ML17310B269
| ML17310B269 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/04/1994 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17310B270 | List: |
| References | |
| 102-02940-WFC-R, 102-2940-WFC-R, NUDOCS 9405120306 | |
| Download: ML17310B269 (16) | |
Text
ACCELERATED DI UTION DEMONS TION SYSTEM
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REGULATORY INFORMATION DISTRXBUTION SYSTEM (RIDS)
ACCESSION NBR:9405120306 DOC.DATE: 94/05/04 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 RECXPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Application for amends to licenses NPF-41,NPF-51 & NPF-74, forwards TS amendments clarify that subject spec are D applicable during steady state conditions in reactor coolant system heatup/cooldown evolutions.
DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR ( ENCL / SXZE:
TITLE: OR Submittal: General Distribution A
NOTES'STANDARDIZED PLANT 05000528 Standardized plant. 05000529 D Standardized plant. 05000530 D
RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDIV-3 LA 1 PDIV-3 PD 1 1 HOLXAN, B 2 2 TRAN,L 2 2 INTERNAL: ACRS 6 6 NRR/DE/EELB 1 1 NRR/DORS/OTSB 1 1 NRR/DRCH/HICB 1 1 NRR/DRPW 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OC/LFDCB 1 0 OGC/HDS 1 1 0 REG ~ E Ol 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 R
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D NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 22
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Arizona Public Service Company P.O. BOX 53999 ~ PHOENIX, ARIZONA 85072-3999 WILLIAMF. CONWAY 102-02940-WFC/RAB/ZJE EXECUTIVEVICE PRESIDENT NUCLEAR May 4, 1994 U. S. Nuclear Regulatory Commission ATl N: Document Control Desk Mail Station P1-37 Washington, DC 20555
References:
- 1. Letter dated February 7, 1992, from C. M. Thompson, Project Manager, Project Directorate V, Division of Reactor Projects III/IV/V, Office of Nuclear Reactor Regulation, NRC to W. F. Conway, Executive Vice President, Nuclear, APS
-2 Letter 161-0471 8-WFC/DAF, dated April 13, 1991, from W. F. Conway, APS, to NRC, "Response to NRC Request for Additional Information - Amendment Application Under Generic Letter 90-06"
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1,2, and 3 Docket Nos. STN 50-528/529/530 Proposed Technical Specification Amendments to Clarify LCO 3.4.8.3 and Surveillance Requirement 4.4.8.3.1 Applicability File: 94-005-41 9.05 94-056-026 As a result of an NRC request for additional information (Reference 1),
Arizona Public Service Company (APS) determined that Technical Specification amendments clarifying the subject specifications were necessary (Reference 2).
Therefore, pursuant to 10 CFR 50.90, APS submits herewith the proposed Technical Specification amendments. Specifically, these amendments clarify that the subject specifications are applicable during steady state conditions in reactor coolant system heatup/cooldown evolutions.
Provided in the enclosure to this letter are the following sections which support the proposed Technical Specification amendments:
'~P,: 9405i20306 940504 PDR ADDDK 05000528
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U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Proposed Technical Specification Amendments Page 2 Description of the Technical Specification Amendment Request Purpose of the Technical Specifications Need for the Technical Specification Amendments No Significant Hazards Consideration Determination Safety Analysis for the Technical Specification Amendment Request Environmental Impact Consideration Determination Marked-up Technical Specification Pages Pursuant to 10 CFR 50.91(b)(1) and by copy of this letter and enclosure, the Arizona Radiation Regulatory Agency is being notified of this request for Technical Specification amendments.
Should you have any questions, please contact Richard A. Bernier at (602) 393-5882.
Sincerely, WFC/RAB/ZJE/did Enclosure cc: K. E. Perkins K. E. Johnston B. E. Holian A. V. Godwin (ARRA)
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STATE OF ARIZONA . )
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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 , 1994.
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ENCLOSURE PROPOSED AMENDMENTTO TECHNICAL SPECIFICATIONS
A. DESCRIPTION OF THE TECHNICAL SPECIFICATION AMENDMENT RE VEST This amendment request proposes a revision to LCO 3.4.8.3 and Surveillance Requirements 4.4.8.3.1 Overpressure Protection Systems. Specifically, the LCO and Surveillance Requirements are revised to clarify that both shutdown cooling system (SCS) suction line relief valves shall be OPERABLE and aligned to provide overpressure protection not only during RCS cooldown or heatup evolutions, but also during any steady state temperature periods maintained in the course of RCS cooldown or heatup evolutions.
B. PURPOSE OF THE TECHNICAL SPECIFICATIONS The purpose of. Specification 3.4.8.3 is to provide low temperature overpressure protection for the RCS. The operability and alignment of two shutdown cooling suction line relief valves, one located in each shutdown cooling suction line, while maintaining the limits imposed on the RCS heatup and cooldown rates, ensures that the RCS will be protected from pressure transients which could exceed the limits of Appendix G to 10 CFR 50 when one or more of the RCS cold legs are less than or equal to 214'F during cooldown, 291'F during heatup.
C. NEED FOR THE TECHNICAL SPECIFICATION AMENDMENTS This clarification addresses conditions outside the current LCO and surveillance applicability. The clarification is necessary since it is possible to achieve and maintain a steady state in the course of either a heatup or cooldown evolution. As such, this clarification is needed for operator's further awareness of LCO and Surveillance Requirement applicability during steady state.
D. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The Commission has provided Standards for determining whether a significant hazard exists as stated in 10 CFR 50.92. 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 'ncrease in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or a different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety.
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A discussion of the above standards as they relate to the amendment request follows:
Standard 1 Involve a significant increase in the probability or consequence of an accident previously evaluated.
The proposed amendments provide .further clarification of the Technical Specifications and represent an additio'nal operating limitation. Incorporating the noted clarification will'not change the bases or assumptions contained in the safety analysis for this system. The most limiting low-temperature overpressure protection (LTOP) transients, the starting of an idle reactor coolant pump (RCP) and the inadvertent actuation of two high pressure safety injection (HPSI) pumps into a solid RCS, are not affected by the proposed clarification. Therefore, the proposed amendments do not involve a significant increase in the probability or consequences of an accident previously evaluated.
Standard 2 Create the possibility of a new or different kind of accident from any accident previously evaluated.
Clarifying the applicability of the LCO's and surveillance for steady state periods achieved and maintained during either a heatup or cooldown evolution does not modify the-design or operation of plant equipment. No new or different failure modes will be introduced by incorporating this clarification into the LCO and surveillance requirement. Therefore, the proposed amendments will 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 clarification will enhance LCO 3.4.8.3 and Surveillance Requirement 4.4.8.3.1 for heatup and cooldown evolutions by ensuring operators are aware of this applicability during periods of steady state conditions. This clarification does not involve a change to safety limits, setpoints, or design margins. As such, the proposed amendments will not involve a significant reduction in a margin of safety at PVNGS.
. E. SAFETY ANALYSIS FOR THE TECHNICAL SPECIFICATION AMENDMENT RECEUEST The Bases section 3/4.4.8 states that "Either one of the two SCS suction relief valves provides relieving capability to protect the RCS from overpressurization when the transient is limited to either (1) the start of an idle RCP with the secondary water temperature of the steam generator less than or equal to 100'F 2 of 3
above the RCS cold leg temperatures or (2) the inadvertent safety injection actuation with two HPSI pumps injecting into'a water solid RCS with full charging capacity and with the letdown isolated. These events are the most limiting energy and mass addition transients, respectively, when the RCS is at low temperatures."
As such, these transients are Independent of heatup and cooldown evolutions (i.e.,
these transients are possible during any potential steady state period in the course of a heatup or cooldown). While the current PVNGS Technical Specifications do not identify steady state as applicable to the LCO and surveillance requirements, APS has determined that it is prudent to incorporate clarifications for further operator guidance during heatup and cooldown evolutions. The proposed ciarifications involve no modifications to plant design nor changes to system operating parameters.
The discussion presented above, therefore, demonstrates an adequate level of safety'to support the requested Technical Specification amendments.
F. ENVIRONMENTALIMPACT CONSIDERATION DETERMINATION APS has determined that-the proposed amendments involve no change in the amount or type of effluent that may be released offsite, and that there is no increase in individual or cumulative 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.
G. MARKED-UP TECHNICAL SPECIFICATION CHANGE PAGES See attached pages 3/4 4-32, 3/4, 4-33, and B 3/4 4-1 for Units 1, 2, and 3, respectively. The changes marked-up on page B 3/4 4-1 are corrections that were overlooked in a prevjous amendment to section 3/4.4.1, approved by the NRC.
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