ML061710465
| ML061710465 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/23/2006 |
| From: | Fields M NRC/NRR/ADRO/DORL/LPLG |
| To: | James M. Levine Arizona Public Service Co |
| Fields M , NRR/ADPT,415-3062 | |
| References | |
| TAC MC9425, TAC MC9426, TAC MC9427 | |
| Download: ML061710465 (6) | |
Text
June 23, 2006 Mr. James M. Levine Executive Vice President, Generation Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -
REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION AMENDMENT SUBMITTAL (TAC NOS. MC9425, MC9426, AND MC9427)
Dear Mr. Levine:
By letter dated December 23, 2005, Arizona Public Service Company submitted a license amendment request for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The request is to extend the allowed out-of-service time for one inoperable emergency diesel generator from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 10 days, add a clarifying note to Condition F of Technical Specification (TS) 3.8.1, "AC [alternating current] Sources - Operating," and revise TS 3.4.9, "Pressurizer," to delete the words which require that the two groups of pressurizer heaters be capable of being powered from an emergency power supply.
The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided and determined that additional information is required in order to complete the evaluation. The additional information being requested is enclosed. As discussed with Glenn Michael of your staff, the NRC staff is requesting a response within 30 days of the date of this letter.
If you have any questions, please contact me at 301-415-3062.
Sincerely,
/RA/
Mel B. Fields, Senior 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
Enclosure:
Request for Additional Information cc w/encl: See next page
June 23, 2006 Mr. James M. Levine Executive Vice President, Generation Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -
REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION AMENDMENT SUBMITTAL (TAC NOS. MC9425, MC9426, AND MC9427)
Dear Mr. Levine:
By letter dated December 23, 2005, Arizona Public Service Company submitted a license amendment request for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The request is to extend the allowed out-of-service time for one inoperable emergency diesel generator from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 10 days, add a clarifying note to Condition F of Technical Specification (TS) 3.8.1, "AC [alternating current] Sources - Operating," and revise TS 3.4.9, "Pressurizer," to delete the words which require that the two groups of pressurizer heaters be capable of being powered from an emergency power supply.
The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided and determined that additional information is required in order to complete the evaluation. The additional information being requested is enclosed. As discussed with Glenn Michael of your staff, the NRC staff is requesting a response within 30 days of the date of this letter.
If you have any questions, please contact me at 301-415-3062.
Sincerely,
/RA/
Mel B. Fields, Senior 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
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
PUBLIC LPLIV Reading RidsNrrDorlDpr RidsNrrDorlLpl4 RidsRgn4MailCenter (TPruett)
RidsAcrsAcnwMailCenter RidsNrrLALFeizollahi RidsNrrPMMFields RidsOgcRp ADAMS ACCESSION NO: ML061710465 OFFICE LPL4/PM LPL4/LA LPL4/BC NAME MFields LFeizollahi DTerao DATE 06/22/06 06/22/06 06/23/06 OFFICIAL RECORD COPY
REQUEST FOR ADDITIONAL INFORMATION 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 By letter dated December 23, 2005, Arizona Public Service Company submitted a license amendment request for the Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3.
The request is to extend the allowed out-of-service time (AOT) for one inoperable emergency diesel generator (EDG) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 10 days, add a clarifying note to Condition F of Technical Specification (TS) 3.8.1, "AC [alternating current] Sources - Operating," and revise TS 3.4.9, "Pressurizer," to delete the words which require that the two groups of pressurizer heaters be capable of being powered from an emergency power supply.
The staff has reviewed the information provided and determined that the following additional information is required in order to complete the evaluation.
1.
Provide a qualitative or quantitative assessment of the following risk changes:
Information on risk-important components and configuration that will be affected by the proposed extension, including Diesel Fuel Oil and Pressurizer Heaters.
Please provide a brief discussion and related information regarding the risk quantification tool.
Provide a discussion of the probabilistic risk assessment (PRA) quality, with emphasis on the system(s) and train(s) affected by the amendment. The discussion may include parametric uncertainty.
Please provide relative risk impact on incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP), using zero maintenance model versus regular model with baseline test/maintenance activities.
Are there any compensatory measures to mitigate the potential risk increases due to the amendment? If so, provide a discussion of the proposed compensatory measures and the associated benefit in both quantifiable and non-quantifiable terms.
Provide a brief discussion of the plant configuration control program and the on-line risk monitor.
2.
Your risk assessment in the submittal was based on internal events only. Discuss the impact of potential external events and risk contributors, such as fire.
3.
On page 17 of Enclosure 2 you state that your ICCDP would exceed the Regulatory Guide (RG) guideline. The intent in making the comparison of the PRA results with RG 1.177 is to demonstrate, with reasonable assurance, that Principle 4 in the Discussion section of RG 1.177 is being met. Please discuss how Principle 4 is being met.
4.
In Table 3, Enclosure 2 of your request letter, you have recalculated internal event core damage frequency based on your new reliability number. However, Table 2 of the enclosure clearly indicated that the plant risk (ICCDP) under the proposed amendment would increase by 6.44E-7 and 6.05E-7 for EDG A and EDG B, respectively. With this proposed TS change, it appears that the risk would increase by 6.44E-7/yr and 6.05E-7/yr, respectively, by annualizing the ICCDP for one year. Please explain these results.
5.
In your reliability recalculation presented in the second paragraph of page 17 of, the increase of the actual unavailability was assumed as 5.5 days instead of the 10-day proposed extension. The 5.5 days of maintenance outage discussed implies that the TS AOT will be used as a part of your routine online maintenance activities. Please explain.
6.
Please discuss the impacts of the uncertainties and risk contributors for both those explicitly accounted for in the results and those that were not.
7.
According to your risk assessment, EDG A has higher risk importance than that of EDG B. Please Explain.
8.
What are the risk assessment methodologies (such as FIVE) that you have employed for fire? Have you considered providing fire watch during the proposed AOT period?
9.
As a part of maintenance activities associated with EDGs, is this extension a part of the routine maintenance activities? Please elaborate.
10.
In diesel generator reliability, have you evaluated the Maintenance Preventable Function Failure (MPFF) under the 50.65 maintenance rule? If so, have you incorporated the MPFF in your EDG reliability?
11.
How does this extension impact the station blackout (SBO) sequences? Please discuss your reliability program in general and specifically the ability and timing of the EDGs to recover from an SBO event.
Palo Verde Generating Station, Units 1, 2, and 3 cc:
March 2006 Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Mr. Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 40 Buckeye, AZ 85326 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040 Mr. Craig K. Seaman, General Manager Regulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034 Mr. Matthew Benac Assistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 Mr. John Taylor Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224 Mr. Thomas D. Champ Southern California Edison Company 5000 Pacific Coast Hwy Bldg D1B San Clemente, CA 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, AZ 85251 Mr. Jeffrey T. Weikert Assistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901 Mr. John Schumann Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Mr. Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326 Ms. Karen O'Regan Environmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix AZ 85003