ML17306B034

Forwards Response to NRC 920205 Request for Addl Info Re TS Change Request to Incorporate Recommedations of GL 87-09, Transmitted Via Util 910828 Ltr

ML17306B034
Person / Time
Site:	Palo Verde
Issue date:	10/02/1992
From:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
102-02302-WFC-J, 102-2302-WFC-J, GL-87-09, GL-87-9, NUDOCS 9210140264
Download: ML17306B034 (13)

Text

~ccEzER~TED DrgmsUTroN DEMoNsTR<TroN svsTEM REGULATORY INFORMATION DISTRIBUTION ZEM (RIDE)

ACCESS/ON NBR:9210140264 DOC.DATE: 92/10/02 NOTARIZED: YES FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi DOCKET I 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 CONWAYFW.F. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards response to NRC 920205 request for addi info re TS change request to incorporate recommedations of GL 87-09, transmitted via util 910828 ltr.

DISTRIBUTION TITLE: OR CODE AOOZD COPIES RECEIVED LTR Submittal: General Distribution

( ENCL g SIZE il NOTES:STANDARDIZED PLANT 05000528 Standardized plant.

i'tandardized plant.

05000529 05000530 A

D RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD5 LA 1 1 PD5 PD 1 1 TRAMMELL,C 2 2 INTERNAL: ACRS 6 6 NRR/DET/ESGB 1 1 NRR/DOEA/OTSB11 1 1 NRR/DST/SELB 7E 1 1 NRR/DST/SICB8H7 1 1 NRR/DST/SRXB 8E 1 1 NUDOCS-ABSTRACT 1 1 O4C 1 0 OGC/HDS1 1 0 01 1 1

! RES/DSIR/EIB 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 NOTE TO ALL "RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL 20

Arizona Public Service Company P.O. BOX 53999 ~ PHOENIX. ARIZONA 850724999 WILLIAMF. CONWAY 102-02302-WFC/JNI EXECUTIVEVICE PRESIDENT October 2, 1992 NUCLEAR U. S. Nuclear Regulatory Commission ATlN: Document Control Desk Mail Station P1-37 Washington, DC 20555

References:

1. Letter dated February 5, 1992, from D. H. Coe, NRC, to W. F. Conway, APS, "Request for Additional Information."

2. Letter dated August 28, 1991, from W. F. Conway, APS, " Proposed Technical Specification Amendments to Incorporate the Recommendations of Generic Letter 87-09."

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3 Docket Nos. STN 50-528/529/530 Response to NRC Request for Additional Information Related to Generic Letter 87-09 Technical Specification Amendment Request File: 92-005-419.5 The enclosure to this letter provides Arizona Public Service Company (APS) response to an NRC Staff written request for additional information (Reference 1), regarding Specification Change Request pursuant to Generic Letter (GL) 87-09 for PVNGS APS'echnical Units 1, 2, and 3.

APS requests that the Technical Specifications amendment become effective 90 days after issuance by the NRC.

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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Additional Information Related to GL 87-09 TS Amendment Page 2 If you have any questions, please call Thomas R. Bradish at (602) 393-5421.

Sincerely, WFC/JNI/pmm Enclosure cc: J. B. Martin J. A. Sloan W. R. Wright

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STATE OF ARIZONA )

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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 Dt Day Of 0 ~, 1992.,

""'~'"Notary Public My Commission Expires

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ENCLOSURE ADDITIONALINFORMATION RELATED TO GENERIC LETTER 87-09 TS AMENDMENT

ENCLOSURE ADDITIONALINFORMATION RELATED TO GENERIC LETTER (GL) 87-09 TS AMENDMENT The NRC Staff has requested that:

1. For each proposed Technical Specification exception (those Specifications which would be given added flexibilityfor mode or condition changes) to be granted under GL 87-09, you affirm that remedial measures prescribed by the affected ACTION STATEMENTS are consistent with the Updated Safety Analysis Report (UFSAR) and its supporting safety analysis.

2. Please identify and affirm the use of those administrative controls (e.g., maintenance program provisions, plant operating procedures, management directives, on site safety reviews, etc.) that have been established to limit the use of the Specification 3.0.4 exceptions granted. Your affirmation should address training necessary for "ensuring that plant operators are made aware of, and are instructed to exercise the controls promulgated in limiting the use of such exceptions.

APS Response:

1. APS has reviewed each of the proposed changes to Technical Specification 3.0.4 and determined that the proposed actions are consistent with the UFSAR and its supporting safety analysis. As discussed in Reference 2, the proposed amendments make no changes to safety limits, setpoints, or design margins at PVNGS.

2. APS will implement the following administrative controls prior to the effective date of the proposed Technical Specification amendment:

a. APS will revise Operating Procedures to require appropriate management approval prior to operating mode changes while in a Technical Specification Limiting Condition for Operation as allowed in the proposed Technical Specification 3.0.4 changes. This will limit the reliance on Technical Specification 3.0.4 for plant startups to those situations that are necessary and safe for plant operations. As part of the mode transition review, the appropriate plant management will review the priority and schedule for equipment repair for maintenance related to items affected by the proposed change to Technical Specification 3.0.4.

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b. For each Technical Specification to which the proposed change to Technical Specification 3.0.4 will be applied, the action statement for that Technical Specification provides an adequate level of protection for a change in operational mode or specified condition. Administrative controls will be implemented at Palo Verde Units 1, 2, and 3, to limit the use of Technical Specification 3.0.4 exceptions and that appropriate plant personnel will be made aware of and instructed to exercise the administrative controls in limiting the use of such exceptions.

In addition, the proposed Technical Specification Bases for Specification 3.0.4, states; "It is not intended that the shutdown ACTION requirements be used as an operational convenience which permits (routine) voluntary removal of a system(s) or component(s) from service in lieu of other alternatives that would not result in redundant systems or components being inoperable." ... "The provisions of this specification should not, however, be interpreted as endorsing the failure to exercise good practice in restoring systems or components to OPERABLE status before plant startup."

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