ML17305B590
| ML17305B590 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/07/1991 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17305B591 | List: |
| References | |
| REF-GTECI-070, REF-GTECI-094, REF-GTECI-NI 161-03995-WFC-D, NUDOCS 9106110247 | |
| Download: ML17305B590 (18) | |
Text
ACCELERATED DI TIUBUTION DEMONS TION SYSTEM l ~
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9106110247 DOC.DATE: 91/06/07 NOTARIZED: YES DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 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 R RECIP.NAME RECIPXENT AFFILIATION Document Control Branch (Document Control Desk) l SUBZECT: Application for amends to licenses NPF-41,NPF-51 6 NPF-74, D respectively. Reducing allowed out of svc time for shutdown cooling sys suction relief valves,addinq ACTXON Statements for SCS Suction relief valve inoperability 6 Clarification. S DISTRIBUTION CODE: A019D TITLE: Generic Ltr COPIES RECEIVED: LTR 90-06 Resolution of GE J ENCL 70N94 PORVs 6 $ Block SIZE:
Valve Relxabil A
NOTES:STANDARDIZED PLANT 05000528 Standardized plant. 05000529 Standardized plant. 05000530 D
RECIPIENT COPIES RECIPIENT COPIES XD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 TRAMMELL,C 1 1 THOMPSON,M 1 1 INTERNAL: KIRKWOOD, R. NLS3 1 1 NRR/EMEB 1 1 NRR/S XB 1 1" PICKETT,D 13H15 1 1 RE 1 1 RES/DSIR/EIB 1 1 RE DSTK/RPMB 1 1 EXTERNAL: NRC PDR 1 1 NUDOCS-ABSTRACT 1 1 NOTES 1 1 D
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NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WAS'ONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED! ~
TOTAL NUMBER OF COPXES REQUIRED: LTTR 14 ENCL 14
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Arizona Public Service Company P.O. BOX 53999 ~ PHOENIX, ARIZONA85072-3999 WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR 161-03995-tJFC/DAF June 7, 1991 Docket Nos. STN 50-528/529/530 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station Pl-37 Washington, DC 20555
Dear Sirs:
Subj ect: Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3 Proposed Technical Specification Amendments to Specification 3.4.8.3 and Associated Surveillance Requirements, to Incorporate the Recommendations of Generic Letter 90-06, "Resolution of Generic Issue 70, Power-Operated Relief Valve and Block Valve Reliability," and Generic Issue 94, "Additional Low-Temperature Overpressure Protection for Light-Water Reactors, Pursuant to 10 CFR 50.54 (f)"
File: 91-005-419.05; 91-056-026 On June 25, 1990, the NRC issued Generic Letter 90-06 which provided licensees with guidance on preparing license amendments to incorporate additional low temperature overpressure protection. In response to the Generic Letter and pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) submits herewith a request to amend Facility Operating Licenses NPF-41, NPF-51, and NPF-74, for PVNGS Units 1, 2, and 3, respectively. The proposed amendments 1) reduce the allowed out of service time for the shutdown cooling system (SCS) suction relief valves; 2) add new ACTION Statements for SCS suction relief valve inoperability; and for periodic verification that the Reactor Coolant System (RCS) is properly vented, and 3) clarify the associated Surveillance Requirements.
Provided in the attachment to this letter are the following sections which support the proposed Technical Specification change:
Description of the Proposed Technical Specification Amendment Request B. Purpose of the Technical Specifications C. Need for Technical Specification Amendment D. No Significant Hazards Consideration Determination E. Safety 'Analysis for the Proposed Technical Specification Amendment Request F. Environmental Impact Consideration Determination G. Marked-up Technical Specification Change Pages 9106i10247 910607 PDR ADOCK 05000528 P PDR
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U. S. Nuclear Regulatory Commission Attn: Document Control Desk Proposed Technical Specification Amendments to Specification 3.4.8.3 Page Two Pursuant to 10 CFR 50.91 (b)(l), and by copy of this letter and attachment, the Arizona Radiation Regulatory Agency is being notified of this request for a Technical Specification change.
If you should have questions, please contact Michael E. Powell of my staff at (602) 340-4981.
Sincerely, WFC/DAF/pmm Attachment cc: J. B. Martin C. F. Tedford C. M. Trammell.
D. H. Coe A. C. Gehr A. H. Gutterman
t STATE OF ARIZONA )
) ss.
COUNTY OF MARICOPA )
I, W. F. Conway, represent that I am Executive Vice President Nuclear, 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.
W. F. Conway Sworn To Before Me This Day Of 1991.
'otary -Public sl I
ly
'c(v My Commission Expires
b ATTACHMENT A. DESCRIPTION OF THE PROPOSED TECHNICAL SPECIFICATION AMENDMENT RE UEST A new Technical Specification 3.4.8.3 ACTION Statement a is added which reads as follows:
- a. From MODE 4 with one SCS relief valve inoperable, restore the inoperable valve to OPERABLE status bourse'o within 7 days or depressurize and vent the RCS through at least a 16 square inch vent(s) within the next 8 not start a reactor coolant pump if the steam generator water temperature is greater than 100'F above any RCS cold leg temperature.
The existing Technical Specification 3.4.8.3 ACTION Statement a is changed to ACTION Statement b, and is revised to reduce the allowed out of service time for SCS relief valve inoperability while in MODES 5 or 6. The revised ACTION Statement reads as follows:
- b. From MODES 5 or 6 with one SCS relief valve inoperable, either (1) restore the inoperable valve to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or (2) reduce T~ to less than 200'F and complete depressurization and venting of the RCS through at least a 16 square inch vent(s) within a total of 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />. Do not start a reactor coolant pump if the steam generator secondary water temperature is cold leg temperature.
greater than 100'F above any RCS A new Technical Specification 3.4.8.3 ACTION Statement d is added which reads as follows:
- d. With the RCS vented per ACTIONS a, b, or c, verify the vent pathway at least once per 31 days when the pathway is provided by a valve(s) that is locked, sealed, or otherwise secured in the open position; otherwise, verify the vent pathway every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The existing Technical Specification 3. 4.8.3
~ ACTION Statements b, c, and d are changed to c, e, and f, respectively.
Technical Specification Surveillance Requirement 4.4.8.3.1 is revised to delete "once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />" and add in its place the following: "at least once per 31 days when the pathway is provided by a valve(s) that is locked, sealed, or otherwise secured in the open position; otherwise, verify alignment every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />".
P Technical Specification Surveillance Requirement 4.4.8.3.2 is revised to read as follows:
4.4.8 '.2 The SCS suction line relief valves shall be verified OPERABLE as required by Specification 4.0.5.
PURPOSE OF THE TECHNICAL SPECIFICATIONS The purpose of Technical Specification 3.4.8.3 is to provide low temperature overpressure protection for the reactor coolant system. This specification requires that both SCS suction relief valves be operable and aligned to provide overpressure protection whenever the RCS is less than or equal to 214'F during cooldown and 291'F during heatup.
The Technical Specification 3.4.8.3 ACTION Statements describe the specific actions required to be taken should one or both of the SCS suction relief valves be inoperable.
The Technical Specification Surveillance Requirements 4.4.8.3,1 and 4.4.8.3.2 require that specific tests and verifications be performed to ensure that the SCS suction relief valves are capable of performing their intended function.
C. NEED FOR THE TECHNICAL SPECIFICATION AMENDMENT The proposed Technical Specification changes are necessary to provide increased reliability for the low temperature overpressure protection relief valves.
D,. 'O SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50 '2. A proposed amendment to an operating license for a facility involves a 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.
'l The NRC has previously issued, in the Federal Register, examples of amendments that are considered not likely to involve significant hazards considerations.
This proposed amendment request matches example I(C)(2)(e)(ii) described in Federal Register notice 51FR7751, dated March 6, 1986, as follows:
"(ii) A change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications, e.g., a more stringent surveillance requirement."
A discussion of the above 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 amendments 1) reduce the allowed out of service time for the SCS suction relief valves; 2) add new ACTION Statements for SCS suction relief valve inoperability; and for periodic verification that the RCS is properly vented, and 3) clarify the associated Surveillance Requirements. These changes to the Technical Specifications provide increased reliability for the low temperature overpressure protection relief valves which will reduce the probability of a low temperature overpressurization event. The consequences of a low temperature overpressurization event are unchanged. Therefore, the proposed amendments do not involve a significant increase in, the probability'r consequences of an accident previously evaluated.
Standard 2 -- Create the possibility of a new or different kind of accident ~from any accident previously evaluated.
't The proposed amendments limit the period of time that an individual low temperature overpressure protection relief valve may be out of service before compensatory action 4s initiated, thereby reducing the possibility of a low temperatur'e overpressurization event. The proposed amendments do not modify the design or operation of plant equipment. Therefore, the proposed amendments do not create the possibility of a new or different kind of accident from any accident previously evaluated.
Standard 3 -- Involve a significant reduction in a margin of safety.
The proposed amendments ensure that the low temperature overpressure protection system has appropriate compensatory measures implemented in a more timely manner whenever an individual SCS 'valve is inoperable. These changes represent an additional operating limitation but do not change the bases or assumptions used in the safety analyses for this system. Therefore, the proposed amendments will not involve a significant, reduction in a margin of safety.
yt E. SAFETY ANALYSIS FOR THE PROPOSED TECHNICAL SPECIFICATION AMENDMENT RE UEST NRC Generic Letter 90-06 recommended a more limited out of service time for low temperature overpressure protection relief valves to reduce the probability of a low temperature overpressurization event. The proposed amendments 1) reduce the allowed out of service time for the SCS suction relief valves; 2) add new ACTION Statements for SCS suction relief valve inoperabili,ty; and for periodic verification that the RCS is properly vented, and 3) clarify the associated Surveillance Requirements. These changes to the Technical Specifications provide increased reliability for the low temperature overpressure protection relief valves which will reduce the probability of a low temperature overpressurization event. The consequences of a low temperature overpressurization event are not affected by these changes. Therefore, the proposed amendments do not involve an increase in the probability or consequences of an accident previously evaluated.
The proposed amendments do not modify the low temperature overpressure protection system or related plant equipment. In addition, operation of plant equipment is not affected by these changes. As such, this amendment request does not create the possibility of a new or different kind of accident from any accident previously evaluated.
This amendment request incorporates conservative limitations for SCS suction relief valve inoperability and RCS low temperature overpressure protection. These measures enhance overall plant safety by increasing the reliability of the low temperature overpressure protection system. These
,limitations do,not change the bases or assumptions used in the safety analyses for 'this syst'm. As such, the proposed amendments will not reduce the margin of safety at PVNGS.
F. ENVIRONMENTAL IMPACT CONSIDERATION DETERMINATION NRC Generic Letter 90-06 recommended a more limited out of service time for low temp'erature overpressure p'rotection"'relief valves to reduce the probability of'a low temperature overpressurization event. The proposed amendments 1) reduce the allowed out of service time. for the SCS suction relief valves; 2) add new ACTION Statements for SCS suction relief valve inoperability and for periodic verification that the RCS is properly vented, and 3) clarify the associated Surveillance Requirements. These changes to the Technical Specifications provide increased reliability for the low temperature overpressure protection relief valves which will reduce the probability of a low temperature overpressurization event.
APS has determined that the proposed amendments involve no change in the amount or type of any effluent that may be released offsite, and that there is no increase in individual or'umulative occupational radiation exposure. As such, operation of PVNGS Units 1, 2, and 3, in accordance with the proposed amendments, does not involve an unreviewed environmental safety question.
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G. NARKED-UP TECHNICAL SPECIFICATION CHANGE PAGES r
See attached Technical Specification pages 3/4 4-32 and 3/4 4-33 for PVNGS Units l, 2, and 3, respectively.