ML17298B105

Forwards Request for Addl Info Re Surveillance Requirements for ESF Actuation Sys.Planned Date for Response Requested within 2 Wks of Ltr Receipt

ML17298B105
Person / Time
Site:	Palo Verde
Issue date:	07/02/1984
From:	Knighton G Office of Nuclear Reactor Regulation
To:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
NUDOCS 8407230204
Download: ML17298B105 (10)

Text

JUL 8 1984 Docket Nos.:

50-528, 50-529 and 50-530 Mr. E.

E.

Van Brunt, Jr.

Vice President - Nuclear Projects Arizona Public Service Company Post Office Box 21666 Phoenix, Arizona 85036

Subject:

Request for Additional Information - Palo Verde ESFAS In order to complete our review of the Palo Verde Technical Specifications, we require 'additional information relating to the surveillance requirements for the Engineered Safety Features Actuation System (ESFAS).

The specific information required is identified in the enclosed request for information.

We request that you provide the required information discussed in the enclosure.

Please inform us within two weeks of receipt of this letter as to when you plan to respond.

If you have any questions regarding this request, you should contact Manny Licitra, the Licensing Project Manager.

Sincerely, js

Enclosure:

As stated cc:

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 2 )984 Docket Nos.:

50-528, 50-529 and 50-530 Mr. E.

E.

Van Brunt, Jr.

Vice President - Nuclear Projects Arizona Public Service Company Post Office Box 21666

Phoenix, Arizona 85036

Subject:

Request for Additional Information - Palo Verde ESFAS In order to complete our review of the Palo Verde Technical Specifications, we require additional information relating to the surveillance requirements for the Engineered Safety Features Actuation System (ESFAS).

The specific information required is identified in the enclosed request for information.

We request that you provide the required information discussed in the enclosure.

Please inform us within two weeks of receipt of this letter as to when you plan to respond.

If you have any questions regarding this request, you should contact Manny Licitra, the Licensing Project Manager.

Sincerely, t'eorge W

nighton, ef Licensing Branch No.

3 Division of Licensing

Enclosure:

As stated cc:

See next page

t l

Pal o Verde Hr.

E.

E.

Van Brunt, Jr.

Vice President - Nuclear Projects Arizona Public Service Company P. 0.

Box 21666 Phoenix, Arizona 85036 Arthur C. Gehr, Esq.

Snell

& Wilmer 3100 Valley Center Phoenix, Arizona 85073 Mr. James M. Flenner, Chief Counsel Arizona Corporation Commission 1200 West Washington Phoenix, Arizona 85007 Charles R. Kocher, Esq. Assistant Counsel James A. Boeletto, Esq.

Southern California Edison Company P. 0.

Box 800

Rosemead, Gal ifornia 91770 Ms. Margaret Walker Deputy Director of Energy Programs Economic Planning and Development Office 1700 West Washington Phoenix, Arizona 85007 Mr. Rand L. Greenfield Assistant Attorney General Bataan Memorial Building Santa Fe, New Mexico 87503 Resident Inspector Palo Verde/NPS U.S. Nuclear Regulatory Commission P. 0.

Box 21324 Phoenix, Arizona 85001 Ms. Patricia Lee Hourihan 6413 S. 26th Street Phoenix, Arizona 85040 Regional Administrator - Region V

U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Kenneth Berlin, Esq.

Winston

& Strawn Suite 500 2550 M Street, NW Washington, DC 20037 Ms. Lynne Bernabei Government Accountability Project of the Institute for Policy Studies 1901 gue Street, NW Washington, DC 20009 Ms. Jill Morrison 522 E. Colgate Tempi, Arizona 85238

~ ~

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ENCLOSURE ICSB Request For In format ion It is stated in the Palo Verde and CESSAR FSARs (Sections 7.3.1.1.8r 7.3.2.3.3 and 7.1.2.7i 7.1.2.15'espectively) that testing meets the criteria of IEEE Standard 338 and Regulatory Guide (R ~ G.) 1.22 and that the system can be checked from the sensor to and including the actuated de vices during reactor operation or when the reactor is shut down.

Also'ased on an audit reviewi the staff conc luded that the Palo Verde plant design complied with the provi.

sions of R.G.

1.22 and IEEE Standard 338.

This incLuded the testing at power of aLL ESFAS actuation devices (initia-tion relaysi subgroup relaysi etc.)

even if associated actuated equipment could not be tested during normaL reactor operation.

It has been fundamenta l regulatory practice to require that plants be designed to allow the protection system to be tested in its entirety while the plant is at power as indicated by General Design Criterion (GDC) 21 of Appendix A to 10 CFR Part 50 and as supplemented by R.G. 1.22'.G. 1.118'nd IEEE Standard 338.

Howevers during recent reviews (San Onofre 2 8 3i Callawayi Wolf Creeki and Waterford 3)r the staff dis-covered that plant designs do not fuLLy comply with on-Line

testabiLity requirements.

Specificallyi various actuation devices cannot be tested at power since associated actuated equipment (pumpsi valvesi etc.)

cannot be operated during plant operation without causing unsafe plant operating condi~

tions.

The staff has aLLowed the applicantsi for the plants described above'o exempt from on-line testing various actuation devices associated only with actuated equipment that was justified as not being testable while at power because of impact on safe plant operation.

The exemptions were allowed in Lieu of requiring 'design modifications or plant shutdowns to perform the required testing.

Provide information in support of the Palo Verde design as it relates to compliance with GDC 21 as supplemented by the pro-visions of R.G. 1.22'

~ G.. 1.118'nd IEEE Standard 338.

If it is determined that various actuation devices (i.e.i ESFAS subgroup relaysi etc.)

cannot be tested while at power in accordance with the design criteriar then provide:

(1)

A List of ESFAS actuation devices and actuated equipment associated with each that should not be t'ested during plant operationi

V

(2)

Justification for why each actuation device identified in item 1

above cannot be tested at powers (3)

Verification thats for each actuation device and associated actuated equipment identified in item 1 above'here are comparable components which will be tested during reactor operationi (4)

Justification to show that the actuated equipment assign-ments to each actuation device were made in a manner to minimize the number of components which cannot be tested with the plant in operationi and (5)

A List of ESFAS actuation devices and associated actuated equipment which can be tested at power.