ML17298C114

Requests Relief from License Condition 2.C.18(b) to Allow Time for Util to Investigate Operability Problem of Two Atmospheric Dump Valves,Per Sser 7 (NUREG-0857). Justification for Continued Operation Encl

ML17298C114
Person / Time
Site:	Palo Verde
Issue date:	05/10/1985
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Knighton G Office of Nuclear Reactor Regulation
References
RTR-NUREG-0857, RTR-NUREG-857 ANPP-32608-EEVB, NUDOCS 8505130329
Download: ML17298C114 (10)

Text

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Arizona Nuclear Poorer Project P.O. BOX 52034 o PHOENIX, ARIZONA85072-2034 Director of Nuclear Reactor Regulation ANPP-32608-EEVB/BJA Attention: Mr. George W. Knighton, Chief May 10, 1985 Licensing Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Unit 1 Docket No. STN 50-528, License No. NPF-34 License Condition 2.C.18(b)

File: 85-056-026 G.l.01.10

References:

(1) Letter from E. E. Van Brunt, Jr., ANPP, to G. W. Knighton, NRC, dated December 10, 1984 (ANPP-31416);

Subject:

PVNGS Pump and Valve Operability Assurance Program.

(2) NUREG-0857, Supplement No. 7, "Safety Evaluation Report Related to the Operation of Palo Verde Nuclear Generating Station, Units 1, 2, and 3", dated December, 1984.

Dear Mr. Knighton:

Reference (1) submitted a Justification for Interim Operation (JIO) for the valve operability testing of the four atmospheric dump valves (ADV).

Subsequently, the NRC staff has imposed License Condition 2.C.18(b) for Palo Verde Unit 1 to complete the operability testing of the four ADVs prior to initial criticality. During the performance of the required valve operability testing of the four ADVs, two of the ADVs did not successfully complete the testing. However, two of the ADVs did successfully complete the testing and the action statement of Technical Specification 3.7.1.6 has been satisfied.

Attached is a Justification for Continued safe Operation (JCO) for the two ADVs that have not been demonstrated to be operable. Relief is requested from License Condition 2.C.18(b) to allow ANPP the time to investigate the operability problem of the two ADVs and to implement a solution. ANPP will continue to pursue an expeditious resolution of this problem and will implement necessary repairs or modifications at the earliest possible opportunity. The valve operability testing for the two inoperable ADVs will be completed no later than prior to the return to power following the first refueling outage for Palo Verde Unit 1. The JCO for the two inoperable ADVs is attached.

If you have any questions on this matter, please contact Mr. W. F. quinn of my staff.

Very truly you 8505lg03299 8Sasio pDR ADOCK ooooosp8 pDR E E. E. Van Brunt, Jr.

Executive Vice President Project Director EEVB/BJA/slh Attachment

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Mr. G. W. Knighton License Condition 2.C.18(b)

,ANPP- 32608 Page 2 cc: E. A. Licitra (w/a)

A. C. Gehr (w/a)

R. P. Zimmerman (w/a)

STATE OF ARIZONA )

) SSe COUNTY OF NARICOPA)

I, Edwin E. Van Brunt, Jr., represent that I am Executive Vice President, Arizona Nuclear Power Project, 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.

Edwin E. Van Brunt, Jr.

Sworn ro before me rbie~G day of , -1985.

Notary Publ c My Commission~dExpires:

C My Commlsslon'Expires April 6, 1987

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Attachment:

Justification for Contin'ued Safe Operation for Two Atmospheric Dump Valves

PURCHASE ORDER NUMBER: DESCRIPTION: PROJECTED DATE OF COMPLETION OF OPERABILITY ASSURANCE PROGRAM:

13-JM-601A Atmospheric Dump Valves (ADVs) Prior to startup following the first Refueling Outage.

ENVI.

TAG NUMBER: DESIG." SAFETY FUNCTION J-SGA-HV-179 Decay heat removal J-SGA-HV-184 Decay heat removal HISTORY:

During preoperational testing of the four atmospheric dump valves (ADV), it was observed that SGB-HV-178 behaved errat-ically. Investigation revealed condensate buildup in the lines created excess force which damaged the internals of the valves. All four ADVs were disassembled, inspected, and repaired.

Subsequently, additional drain capability has been installed to remove condensate from the outlet port of the valve.

The valves were then tested at operating conditions in order to demonstrate operability per the Pump and Valve Operability Assurance Program requirements. This testing identified operability problems with SGA-HV-179 and SGA-HV-184.

The root cause of the operability problems has not yet been identified and further investigation is required to identify the problem and the proper solution. The operability problem will be corrected and the valve operability for SGA-HV-179 and SGA-HV-184 will be established prior to the return to power after the first refueling outage.

JUSTIFICATION FOR CONTINUED OPERATION:

Two of the ADVs have been successfully tested and are fully operational. The action statement for Technical Specifi-cation 3.7.1.6 has been satisfied since there is one operable ADV per steam generator. This ensures that the required number of ADVs are available for decay heat removal to achieve safe shutdown.

Additionally, in the unlikely event of a failure of the ADVs, reactor decay heat can be removed through the main steam line safety valves which will be opened when pressure in the steam generator reaches the pressure relief-set point.

Steam release will continue until the pressure is reduced to the safety valve reset pressure. The safety valves will continue to- cycle in this manner as steam generator pressure rises and is relieved. The reactor coolant system will remain at hot standby conditions during this pressure relief cycling. Cooldown of the reactor coolant can be accomp-lished through manual operation of the atmospheric dump valves. Each ADV has a handwheel that can be operated locally.

Manual operation of all four ADVs is possible at this time.

BEST EFFORTS:

ANPP is thoroughly evaluating the ADV inoperability to determine the cause and proper solution of the problem.

ANPP will continue to seek an expeditious resolution, and will implement the necessary repairs or modifications at the earliest possible opportunity.

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