NUREG-1432, Request for Additional Information, Round 3, Request to Revise Technical Specifications to Eliminate Use of the Term Core Alteration Consistent w/TSTF-471 and NUREG-1432, Rev. 3 (TAC ME8160-ME8162)
| ML12362A292 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/03/2013 |
| From: | Lauren Gibson Plant Licensing Branch IV |
| To: | Edington R Arizona Public Service Co |
| Gibson L | |
| References | |
| TAC ME8160, TAC ME8161, TAC ME8162, NUREG-1432 R3 | |
| Download: ML12362A292 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 3, 2013 Mr. Randall K. Edington Executive Vice President Nuclearl Chief Nuclear Officer 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 LICENSE AMENDMENT REQUEST TO ELIMINATE THE USE OF THE TERM CORE ALTERATION (TAC NOS. ME8160, ME8161, AND ME8162)
Dear Mr. Edington:
By letter dated March 8, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12076A045), as supplemented by letter dated October 11, 2012 (ADAMS Accession No. ML12286A330), Arizona Public Service Company (APS, the licensee) submitted a license amendment request (LAR) for Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The proposed amendment would eliminate the use of the term CORE ALTERATION from the Technical Specifications.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information provided by the licensee and determined that the additional information identified in the enclosure to this letter is needed in order for the NRC staff to complete its review. The draft copy of the request for additional information was provided to Mr. Robert Roehler of your staff via e-mail on November 8,2012. A clarifying conference call was held on December 13, 2012. The response is due January 31,2013.
R. Edington
- 2 If you have any questions, please contact me at (301) 415-1056 or via e-mail at Lauren.Gibson@nrc.gov.
Sincerely, Lauren K. Gibson, 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:
As stated cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ELIMINATE THE USE OF THE TERM CORE ALTERATION IN THE TECHNICAL SPECIFICATIONS ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1,2, AND 3 DOCKET NOS. 50-528, 50-529, AND 50-530 By letter dated March 8, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12076A045), as supplemented by letter dated October 11,2012 (ADAMS Accession No. ML12286A330), Arizona Public Service Company (APS, the licensee) submitted a license amendment request (LAR) for Palo Verde Nuclear Generating Station, Units 1, 2, and 3. Specifically, the licensee proposed to remove "CORE ALTERATION" from the Technical Specifications (TSs) including TS 3.9.2, "Nuclear Instrumentation."
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the submitted information and determined that the following additional information is required to complete the review.
- 1.
The LAR states:
In summary, with the exception of suspending movement of irradiated fuel assemblies, there are no design basis accidents or transients that are initiated by, or mitigation affected by, suspension of CORE ALTERATIONS. Therefore, removing CORE ALTERATIONS from applicability of TS 3.3.8, Containment Purge Isolation Actuation Signal (CPIAS) and TS 3.9.3, Containment Penetrations, is justified. In addition, with the exception of two TSs discussed below, the TS Required Actions that currently require suspension of CORE ALTERATIONS also require suspension of movement of irradiated fuel. For these TSs, suspension of CORE ALTERATIONS provides no safety benefit
[emphasis added] and the removal of the suspension of CORE ALTERATIONS is justified.
NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," (SRP) Section 15.7.4, "Radiological Consequences of Fuel Handling Accidents," states:
The purpose of the review is to evaluate the adequacy of system design features and plant procedures provided for the mitigation of Enclosure
- 2 the radiological consequences of accidents that involve damage to spent fuel. Such accidents include the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies [emphasis added].
Previously, suspension of CORE ALTERATIONS would preclude not only the movement of fuel, but would also preclude the movement of SOLlrces and reactivity control components. Dropped fuel sources or reactivity control components could break or they could damage a fuel assembly. Per SRP 15.7.4, these scenarios are to be considered. Although the amount of damage to fuel assemblies due to a dropped radioactive source or components would likely be less than for a dropped assembly, the overall dose to the public and operators might be greater because with the proposed change certain mitigating systems are no longer required to be operable. Please clarify how the suspension of CORE ALTERATIONS would provide "no safety benefit."
Based on the SRP summarized above, please state whether a dropped source or component (or any other item allowed to be moved by CORE ALTERATIONS) can damage a fuel assembly or break and create a radioactive source term. If so, please provide the analysis that shows that the dose consequences of these scenarios are less limiting than the current fuel handling accident. Provide the assumptions, inputs and results of these analyses.
R. Edington
- 2 If you have any questions, please contact me at (301) 415-1056 or via e-mail at Lauren. Gibson@nrc.gov.
Sincerely, IRA!
Lauren K. Gibson, 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:
As stated cc wtencl: Distribution via Listserv DISTRIBUTION:
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