ML17305B478

Supersedes Re Request for Temporary Waiver of Compliance for Limiting Condition for Operation 3.0.4

ML17305B478
Person / Time
Site:	Palo Verde
Issue date:	04/20/1991
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
161-0337-WFC-GE, 161-337-WFC-GE, NUDOCS 9104260120
Download: ML17305B478 (13)

Text

'CCELERATED DISTRIBUTION DEMONSTPA.TION SYSTEM t

t REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9104260120 DOC.DATE: 91/04/20 NOTARIZED: NO 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 RECXPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Supersedes 910419 ltr re request for temporary waiver of compliance for Limiting Condition for Operation 3.0.4.

DISTRIBUTION CODE:

AOOID COPIES RECEIVED:LTR g ENCL g SIZE:

TITLE: OR Submittal:

General Distribution NOTES:Standardized plant.

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05000530 RECIPXENT ID CODE/NAME PD5 LA TRAMMELL,C INTERNAL: ACRS NRR/DET/ESGB NRR/DST 8E2 NRR/DST/SICB 7E NUDOCS-ABSTRACT OGC/HDS 1 RES/DSIR/EIB EXTERNAL: NRC PDR NOTES:

COPXES LTTR ENCL 1

1 2

2 6

6 1

1 1

1 1

1 1

1 1

0 1

1 1

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1 RECIPIENT XD CODE/NAME PD5 PD THOMPSON,M NRR/DET/ECMB 9H NRR/DOEA/OTSBll NRR/DST/SELB 8D NRR/DST/SRXB 8E OC LFMB 01 NSIC COPIES LTTR ENCL 1

1 2

2 1

1 1

1 1

1 1

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM 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

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PHOENIX, ARIZONA85072<999 WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR 161-03887-WFC/GEC April 20, 1991 Docket No.

STN 50-530 U.

S. Nuclear Regulatory Commission Attention:

Document Control Desk Mail Station Pl-37 Washington, D.

C.

20555

Reference:

Letter from W. F. Conway (APS) to USNRC Document Control Desk, dated April 19, 1991;

Subject:

Request for a

Temporary Waiver of Compliance for Limiting Condition for Operation 3.0.4

Dear Sirs:

Subj ect:

Palo Verde Nuclear Generating Station (PVNGS)

Unit 3 Request for a Temporary Waiver of Compliance for Limiting Condition for Operation 3.0.4 File:

91-056-026 This letter supersedes the referenced letter.

Arizona Public Service Company (APS) requests a

temporary waiver of compliance from the'equirements of Specification 3.0.4 to allow fuel loading to commence in Unit 3.

This temporary waiver of compliance was discussed in conversations with Mr. Charles M. Trammell, NRR, on April 18 and 19, 1991, and Mr. Howard J.

Wong, NRC Region V, on April 19, 1991.

RE UIREMENTS FOR WHICH A WAIVER IS RE UESTED Technical Specification 3.0.4 does not allow entry into an OPERATIONAL MODE unless the conditions of the Limiting Conditions for Operation are met without reliance on provisions contained in the ACTION requirements.

As a part of the outage maintenance activities, Train A of the essential spray pond

system, essential cooling water system, and essential (emergency) chill water system is currently not functional.

Train A of the control room essential filtration

system, being dependent on these

systems, is therefore not considered operable.

Specification 3.7.7 requires that two independent control room essential filtration systems be operable in All MODES.

As currently allowed by the technical specifications, fuel loading (entry into MODE 6) could not begin until completion of the current maintenance activities on these systems an'd their return to a functional status, as well as the control room essential filtration system returned to an operable status.

Therefore, the temporary waiver of compliance from the requirement of Specification 3.0.4, as it relates to entry into MODES 5 and 6 of Specification 3.7.7, is requested to allow entry into MODES 5 and 6, with only one control room essential filtration system operable.

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161-03887-WFC/GEC April 20, 1991 U.

S. Nuclear Regulatory Commission Request for a Temporary Waiver of Compliance Page Two CIRCUMSTANCES SURROUNDING THE SITUATION The unit currently is defueled with fuel loading (entry into MODE 6) scheduled to begin on April 21, 1991 and entry into COLD SHUTDOWN (MODE 5) currently scheduled to occur on April 29, 1991.

In the current, defueled condition (no mode) there is no restriction on the unit resulting from the inoperable Train A control room essential filtration system.

However, upon commencement of fuel loading (entry into MODE 6) the unit would enter an Action Statement (ACTION a for MODES 5 and 6) requiring that APS "restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control room essential filtration system."

NEED FOR PROMPT ACTION The maintenance activities on the essential spray pond system are currently scheduled to be complete on May 1, 1991.

The unit currently is defueled with fuel loading (entry into MODE 6) scheduled to begin on April 21, 1991. If the temporary waiver of compliance is not granted, fuel loading may be delayed to May 1,

1991, a delay of ten days to the outage schedule.

This delay will result in a day for day postponement of the scheduled date for return to power operation by Unit 3 following the refueling outage.

DESCRIPTION OF WHY THE SITUATION COULD NOT HAVE BEEN AVOIDED During planning and scheduling for the Unit 3 outage; the potential for the plant being in the situation described above was not recognized.

Although the Technical Specification for the essential chilled water system is not applicable in MODES 5

and 6,

PVNGS did recognize the criteria stated in Surveillance Requirement (SR) 4.7.7d.4 to verify the ability of the essential chilled water system to maintain the temperature in the control room at

<80'F.

An interpretation of this requ'irement,had previously beenapproved in September 3.987 and revised in December 1988.',This'interpretation was based'on the requiremen't of SR 4.7.7d.4 being'met by a'combination of essential chilled water and control room essential filtration systems being functional.

Maintaining control room temperature

<80'F is also required by Specification 3.7.12 in all MODES and it does not specify which system(s) must be used.

While reviewing plant conditions fdr anticipated entry into MODE 6,

PVNGS determined, by applying stricter criteria for support system operability, that SR 4.7.7d.4 is required to be met by independent trains of control room essential filtration.

In order to meet this requirement, both essential chilled water systems would be required to be functional.

At the time the determination was

made, maintenance of the essential chiller and the essential cooling water systems had progressed "to a stage

.where they could not readily be returned to service.

The Train A essential chiller and essential cooling water system had been removed from service and work started on April 16, 1991.

The situation described above was determined on April 18, 1991.

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161-03887-MFC/GEC April 20, 1991 U.

S. Nuclear Regulatory Commission Request for a Temporary Waiver of Compliance Page Three Prior to the outage, PVNGS decided to off-load fuel from the Unit 3 reactor vessel since several evolutions were planned which would have required midloop operation. If the unit had not off-loaded the core and had remained in MODE 6, the ACTION would have been entered and this mode change restriction would not have occurred.

COMPENSATORY MEASURES During the period of this temporary waiver the control room essential filtration system will be operated in conformance with ACTION requirements a

and b of Limiting Condition for Operation 3.7.7 for MODES 5

and 6,

and will be in conformance with the BASES for the control room essential filtration system.

PRELIMINARY EVALUATIONOF THE SAFETY SIGNIFICANCE AND POTENTIAL CONSE UENCES OF THE PROPOSED RE UEST The purpose of the ACTION requirements for MODES 5

and 6

in Technical Specification 3.7.7 is to ensure, that one train of the control room essential filtration system is operable at all times when the reactor is in MODES'5 and 6

and CORE ALTERATIONS or positive reactivity changes are'ccurring; and to further ensure that if both control room essential filtration systems are inoperable, that no CORE ALTERATIONS or positive reactivity changes occur during that period.

The duration of the ACTION is not limited and once entered can continue indefinitely; consequently, there are no additional safety implications resulting from entering MODES 6 or 5 by relying on the provisions of the ACTION statements.

DURATION OF THE RE UEST The maintenance activities on the essential spray pond system, essential cooling water

system, and essential chill water system are currently scheduled to be complete on May 1, 1991.

The unit currently is defueled with fuel loading (entry into MODE 6) scheduled to begin on April 21, 1991 and entry into COLD SHUTDOWN (MODE

5) currently scheduled to occur on April 29, 1991.

Therefore, the temporary waiver of compliance is requested during the period from when the reactor would enter MODE 6 (April 21, 1991) until both control room essential filtration systems are OPERABLE (May 1, 1991).

SIGNIFICANT HAZARDS CONSIDERATION APS has performed a No Significant Hazards Analysis (refer to Enclosure A) and concluded. that this temporary waiver of compliance will have no adverse impact on the continued safe operation of the Unit 3.

This temporary waiver request has been concurred with by the Plant Review Board.

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161-03887-WFC/GEC Appil 20, 1991 U.

S. Nuclear Regulatory Commission Request for a Temporary Waiver of Compliance Page Four ENVIRONMENTAL CONSE UENCES APS has performed an Environmental Impact Consideration Determination (refer to Enclosure A) and concluded that this temporary waiver of compliance does not involve irreversible environmental damage.

Pursuant to 10 CFR 50.91(b)(1),

and by copy of this letter and enclosure, APS has notified the Arizona Radiation Regulatory Agency of this request for a temporary waiver of compliance.

If you should have any questions, please contact Michael E. Powell of my staff at (602) 340-4981.

Sincerely, WFC/GEC/gec Enclosure cc:

C.

M.

J.

B.

D. H.

A. C.

A. H.

C. F.

Trammell Martin Coe Gehr Gutterman Tedford (all w/enclosure)

161-03887-WFC/GEC April 20, 1991 Enclosure A

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 waiver of compliance to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed waiver of compliance would not:

(1) involve a significant increase in the probability or consequences'f 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 this temporary waiver of compliance request follows:

Standard 1:

Involve a

si nificant incre'ase in the robabilit or conse uences of an accident reviousl evaluated.

The waiving of the restriction of Specification 3.0.4 for entry into MODES 6

and 5 of Specification 3.7.7 does not involve an increase in the probability or consequences of an accident previously evaluated.

Specification 3.7.7 requires that two independent control room essential filtration systems be OPERABLE.

For MODES 5 and 6, the Action Statement requires that:

(a)

"With one control room essential filtration system inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE control room essential filtration system.",

The Action State'ment also requires that:

(b) "With both control room essential filtration systems inoperable, or with the OPERABLE control room essential filtration system, required by ACTION a.,

not capable, of being powered'y an operable emergency,.power

source, suspend all operations involving CORE ALTERATIONS" or positive reactivity changes."

These Action Statements would -be in,effect had Unit 3 entered lfODE 6 'or, MODE 5 just before the', maintenance activity was started on" the essential spray pond system 'nd the unit could continue operation under 'this condition for an indefinite period performing core alterations or positive reactivity changes associated with refueling.

Therefore, temporarily waiving the Specification 3.0.4 restriction on entering MODE 6 or MODE 5 does not result in an increase in the probability or consequences of any accident previously evaluated.

n Standard 2: Create the ossibilit of a new or different'kind of accident from an accident reviousl evaluated.

The waiving of Specification 3.0.4 restricting entry into MODES 6 and 5

does not create the possibility of a new or different kind of accident from any previously evaluated.

The change does not affect operation of the plant except to allow entry into these modes with one control room essential filtration system inoperable.

Immediately upon entering MODE 6 the applicable Action Statement will be entered and Unit 3 will continue

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161-03887-WFC/GEC April 20, 1991 Basis for No Significant Hazards Consideration Page Two to operate within the restrictions oE the Action Statements for the duration of the temporary waiver period, thus ensuring that no possibility of a

new or different kind of accident from any accident previously evaluated will be created.

Standard 3

Involve a si nificant'lreduction in a mar in of safet The waiving of Specification 3.0.4 restricting entry into MODES 6 and 5

does not involve a significant reduction in a margin of safety.

The change does not affect operation of the plant except to allow entry into

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these modes with one control room essential filtration system inoperable.

Immediately upon entering MODE 6 the applicable Action Statement will be entered and Unit 3 will continue to operate within the restrictions oE the Action Statements for the duration of the waiver period, thus ensuring that no reduction in a margin of safety will occur.

Environmental Impact Consideration Determination The proposed waiver oE compliance reques't does not involve an'nreviewed environmental question because operation of PVNGS Unit'3 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 the staff's testimony to 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 signiEicant environmental impact.

As discussed

above, no signiEicant reduction in safety and no new accidents are introduced by this change.

This waiver of compliance does not aEEect effluents or power levels, and consequently does not involve irreversible environmental consequences'

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