ML17311A758
| ML17311A758 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/03/1995 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| 95-4-0002, 95-4-2, NUDOCS 9504110087 | |
| Download: ML17311A758 (7) | |
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t UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON,TEXAS 76011 6064 APR q.os Arizona Public Service Company ATTN:
William LE Stewart Executive Vice President, Nuclear P. 0.
Box 53999
- Phoenix, Arizona 85072-3999
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION FOR ARIZONA PUBLIC SERVICE COMPANY (APS)
REGARDING PALO VERDE NUCLEAR GENERATING STATION UNIT 1
(HOED TRACKING 95-4-0002)
By letter dated March 30,
- 1995, APS requested that the NRC exercise enforcement discretion not to enforce compliance with the actions required in Technical Specification (TS) 3,8.4.
1 related to containment penetration overcurrent protection devices.
That letter documented information previously discussed with the NRC in a telephone conversation on March 30,
- 1995, at 10 a.m.
(MST).
You requested that a
NOED be issued and be effective until April 4,
- 1995, at 2 p.m.
(MST), at which time Unit 1 will be in cold shutdown with TS 3.4.8.
1 no longer applicable.
APS stated that the need for this NOED occurred when, during performance of a design bases evaluation of electrical penetrations, it was discovered that certain penetrations did not have the required backup overcurrent protection.
The need for an NOED arises now based on the desire not to deenergize these 34 circuits while in Mode 4 during the shut down of Unit 1 for its refueling outage scheduled to begin on April 1.
The plan for Unit 1 to be in Mode 4 to perform steam generator cleaning at elevated temperatures necessitated an extension of the time (42 hours4.861111e-4 days <br />0.0117 hours <br />6.944444e-5 weeks <br />1.5981e-5 months <br />) for the plant to be in cold shutdown.
Based on our telephone discussions, we understand that these 34 circuits have at least one.installed overcurrent protective device.
We understand that you have committed to take steps to minimize work activities which could cause a
fault in these circuits during the time of the HOED.
In addition, you state that a shift briefing will be conducted of the potential affects of an overcurrent event on the circuits and that a
PRA evaluation of the situation of extending the time to achieve cold shutdown has concluded that this situation is of low risk.
The staff has evaluated your proposal and accepts the arguments provided in support of the request.
The benefits of performing steam generator chemical cleaning are greater than the risk associated with potential electrical faults that could result in penetration damage while in Mode 4.
Alternative approaches to modify the protection circuitry at power to support the extended shutdown or require an undesirable thermal transient to comply with the TS before steam generator chemical cleaning were not considered viable risk options.
9504ii0087 950403 PDR ADQCK 05000528 P
(,
Arizona Public Service Company On the basis of the staff's evaluation of your request, the conduct of shift briefings, and the actions to minimize work activities which could cause an electrical fault, the staff has concluded that the exercise of enforcement discretion is warranted because we are clearly satisfied that this action involves minimal or no safety impact and has no adverse impact on public health and safety.
Therefore, it is our intention to exercise discretion not to enforce compliance with TS 3.8.4. 1 until April 4,
- 1995, 2 p.m.
(MST).
This letter documents our telephone conversation on March 31,
- 1995, 12 noon (MST),
when we orally issued this notice of enforcement discretion.
- However, as stated in Appendix C to 10 CFR Part 2, enforcement action will normally be taken, to the extent that violations were involved, for the root cause that led to the noncompliance for which this discretion was used.
Sincerely, Docket:
50-528 License:
NPF-41 L.
. Callan Regional Administrator I
CC:
Arizona Corporation Commission ATTN:
Mr. Steve Olea 1200 W. Washington Street
- Phoenix, Arizona 85007 Southern California Edison Company ATTN:
T.
E. Oubre, Esq.
P.O.
Box 800
- Rosemead, California 91770 Arizona Radiation Regulatory Agency ATTN:
Aubrey V. Godwin, Director 4814 South 40 Street Phoenix,'rizona 85040 Maricopa County Board of Supervisors ATTN:
Chairman 111 South Third Avenue
- Phoenix, Arizona 85003
Arizona Public Service Company Palo Verde Services ATTN:
Curtis Hoskins, Executive Vice President and Chief Operating Officer 2025 N. 3rd Street, Suite 220
- Phoenix, Arizona 85004 Akin, Gump, Strauss, Hauer and Feld El Paso Electric Company ATTN:
Roy P.
Lessey, Jr.,
Esq.
1333 New Hampshire Avenue, Suite 400 Washington, D.C.
20036 Arizona Public Service Company ATTN:
Angela K. Krainik, Manager Nuclear Licensing P.O.
Box 52034
- Phoenix, Arizona 85072-2034
Arizona Public Service Company bcc to DMB (IE51) bcc distrib.
by RIV:
L. J. Callan DRSS-F IPB Branch Chief (DRP/F, WCFO)
Senior Project Inspector (DRP/F, WCFO)
Leah Tremper (OC/LFDCB, MS:
TWFN 9E10)
R.
Zimmerman, NRR A. Thadani, NRR J.
Lieberman, OE PDR LPDR Technical Assistant, DRP I/II, NRR Resident Inspector MIS System RIV File Branch Chief (DRP/TSS)
B. Henderson (PAO, WCFO)
L, Thomas (DRP)
DOCUMENT NAME:
To receive copy of document, indicate in box: "C" ~ Copy without enclosures "E" ~ Copy with enclos es "N" ~ No copy C:DRP/F DD:DRP D:DRP PD:NRR
~
DRA JWong 03/31/95 RA LJCal an 04/
/95 JEDyer 04/3 /95 Beach 04/3'95 WHBatemangg JMMon ornery 04/3 /95
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04/
/9
Arizona Public Service Company r bcc.to DMB (IE51) i bcc distrib.
by RIV:
L. J. Callan DRSS-F IPB Branch Chief (DRP/F, WCFO)
Senior Project Inspector (DRP/F, WCFO)
Leah Tremper (OC/LFDCB, MS:
TWFN 9E10)
R.
Zimmerman, NRR A. Thadani, NRR J.
- Roe, NRR E.
- Adensam, NRR J.
Lieberman, OE PDR LPDR Technical Assistant, DRP I/II, NRR Resident Inspector MIS System RIV File Branch Chief (DRP/TSS)
BE Henderson (PAO, WCFO)
L. Thomas (DRP)
DOCUMENT NAME:
To receive copy of document, indicate in box: "C" ~ Copy without enclosures "E" ~ Copy with enclos es "N" No copy C:DRP/F JWong 03/31/95 RA LJCal an 04/
/95 DD:DRP JEDyer 04/3 /95 D:DRP Beach 04/3'95 PD'NRR
~
DRA WHBatemangg JMMon ornery 04/3 /95
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04/
/9 460057