ML20016A458
| ML20016A458 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/10/2020 |
| From: | Siva Lingam Plant Licensing Branch IV |
| To: | Lacal M Arizona Public Service Co |
| Lingam S, 301-415-1564 | |
| References | |
| EPID L-2019-LLA-0289 | |
| Download: ML20016A458 (16) | |
Text
February 10, 2020 Ms. Maria L. Lacal Executive Vice President Nuclear/
Chief Nuclear Officer Mail Station 7605 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 - ISSUANCE OF AMENDMENT NOS. 211, 211, and 211 TO EXTEND IMPLEMENTATION DATE FOR AMENDMENT NOS. 209, 209, AND 209 ASSOCIATED WITH INITIATIVE 4b THAT PERMIT THE USE OF RISK-INFORMED COMPLETION TIMES ON THE TECHNICAL SPECIFICATIONS (EPID L-2019-LLA-0289)
Dear Ms. Lacal:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment Nos. 211, 211, and 211, to Renewed Facility Operating License Nos. NPF-41, NPF-51, and NPF-74 for the Palo Verde Nuclear Generating Station (Palo Verde), Units 1, 2, and 3, respectively. The amendments requested changes to the implementation date for Amendment Nos. 209, 209, and 209 in response to your application dated December 26, 2019.
The amendments would extend the implementation date from February 23, 2020, to August 31, 2020 for NRC-approved License Amendment Nos. 209, 209, and 209 for Palo Verde, Units 1, 2, and 3, respectively. These amendments, which were issued by the NRC to the licensee on May 29, 2019, approved the risk-informed completion times in accordance with Nuclear Energy Institute (NEI) Topical Report NEI 06-09, Revision 0-A, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specifications (RMTS)
Guidelines.
R. Bement A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions biweekly Federal Register notice.
Sincerely,
/RA/
Siva P. Lingam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530
Enclosures:
- 1. Amendment No. 211 to NPF-41
- 2. Amendment No. 211 to NPF-51
- 3. Amendment No. 211 to NPF-74
- 4. Safety Evaluation cc: Listserv
ML20016A458 *by e-mail OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DRA/APLA/BC
NAME SLingam PBlechman RPascarelli STurk DATE 1/21/20 1/21/20 1/16/20 2/4/20 OFFICE NRR/DORL/LPL4/BC NRR/DORL/LPL4/PM NAME JDixon-Herrity SLingam DATE 2/5/20 2/10/20 ARIZONA PUBLIC SERVICE COMPANY, ET AL.
DOCKET NO. STN 50-528 PALO VERDE NUCLEAR GENERATING STATION, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 211 License No. NPF-41
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority (collectively, the licensees) dated December 26, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
Enclosure 1
- 2. Accordingly, by Amendment No. 211, Renewed Facility Operating License No. NPF-41 is hereby amended to authorize change to the implementation date of Amendment No. 209, dated May 29, 2019, from February 23, 2020, to August 31, 2020, as set forth in the licensees application dated December 26, 2019, and evaluated in the NRC staffs safety evaluation with this amendment.
- 3. This license amendment is effective as of the date of issuance and shall be implemented by August 31, 2020.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: February 10, 2020
ARIZONA PUBLIC SERVICE COMPANY, ET AL.
DOCKET NO. STN 50-529 PALO VERDE NUCLEAR GENERATING STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 211 License No. NPF-51
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority (collectively, the licensees) dated December 26, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
Enclosure 2
- 2. Accordingly, by Amendment No. 211, Renewed Facility Operating License No. NPF-51 is hereby amended to authorize change to the implementation date of Amendment No. 209, dated May 29, 2019, from February 23, 2020, to August 31, 2020, as set forth in the licensees application dated December 26, 2019, and evaluated in the NRC staffs safety evaluation with this amendment.
- 3. This license amendment is effective as of the date of issuance and shall be implemented by August 31, 2020.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: February 10, 2020
ARIZONA PUBLIC SERVICE COMPANY, ET AL.
DOCKET NO. STN 50-530 PALO VERDE NUCLEAR GENERATING STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 211 License No. NPF-74
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by the Arizona Public Service Company (APS or the licensee) on behalf of itself and the Salt River Project Agricultural Improvement and Power District, El Paso Electric Company, Southern California Edison Company, Public Service Company of New Mexico, Los Angeles Department of Water and Power, and Southern California Public Power Authority (collectively, the licensees) dated December 26, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
Enclosure 3
- 2. Accordingly, by Amendment No. 211, Renewed Facility Operating License No. NPF-74 is hereby amended to authorize change to the implementation date of Amendment No. 209, dated May 29, 2019, from February 23, 2020, to August 31, 2020, as set forth in the licensees application dated December 26, 2019, and evaluated in the NRC staffs safety evaluation with this amendment.
- 3. This license amendment is effective as of the date of issuance and shall be implemented by August 31, 2020.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: February 10, 2020
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 211, 211, AND 211 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-41, NPF-51, AND NPF-74 ARIZONA PUBLIC SERVICE COMPANY, ET AL.
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530
1.0 INTRODUCTION
By application dated December 26, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19360A155), Arizona Public Service Company (APS, the licensee) submitted a license amendment request (LAR) for Palo Verde Nuclear Generating Station (Palo Verde), Units 1, 2, and 3.
The proposed amendments would extend the implementation date from February 23, 2020, to August 31, 2020, for the U.S. Nuclear Regulatory Commission (NRC)-approved Amendment Nos. 209, 209, and 209 for Palo Verde Units 1, 2, and 3, respectively. These amendments, which were issued by the NRC to the licensee on May 29, 2019 (ADAMS Accession No. ML19085A525), approved the risk-informed completion times (RICTs) in accordance with Nuclear Energy Institute (NEI) Topical Report NEI 06-09, Revision 0-A, Risk-Informed Technical Specification Initiative 4b, Risk-Managed Technical Specifications (RMTS)
Guidelines (ADAMS Accession No. ML12286A322).
In the LAR, the licensee stated, in part:
The unforeseen circumstances below required additional personnel resources that inhibited the implementation of the RICT TS [technical specification]:
The level of effort to complete implementation items associated with the PRA [probabilistic risk assessment] model quality has been greater than anticipated.
The methodology used from EPRI [Electric Power Research Institute]
report 3002012997, Revision 4, Pipe Rupture Frequencies for Internal Flooding Risk Assessments, for addressing maintenance induced flooding was recently questioned by a peer reviewer whether it meets the ASME [American Society of Mechanical Engineers]/ANS [American Enclosure 4
Nuclear Society] PRA Standard RA-Sa-2009 [(ASME/ANS, Addenda to ASME RA-S-2008, ASME/ANS PRA Standard ASME/ANS RA-Sa-2009, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications, dated February 2, 2009)]. An alternate methodology proposed by the peer reviewer is being implemented and is much more resource intensive than the EPRI methodology.
Plant events during the implementation period diverted PRA resources away from completion of the RICT PRA License Condition work including:
o Evaluation and corrective actions to address an NRC non-cited violation on the Time Critical Actions Program interface with the PRA model [(ADAMS Accession No. ML19130A127)]
o Unit 2 trip on August 16, 2019, risk significance and evaluation of subsequent offsite power supply realignments for house loads o Open phase modification risk assessment per NEI 19-02, Guidance for Assessing Open Phase Condition Implementation Using Risk Insights [(ADAMS Accession No. ML19122A321)]
o Actions to address an unplanned yellow risk management action level during the 1R21 refueling outage related to a failure to recognize that the Containment Cooling Fans were not available when moving the Reactor Head Retirement of a highly experienced senior PRA engineer who was a key member of the RICT implementation team[.]
2.0 REGULATORY EVALUATION
2.1 Description of Risk-Informed Completion Times The TSs contain limiting conditions for operations (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO is not met, the licensee must shut down the reactor or follow any remedial or required action (e.g., testing, maintenance, or repair activity) permitted by the TSs until the condition can be met. The remedial actions (i.e., ACTIONS) associated with an LCO contain conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated condition are required action(s) and completion times (CTs). The CTs are referred to as the "front stops" in the context of this safety evaluation (SE). For certain conditions, the TSs require exiting the mode of applicability of an LCO (i.e., shut down the reactor).
On May 17, 2007, the NRC staff approved NEI Topical Report NEI 06-09, Revision 0-A, to the extent specified and under the limitations set forth in the NRC staff's SE for NEI 06-09, Revision 0-A (ADAMS Accession No. ML071200238). NEI 06-09 0-A provides a methodology for modifying selected required actions to provide an optional RICT. NEI 06-09, Revision 0-A provides a methodology for extending CTs and, thereby, delay exiting the operational mode of applicability or taking required actions if risk is assessed and managed within the limits and
programmatic requirements established by an RICT Program or a configuration risk management program.
2.2 Description of the Proposed Change License Amendment Nos. 209, 209, 209 for Palo Verde, Units 1, 2, and 3, respectively, required that the RICT Program be implemented within 270 days of the date of issuance of the Amendments, which is February 23, 2020. The licensee is requesting that the original 270 days provided for implementation be extended to no later than August 31, 2020.
2.3 Regulatory Review The NRC staff considered the following regulatory guidance during its review of the proposed changes.
Regulatory Guide (RG) 1.174, Revision 3, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis,"
dated January 2018 (ADAMS Accession No. ML17317A256), describes an acceptable risk-informed approach for assessing the nature and impact of proposed permanent licensing basis changes by considering engineering issues and applying risk insights. This RG also provides risk acceptance guidelines for evaluating the results of such evaluations.
RG 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," dated March 2009 (ADAMS Accession No. ML090410014), describes an acceptable approach for determining whether the quality of the PRA, in total or the parts that are used to support an application, is sufficient to provide confidence in the results, such that the PRA can be used in regulatory decisionmaking for light-water reactors.
RG 1.174 and RG 1.200 summarize one acceptable approach to address technical issues that must be addressed in risk-informed application reviews, while NEI 06-09 provides additional details about addressing technical issues applicable to review and implementation of a proposed RICT Program. None of the documents address administrative issues such as the time provided or required to implement an RICT Program.
In issuing an amendment to an operating license, the NRC staff specifies when the amendment is effective and when the amendment must be implemented. Enclosures 1, 2, and 3 to the NRC's letter dated May 29, 2019, contained Amendment Nos. 209, 209, and 209, for Palo Verde Units 1, 2, and 3, respectively. The amendments each stated, in part, that:
This license amendment is effective as of its date of issuance and shall be implemented within 270 days of the date of issuance.
There are no specific regulatory requirements regarding the time period for amendment implementation. The NRC staff generally specifies an implementation period consistent with that requested in the licensee's application. For Palo Verde Units 1, 2, and 3, Amendment Nos. 209, 209, and 209, implementation dates were requested in the licensees letter dated July 31, 2015 (ADAMS Accession No. ML15218A300) as 180 days. At the request of the licensee on May 16, 2019, the implementation date was changed from 180 days to 270 days (ADAMS Accession No. ML20013C761).
Implementation periods or dates requested by licensees may vary based on the extent of the physical changes needed to the plant, the associated documentation that needs to be revised, and/or personnel training that is required. For example, sometimes licensees request that it be allowed to implement the amendment during the next refueling outage to support physical changes that it wants to make when the plant is shut down.
Since the implementation period specified by the NRC in an amendment is considered part of the operating license, the licensee is required to fully implement the amendment by the date specified (i.e., by a date no later than that specified) or be in violation of its operating license.
Any extension of the implementation period requires prior NRC approval as a license amendment pursuant to Title 10 of the Code of Federal Regulations, Section 50.90, Application for amendment of license, construction permit, or early site permit.
3.0 TECHNICAL EVALUATION
The guidance in RG 1.174, RG 1.200, and NEI 06-09, Revision 0-A identifies acceptable processes, PRA models, and plant procedures that should be in place before acceptable implementation of an RICT Program. At the conclusion of its review of Amendment Nos. 209, 209, and 209, the NRC staff had identified a number of plant specific actions that needed to be completed prior to implementation in order to achieve compliance with all the technical guidance discussed in the guidance documents. Therefore, Amendment Nos. 209, 209, and 209 for Palo Verde, Units 1, 2, and 3, respectively, included the following Additional Condition.
APS will complete the implementation items listed in the Enclosure of APS letter 102-07587, dated November 3, 2017, to the NRC and in Attachment 1, Table 1-1 of APS letter 102-07691, dated May 18, 2018, as updated by APS letter 102-07801, dated October 5, 2018, prior to implementation of RICTs. All issues identified will be addressed and any associated changes will be made, focused scope peer reviews will be performed on changes that are PRA upgrades as defined in the PRA standard (ASME/ANS RA-Sa-2009, as endorsed by RG 1.200, Revision 2), and any findings will be resolved and reflected in the PRA of record prior to implementation of the RICT program.
By letter dated December 26, 2019, the licensees request to change the implementation date for Amendment Nos. 209, 209, and 209 stated that the requested extension is necessary because unforeseen circumstances caused a delay in completion of a number of tasks required by the implementation process. The licensee stated that there had been a delay in completion of the PRA model, training on the new risk model results, procedure changes impacted by the new risk model, and other administrative requirements. Further, the licensees request identified several specific tasks that had not been completed but did not request any changes to the scope of any identified tasks.
The NRC staff agrees that the tasks required by the license condition and associated implementation items included some tasks (e.g., peer reviews as needed and resolution of any findings) that could not have been easily anticipated by the licensee due to their sequential nature. The licensee is not requesting any changes to the additional license condition discussed above and is therefore not requesting any change to the technical issues and issue resolutions reviewed and accepted by the NRC staff. Therefore, no further review of the acceptability of Amendment Nos. 209, 209, and 209 is warranted.
Consistent with its current licensing basis, the current TSs will continue to be used until the license condition and associated tasks and activities are completed and the RICT Program can be implemented. The protection of public health and safety is achieved by the licensee continuing to use the existing approved CTs in its current TSs and for the NRC to approve sufficient time for the licensee to fully prepare for implementation of the new program.
Extending the revised implementation date for the new RICT program has no adverse safety impact, in that the current CT program has previously been approved by the NRC and will continue in effect until the RICT program is implemented. Therefore, the NRC finds the request to be acceptable such that the implementation date can be changed from February 23, 2020, to August 31, 2020.
3.1 Changes to the Operating License License Amendment Nos. 209, 209, and 209 for Palo Verde Units 1, 2, and 3, respectively, required that the RICT Program be implemented within 270 days from the date of issuance of the amendment, which is February 23, 2020. The current license amendment extends the implementation date from February 23, 2020, to August 31, 2020.
3.2 Summary The licensee is requesting that the original 270 days provided for implementation by Amendment Nos. 209, 209, and 209 for Palo Verde Units 1, 2, and 3, respectively, be extended to no later than August 31, 2020. The requested change is an administrative change and has no impact on the technical acceptability of the proposed RICT Program, which was reviewed by the NRC staff and accepted as described in License Amendment Nos. 209, 209, and 209 issued on May 29, 2019.
4.0 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The NRC proposed to find that the requested amendment involves no significant hazards consideration in its Federal Register notice of January 8, 2020 (85 FR 936). The NRCs regulation in 10 CFR 50.92(c) states that the NRC may make a final determination, under the procedures in 10 CFR 50.91, that a license amendment involves no significant hazards consideration if operation of the facility, in accordance with the amendment, would not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (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.
An evaluation of the issue of no significant hazards consideration is presented below:
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed extension of the implementation date of the Risk-Informed Completion Time (RICT) License Amendment (LA) Number (No.) 209 does not involve a significant increase in the probability of an accident previously evaluated because the existing Technical Specification (TS)
Conditions, Required Actions and Completion Times (CT) will remain in effect during the extended implementation period.
The current TSs are effective and acceptable for establishing all actions necessary to mitigate the consequences of an accident previously evaluated and have been previously approved by the NRC. Therefore, the proposed extended RICT TS implementation does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed extension of the implementation date of the RICT LA No. 209 does not create the possibility of a new or different kind of accident from any accident previously evaluated because the existing TS Conditions, Required Actions and CTs will be in effect during the extended implementation period. The proposed change does not involve a physical alteration of the plant and does not involve installation of new or different kind of equipment.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The proposed extension of the implementation date of the RICT LA No. 209 is not a significant reduction in margin of safety since the existing TS Conditions, Required Actions and CTs will remain in effect during the extended implementation period, have an acceptable margin of safety and have been approved by the NRC.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above evaluation, the NRC staff concludes that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff has made a determination that no significant hazards consideration is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR 50.91.
5.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Arizona State official was notified of the proposed issuance of the amendment on January 13, 2020. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendments change requirements with respect to installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, published in the Federal Register on January 8, 2020 (85 FR 936), and there has been no public comment on such finding. Further, the Commission has made a determination that no significant hazards consideration is involved for the proposed amendments as discussed in Section 4.0 of this SE. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: S. Dinsmore, NRR Date: February 10, 2020