ML17304A673

Confirms 881014 Telcon Between C Rogers & Gw Knighton in Which Rogers Requested Informal Appeal of Staff Conclusion Stated in Re Changes to Facility Initial Test Program

ML17304A673
Person / Time
Site:	Palo Verde
Issue date:	10/18/1988
From:	Karner D ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.068, RTR-REGGD-1.068 161-01397-DBK-A, 161-1397-DBK-A, TAC-67076, NUDOCS 8810270314
Download: ML17304A673 (6)

Text

w5 REGULA Y INFORMATION DISTRIBUTION SYSTEM <RIDS)

ACCESSION NBR: 8810270314 DOC. DATE: 88/10/18 NOTARIZED NO DOCKET FACIL:STN-50-530 Palo Verde Nuclear Stationi Unit 3i Ari-zona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION KARNERi D. B.

Arizona Nuclear Poujer Prospect (formerlg Arizona PublicServ.

RECIP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Confirms 881014 telcon between C Rogers Cc GM Knighton re loss of offsite power testing.

DISTRIBUTION CODE:

AOOID COPIES RECEIVED: LTR l

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TITLE:

OR Submittal:

General Distri'bution NOTES: Standardized plant.

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PHOENIX, ARIZONA85072-2034 161-01397-DBK/ACG October 18, 1988 Document Control Desk U.S. Nuclear Regulatory Commission Mail Station Pl-137 Washington, D.C.

20555

References:

1.

Letter from J.

G. Haynes, ANPP, to NRC, ANPP letter 161-00474, dated August 31, 1987.

Subject:

Chang'es to Initial Test Program.

2.

Letter from E. E.

Van Brunt, ANPP, to NRC, ANPP letter 161-00887, dated March 17,'1988.

Subject:

Loss of Offsite Power Testing.

3.

Letter from E.

E. Van Brunt, ANPP, to NRC, ANPP letter 161-01105, dated June 13, 1988.

Subject:

Loss of Offsite Power Testing.

4.

Letter from Michael J. Davis, Project Manager, Project Directorate V, Division of Reactor Projects - III, IV and V and Special Projects, dated September 29, 1988.

Subject:

Changes to Palo Verde 3 Initial Test Program (TAC No. 67076).

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Unit 3 Loss of Offsite Power Testing File:

88-001-419.01;i 88-056-026 This letter confirms the October 14, 1988 telephone call between Carter Rogers and G.

W. Knighton during which Mr. Rogers requested an in'formal appeal of the staff's conclusion stated in Reference 4 that the integrated systems Loss of Offsite Power (LOOP) test is required to be conducted on Palo Verde Unit. 3 and its 'denial of ANPP's proposal to. delete such test on Unit 3.

It is our position that such conclusion is based on a misconception that ANPP was proposing to substitute individual system and systems tests for the integrated test provided for by Regulatory Guide (RG) 1.68 Rev.

2, Appendix A, Section 5.g.g.

That is not the case.

Rather, the proposed deletion of the LOOP test on Unit 3 is based upon the satisfactory completion of such LOOP test on both Palo Verde Unit 1

and Unit 2.

Because (i) Unit 3 is built to the same standard design and has the same or similar equipment as Units 1 and '2, (ii) the standard design and construction of all'hree units has been confirmed by similar responses to transients experienced on all units, (iii) the capability of PVNGS to cope with station blackouts is demonstrably

good, and (iv) the operability of individual, electric systems and subsystems have been tested and found to be operable, it is ANPP's position that the deletion. of the integrated SSi02703l4 SS10}S PDFI',

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161-01397-DBK/ACG October 18, 1988 LOOP test is )ustified, particularily in light of.the unnecessary challenge that would be imposed upon Unit 3's safety systems in conducting the LOOP test on Unit 3.

Additionally, we contend that, contrary to the TER input of your consultant in this matter as set forth in Enclosure 1 of Reference 4,

Section D of RG 1.68 Rev.

2 explicitly authorizes the sta'ff to accept alternative methods proposed by an applicant for compliance with specific portions of RG 1.68 Rev.

2.

We believe that we have proposed an acceptable alternative, i.e., analysis of the results of the successful completion of integrated'OOP tests on Units 1 and 2.

Since this issue has been outstanding for more than a year, we suggest that a

meeting may be in

order, with appropriate NRC staff and consultants if necessary.

We would be pleased to have an open discussion with the staff, concerning their viewpoint as well as ours.

Please communicate with Carter Rogers as to your thoughts on this matter.

Very truly yours, D. B. Karner Executive Vice President DBK/ACG/pvk cc:

G.

W. Knighton M. J. Davis T. L. Chan J.

B. Martin T. J.. Polich A. C. Gehr E. E. Van Brunt, Jr.

J.

G. Haynes

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