ML17299A433
| ML17299A433 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/15/1985 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17299A434 | List: |
| References | |
| ANPP-33030, TAC-59245, NUDOCS 8507170230 | |
| Download: ML17299A433 (10) | |
Text
REGULATORY FORMATION DISTRIBUTION S EM ('RIDS)
ACCESSION NBR 8507170230 DOC ~ DATE: =85/07/15 NOTARIZKD:,NO, DOCKET! 0 FACILtSTN 50 528 Palo Verde Nuclear Station~
Unit ii Arizona Pub) i 05000528 AUTH BYNAME AUTHOR AFFILIATION VAN BRUNTiE.E.
Arizona Pub)ic Service Co ~
RECIP ~ NAME REClPIENT AFFILIATION KNIGHTONt G ~
Licensing Branch 3
SUBJECT:
Application for amend to License,NPF<<ffiqr equesting eyepgency one time an)y change of Tech Spec 3,4 '+2 re RCS.operationa) leakage to allow for add) 72.h in Mode 2 in order to identify RCS
)eakage which began 850711,Fee paidQ.
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Arizona Nuclear Power Project P.o. BOX 52034
~
PHOENIX. ARIZONA85072-2034 Director of Nuclear Reactor Regulation July 15, 1985 Attention:
Mr. George Knighton, Chief ANPP-33030 Licensing Branch No.
3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Palo Verde Nuclear Generating Station Unit 1 Docket No.
STN 50-528 (License No. NPF-41)
Request for Emergency Technical Specification Change File:
85-056-026 G.l.01.10
Reference:
Letter from E. E.
Van Brunt, Jr.,
APS, to G.
W. Knighton, NRC, dated July 12, 1985 (ANPP-33008);
Subject:
Request for Emergency Technical Specification Change.
Dear Mr. Knighton:
Per conversation with your staff on July 12, 1985, submitted herewith is a supplement to the referenced one-time only Emergency Technical Specification Change.
This change is required expeditiously due to the nature'of the unidentified leak which we have experienced in order to provide the most effective manner in which to determine the leak.
Enclosed within this package request is:
a ~
b.
c ~
d.
e.f.
Description of the Proposed Change Request Marked-up Technical Specification Change Page Justification for Emergency Classification Safety Evaluation of the Proposed Amendment Request Significant Hazards Consideration Determination Environmental Impact Consideration Determination Proposed Compensatory Measures In acccordance with 10CFR 170.12(c),
the license amendment application fee of
$150.00 is also enclosed.
If you have any questions, please contact Mr. W. F. Quinn of my staff.
8507170230 850725
'DR ADOCK 05000528 PDR F. F.
Van Brunt> >>.
Executive Vice President Project Director Very truly yours, ZZ'4 ~/mk.
EEVB/WFQ/slh Enclosure (all w/a) cc:
E. A. Licitra R. P.
Zimmerman A. C. Gehr C. F. Tedford, Arizona Radiation Regulatory Agency il ~<"t Qcrn
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G. 'W. Knighton Request for Emergency Technical Specification Change ANPP 33030 Page 2
bcc:
D. B. Karner R. ti. Butler T. F.
Quan
- 0. J. Zeringue J.
R.
Bynum S.
R. Frost D. Cannady J.
Haynes A. C. Rogers (all w/a)
~
~ ~
DESCRIPTION OF PROPOSED AMENDMENT RE UEST 1
Technical Specification 3.5.4.2, Action Statement b
was entered into on July 11, 1985, based on the determination of unidentified Reactor Coolant System leakage of 1.2 gpm.
The plant has been taken to Mode 2 and will enter Mode 5 within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> as required by the Action Statement.
However, for a one time only change, we request that we be allowed an additional 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in Mode 2
prior to entering Mode 5
in order to:
1) allow additional "at-pressure" time for ascertaining the location of the leak (if one exists),
'nd
- 2) provide additional time for collecting additional RCS inventory data to verify the RCS inventory calculations.
If the RCS leakage is determined to increase to greater than 2
gpm within the requested 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> extension, based on inventory surveillance at least every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, PVNGS Unit 1 will proceed immediately to Mode 5.
Attached marked-up Technical Specification page 3/4 4-19 indicates this proposed one-time only change.
JUSTIFICATION FOR EMERGENCY CLASSIFICATION The unidentified leakage which has been determined to exist has not been located at this time. It is speculated that the leakage may be intersystem.
In order to locate the leakage, the system must be at some pressure to produce the pressure differential to promote the leakage.
Therefore, it is necessary to remain above Mode 5 to ensure positive identification of the leakage can be ascertained.
In addition, verification of RCS inventory calculations require that reproducible data and leakage paths remain constant.
In order to achieve the
- above, a
suspension of the premoticing requirements of 10CFR50.91 is required and expeditious granting of the proposed one-time only change be effected.
SAFETY EVALUATION OF PROPOSED AMENDMENT RE VEST The requested one-time only change to the time requirements of Technical Specification 3.5.4.2, Action Statement' will not increase the probability or consequences of any accident or malfunction of equipment, nor will it reduce any margin of safety as defined in the basis to any Technical Specification.
The RCS activity at the time of our discussions was 2.1 X 10 2+Ci/cc which is approximately 200 times less than that assumed in the accident analyses (refer to CESSAR Section 15.6.3.1.3.2 which assumes a
primary activity of 4.6 ~ Ci/gm).
Therefore, the margin of safety is maintained and the probability and consequences of any accident is not increased.
SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The proposed one-time only amendment request does not involve a Significant Hazards Consideration because:
A)
Operation of PVNGS Unit 1 in accordance with this change would not:
Involve a significant increase in the probability or consequences of an accident previously analyzed; or 2 ~
Create the possibility of a new or different kind of accident from any accident, previously analyzed; or 0197K/0011K
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3.
Involve a significant reduction in the margin of safety; and B)
The change does not allow exiting from the design basis envelopes for any accident analyses based on the plant specific primary coolant activity which will be experienced during the time period that the one-time only Technical Specification change will be in effect.
ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION II The proposed amendment request does not involve an unreviewed environmental question because operation of PVNGS Unit 1 in accordance with this change would not:
Result in a
significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by staff's testimony to the Atomic Safety and Licensing
- Board, Supplements to the
- FES, Environmental Impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or 2.
Result in a significant change in effluents or power levels; or 3.
Result in matters not previously reviewed in the licensing basis for PANGS which may have a significant environmental impact.
PROPOSED COMPENSATORY MEASURES There are no other compensatory measures proposed which are not already cited in the request for change.
The upper limit on unidentified RCS leakage during the requested time extension in conjunction with the RCS sampling frequency to be imposed during this period provide sufficient compensatory measures to maintain protection of the public health and safety.
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