ML17299A386
| ML17299A386 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/27/1985 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| ANPP-32917-EEVB, TAC-56647, NUDOCS 8507010308 | |
| Download: ML17299A386 (10) | |
Text
REGULATORYelFORMATION DISTRIBUTION S'EM (RIBS)
'ACCESSION NBR;850?010308 DOC ~ DATE: 85/06/27 NOTARIZED'KS DOCKET' FACIL:STN 50 528 Palo Verde Nuclear Stations Unit 1q Arizona Publi 05000528 AUTH,NAME AUTHOR AFFILIATION VAN BRUNTiE;E ~
Ar izona Public" Service Co.
REC IP,'NAMKI REC IP IENT AF F ILIATION KNIGHTON g G ~ W ~
Licensing, Branch 3
SUBJECT:
. Requests exemption from Tech Spec 3,4, 1 ~ 2i3,4 F 1'. 8 3",?. 1,6 requ)r ements for performing tests during'power ascension testing program. Justification to show exemption will not cause r isk to public health 8 safety e cl.
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Arizona Nuclear Power Project P.o. BOX 52034 o
PHOENIX, ARIZONA85072-2034 Director of Nuclear Reactor Regulation Attention:
Mr. George W. Knighton, Chief Licensing Branch No.
3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555 June 27, 1985 ANPP-32917-EEVB/MA,
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 1 Docket No.
STN 50-528, License No. NPF-41
Subject:
PVNGS Natural Circulation Cooldown Testing File:
85-056-026'.1.01.10
References:
(1) Letter from E. E. Van Brunt, Jr.,
ANPP, to G.
W. Knighton, NRC, dated January 31, 1985 (ANPP-31829).
Subject:
Natural Circulation Cooldown Testing.
(2) NUREG-0857, Supplement No. 8, "Safety Evaluation Report related to the Operation of Palo Verde Nuclear Generating Station, Units 1, 2, and 3", dated May, 1985.
Dear Mr. Knighton:
Reference (1) submitted a copy of the PVNGS Natural Circulation test procedure for NRC review.
ANPP has committed to perform this test program in order to demonstrate PVNGS compliance with the requirements of Branch Technical Position RSB 5-1.
The test program consists of a Loss of Offsite Power test at 50X power and a Natural Circulation Cooldown test at 80X power.
ANPP requests an exemption from the requirements of the PVNGS Unit 1
Technical Specifications for the purpose of performing these two tests during the power ascension testing program.
During the performance of these tests, the reactor coolant pumps must be de-energized for a period of time which is longer than the one hour allowed Sy the Limiting Condition for Operation of Technical Specifications 3.4.1.2 and 3.4.1.3.
Therefore, an exemption to Technical Specifications 3.4.1.2 and 3.4.1.3 is requested to perform these two tests.
Additionally, the atmospheric dump valves will be powered from their backup power sources during the testing in order to demonstrate compliance with BTP RSB 5-1.
The surveillance requirements of Technical Specification 3.7.1.6 for the nitrogen accumulator tank pressure can not be met during the performance of the tests.
An exemption to Technical Specification 3.7.1.6 is requested for the performance of these tests in order to avoid entering into the action statement during these tests.
The attachment to this letter provides a
justification to show that these exemptions for the power ascension testing program will not cause undue risk to the health and safety of the public.
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G.
M. Knighton PVNGS Natural Circulation Cooldown Testing ANPP Page 2
If you have any questions on this matter, please contact Hr.
W. F. Quinn of my staff.
Very truly yours, E. E.
Van Brunt, Jr.
Executive Vice President Project Director EEVB/BJA/mkm Attachment cc:
E. A. Licitra (all w/a)
R. P.
Zimmerman A. C. Gehr C. Liang
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STATE OF ARIZONA
)
) san COUNTY OF MARICOPA)
I, Donald B. Karner, represent that I am Assistant Vice President, Nuclear Production of 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 and correct.
Donald B. Karner Sworn to before me this day o E
My, Commission Expires:
MJ Comm!."she 8:plres PpN 6, <987 1985
'otary Public
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Justification for Exem tions The Technical Specification exemptions are requested for the performance of the Loss of Offsite Power test at 50X power and the Natural Circulation Cool-down test at 80X power.
The Loss of Offsite Power test is expected to take approximately 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to perform (if boron mixing demonstration is performed during this test).
The duration of the Natural Circulation Cooldown test is anticipated to be approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
These two approximations are estimated time durations for which the reactor coolant pumps will be de-energized during the testing.
The requested exemption to allow for the de-energization of the reactor coolant pumps during the testing will not increase the probability of occurrence or consequences of an accident or malfunction of equipment important to safety previously evaluated in the FSAR for the following reasons:
(1) operations involving a reduction in reactor coolant system boron concentration w'ill be suspended
- during, the testing.
(2) core outlet temperature will be maintained at least 10'F below saturation temperature during the testing.
(3) necessar'y safety related equipment will be available for use during the testing.
(4) the reactor coolant pumps will be available per applicable restart procedures during the testing to return the reactor-coolant system to a forced circulation condition.
(5) the reactor will be shutdown in Modes 3 or 4 during the testing.
(6) similar exemptions have been granted to'an Onofre, Diablo Canyon, and Waterford 3 for the purpose of performing natural circulation cooldown testing.
The atmospheric dump valves (ADVs) are used during the performance of these tests to remove decay heat from the reactor.
The ADVs will be powered from their backup'power source during the tests in order to demonstrate an adequate safety-grade backup power supply in accordance with the requirements of BTP RSB 5-1.
Therefore, surveillance requirement 4.7.1.6(a) can not be satisified when the ADVs are being used for decay heat removal and are being powered from their backup power source.
An exemption is requested from the require-ments of Technical Specification 3.7;1.6 to avoid entering into the action statement during these tests.
Operation of the plant with this Technical Specification exemption will not result in a condition that has not been previously analyzed since Technical Specification 3.7.1.6 allows for ADVs to,be inoperable for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
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