ML17311A381
| ML17311A381 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/31/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17311A382 | List: |
| References | |
| NUDOCS 9411080083 | |
| Download: ML17311A381 (14) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055$ 4001s 941'1080083 941031l~
PDR" ADOCK 05000528 PDR SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
85 TO FACILITY OPERATING.LICENSE NO.
NPF-41 AMENDMENT NO.
73 TO FACILITY OPERATING LICENSE NO. NPF-51 AND AMENDMENT NO.
57 TO FACILITY OPERATING LICENSE NO. NPF-74 ARIZONA PUBLIC SERVICE COMPANY ET 'AL.
PALO VERDE NUCLEAR GENERATING STATION UNIT NOS.
1 2
AND 3 DOCKET NOS.
STN 50-528 STN 50-529 AND STN 50-530
- 1. 0 INTRODUCTION By letter dated June 17,
- 1994, as supplemented by letter dated September 21, 1994, the Arizona Public Service Company (APS or the licensee) submitted a
request for changes to the Technical Specifications (TS) for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Appendix A to Facility Operating License Nos.
NPF-41, NPF-51, and NPF-74, respectively).
The Arizona Public Service Company submitted this request on behalf of itself, the Salt River Project Agricultural Improvement and Power District, Southern California Edison
- Company, El Paso Electric Company, Public Service Company of New
- Mexico, Los Angeles Department of Water and 'Power, and Southern California Public Power Authority.
The proposed amendment would remove five tables of component lists from the Palo Verde Technical Specifications (TS) in accordance with NRC Generic Letter (GL) '91-08, "Removal of Component Lists from Technical Specifications."
The affected tables are Table 3.3-9B, Table 3.3-9C, Table 3.6-1, Table 3.8-2, and Table 3.8-3.
The references to these tables would also be removed from the text of the TS in accordance with the sample TS change amendment provided, by the NRC in GL 91-08.
These five removed tables will be incorporated into,a new document, which will be administratively controlled according to the change controls provisions of the TS.
The supplemental letter provided certain revised TS pages for clarification purposes and did not change the original no significant hazards determination.
2.0'DISCUSSION Section 50.36 of Title 10 of the Code of Federal Regulations established the regulatory requirements related to the content of TS.
The rule requires that TS include items in specific categories, including safety limits," limiting conditions for operation, and surveillance requirements; however, the rule does not specify the particular requirements to be included in a plant's TS.
The NRC developed criteria, as described in the "Final Policy Statement, on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39132), to determine which of the design conditions and associated surveillances need to be located in the TS.
The Final.Policy Statement
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r adopted the subjective statement of the Atomic Safety and Licensing Appeal Board as the basis for the criteria.
The Appeal Board stated that:
...there is neither a statutory nor a regulatory requirement that every operational detail set,forth in an applicant's safety analysis report (or equivalent) be subject to a Technical Specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval.
- Rather, as best we can discern it, the contemplation. of both the Act and the regulations is the Technical Specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an event giving rise to an immediate threat to the public health and safety.
Briefly, the criteria in the Final Policy Statement related to TS content are (1) detection of abnormal degradation of the reactor coolant pressure
- boundary, (2) boundary conditions for design-basis accidents and transients, (3). primary success paths to prevent or mitigate design basis accidents and transients, and (4) functions determined to be important to risk or operating experience.
The Commission's final policy statement acknowledged that its implementation may result in.the relocation of existing TS requirements to licensee-controlled documents and,programs.
- 3. 0 EVALUATION In accordance with GL 91-08, and 10 CFR 50.90, the licensee proposed the following changes to the Palo Verde TS.
The licensee's proposed changes are discussed in the order the associated TS appears in the Palo Verde TS.
The staff's evaluation and conclusion follow each proposed change.
(1)
The licensee proposed changes to TS index pages to make editorial corrections associated with the proposed TS changes to reflect the deletion of tables which contain component lists or to reflect renumbering of pages due to deletion of large lists of component tables.
The staff concludes that the proposed changes are acceptable
.because they are administrative in nature only (reflecting the TS changes evaluated below).
(2)
The licensee proposed to makes changes to TS Definition 1.7, "Containment Integri.ty."
The licensee proposed to delete references to TS Table 3.6-1 and to clarify the revised TS.
The proposed changes to the TS Definition are administrative or editorial in nature (reflecting the TS changes evaluated below) or provide clarification to existing TS (no technical change to the current requirements)'.
Therefore, the staff finds the licensee's proposed changes acceptable.
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The licensee has proposed the removal of Table 3.3-B, "Remote Shutdown Disconnect Switches,"
and Table 3.3-C, "Remote Shutdown Control Circuits," from TS 3.3.3.5.
The licensee's proposal is consistent with the gui'dance of GL 91-08.
The content of these two TS tables is not changed, only their location.
Therefore, since the proposal does not technically change the current intent of the TS and is in accordance with the guidance provided in GL 91-08, the change is acceptable.
The licensee's original marked-up TS pages for this change inadvertently also showed Table 3.3-A as being deleted.
The licensee corrected this page by providing a new marked-up page by letter of September 21, 1994.
The new page corrected this administrative error and clarified.the wording of the limiting condition for operation (L'CO).
The staff proposed a minor editorial change to the wording of TS 3.3.3.5 as submitted by the licensee's supplemental letter dated September 21, 1994.
In a phone discussion on October 26,. 1994, the licensee requested that the staff's revised wording be used to further clarify operability requirements.
These changes are administrative in nature and did not change the original no significant hazards determination.
(4)
The licensee has proposed the removal of Table 3.6-1, "Containment Isolation Valves," which is referenced in TS 3/4.6.3.
With the removal of this table, the licensee has proposed'o include the following, statement of the LCO under TS 3/4.6.3:
Each containment isolation valve shall be OPERABLE.
In addition, the licensee proposed to revise the definition of containment integrity and to delete all references to Table 3.6-1 under the action requirements of TS 3.6.3, TS 4.6.3. 1, and TS 4.6. 1.1.
Technical Specification 4.6. 1. 1 and the definition of containment integrity refer to TS 3.6.3 for an exception regarding the use of administrative controls to maintain valves in the open position.
This exception, which was contained in the table (now removed from the TS),
is now a footnote to the LCO.
With the removal of the reference to Table 3.6-1, the licensee has proposed to state this exception as follows:
...except for valves that are open under administrative control as permitted by Specification 3.6.3.
The licensee has proposed to revise the surveillance requirement of TS 4.6.3. 1 to state "Each containment isolation valve...," rather than stating the requirements in relation to the valves specified in Table 3.6-1.
The licensee has proposed to revise the surveillance requirement of TS 4.6.3.2 to state "Each isolation valve used in containment isolation,
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containment
- spray, or containment purge...,"
instead of referring to the varieus sections of Table 3.6-1.
The licensee has proposed to revise the surveillance requirement of TS 4.6.3.3 to state "The isolation time of each power operated or automatic valve used in CIAS, CPIAS, or CSAS...," instead of referring to the various sections of Table 3.6-1.
The 1icensee has proposed to revise the surveillance requirement of TS 4.6.3.4 to state "The containment isolation check valves...," rather than stating the requirements in relation to the valves specified in Section D of Table 3.6-1.
The licensee proposed to revise the surveillance requirement of TS 4.6.3.5 to-state "The containment isolation valves used as safety/relief, normally open-ESF actuated
- closed, or required open during accident conditions...,",instead of referring to the various sections of Table 3.6-1.
The licensee has proposed to revise the surveillance requirement of TS 4 6.3.6 to state "The manual containment isolation valves (normally closed post accident closed valves)...,"
instead of referring to the various sections of Table 3.6-1.
The above changes are consistent with the guidance in GL 91-08 and are, therefore, acceptable.
Additionally, because.
Table 3.6-1 notes that the provisions of Specification 3.0.4 are not applicable to specific valves, the licensee proposed to add the following statement to the LCO for TS 3.6.4:
'Ne provisions. of Specification 3.0.4 do not apply.
The exception will now apply to all containment isolation valves rather than to specific valves.
The change is acceptable
The table of containment isolation valves identified specific manually operated locked or, sealed closed valves with a footnote stating that these valves may be opened intermittently under administrati.ve control.
These valves are locked or sealed closed consistent with the regulatory requirements for manually operated valves that are used.as containment isolation valves.
Because opening these valves would be contrary to the operability requirements of these valves, the following footnote to the LCO has been proposed:
locked or sealed closed valves may be opened on an intermittent basis under administrative control.
This change is consistent with the guidance in GL 91-08 and is, therefore, acceptable.
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(5)
The licensee has proposed the removal of Table 3.8-2, "Containment Penetration Conductor Overcurrent Protective Devices," which is referenced in TS 3/4.8.4.
With the removal of this table, the licensee has proposed to include the following statement for the LCO under TS 3.8.4.1:
Primary and backup containment penetration conductor overcurrent protective devices associated with each containment electri.cal penetration circuit shall be OPERABLE.
The scope of these protective devices excludes those circui.ts for which credible fault currents would not exceed the electrical penetration design rating.
In addition, the licensee has proposed to revise TS 4.8.4.1 to remove the reference to Table 3.8-2.
The surveillance requirement for TS 4.8.4.1 has been revised to state the following:
The above noted primary and backup containment penetration conductor overcurrent protective devices.(except fuses) shall be demonstrated OPERABLE:
The licensee has proposed changes
-to the above TS that are consistent with the guidance provided in GL 91-08 and're, therefore, acceptable.
(6)
The licensee has proposed the removal of Table 3.8-3, "Motor-Operated Valves Thermal Overload Protection And/Or Bypass Devices," which provides a list of valves with bypass devices that.is referenced in TS 3.8.4.2.
By letter dated September 21, 1994, the licensee provided the new marked-up page which corrects an administrative error and did not change the original no significant hazards determination.
The licensee has proposed to include the.following statement of the LCO under TS 3.8.4.2:
The thermal overload protection and bypass
- devices, integral with the motor starter, of each valve used in safety systems shall be OPERABLE.
The licensee's proposal is consistent with the guidance of GL 91-08 and does not technically, change the intent of the current TS and is, therefore, acceptable.
4.0
SUMMARY
The staff's review of the proposed changes determined.that the removal of these tables does not eliminate the requirements for the licensee to ensure that the system, structure, or. component
.is capable of performing its safety function..
Although these tables are removed from the TS and incorporated into the Palo Verde administratively controlled document, the licensee must continue to evaluate any plant modifications that affect any of these components in accordance with 10 CFR 50.59.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to
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either (1) an increase in the probabili.ty or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and:, licensee adherence to Updated Final Safety Analysis commitments and to take any remedial action that may be appropriate.
The staff's review concluded that 10 CFR 50.36 does not require these tables to be retained in TS.
Requirements related to operability, applicability, and surveillance requirements, including performance of testing to ensure operability, are" retained due to, the importance in mitigating the consequences of an accident.
However, the staff determined that the inclusion of these tables is an operational, detail related to the licensee's safety analyses, which are adequately controlled by the requirements of 10 CFR 50.59; Therefore, the continued processing of license amendments related to revisions of the affected these. tables, where. the revisions to those requirements do not involve an unreviewed safety question under 10 CFR 50.59, would afford no significant benefit with regard to protecting the public health and safety.
The staff has concluded, therefore, that removal of these tables is acceptable because (1) their inclusion in technical specifications is not specifically required by 10 CFR:50.36 or other regulations, (2) these five tables have been remove from the TS and'ncorporated into the Palo Verde administratively controlled document, are adequately controlled by 10 CFR 50.59, and their inclusion in the TS is not required to avert an immediate threat to the public health and safety, and (3) changes that are deemed to involve an unreviewed safety question will require prior NRC approval in accordance with 10 CFR 50.59(c).
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Arizona State official was notified of the proposed i'ssuance of the amendments.
The State official had no comments.
- 6. 0 ENVIRONMENTAL CONSIDERATION The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements.
The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a
proposed finding that the amendments involve no significant hazards considera-tion,'and there has been no public comment on such finding (59 FR 37061).
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no
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environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
- 7. 0 CONCLUSION The Commission has concluded, based on the considerations discussed
- above, that (I) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
T. Dunning L. Tran Date:
October 31, 1994
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