ML17303A783
| ML17303A783 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/01/1988 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML17303A784 | List: |
| References | |
| 161-00844-EEVB, 161-844-EEVB, TAC-67456, NUDOCS 8803030073 | |
| Download: ML17303A783 (14) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRA'I'ION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM,(RIDS)
~i ACCESSION NBR:8803030073 DOC.DATE: 88/03/01 NOTARIZED: NO DOCKET FACIL:STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION VAN BRUNT,E.E.
Arizona Nuclear Power Project (formerly Arizona Public Serv RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Application for amend to License NPF-65,revising Tech Spec Surveillance Requirement 4.7.9.b.
DISTRIBUTION CODE:
A001D COPIES RECEIVED:LTR NCL SIZE:
TITLE: OR Submittal:
General Distribution NOTES:Standardized plant.
05000530@
RECIPIENT ID CODE/NAME PD5 LA LICITRA,E INTERNAL: ACRS NRR/DEST/ADS7E4 NRR/DEST/MTB 9H NRR/DOEA/TSB11F OGC 15-B-18 RES/DE/EIB EXTERNAL: LPDR NSIC NOTES:
COPIES LTTR ENCL 1
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6 6
1 1
1 1
1 1
1 0
1 1
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1 1
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RECIPIENT ID CODE/NAME PD5 PD DAVIS,M ARM/DAF/LFMB NRR/DEST/CEB8H7 NRR/DEST/RSB 8E ILRB12 EG FILE 01 NRC PDR COPIES LTTR ENCL 5
5 1
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'A TOTAL BER OF COPIES REQUIRED:
LTTR 28 ENCL 25
Arizona Nuclear Power Project P.O. BOX 52034
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PHOENIX, ARIZONA85072-2034 Docket No.
STN 50-530 161-00844-EEVB/MA March 1, 1988 U.S. Nuclear Regulatory Commission Washington, D.
C.
20555 Attention:
Document Control Desk
Reference:
(1) Letter from J.
G. Haynes, ANPP, to G.
W. Knighton, NRC, dated December 26, 1986.
Subject:
Proposed Technical Specification Change
- Snubber Visual Inspections.
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 3 Proposed Technical Specification Change-Snubber Visual Inspections File: 88-G-056-026; 88-F-005-419.05 The purpose of this letter is to request a change to the PVNGS Unit 3 Technical Specifications.
The proposed change revises Technical Specification Surveillance Requirement 4.7.9.b to postpone the first inservice visual inspection for all inaccessible snubbers in Unit 3 until the first refueling outage.
The remainder of the snubbers (those accessible during power operations) will be visually inspected in accordance with the current Technical Specification requirements.
This proposed change is similar to the change previously submitted by Reference (1) in that it postpones the first inservice visual inspection for certain snubbers until the first refueling outage.
We understand that this previous change request would have been approved by the NRC Staff had it not been withdrawn by ANPP.
Enclosed within this change request package are the following:
A.
B.
C D.
E.
F.
G.
Description of the Proposed Change.
Purpose of the Technical Specification.
Need for the Technical Specification Amendment.
Basis for No Significant Hazards Consideration.
Safety Evaluation for the Proposed Change.
Environmental Impact Consideration Determination.
Marked-up Technical Specification Change Pages.
8803030073 880301
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USNRC Document Control Desk
'Page 2
161-00844-EEVB/BJA March 1, 1988 Pursue'nt to the requirements
'of 10CFR50.92(b)(l),
and by copy of this letter, we have notified the Arizona Radiation Regulatory Agency of this request for a
Technical Specification
.change.
'In accordance with the requirements of 10CFR170.12(c),'he license amendment application fee'f
$150.00 is being forwarded to the Facilities Program Coordinator of LFMB.
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Very truly your IC
~A
~ cRP E.
E. Van Brunt, Jr.
Executive Vice President Project Director EEVB/BJA/ls Attachment cc:
0.
M.
De Michele (all w/a)
G.
W. Knighton E. A. Licitra J.
B. Martin T. J. Polich A. C. Gehr
- Director, ARRA R.
M. Diggs (w/WFD $ 150)
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ATTACHMENT A.
DESCRIPTION OF THE PROPOSED CHANGE This proposed Technical Specification change revises Surveillance Requirement 4.7.9.b to postpone the first inservice visual inspection for all inaccessible snubbers in Unit 3 until the first refueling outage.
Presently, the Technical Specifications require the first inservice visual inspection to be conducted after 4 months but within 10 months after commencing power operations (i.e.,
initial Mode 1 entry).
The Technical Specifications also require categorization of the snubbers as either accessible or inaccessible during reactor operations'he accessibility determination is based upon factors such as existing radiation levels, duration of time required to perform an inspection at the snubber
- location, temperature, atmosphere, and the recommendations of Regulatory Guides 8.8 and 8.10.
There are a total of 720 mechanical snubbers and 12 hydraulic snubbers in Unit 3.
Of the 720 mechanical
- snubbers, 455, are inaccessible during reactor operations'nd 265 are accessible.'f the 455 inaccessible mechanical snubbers, all but 12 of these are located inside the containment building.
Additionally, all 12 hydraulic snubbers are located inside containment and are inaccessible during reactor operations.
The snubbers (mechanical and hydraulic) are part of the chemical and volume control system, Reactor Coolant System (RCS),
- system, and safety injection syst: em.
Although the snubbers are categorized as inaccessible during reactor operations, many of the snubbers can be visually inspected when the plant is in Mode 3.
Therefore, ANPP will perform visual inspections on as many of the inaccessible snubbers's possible during any unplanned reactor shutdowns.
The visual inspections will continue until such time as the reactor is ready to be returned to service.
In this
- way, ANPP plans to visually inspect a portion of the inaccessible snubbers during any unplanned reactor shutdowns prior to the refueling outage.
It should be recognized that not all of the inaccessible snubbers can be inspected in this manner as scaffolding must be installed to inspect some of the snubbers and an inspection platform must be installed to inspect the containment dome snubbers.
Additionally, the quantity of snubbers inspected in this manner is directly related to the number and duration of unplanned reactor shutdowns.
B.
PURPOSE OF THE TECHNICAL SPECIFICATION The purpose of Technical Specification 3.7.9 and the associated surveillance requirements is to ensure the operability of all mechanical and hydraulic snubbers.
The operability of the snubbers helps to ensure the structural integrity of the RCS and other safety related systems during and following a
seismic or other event initiating dynamic loads.
C.
NEED FOR THE TECHNICAL SPECIFICATION AMENDMENT Due to occupational radiation exposure and personnel safety considerations, the inaccessible snubbers that are'the subject 'of this amendment request can not be visually 'nspected during reactor
. operations.
Most of these inaccessible snubbers can be inspected while the plant is in Mode 3.
- However,
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the snubbers that are located in the dome region of the containment building require Mode 5 conditions to perform the inspection.
This is due to the fact that the inspection platform must be brought into containment through the containment, equipment hatch that can not be opened until Mode 5 conditions are reached.
r The performance of the first inservice visual inspection for the inaccessible snubbers.in Unit',3 would require an-outage of an estimated 2 week duration.
This outage would have to be conducted sometime in the middle of the first operating cycle for Unit 3.
Based upon (i) the results from previous inspections of this type in'Units 1 and 2, ii:) the fact that the three PVNGS units are essentially identical, and iii) Unit 3 has experienced far fewer transient events and heatup/cooldown cycles than the other two units, ANPP believes that the requirement to shut down the reactor solely to inspect these snubbers has no safety benefit'.
BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION 1.
The Commission has provided standards for determining whether a
significant hazards consideration exists as stated in 10CFR50.92.
A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident, previously evaluated; or (3) involve a
significant reduction in a margin of safety.
A discussion of these standards as they relate to the amendment request follows:
Standard 1--Involve a significant increase in the probability or the consequences of an accident previously evaluated.
0 Basis This proposed Technical Specification amendment does not involve a significant increase in the probability or the consequences of an accident previously evaluated.
The inaccessible snubbers that are the subject of this amendment request function to ensure the structural integrity of the RCS and several other safety related systems during seismic events or other events initiating dynamic loads on the systems.
The events that initiate seismic occurrences or other transients are independent of the frequency of performing snubber visual inspections.
The inaccessible snubbers help to ensure that the consequences of previously evaluated accidents are not increased by ensuring the structural integrity of safety related systems.
The proper operation of these snubbers is assured by the following considerations:
i) the relatively short time frame involved with this amendment request, ii) the successful completion of previous inspections of this type on Units 1 and 2, and iii) a portion of these snubbers are in an inactive portion of the containment spray system.
- Thus, the proposed change will not increase the probability or the consequences of previously evaluated accidents.
Standard 2--Create the possibility of a new or different kind of accident from any accident previously evaluated.
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Basis This proposed Technical Specification change will not create the possibility of a new or different kind of accident from any accident previously analyzed.
Proper operation of the inaccessible snubbers during seismic or transient events helps to ensure the structural integrity of the RCS and other safety related systems.
No new or different types of accidents are created by this proposed change since the snubbers will operate as intended which will help to ensure that the associated mechanical systems perform as originally intended.
Standard 3--Involve a significant reduction in a margin of safety.
Basis This proposed amendment does not involve a significant reduction in a margin of safety.
The bases section for Technical Specification 3.7.9,states that the purpose of the snubbers is to ensure the structural integrity of the RCS and all other safety related systems during and following a, seismic event or another event initiating dynamic loads.
Based upon the successful completion of previous inspections of this type on Units 1 and 2, there is adequate assurance that the inaccessible snubbers in Unit 3 will perform as required to ensure the structural integrity of the RCS and other safety related systems.
2.
The Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples (51FR7751) of amendments that are considered least likely to involve a significant hazards consideration.
The proposed Technical Specification change does not match any of the examples given in 51FR7751 but this change can be described as a
relief from an inspection requirement based upon the short time duration involved with the extension and successful completion of previous inspections on Units 1 and 2.
SAFETY EVALUATION FOR THE PROPOSED CHANGE The proposed Technical Specification change will not increase the probability or the consequences of previously evaluated accidents nor will it create the possibility of a new or different kind of accident.
This proposed amendment will only postpone the performance of the first inservice visual inspection for all inaccessible snubbers in Unit 3 until the first refueling outage.
The inaccessible snubbers (mechanical and hydraulic) that are the subject of this amendment request function to ensure the structural integrity of the RCS and other safety related systems.
Pro'per operation of the snubbers during accident situations helps to ensure the structural integrity of the safety related systems which ensures that the consequences of the previously evaluated accidents are not increased.
Proper operation of these inaccessible snubbers is assured by the following considerations:
(1)
There is a
relatively short time involved with this amendment request.
The extension to the surveillance interval is estimated as approximately 6
months.
This estimate is based upon expiration of the 10 month surveillance interval near the end of September, 1988 and shutdown for the first refueling outage at the beginning of April, 1989.
(2) Previous experience with snubber inservice visual inspections on PVNGS Units 1
and 2 indicates that no inoperable
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snubbers have been found during the performance of the visual inspections.
In addition to the preservice snubber inspections, two inservice visual inspections have been conducted on Unit 1 and one inservice visual inspection has been performed on Unit 2.
This data is very significant when applied to Unit 3 since Unit 3 has not experienced the number of transient events and heatup/cooldown cycles that Units 1 and 2
have.
(3)
A portion of these inaccessible snubbers (th'ose located in the dome region of the containment building) are part of the containment spray system, This system has not been
.operated with water, subjected to transients, or s'ubjected to the thermal and mechanical stresses a'ssociated with system operation".
This Technical Specification change will not reduce the margin of safety as defined in the, basis for any Technical Specification.
The basis for Technical Specification 3.7.9 concerning snubbers i's to ensure the structural integrity of the RCS and other safety related systems during and following a seismic event or another event initiating dynamic, loads.
There is adequate assurance that the inaccessible snubbers'ill perform as required to ensure the structural integrity of the RCS and other safety related systems due to the considerations listed in the preceding paragraph.
F.
ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION The proposed change request does not involve an unreviewed environmental question because operation of PVNGS Unit 3 in accordance with this change would not:
1.
Result in a significant increase in any adverse previously evaluated in the Final Environmental modified by the staff's testimony to the Atomic Board (ASLB), Supplements to the FES, Environmental in any decisions of the ASLB; or environmental impact Statement 'FES) as Safety and Licensing Impact Appraisals, 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 PVNGS which may have a significant environmental impact.
G.
MARKED-UP TECHNICAL SPECIFICATION CHANGE PAGE See attached page 3/4 7-21 of the PVNGS Unit 3 Technical Specifications.
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