS vent in ITS LC0 3.4.13, compliance with the ACTIONS when the SCS relief valves are inoperable will result in a plant condition where the plant is in compliance with the TS, without requiring the unnecessary removal of the reactor vessel head. Also, including the provision for a depressurized RCS with a 16 square-inch RCS vent in ITS LC0 3.4.13 will allow entry into a MODE of Applicability of ITS LC0 3.4.13 with one or more SCS relief valves inoperable, as long as the RCS is depressurized and the required vent is established. This is acceptable because the depressurized and vented RCS (in accordance with the ITS LCO) will be prevented from exceeding P/T limits. This change is consistent with NUREG-1432. The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves a no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not 1) involve a significant increase in the probability or consequences of an accident previously evaluated: 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
- 3) involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:
PALO VERDE - UNITS 1,2, AND 3 8 Rev.B 1 b
NO SIGNIFICANT IIAZARDS CONSIDERATION ITS Section 3.4.13 - Low Temperature Overpressure Protection (LTOP) System s TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.13 Discussion of Changes Labeled L.2) (continued) Standard 1.- Does the proposed change involve a significant increase in the l probability or consequences of an accident previously evaluated? i 1 The proposed change allows the provision for a depressurized RCS and a l 16 square-inch vent as an alternative to two OPERABLE SCS system suction ' line relief valves to provide overpressure protection for the RCS in ITS LC0 3.4.13. The purpose of the OPERABLE SCS suction line relief valves is to ensure that the RCS will be protected from pressure transients which could exceed the limits of 10 CFR 50, Appendix G. " Fracture Toughness ! ! Requirements." The requirement to depressurize and vent the RCS ensures the same protection. With the RCS depressurized, analyses show a vent size of 16 square inches is capable of mitigating the limiting allowed LTOP overpressure transient. In that event, this size vent maintains RCS pressure less than the maximum RCS pressure on the P/T limit curve. This change does not impact an initiator of any analyzed event. The consequences of an accident are not significantly affected by this change. Therefore, this change will not involve a significant increase in the probability or consequences of an accident previously evaluatN. i l PALO VERDE - UNITS 1,2, AND 3 9 Rev.B
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.13 - Low Temperature Overpressure Protection (LTOP) System TECHNICAL CHANGES LESS RESTRICTIVE (ITS 3.4.13 Discussion of Changes Labeled L.2) (continued) Standard 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
- The proposed change allows the provision for a decressurized RCS and a 16 l square-inch vent as an alternative to two OPERABLE SCS system suction line 2
relief valves to provide overpressure protection for the RCS in ITS
- LC0 3.4.13. The purpose of the OPERABLE SCS suction line relief valves is to ensure that the RCS will be protected from pressure transients which could exceed the limits of 10 CFR 50. Appendix G. " Fracture Toughness Requirements." The requirement to depressurize and vent the RCS ensures the same protection. With the RCS depressurized, analyses show a vent size of 16 square inches is capable of mitigating the limiting allowed LTOP i overpressure transient. In that event, this size vent maintains RCS
- pressure less than the maximum RCS pressure on the P/T limit curve.
Although CTS 3.4,8.3 does not have the provision for a depressurized RCS and a 16 square-inch vent in the LCO, CTS 3.4.8.3 ACTIONS a. b, and c result in relying on a depressurized and vented RCS for overpressure prevention with SCS relief valve (s) inoperable. ITS LC0 3.4.13 ACTION C.1 4 also results in relying on a depressurized and vented RCS for overpressure ; i prevent' ion with SCS relief valve (s) inoperable. As stated in ITS Bases ! B3.4.13 LCO, this overpressure prevention is provided by either the SCS i suction line relief valves or a depressurized RCS with a 16 sauare-inch RCS 1 i' vent. This change does not physically alter the plant and there is no new or different type of structures, systems or components installed. The change does not require any new or different operator actions. Therefore. l this proposed change does not create the possibility of a new or different i 4 kind of accident from any accident previously evaluated. 4 1 l a I 4 3 l PALO VERDE - UNITS 1,2, AND 3 10 Rev. B 9
NO SIGNIFICANT HAZARDS CONSIDERATION ITS Section 3.4.13 - Low Temperature Overpressure Protection (LTOP) System l TECHNICAL CHANGES - LESS RESTRICTIVE (ITS 3.4.13 Discussion of Changes Labeled L.2) (continued) 1 Standard 3.- Does the proposed change involve a significant reduction in a margin of safety? The proposed change allows the provision for a depressurized RCS and a 16 square-inch vent as an alternative to two OPERABLE SCS system suction line relief valves to provide overpressure protection for the RCS in ITS LCO 3.4.13. The purpose of the OPERABLE SCS suction line relief valves is to ensure that the RCS will be protected from pressure transients which could exceed the limits of 10 CFR 50. Appendix G. " Fracture Toughness Requirements." The requirement to depressurize and vent the RCS ensures the same protection. With the RCS depressurized. analyses show a vent size of 16 square inches is capable of mitigating the limiting allowed LTOP overpressure transient. In that event, this' size vent maintains RCS pressure less than the maximum RCS pressure on the P/T limit curve. The margin of safety is not affected by this change. Therefore the proposed change does not involve a significant reduction in the margin of safety. PALO VERDE - UNITS 1,2, AND 3 11 Rev. B
1 I 1 l I I l l CE STS ; i NUREG-1432 REV.1 l J SPECIFICATION 3.4.14 MARK UP l 1 1 1 1 I l I
RCS Operational LEAKAGE h
<' as .) % i 3.4 REACTOR COOLANT SYSTEM (RCS) 1 3.4. RCS Operational LEAKAGE 3.4. RCS operational LEAKAGE shall be limited to:
LC0 No pressure boundary LEAKAGE;
.4,52. A) a.
- b. 1 gpa unidentified LEAKAGE;
.4.5.2. b ;
- c. 10 gpa identified LEAKAGE;
,q ,y,7 ,
- d. I gpa total primary to secondary LEAKAGE through all steam generators (SGs); and
<5.45 4 1720da11ons per day primary to secondary LEAKAGE h l e. /g,4,g,7,c through any one SG.
\
APPLICABILITY: MODES 1, 2, 3, and 4. l ACTIONS- ' COMPLETION TIME CONDITION REQUIRED ACTION Reduce LEAKAGE to 4 hours A. RCS LEAKAGE not within A.1 limits for reasons within limits. er b, other than pressure boundary LEAKAGE.
~
B.1 Be in MODE 3. 6 hours B. Required Action and C.T b . associated Completion Time of Condition A 8tgl not met. Se in MODE 5. 36 hours B.2 E Pressure boundary / y q, LEAKAGE exists. s a T hY t- NAS \gl 3 Rev 1, M/07/73-
.... ;i;-
3.4-30
i i INSERT FOR ITS 3.4.14 ACTION C (Units 1,2, and 3) INSERT 1 ACTIONS I CONDITION REQUIRED ACTION COMPLETION TIME C. One or more SGs C.1 Enter 3.0.3. Immediately inoperable. l l s i
l ! RCS Operational LEAKAGE l 3.4.
- SURVEILLANCE REQUIREMENTS f
i SURVEILLANCE FREQUENCY l
-----NOTE------
~
.q,5,7., SR 3.4. .1 ------------------NOTE--------------------
Not required to be perfomed in NODE 3 or 4 Only required b8[y'T until 12 hours of steady state operation. to be performed during steady state operation Perform RCS water inventory balance. 72 hours 4 SR 3.4./.2 Verify SG tube integrity is in accordance In accordance with the Steam Generator Tube Surveillance with the Steam l 'N+N a0 Program. Generator Tube
. Surveillance Program i
4 i I i l I Undo 1,?. O CEOG STS 3.4-31 Rev 1, 04/07/95
)
e i k
l l 1 1 l l l l l l l 1 I CE STS NUREG-1432 REV.1 SPECIFICATION 3.4.14 BASES MARK UP l 1 l l
. l 1
l 1 l l I l l l l 1 i
\
i l ! I l I l l
-l RCS Operational B 3.4 LEAKA[GE J t
l B 3.4 REACTOR COOLANT SYSTEM (RCS) I B 3.4. RCS Operational LEAKAGE 1 l 44 BASES
)
BACKGROUND Components that contain or transport the coolant to or from the reactor core make up the RCS. Component joints are made ! > by welding, bolting, rolling, or pressure loading, and 1 valves isolate connecting systems from the RCS, During plant life, the joint and valve interfaces can produce varying amounts of reactor coolant LEAKAGE, through l either normal operational wear or mechanical deterioration. 1 The purpose of the RCS Operational LEAKAGE LCO is to limit l system operation in the presence of LEAKAGE from these " sources to amounts that do not compromise safety. This LC0 1 specifies the types and amounts of LEAKAGE. , 10 CFR 50, Appendix A, GDC 30 (Ref.1), requires means for detecting and, to the extent practical, identifying the i source of reactor coolant LEAKAGE. Regulatory Guide 1.45 ] (Ref. 2) describes acceptable methods for selecting leakage 1 I detection systems. The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring reactor coolant LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE is - necessary to provide quantitative information to the operators, allowing them to take corrective action should a leak occur detrimental to the safety of the facility and the , public. ! ! I A limited amount of leakage inside containment is expected j from auxiliary systems that cannot be made 100% leaktight. Leakage from these systems should be detected, located, and isolated from the containment atmosphere, if possible, to not interfere with RCS LEAKAGE detection. I This LC0 als with protection of the [eactor %olant fressure oundary (RCPB) from degradation and the core from i i inadequate cooling, in addition to preventing the accident ! analysis radiation release assumptions from being exceeded. I The consequences of violatJn this LCO include the possibilityofafosseffooantpcident(LOCA). ' #_~ V (continued) ( Ye \)r d 6 h E. @ _5 .L B 3.4-68 Re v : , " ' '^' "'i
. - . _ _ . . _ _ . m_ ._ . _ _ ~ . . _ . - _ - _ - - . . _ . _ . . -
l 4 ! l I l i l I i RCS Operational LEAKAGE l
.B 3.4.
l A m 1 \ BASES (continued) Except for primary to secondary LEAKAGE, the safety analyses j APPLICABLE SAFETY ANALYSES do not address operational LEAKAGE. However, other ! i operational LEAKAGE is related to the safety analyses for LOCA; the amount of leakage can affect the probability of 3' such an event. The safety analysis for an event resulting in steam discharge to the atmosphere assumes a 1 gpm primary a to secondary LEAKAGE as the initial condition. I Primary to secondary LEAKAGE is a factor in th dose r>1easesoutsidecontainmentresultingfromafteam[idents ine ) e7reak(SLB) accident. To a lesser extent, other acc or transients involve secondayy steam rele to the atmosphere,suchasafteampeneratorfube upture (SGTR). Th leakage contaminates the secondary flui . ThPFSAR (Ref. 3) analysis for SGTR assumes the contaminated , secondary fluid is only briefly released via safety valves i and the majority is steamed to the condenser. The I gpa f primary to secondary LEAKAGE is relatively inconsequential. The SLB is more limiting for site radiation releases. The ; i safety analysis for the SLB accident assumes I gpm primary to secondary LEAKAGE in one generator as an initial l
) condition. The dose consequences resulting from the SLB i accident are well within the limits defined in 10 CFR 50 or the staff approved licensing basis (i.e., a small fraction of these limits).
RCS operational LEAKAGE satisfies Criterion 2 th M Nte-
.hLD } 2 d. !
1 LCO RCS operational LEAKAGE shall be limited to: ,
- a. Pressure Boundary LEAKAGE ,
No pressure boundary LEAKAGE is allowed, being indicative of material deterioration. LEAKAGE of this i type is unacceptable as the leak itself could cause further deterioration, resulting in higher LEAKAGE. Violation of this LCO could result in continued degradation of the RCPB. LEAKAGE past seals and gaskets is not pressure boundary LEAKAGE.
) (continued) 4Eer- W B 3.4-69 Re M /C /37-"'
b Ya - M 3 h2. O
l RCS Operational LEAKAGE B3.4.)Vh BASES LCO b. ILrtidentified LEAKAGE (continued) One gallon per minute (gpm) of unidentified LEAKAGE is allowed as a reasonable minimum detectable amount that the containment air monitoring and containment sump level monitoring equipment can detect within a reasonable time period. Violation of this LCO could result in continued degradation of the RCPB, if the LEAKAGE is from the pressure boundary.
- c. Identified LEAKAGE Up to 10 gpm of identified LEAKAGE is co,nsidered ..
allowable because LEAKAGE is from known sources that do not interfere with detection of identified LEAKAGE and is well within the capability of the RCS makeup system. Identified LEAKAGE includes LEAKAGE to the containment from specifically known and located sources, but does not LEAKAGE or controlled'jpelude gressure boundaryyeactorfoolantfump(RC leakoff (a rormal function not considered LEAKAGE). Violation of this LCO could result in continued
, degradation of a component or system. !
LCO 3.4.14, 'RCS Pressure Isolation Valve (PIV) Leakage," measures leakage through each individual PIV and can impact this LCO. Of the two PIVs in series in each isolated line, leakage measured through one PIV does not result in RCS LEAKAGE when the other is leaktight. If both valves leak and result in a loss of mass from the RCS, the loss must be included in the allowable identified LEAKAGE.
- d. Primary to Secondarv LEAKAGE throuah All Steam Generators (SGs)
Total primary to secondary LEAKAGE amounting to I gpm through all SGs produces acceptable offsite doses in the SLB accident analysis. Violation of this LCO could exceed the offsite dose limits for this accident analysis. Primary to secondary LEAKAGE must be included in the total allowable limit for identified LEAKAGE. (continued) r ^^ T: B 3.4-70 Rev :. 04/ M /7, V
- Mb I s 7 ,D
. _ . . ._. __.m _ _ __._ ___._ _-_ _ _ _ _ _ _ .- _ ._ _ . _ _
i. l l l RCS Operational LEAKAGE B 3.4 s ' i BASES LCO e. Primary to Secondary LEAKAGE throuch Any One SG The 72 gallon per day limit on primary to secondary L GE rough any one SG allocates the total 1 gpm allowed primary to secondary LEAKAGE equally between the two generators. APPLICABILITY In MODES 1, 2, 3, and 4, the potential for RCPB LEAKAGE is greatest when the RCS is pressurized.
- In MODES 5 and 6, LEAKAGE limits are not required because the reactor coolant pressure is far lower, resulting in lower stresses and reduced potentials for LEAKAGE.
ACTIONS El Unidentified LEAKAGE, identified LEAKAGE, or primary to secondary LEAKAGE in excess of the LCO limits must be reduced to within limits within 4 hours. This Completion Time allows time to verify leakage rates and either identify unidentified LEAKAGE or reduce LEAKAGE to within limits before the reactor must be shut down. This action is necessary to prevent further deterioration of the RCPB. B.1 and B.2
, If any pressure boundary LEAKAGE exists or if unidentified, identified, or primary to secondary LEAKAGE cannot be reduced to within limits within 4 hours, the reactor must be brought tL lower pressure conditions to reduce the severity of the LEAKAGE and .its potential consequences. The reactor must be brought to MODE 3 within 6 hours and to MODE 5 within 36 hours. This action reduces the LEAKAGE and also reduces the factors that tend to degrade the pressure boundary.
The allowed Completion Times are reasonable, based on operating experience, to reach the required conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 5, the pressure stresses
} (continued)
Rev !. M/^'/Z - m u B 3.4-71 D k
i i I Lt G .=.e.more, h = imp &.&uo.SA4.\54. E OL. ursk \faiA C mds#WS OUkesdA. h Ot.Iida.rd arvdgini.h,bt.[tra., rational L E L(O 1.0, *)n tws4 h s.nh12. rad itnrNd f y , BASES ACTIONS B.1 and B.2 (continued) acting on the RCPS are much lower, and further deterioration ( 4muchlesslikely. 1 r A SURVEILLANCE 5R 3.4. '
.1 REQUIREMENTS Verifying RCS LEAKAGE to be within the LCO limits ensures the integrity of the RCPB is maintained. Pressure boundary LEAKAGE would at first appear as unidentified LEAKAGE and can only be positively identified by inspection.
Unidentified LEAKAGE and identified LEAKAGE are determined by performance of an RCS water inventory balance. Primary to secondary LEAKAGE is also measured by performance of an ' RCS water inventory balance in conjunction with effluent monitoring within the secondary steam and feedwater systems. The RCS water inventory balance must be performed with the \ _ reactor at steady state operating conditions and near operating pressure. Therefore, this SR is not required to ' 4m3 enefit h."\ m be performed in MODES 3 and 4, until 12 hours of steady / gg g state operation near operating pressure have elapsed.4 }g g8 *^ g i Comds%Q Of1L St%b% tea)y state operation is required to perform a proper wate V. hcw to o\\emd inventory balance; calculations during maneuvering are not g 4k y 4 4 useful and a Note requires the Surveillance to be met when Pg"'4"'$ g steady state is established. For RCS operational LEAKAGE Tbanad e,@ 6, rot.3\\gnc,s., d h determination by water inventory balance, steady state is m at e defined as stable RCS pressure, temperature, power level, g 4 Q, haSGnca. Fr1.qvuc.1 pressurizer and makeup tank levels, makeup and letdown, en . irAg\p o g g RCP seal injection and return flows. bcku pmee rrra,pMW3
'h @f b D fAf An early warning of pressure boundary LEAKAGE or dewcri J os, uata. unidentified LEAKAGE is provided by the automatic systems *E"31, M I that monitor the containment atmosphere radioactivity and hk it M m Din the containment sump leve These leakage detection systems f " nan d are specified in LCO 3.4 'RCS Leakage Detection yi pT%. Instrumentation."
The 72 hour Frecuency is a reasonable interval to trend LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents. A Note under the Frequency column states that this SR is required to be performed during ster.dy state operation. (continued)
-- ii' B 3.4-72 Rev i, 04/07/ Z-iche Verdc.- Una blb
.. . -- . . . . . . . . - - . . .- - .. .. ~ . . . . - _ . - . . - - - . . .-
l s
]
l i RCS Operational LEAKAGE B 3.4 1 BASES SR SURVEILLANCE 3.4.' ) REQUIREMENTS (continued) This SR provides the means necessary to determine SG l 4 OPERABILITY in an operational MODE. The requirement to demonstrate SG tube integrity in accordance with the Steam Generator Tube Surveillance Program emphasizes the - importance of SG tube integrity, even though this i Surveillance cannot be performed at normal operating ,' conditions. l I 1 REFERENCES 1. 10 CFR 50, Appendix A, GDC 30. 1 2. Regulatory Guide 1.45, May 1973. 3hFSAR,Section(15(. l 4 i I a
) !
] l 1 1 I 4 I i
% B 3.4-73 Rev i . O'f"'ot ;
YP# C-OntIDk12h
NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.14 1 i I l
_ _ _ . ~ . . - _ . . _ . . . - . . _ _ . . _ _ _ - _ . _ . . . _ . _ . . .__ _ . _ . . - . _ . _ PALO VERDE ITS CONVERSION NUREG-1432 EXCEPTIONS SPECIFICATION 3.4.14 - RCS Operational Leakage
- 1. Grammar and/or editorial changes have been made to enhance clarity. No l technical or intent changes to the Specification are made by this change.
- 2. ITS 3.4.14 contains Action C which directs immediate entry into LCO 3.0.3 i when one or more SGs are inoperable, due to SR 3.4.14.2.. in Mode 1, 2. 3.
or 4. NUREG-1432. LCO 3.4.13. contains no such action. This is acceptable because NUREG-1432. LC0 3.4.13. contains no explicit Actions for an inoperable SG, due to SR 3.4.13.2. in Mode 1, 2. 3. or 4. therefore. LC0 3.0.3 would apply. Since both ITS and NUREG-1432 Actions result in identical Actions (LCO 3.0.3 entry) there is no technical change. ITS 3.4.14. Action C. is added to provide clarification to ensure the correct Action is applied and the correct LCO is entered. This change is consistent with PVNGS licensing basis. The Bases has also been revised to be consistent with the LCO. l
- 3. The plant specific titles, nomenclature, number. parameter /value, reference, system description, system design, operating practices or analysis description was used (additions, deletions, and/or changes are included). Plant specific parameters / values are directly transferred from i the CTS to the ITS.
i l I PALO VERDE - UNITS 1,2, AND 3 1 REV.A
PVNGS CTS SPECIFICATION 3.4.14 MARK UP l l I
.6pakabn .M.R (M.M /3.4.10 I
1
, 1 l
I I 1 I A.\ 1
,c v 4- REACTOR COOLANT SYST.M ,
j 3k% w~ '~ OPERATIONAL LEAKAGE LIMITING CONDITION FOR OPERATION .
.f O M. A "A Reactor Cooiant System ieakage shali be limited to: -
- a. No PRESSURE BOUNDARY LEAKAGE,
- b. I gpm UNIDENTIFIED LEAKAGE, -
- c. I gpm total primary-to-secondary leakage through all steam generators, and 720 gallons per day through any one steam generator,
(
- d. 10 gpm IDENTIFIED LEAKAGE from the React:,r Coolant System, and )
3.Tb S A.ib e. 1 gpm leakage at a Reactor Coolant System pressure of 2250 2 20 psia
,J5 dad 6 from any Reactor Coolant System pressure isolation valve specified in Table 3.4-1.
To SA16 APPLICABILITY: HODES 1, 2, 3, and 4. c: ACTION: TD- , [ With any PRESSURE B0UNDARY LEAKAGE, be in at least HOT STANDBY ( within 6 hours and in COLD SHUTDOWN within the fol_ lowing 30 hours. A(,T k N With any Reactor Coolant System leakage greater than any one of the limits, excluding PRESSURE BOUNDARY LEAKAGE and leakage from Reactor Coolant System pressure isolat_ ion valves, reduce the leakace rate to ithin limits within 4 hour.LFr be in at least NOT STANDBY within T ggA.%. , kb hthenext6hoursandinCOLDSHUTDOWNwithinthefollowing30 hours.)
, _ . c. With any Reactor Coolant System preissure isolation valve leakage . C O.*1. 6 greater than the above limit, isolate the high pressure portion of the affected system from the low pressure portion within 4 hours by use of at least one closed manual or deactivated automatic valve, or be in at least HOT STANDBY within the next 6 hours and in COLD $pg SHUTDOWN within the following 30 hours.
3 $*4* q d. With RC5 leakage alarmed and confirmed in a flow path with no !)ow ] rate indicators, commente an RCS water inventory balance within f L,,. / I hour to determine the leak rate. *g A SURVEILLANCE REQUIREMENTS n --
, - - - - Logw_itea\ Lt AY A(.st )
M.,",h ,6,li . \ (C4.44-d fac( c f MeReactor
- 41. rove Coolant 111mits by:SystemM shall be demonstrated to be within Monitoring the containment atmosphere gaseous and particulate b
( a. radica:tivity monitor at least once per 12 hours. _j' -]
.,td ,*'%
PALO VERDE - UNIT 1.E s'd 3/4 4~19 ..
. . , . Ojki'Gis W i %~=E M b'
~
hKAkur\ b 4.ik GbA.R/S4,\5) j l 1 s i
~
A.\ Y l l . l I i l
$UPVElllANCE REOUTREMENTS Mont hued)
J i e ntainmenfsumpinveporyandAscharge[leastAce
~ ~
A Performance of a'ReacIor 75'oiarit SNtes water inventory balance aQ I p east once ner 72 hours **. 1 l , 4{Mytopst)WreactorfdTangeIporsys east /nceperg 3 5 3 .4 \*5 4.4.5.2.2 Each Reactor Coolant Systes pressure isolation valve specified in Table 3.4-1 shall be demonstrated OPERABLE by verifying leakage to be within its limit **:
- a. At least once per 18 months, b.* Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 7 days or more and if leakage testing has not been performed in l the previous g months,
- c. Prior to returning the valve to service following maintenance, repair or replacement work on the valve, d.* Within 24 hours following valve actuation due to automatic or manual action or flow through the valve, e.* Within 72 hours following a system response to an Engineered Safety Feature actuation signal D3,4.\6 *The provisions of Specifications 4.4.5.2.2.b. 4.4.5.2.2.d. and 4.4.5.2.2.e are not rpplicable for valves UV 651, UV 652, UV 653 and UV 654 due to position indication of valves in the control room.
~
U$ft.\ *MM oro(1ston/of 1sicifir21on 4.DMe not_ppplicable for entry into MODE 4 PA 0 VEr.DE 34
l INSERT FOR CTS 3.4.5.2 t SR 4.4.5.2.1. C NOTE (Units 1,2, and 3) INSERT 1 1
........_ _. _. ... N OTES------....----_-..-- l Not required to be performed in MODES 3 and 4 until 12 hours of steady state operation l
l l 1 i I l 1 l I l I
h6hn M.M
%.4. \ 53
)
CD b D.b b6 & m_ued +0 1T& 3Aa5 l Ad. dT634 \ 5 coc_. !
'k )( b*C W Y l
/ ~
TABLE 3.4-l'
/
p l [ REACTOR COOLANT SYSTEM PRES $URE ISOLATION VALVES j
, VALV[
/0ESCRIPTION
) SIE-V237 .
,/ LOOP 1A RC/SI CHECK
' j
- 2) SIE-V247 /
LOOP 1B RC/SI CHECK f,r 3) SIE-V217
- 4) SIE-V227
[ LOOP 2A RC/SI CHECK , i
' LOOP 2B RC/SI CHECK
, 5) 5!E-V235 ,
LOOP 1A SIT CHECK /
; 6) SIE-V245 ,
LOOP IB SIT CHECK j/ ?
- 7) SIE-V215 LOOP 2A SIT CHECK'
, 8) SIE-V225 LOOP 2B SIT CHECK i 9) SIE-V542 ,
I LOOP 1A SI HEADER CHECK
- 10) SIE-V543
! 11) SIE-V540 LOOP 1B SIJEADER CHECK b LOOP 2A SI HEADER CHECK
- 12) SIE-V 1 LOOP 28'SI HEADER CHECK / i l 13) SIA- 522 '
- 14) 5 -V523 LOOP'1 HP LONG TERM RECIRCULATION CHECK' {
{
- 15) IB-V532 LOOP 1 HP LONG TERM RECIRCULATION CHECK l , LOOP 2 HP LONG TERM RECIRCULATION / CHECK
, 16 SIB-V533 i
,- LOOP 2 HP LONG TERM RECIRCULATION CHECK l
) SIA-UV651*,# / LOOP 1 SHUTDOWN COOLING ISOLATION i
- 18) SIB-UV652*,# / LOOP 2 SHUTDOWN COOLING ISOL'ATION '
- 19) SIC-UV653*,# '
LOOP 1 SHUT 00WN COOLING IS'OLATION
- 20) SID-UV654*,# '
LOOP 2 SHUT 00WN C00LIN ISOLATION
/
- Testing per Specifiestion 4.4.5.2.2.d is not applicable due to positive indica-tion of valve position in the control room.
#1. Leakage rates' greater than 1.0 gpm but less then[or equal to 5.0 considered acceptable if the latest measured pate has not exceeded the j rate determined by previous test by an amoup( that reduces the margin between by 50% ormeasured greater. leakage rate and the maxi um permissible rate of 5.0 ppm /
- 2. Leakage rates greater than 1.0 gpm but ess than or equal to 5.0 gpm are,,/
considered unacceptable if the latest measured rate exceeded the rate determined by the previous test by en amount that reduces the margin ' 1 between by 50% ormeasured greater. leakage rate and the maximum permissible rate of 5.0 gpm I , ,3'. Leakage rates greater than 5.0 ! pm are considered unacceptable. l
-- . /
PALO VERDE - UNIT 1.E @ 3/4 4-21 l l
l'hC.Ciluf\ '3, "T. N (3A.w/5.03 i i t l I l l I 1 I i 1 1 3, REACTORCOOLANTSYSTEM(D) A A , lk ?!' ^ ' STE'"C T T0Z "f6 o und L2 AO(=f M I D 10 OR OPERATION )
-= - % D.S,N.( %.4.- Each steam cenerator shall be OPERABLE) l APPLICABILITY: MODES 1, 2, 3, and 4.
ACTION: i With one or more steam generators inoperable, restore the inoperable ACT ' generator (s) to OPERABLE status prior to increasing T en1d above 2 M . j s [( .
)
hv as-t:s- Q~ 9 l
\
N'h N*d 4.4.4. F Each steam generator shall be demonstrated OPERABLE by performance of g g4g the following augmented inservice inspection program. IT3 3'0 4.4.4.1 Steam Generat r Samp e Selecti n and Inspecti n - Each steam generator shall be ceterminec OPERABLE curing shutdown by selecting and inspecting at least the minimum number of steam generators specified in Table 4.4-1. 4.4.4.2 Steam Generator Tube Sample Selection and Inspection - The steam . - generator tube minimum sample size, inspection result classification, and the l '. corresponding action required shall be as specified in Table 4.4-2. The i l inservice inspection of steam generator tubes shall be performed at the frequencies specified in Specification 4.4.4.3 and the inspected tubes shall l be verified acceptable per the acceptance criteria .cf Specification 4.4.4.4. ! The tubes selected for each inservice inspection shall include at least 3% of the total number of tubes in all steam generators; the tubes selected for these inspections shall be selected on a random basis except: a. Where experience in similar plants with similar water chemistry indicates critical areas to be inspected, then at least 50% of the tubes inspected shall be from these critical areas. b. The first sample of tubes selected for each inservice inspection (subsequent to.the preservice inspection) of each steam generator shall include: f PALO VERDE - UNIT 1,2g3 3/4 4-11
p AtatLn 3A M (c.oh
/cm 3.4.4 6 6 mcued to 1T3 5. o. '
kf. ITb 5. O tcc b- dwCL6*:$m ( ' REACTOR COOLA SYSTEM SURVEILL REQUIREMENTS (Continued) !
- 1. All nonplugged tubes / hat previously / had detectable A penetrations (grea r than 20%). /
- 2. Tubes in those 'eas where experience has indicated potential problems.
/
- 3. A tube ins tion (pursuant to specification 4.4.4.4a.8.) shall be perforjned on each selected tube. If any selected tube does not permit the passage of the eddy currant probe for.a tube inspe ' ion, this shall be recorded an#'an adjacent tube shall be s ected and subjected to a tube nspection. ,
i
- c. The tu s selected as the second and t ird samples (if required by Tabl 4.4-2) during each inservice 1,nspection may be subjected to a par al tube inspection provided: /
/
The tubes selected for *hept samples include the tubes fr those areas of the tube sheet array where tubes with , imperfections were previously found. '
- 2. The inspections incifde those portions of the tubes here j
imperfections werje previously found. , l The results of each sample in ection / shall be classified in one of the following three categories: Category Inspection Resul s C-1 Less than 5% of the to tubes inspected are degraded tubes and no of the inspected tubes l are defective. I C- One or more tube , but not more than 1% of the i total tubes in ected are defective, or betwee 5% and 10% of he total tubes inspected are i degraded tu 5, I C-3 More tha 10% of the total tubes inspect d are 1egrad tubes or more than 1% of the spected tubes re defective. j Note: In all inspe ions, previously degraded tub must exhibit significan (greater than 10%) further wal penetrations to be in uded in the above percentage e culations. PALO VERDE - UNIT gI t.g3 3/4 4-12
rtkN .b.4. N (s.03 CD 3A.4 hkoan m A -b nd s.C (saf dT.S 5.O iEI S e 6 r a .r. s i A . [REACTORCOOLANT/YSTEMS i [ SURVEILLANM REOUIREMENTS (Continued) 4.4. 3 Insoection Frecuencies - Th above required inservice inspe ns of st m generator tuDes shall be per rmed at the following frequenct(s:
- a. The first inservice i pection shall be performed aft 6 Effective Full Power Months b within 24 calender months of 141tial crit-icality. Subseque inservice inspections shall be<' performed at intervals the previousof inotpection."
essthan12normorethan24cdendarmonthsafter If two consecutive i service under VT conditions, not including t ,dspections following result in a inspection results falling in the preservice inspection, C-1 category or if two conse tive inspections demonstrate t previously observed degradat n has not continued and no add ional dagradation has occurr , the inspection interval may _ u tended to a maximum of once er 40 months.
- b. If the results of the inservice i I ection of a steam generator nducted in accordance with Tab 4.4-2 at 40 month intervals f 1 l into Category C-3, the inspect n frequency shall be increased o at ')
least once per 20 months. T increase in inspection freque y shall cpply until the subse ent inspections satisfy the er eria of Specification 4.4.4.3a.; e interval may then be extende to a maximum of once per 40 mahths.
- c. Additional, unschedul d inservice inspections shall performed on each specified in Tab) 4.4-2 during the shutdown subs uent inspection steam generato in accordance with the first s pie to any of the following co ditions:
- 1. Primary- o-secondary tubes leaks (not i luding leaks origin ing from tube-to-tube sheet we ds) in excess of the limi of Specification 3.4.5.2.
- 2. eismic occurrence greater tha he Operr. ting Basis arthquake. ,
j i 3 A loss-of-coolant accident r ufring actuation of the engineered safeguards. l
- 4. A main steam line or fe water line break.
Except that the inservice ins;p!ction due not later than July 91 may be deferreduntiltheendoffuf1 Cycle 3, but not beyond Marc 992. FALO VERDE - UNIT 1,2.,3 3/4 4-13
i ki d h 3.4,% (5.,03 m 34A M ban i yoAic, _u o 50
- 14. dTb 6.0 CbL
& deomun
{ [ REACTOR COOLAN h YSTEM SURVEILLA EQUIREMENTS (Continued) 4.4 .4 Acceptance Criteria j
- a. As used in this Specif ation 1.
_ Imperfection m ans an exception to the dimensio , finish, or contour of a ube from that required by fabri tion drawings or specificati ns. 1 Eddy-current testing indic ions below 20% of ' the nomin tube wall thickness, if detect le, may be considered as impe actions. , I
- 2.
Dear ation means a service-induced acking,
wastage, wear, or ge ral corrosion occurring on eith inside or outside of a l be.
- 3. Deoraded Tube means a tube con ining imperYections greater !
than or equal to 20% of the minal wall thickness caused by degradation.
- 4. % Degradation means the ercentage of the tube wall thic ess affected or removed b degradation.
- 5. Defect means an i rfection of such severity that exceeds the plugging lim . A tube containing a defect i defective.
- 6. Plugaino Limi means the imperfection depth a or beyond which the tube sh I be removed from service and i equal to 40%
of the no nal tube wall thickness.
- 7. Unserv ceable describes the condition a tube if it leaks or cont ns a defect large enough to aff t its structural integrity in he event of an Operating Basis rthquake, a loss-of-coolant cident, or a steam line or feed ter line break as specified n 4.4.4 3c., above.
Tube Inspection means an ins ction of the steam generator tu from the point of entry (h leg side) completely around th U-bend to the top suppor of the cold leg.
- 9. Preservice Inspection eens an inspection of the full ngth of each tube in each s am generator performed by eddy rrent techniques' prior t service to establish a baselin PALO VERDE - UNITi l 2.p 3/4 4-14
._m.. =_m m.. . _ . . _. _-. . , . - . . _ - _ . _ . _ _ . . . ._ _ .
L t t TABLE 4'4-2 . D g M N STEAM GENE TOR TUBE INSPECTION x . i t 1SbS, AMPLE INSPECTION 2ND5 LE INSPECTION : [ ; Sample Sire \ Result Action Required}}