ML023300333

Request to Withdraw Proposed Exigent Amendment to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program in Accordance with 10 CFR 2.107(a)

ML023300333
Person / Time
Site:	Palo Verde
Issue date:	11/19/2002
From:	Mauldin D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-04865-CDM/TNW/RJR
Download: ML023300333 (2)

Text

10 CFR 50.90 10 CFR 50.91 David Mauldin 10 CFR 2.107(a)

Vice President Mail Station 7605 Palo Verde Nuclear Nuclear Engineering TEL (623) 393-5553 P 0 Box 52034 Generating Station and Support FAX (623) 393-6077 Phoenix, AZ 85072-2034 102-04865-CDM/TNW/RJR November 19, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001 References 1. Letter 102-04844-CDM/TNW/JAP, "Exigent Amendment Request to Technical Specification 5.5.9, Steam Generator (SG) Tube Surveillance Program," dated September 26, 2002, C. D. Mauldin, APS to USNRC

2. Letter 102-04856 CDM/TNW/RJR, "Response to Request for Additional Information to Proposed Exigent Amendment to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program,"

dated October 23, 2002, C. D. Mauldin, APS to USNRC

3. Letter dated October 25, 2002, from the NRC to APS, "Palo Verde Nuclear Generating Station, Unit 1 - Review Related to Steam Generator Tube Inspection."

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Unit 1 Docket No. STN 50-528 Request to Withdraw Proposed Exigent Amendment to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program in Accordance with 10 CFR 2.107(a)

In References 1 and 2 above, Arizona Public Service Company (APS) requested and provided additional information in support of an exigent amendment to the Unit 1 Technical Specification (TS) 5.5.9, Steam Generator (SG) Tube Surveillance Program.

On October 25, 2002, the NRC issued to APS Reference 3 concluding that the requested amendment was not needed prior to restart of Unit 1. Reference 3 states that the NRC Staff has no objection to the "inspection of the SG tubes under the current TSs prior to restart of Unit 1 from the current refueling outage," and that "the proposed amendment is not needed on an exigent basis prior to restart of the plant."

A member of the STARS (Strategic Teaming and Pesource Sharing) Alliance Callaway

• Comanche Peak 0 Diablo Canyon

• Palo Verde 0 South Texas Project

• Wolf Creek }0DoI

U. S. Nuclear Regulatory Commission Request to Withdraw Proposed Exigent Amendment to Technical Specification 5.5.9, Steam Generator Tube Surveillance Program in Accordance with 10 CFR 2.107(a)

Pg. 2 We also understand from the October 25, 2002 letter that the underlying technical issues regarding SG tube inspections will be addressed without the need for immediate individual licensee amendment requests, but rather "on a generic basis,"

and that these issues "may be the subject of future generic communications."

Based on NRC Staff guidance contained in the October 25, 2002 letter and recent conversations with NRC Staff on this same subject, we have concluded that the proposed TS change is not needed to demonstrate operability of the SGs in Unit 1.

Specifically, APS can conduct the plus point coil tube inspections as described in References 1 and 2 within the terms of the current TS governing SG tube inspections.

Therefore, in accordance with 10"CFR § 2.107(a), APS requests to withdraw the proposed amendment request.

Additionally, as the TS inspection issue addressed in the NRC's October 25, 2002 letter applies also to Units 2 and 3, we do not believe that a TS change is required for Units 2 or 3 based upon the same rationale that no TS amendment is required for Unit

1. APS will, however, attempt to pursue resolution of this and other SG tube inspection issues on a generic basis with the Nuclear Energy Institute Steam Generator Task Force and the NRC technical staff.

No new commitments are being made to the NRC by this letter. Should you have any questions, please contact Thomas N. Weber at (623) 393-5764.

Sincerely, CDM/TNW/RJPRkg cc: E. W. Merschoff J. N. Donohew N. L. Salgado A. V. Godwin