ML17305B187
| ML17305B187 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/14/1990 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17305B188 | List: |
| References | |
| NUDOCS 9011200180 | |
| Download: ML17305B187 (22) | |
Text
ACCELERATED TRIBUTION DEMONS I
TION b-xw-s-r,lvl REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9011200180 DOC.DATE: 90/11/14 NOTARIZED: YES DOCKET FACIL:STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Arizona Public Service Co.
(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
R D
8 05000530 /
NOTES:Standardized plant.
SUBJECT:
Application for amend to License NPF-74,postponing performance of certain 18 month surveillance requirements.
DISTRIBUTION CODE:
AOOID COPIES RECEIVED:LTR J ENCL g SIZE: i ~ + +
TITLE: OR Submittal:
General Distribution RECIPIENT ID CODE/NAME PD5 LA PETERSON,S.
INTERNAL: ACRS NRR/DET/ESGB NRR/DST 8E2 NRR/DST/SICB 7E NUDOCS-ABSTRACT OGC/HDS1 RES/DSIR/EIB EXTERNAL: NRC PDR NOTES:
COPIES LTTR ENCL 1
1 2
2 6
6 1
1 1
1 1
1 1
1 1
0 1
1 1
1 RECIPIENT ID CODE/NAME PD5 PD TRAMMELL,C.
NRR/DET/ECMB 9H NRR/DOEA/OTSB11 NRR/DST/SELB 8D NRR/DST/SRXB 8E OC LF EG 01 NSIC COPIES LTTR ENCL 1
1 2
2 1
1 1
1 1
1 1
1 1
0 1
1 1
1 D
D D
NOTE TO ALL"RIDS" RECIPIENTS:
D D
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 27 ENCL 25
Arizona Public Service Company P.O. BOX 53999
~
PHOENIX, ARIZONA85072<999 WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR 161-03590-WFC/JRP November 14, 1990 Docket No.
STN 50-530 Document Control Desk U.
S. Nuclear Regulatory Commission Mail Station Pl-37 Washington, D.
C.
20555
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 3 Proposed Technical Specification Amendment File:
90-F-005-419.05; This letter is provided to request a one-time amendment to the PVNGS Unit 3
Technical Specifications.
The proposed amendment will, until the second refueling outage for Unit 3, postpone the performance of certain 18 month Surveillance Requirements which cannot be performed at power.
The surveillance tests are scheduled during the second refueling outage.
A list of the affected Technical Specification Surveillance Requirements is contained in Section A of the attachment to this letter.
The proposed Technical Specification amendment will allow Unit 3 to remain at power until its scheduled refueling outage, thus avoiding an unnecessary plant shutdown.
The affected Technical Specification Surveillance Requirements will be performed prior to the end of the next refueling outage or by June 15, 1991.
The attachment to this amendment request includes:
A.
Description of Amendment Request.
BE Purpose of the Technical Specifications.
C.
Need for the Technical Specification Amendment.
D.
Basis for No Significant Hazards Consideration.
E.
Safety Analysis of the Proposed Amendment Request.
F.
Environmental Impact Consideration Determination.
G
~
Marked-Up Technical Specification Pages.
90ii200180 901114 PDR ADOCK 05000530 PDC
Document Control Desk U.
S. Nuclear Regulatory Commission Page Two 161-03590-MFC/JRP November 14, 1990 Pursuant to 10 CFR 50.91(b)(1),
and by copy of this letter and attachment, we have notified the Arizona Radiation Regulatory Agency (ARRA) of this request for a Technical Specification amendment.
Should you have any questions please call Michael E. Powell at (602) 340-4981.
Sincerely, WFC/JRP Attachments cc:
C.
M. Trammell J.
B. Martin D.
HE Coe C.
F. Tedford A
H. Gutterman
I
(
161-03590-MFC/JRP November 14, 1990 STATE OF ARIZONA
)
) ss.
COUNTY OF MARICOPA
)
I, J. M. Levine, represent that I am Vice President Nuclear Production, 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.
J.
M. Levine Sworn To Before Me This Day Of
'Cg 1990.
lf /I
~ t gE Notary Public My Commission Expires My Commission Expires April 6, 1991
4 o
V V
ATTACHMENT A.
DESCRIPTION OF AMENDMENT RE UEST The proposed Technical Specification Amendment will postpone the performance of the following 18 month Surveillance Requirements (S.R.) for Unit 3 until the second refueling outage.
The second refueling outage is tentatively scheduled to begin on March 16,1991.
The affected Technical Specification Surveillance Requirements will be performed prior to the end of the next refueling outage or by June 15, 1991.
The following is a list of the affected Surveillance Requirements and their due dates (including the 25% time extension allowed by Technical Specification Section 4.0.2.a):
ST R. 4.8.2.1.d (Due 3/1/91)
- Each 125-volt battery bank and charger shall be demonstrated OPERABLE at least once per 18 months, during shutdown, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulated emergency loads for the design duty cycle when the battery is subjected to a battery service test.
S.R.
4.8.4.1.a.2 (Due 1/12/91)
All containment penetration conductor overcurrent protective devices (except fuses) shown in Table 3.8-2 shall be demonstrated OPERABLE, at least once per 18 months, by selecting and functionally testing a representative sample of at least 10% of each type of lower voltage circuit breakers.
Circuit breakers selected for functional testing shall be selected on a rotating basis.
Testing of these circuit breakers shall consist of injecting a current with a value equal to 300% of the setpoint (pickup) of the long-time delay trip element and 150% of the setpoint (pickup) of the short time delay trip element, and verifying that the circuit breaker operates within the time delay band width for that current specified by the manufacturer.
The instantaneous element shall be tested by injecting a current for a frame size of 250 amps or less with tolerances of +40%/-25%
and a frame size of 400 amps or greater of +25% and verifying that the circuit breaker trips instantaneously with no apparent time delay.
Molded case circuit breaker testing shall also follow this procedure except that generally no more than two trip elements, time delay and instantaneous, will be involved.
Circuit breakers found inoperable during functional testing shall be restored to OPERABLE status prior to resuming operation.
For each circuit breaker found inoperable during these functional
- tests, an additional representative sample of at least 10% of all the circuit breakers of the inoperable type shall also be functionally tested until no more failures are found or all circuit breakers of that type have been functionally tested.
B.
PURPOSE OF THE TECHNICAL SPECIFICATIONS Surveillance Requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that'acility operation will be within the safety limits, and that the limiting conditions of operation willbe met.
The Surveillance Requirements are requirements applicable to lower voltage circuit breakers provide assurance of breaker reliability by testing at least one representative sample of each type of circuit breaker.
lf f
'I fl f
The Surveillance Requirement for demonstrating the OPERABILITY of the station batteries are based on the recommendations of Regulatory Guide 1.129 and IEEE Standard 450-1980.
This will ensure the operability of Class 1E batteries and demonstrate their ability to feed requisite station loads required to maintain core cooling and containment integrity.
C, NEED FOR THE TECHNICAL SPECIFICATION AMENDMENT The proposed Technical Specification Amendment will allow Unit 3 to remain at power until its second refueling outage, tentatively scheduled for March 16,
- 1991, thus avoiding an unnecessary plant shutdown.
If the'roposed amendment is not granted in a timely manner, a plant shutdown will be required solely to perform refueling surveillances.
This increases the probability that plant systems may be needlessly challenged, a condition that is undesirable since it potentially increases the risk to the plant and public safety.
During the shutdown evolution, the plant would be in a transient state involving changing plant conditions; conditions that offer the potential for an upset that could lead to a
demand for the system(s) or component(s) scheduled to be tested.
Additionally, a
shutdown would increase the pressure on the plant staff to expeditiously complete th'e required surveillance in support of a return to power operation.
Thi's would further increase the potential for a plant upset when both the shutdown and surveillance activities place a demand on the plant operators.
It is overly conservative to assume that systems, or compone'nts are inoperable when a surveillance requirement has not been performed.
The opposite is in fact the case; the vast majority of Surveillance Requirements demonstrate that systems or components are in.fact operable.
This fact and the above considerations have led to this request for extension of the test interval for the refueling Surveillance Requirements listed in Section A of this amendment request.
D.
BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92.
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 consequences of an accident previously evaluated.
The proposed Technical Specification change does not involve a significant increase in the probability or consequences of an accident previously evaluated because:
0 f
A
(,
I I
I I
'll
~
Station Batteries The 125 volt batteries are subject to periodic surveillance testing to verify electrolyte level, specific gravity, cell voltage and general condition of the batteries.
The capacity of all batteries was demonstrated to be greater than required during performance of the 18'onth, surveillance test of station batteries (32ST-9PK03) conducted during the 1989 refueling outage.
~Baaaea Min Volta e Re uired Min Volta e Tested 3EPKAFll 3EPKBF12 3EPKCF13 3EPKDF14 109.79
112.2 109.98 115.38 108.69 117.9
'08.39
"'16.1*
l Actual test voltage was 112.2 without cells 4 and 6.
Subsequently, cells 4 and 6 have been replaced and credit to the battery is given for two cells at 1.95 vdc, the lowest value for any cell at the end of the discharge.
The capacity of the batteries is expected to increase through year 12, 60$ of its life.
Since these batteries are approximately seven years old, the capacity is projected to be greater during the 1991 tests than during the 1989 tests.
Weekly and quarterly surveillance testing of the batteries provides assurance that the batteries are adequately maintained to perform their required function.
Molded Case Circuit Breakers A review of the historical data on surveillance testing of "TED", "TJD", and "TEB", breakers was performed to assess past performance.
These breakers are surveillance tested because they provide backup protection to the primary overcurrent device for containment penetrations.
The reliability of these breakers has been established by successful completion of the "Molded Case Circuit Breaker Surveillance Test" (32ST-9ZZ74) in all units.
Breaker T
e Unit Date TED TED TED 09/14/89 11/09/89 04/28/89 TJD TJD TJD 03/08/90 04/10/90 04/28/89 TEB TEB TEB 01/30/89 07/21/89 04/04/89 The surveillance tests were performed during 1989 and 1990 with only one of the subject "TJD" breakers failing, no failures were recorded for the TED or TEB
t I
breakers during this period.
The breaker failed to meet specifications during the test and was replaced.
The replacement breaker was successfully tested.
Because of the failure of the 10$
representative
- sample, a
second 10%
surveillance test was generated and successfully performed.
Due to the loads being fed from Motor Control Circuit Breakers types TED, TJD, and TEB, they cannot be tested while the unit is on line.
~Summa'ased on this evaluation and past surveillance testing of the circuit breakers and weekly and quarterly testing of the 125 volt batteries the proposed amendment will not involve a significant increase in the probability of an accident previously evaluated.
The 125 volt batteries are maintained in a fully charged condition and have sufficient stored energy to operate all necessary circuit breakers and to provide an adequate amount of energy for all required emergency loads for two hours after loss of AC powers The subject breakers provide the backup protection for primary devices in a redundant scheme of two overcurrent devices in series.
The primary oyercurrent devices for the, circuits with the "TED" breaker are,15 amp fuses.
, The primary overcurrent protection 'for" the, circuit with the "TJD" breaker is provided by a "TED" breaker, which has a
25 amp trip element'.
'he "TED" and "TJD" provide the backup overcurrent protection with 250 amp trip elements.
In a fault situation, the backup breakers would not react unless'the primary device failed to clear the fault.
Therefore, the proposed amendment willnot involve a significant increase in the consequences of an accident previously evaluated.,
t STANDARD 2 -- Create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed Technical Specification change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change does not alter the current design or operation of the facility.
The change allows an extension of certain surveillance intervals to permit performance of surveillance requirements during the next refueling outage currently scheduled to begin on March 16, 1991.
The extensions beyond those allowed by Technical Specification 4.0.2.a will not constitute a significant increase over the original test interval as they would constitute an increase of less than 20% of the allowable surveillance "interval.
Since there are no changes in the way the facility is being
- operated, the potential for an unanalyzed accident is not created.
No new failure modes are introduced by the proposed change.
Therefore, the proposed change willnot create the possibility o'f a new or different kind of accident from any ac'cident previously evaluated.
lt ll C
STANDARD 3 -- Involve a significant reduction in a margin of safety.
The proposed Technical Specification change does not involve a significant reduction in a margin of safety.
The proposed change to extend the time span for certain surveillance requirements to permit their performance during the next refueling outage (to begin in March 1991) will not constitute a significant increase (less than a 20% increase) beyond the allowable test interval.
The 125 volt batteries are subject to periodic surveillance testing to verify their general condition to ensure they are maintained in a fully charged condition and have sufficient stored energy to operate all necessary circuit breakers and to provide an adequate amount of energy for all required emergency loads for two hours after loss of AC power.
The subject breakers only provide the backup protection for primary devices in a redundant scheme of two overcurrent devices in series.
In a fault situation, the backup breakers would not react unless the primary device failed to clear the fault.
The past history on surveillance testing of the subject breakers establishes a good reliability of these circui,t breakers and an extension of the testing interval would have little or no affect on the margin of safety.
Therefore, the proposed change will not,involve a significant reduction in a margin of safety.
E.
SAFETY ANALYSIS OF THE PROPOSED AMENDMENT RE VEST
[
The proposed Technical Specification amendment willnot'increase the probability of occurrence or the consequences of an accident'r malfunction of equipment important to safety previously evaluated in the Updated Final Safety Analysis Report.
The amendment will not make changes to the facility.
The additional time between surveillance tests will not increase the probability of failure of the equipment.
The equipment for which this surveillance interval extension is sought have other surveillance testing as delineated below which will verify operability until such time as it can be taken out of service during a shutdown for integrated testing.
The need to shut down to perform surveillance testing is also recognized in the Technical Specifications which state "At least once every 18 months during shutdown."
The NRC has also stated in Generic Letter 89-14 that exceptions to the existing refueling surveillance intervals have been granted on a routine basis because the risk to safety is low in contrast to the alternative of a forced shutdown to perform these surveillances
~
The 125 volt batteries are subject to periodic surveillance testing to verify electrolyte level, specific gravity,. cell voltages, and general condition of the batteries.
Moreover, all important system components can be tested during service to detect faults.
Abnormal conditions of important system parameters are annunciated in the unit control room.
The capacity of the batteries is expected to increase through year 12, 60% of its life.
Since these batteries are approximately seven years old, the capacity is projected to be greater during the 1991 surveillance tests than during the 1989 surveillance tests.
In addi.tion
j
to this engineering performed a study of the batteries and concluded that 1) the extension of the discharge test by approximately 3 months represents a negligible interval compared to the 20 year design life and 2) there is a considerable level of safety margin of voltage for the four batteries.
The extension for the containment overcurrent protective device testing involves the testing of a 10% sample of each type of breaker.
This testing was performed on identical breakers in all Units with only one failure which occurred in Unit 2.
The breaker failed to meet specifications during the test and was replaced.
The replacement breaker was successfully tested.
Because of the failure of the 10% representative
- sample, a second 10% was generated and successfully performed.
This testing represents more than the required 10% sample if considered on a
site wide basis.
Thus the reliability of this type of breaker has been established and an extension of the testing interval would have little or no affect on the safe operation of the plant.
As stated in Generic Letter 83-27, the 18 month surveillance intervals were established based upon operating experience and the knowledge that some reactors would be utilizing 18-month fuel cycles.
An extension of 25% beyond this test interval is allowed to accommodate normal outage time.
The extension of this test interval to the next refueling outage in Unit 3
does not violate the licensing basis of the plant or the intent of the 18 month interval and is not a significant increase over the original test interval.
That intent was to verify that equipment was still OPERABLE after each fuel cycle and to ensure that prior to returning the Unit to service following refueling, all equipment important to safety has been tested and is OPERABLE.
All required testing will be performed during the refueling outage to validate the testing interval.
Generic Letter 89-14 recognizes that the 3.25 limitation on extending refueling surveillances is not a practical limit because the risk to safety is low in contrast to the alternative of a forced shutdown to perform these surveillances.
For that reason the NRC has routinely granted requests for exceptions to the 3.25 limit and concluded that removal of the 3.25 limitwill have an overall positive impact on safety.
- Thus, extending the test interval
~ for the specified surveillances will have a,,positive'mpact on plant safety in the, same, manner as not imposing the 3.25 limit on consecutive refueling surv'eillances.
(
F.
ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION The proposed Technical Specification Amendment 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 environmental impact previously evaluated in the Final Environmental Statement (FES),
as modified by the 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 PVNGS which may have a significant environmental impact.
G.
MARKED-UP TECHNICAL SPECIFICATION PAGES 3/4 8-10 3/4 8-18
e