ML17298B123
| ML17298B123 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/01/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| ANPP-30093-EEVB, GL-83-23, NUDOCS 8408030097 | |
| Download: ML17298B123 (15) | |
Text
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REGULATOR INFORMATION DISTRIBUTION
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< ACCESSION NBR:8408030097 DOC~DATE: 84/08/01 NOTARIZED: YES, DOCKET FACIL:STN"50 528 Palo Verde Nuclear Stationi Unit ii Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Stationi Unit 2~ Arjzona Publi 05000529 STN"50-530 Palo Verde nuclear Stationi Unit 3i Arizona Publi '5000530 AUTH,NAME AUTHOR AFFILIATION VAN BRUNTrE.E Arizona Public Service Co ~
RECIP,NAME RECIPIENT AFFILIATION KNIGHTONiG o Licensing Branch 3
SUBJECT; Forwards response to NRC 840605 comments re emergency procedure generation package, Steps to verify adequate instruments 8, controls available for operator to perform assigned task incorporated into validation procedure.
DISTRIBUTION CODE:
A003S COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR/Licensing Submittal:
Suppl 1 to NUREG 0737(Generic Ltr 82-33)
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Arizona Public Service Company ANPP-30093-EEVBJr/MAJ August 1, 1984 Director of Nuclear Reactor Regulation Attention:
Mr. George Knighton, Chief Licensing Branch No.
3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3
Docket Nos.
STN 50-528/529/530 File:
84-056-026 G.1.01.10
Reference:
(1) Letter from G.
W. Knighton, NRC, to E. E.
Van Brunt, Jr.,
APS, dated June 5, 1984.
Subject:
Procedure Generation Package (PGP) for Palo Verde.
(2) Generic Letter 83-23 dated July 29, 1983.
Safety Evalua-tion of "Emergency Procedure Guidelines" for Combustion Engineering PMR's.
(3) Letter from E. E.
Van Brunt, Jr.,
APS, to G.
M. Knighton, NRC, dated July 15, 1983 (ANPP-27309).
Subject:
Submittal of PVNGS Procedure Generation Package.
Dear Mr. Knighton:
Reference (1) identified 3 comments from the NRC's review of the PVNGS PGP to be resolved.
Attached is the APS response to these comments.
If you have any questions, please call me.
EEVBJr/MAJ/mb Attachment Very truly yo C~g E. E.
Van Brunt, Jr.
APS Vice Pr'esident Nuclear Production ANPP Project Director 0) qcP 8408030097 840801 PDR ADOCK 05000528 F
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Mr. George Knightor PVNGS Procedure Generation Package ANPP-30093 Page 2
cc:
A. C. Gehr E. A. Licitra M.
Goodman J.
Glifford G.
Mazetis R.
Zimmerman
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Mr. George Knighto PVNGS Procedure Generation Package ANPP-30093 Page 3
bcc:
D. B. Karner W. F. Quinn T. F.
Quan K. E. Jones M. J. Winsor LCTS Coordinator T. G. Woods K. W. Gross J.
E. Kirby J.
M. Allen J.
R.
Bynum D. R. Canady
- 0. J. Zeringue J.
D. Houchen W. F. Fernow S.
- Shepherd, M
Barnoski
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k ANPP-30093 STATE OF ARIZONA
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COUNTY OF MARICOPA)
I, Edwin E.
Van Brunt, Jr.,
represent that I am Vice President, Nuclear Production, of Arizona Public Service
- Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its
- contents, and that to the best of my knowledge and belief, the statements made therein are true.
EE E
Sworn;to.,before me this day of
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My Commission Expires:
N Commlsslon Expires Aprl1 6, 1987 1984.
Notary Public
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Attachment 1
Page 1 of 3
RESPONSE
TO NRC COMMENTS ON THE PVNGS PROCEDURE GENERATION PACKAGE NRC Comment (1)
In your submittal, you state that the control room staff can implement the EOP's for any unusual condition that occurs in the plant during any mode of operation.
- However, the GEOG generic emergency procedure guidelines do not cover conditions other than off-normal events which require a reactor trip from power operation.
Therefore, we require that you provide confirma-tory information documenting the technical bases for extending the Palo Verde plant specific guidelines to all operating modes.
Response
The APS Procedure Generation Package submittal, dated July 15,
- 1983, had extended PVNGS Emergency Procedures to be applicable to all plant modes:
It was the position of APS that the various setpoints for safety systems (Safety Injection, Main Steam Isolation, and Containment Isolation) would provide indication of an event in all plant modes.
Safety system actuation would alert the operator to a problem and aid in diagnosis of the event.
Since the July 15, 1983 submittal of the PVNGS Procedure Generation
- Package, the NRC has issued Generic Letter 83-23, Safety Evaluation of "Emergency Procedure Guidelines" for all Combustion Engineering (CE) Pressurized Water Reactors.
Long term item 4.3(5),
"Coverage of Conditions which occur at other than Power Operations," of Generic Letter 83-23, identifies the need to expand the Emergency Procedure Guidelines to cover conditions other than reactor trip and power operations.
APS will remove the deviation in the
- PGP, extending the EOP's to any mode of operation, and will participate with the CE Owners Group in resolution of the "any mode" concern.
APS will upgrade the EOP's when resolution of this issue is finalized.
/
NRC Comment (2)
Our evaluation of the CEOG generic guidelines identified open issues.
We will require that you appropriately update the Palo Verde plant-specific guidelines and EOP's to reflect any changes made to the GEOG generic guide-lines as a result of resolving those open issues.
Response
APS will upgrade the PVNGS Emergency Procedures upon NRC approval of the revised CEOG guidelines.
The schedule for plant specific activities to upgrade the PVNGS Emergency Procedures is given 'in Figure 1.
The implemen-tation of the upgraded EOP's will be based upon a refueling schedule.
This will require NRC approval of the revised guidelines eight (8) months prior to a PVNGS refueling outage.
I I
ANPP-30093 Page 2 of 3.
NRC Comment (3)
The validation and verification programs in the Palo Verde PGP did not clearly address how the programs would evaluate the adequacy of the existing instrumentation and controls since operator information and control require-ments were not addressed.
In response to this discrepancy (which also relates to our review of the task analysis process for the Palo Verde Detailed Control Room Design Review),
by letter dated April 9, 1984, you provided a description on how operator information and control requirements were identified.
This information is currently under staff review.
You will be advised of the results after the review is complete.
Response
The PVNGS validation procedure incorporates a step to verify adequate instruments and controls are available for the operator to perform the assigned task.
This methodology provides an independent second check of the control room design.
This action adequately addresses the concern of ensuring the operator has the needed indications and controls.
P
Page 3 of NRC APPROVAL OF REVISED GUIDELINES Review of Revised Guide-lines (1 month)
Revised Plant Specific Technical Guidelines (1 month)
APS PLANT SPECIFIC ACTIVITIES FOR REVISING EMERGENCY PROCEDURES 5
7 Refueling Outage Revise Plant Emergency Procedures'1 month)
Verify Revised Procedures (1 month).
Validate
'Revised Procedures,
($ month) 8 months for Procedure Upgrade 3 months for Training 11 months for Implementing Incorporate NRC Comments (1 month)
Revised Procedures Reviewed By Plant Review Board
(
1 month)
NRC REVIEN OF REVISED PLANT SPECIFIC TECHNICAL GUIDELINES (3 months)
Revised Procedures to Training for Lesson Plan Upgrade (3 months)
Training Upgraded Procedures (3 months)