ML17306B060

Advises That Proposed Amend,Submitted Via ,Re Containment Purge Isolation Actuation Sys Considered Unnecessary & Withdrawn

ML17306B060
Person / Time
Site:	Palo Verde
Issue date:	10/15/1992
From:	Trammell C Office of Nuclear Reactor Regulation
To:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
TAC-M83103, TAC-M83104, TAC-M83105, NUDOCS 9210220148
Download: ML17306B060 (8)

Text

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~o O0 4**+4 UNITED STATES NUCLEAR REGULATORY COMMISS(ON WASHINGTON, D.C. 20555 October 15, 1992 Docket Nos. 50-528, 50-529 and 50-530 Mr. William F.

Conway Executive Vice President, Nuclear Arizona Public Service Company P.O.

Box 53999

Phoenix, Arizona 85072-3999

SUBJECT:

PROPOSED AMENDMENT TO TECHNICAL SPECIFICATION 3/4 9.9 REGARDING CONTAINMENT PURGE ISOLATION ACTUATION SYSTEM PALO VERDE NUCLEAR GENERATING STATION (TAC NOS.

M83103, M83104, AND M83105)

This refers to your letter of March 20, 1992, in which you requested a change to the Surveillance Requirement (SR) for the containment purge valve isolation system in the Technical Specifications (TS).

The change would provide an alternate SR to be applied when the system is inoperable.

The perceived need for this change reflects what appears to be a misunderstanding of TS 3/4 9.4, 3/4 9.9 and 4.0.3.

We would like to take this opportunity to explain why we believe the proposed change is unnecessary.

Technical Specification 3/4 9.4, Containment Building Penetrations, is applicable to containment building penetrations used for containment purge.

Limiting Condition for Operation (LCO) 3.9.4 and its related Surveillance Requirement 4.9.4 allow the requested alternatives, i.e., the penetration closed by an isolation valve, blind flange, or manual valve, or capable of being closed by an OPERABLE automatic containment purge valve, and only one surveillance is required (a. or b.).

TS 3/4 9.9, Containment Purge Valve Isolation System, provides an automatic and manual isolation signal to the valves upon detection of high radiation levels within containment (Bases 3/4 9.9).

TS 4.0.3 states that Surveillance Requirements do not have to be performed on inoperable equipment.

Thus, SR 4.9.9, demonstrating the operability of the containment purge valve isolation

system, does not have to be performed when the containment purge penetrations are closed (in the action statement for TS 3.9.9).

However, SR 4.9.4 a.,

verifying that the penetration is isolated, does have to be performed, since TS 3.9.4 is satisfied by virtue of having either the valve closed or capable of being closed (TS 3.9.4.c).

Although it might be argued that the proposed duplication of what is already in the supported system (TS 3/4.9.4) would,add some clarity, the significance is not great enough to justify changing the existing STS, particularly since TS 4.0.3 was created to cover the situation where equipment is inoperable and surveillance would otherwise be due.

The revised STS (NUREG-1432) includes ennnaz 9210220148 921015 PDR ADOCK 05000528 I

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Mr. William F.

Conway October 15, i992 the same, requirements with its modified format, which is intended to be an operational improvement for licensees that convert to the revised STS.

In addition, not making the change avoids the situation where a surveillance requirement that can be passed is created just to be able to call the system "operable" when it clearly is not.

Based on the foregoing, we believe that the proposed change is unnecessary and consider your proposed change to be withdrawn.

We discussed this matter with your licensing staff in a telephone conversation on October 8, 1992.

We have prepared a proposed Notice of Withdrawal of Application for Amendment to Facility Operating License.

Unless you notify us that we are incorrect within 10 days of receipt of this letter, we will file the notice with the Office of the Federal Register for publication.

Sincerely, Original Signed By:

CC:

See next page Charles M. Trammell, Sr. Project Manager Project Directorate V

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Mr. William F.

Conway the same requirements with its modified format, which is intended to be an operational improvement for licensees that convert to the revised STS.

In addition, not making the change avoids the situation where a surveillance requirement that can be passed is created just to be able to call the system "operable" when it clearly is not.

Based on the foregoing, we believe that the proposed change is unnecessary and consider your proposed change to be withdrawn.

We discussed this matter with your licensing staff in a telephone conversation on October 8, 1992.

We have prepared a proposed Notice of Withdrawal of Application for Amendment to Facility Operating License.

Unless you notify us that we are incorrect within 10 days of receipt of this letter, we will file the notice with the Office of the Federal Register for publication.

Sincerely, Charles M. Trammell, Sr. Project Manager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation CC:

See next page

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Mr. William F.

Conway Arizona Public Service Company Palo Verde CC:

Nancy C. Loftin, Esq.

Corporate Secretary 8 Counsel Arizona Public Service Company P. 0.

Box 53999, Mail Station 9068

Phoenix, Arizona 85072-3999 James A. Beoletto, Esq.

Southern California Edison Company P. 0.

Box 800

Rosemead, California 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission HC-03 Box 293-NR Buckeye, Arizona 85326 Regional Administrator, Region V

U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Mr. Charles B. Brinkman, Manager Washington Nuclear Operations ABB Combustion Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Mr. William A. Wright, Acting Director Arizona Radiation Regulatory Agency 4814 South 40 Street

Phoenix, Arizona 85040 Chairman Maricopa County Board of Supervisors 111 South Third Avenue

Phoenix, Arizona 85003 Jack R.

Newman, Esq.

Newman

& Holtzinger, P.C.

1615 L Street, N.W., Suite 1000 Washington, D.C.

20036 Curtis Hoskins Executive Vice President and Chief Operating Officer Palo Verde Services 2025 N. 3rd Street, Suite 220

Phoenix, Arizona 85004 Roy P.

Lessey, Jr.,

Esq.

Bradley W. Jones, Esq.

Arkin, Gump, Strauss, Hauer and Feld El Paso Electric Company 1333 New Hampshire Ave., Suite 400 Washington, D.C.

20036

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