ML17311B313

Application for Amends to Licenses NPF-41,NPF-51 & NPF-74, Revising TS for Implementation of 10CFR50,App J,Option B for Determining Test Frequency for Containment Leakage Rate Testing

ML17311B313
Person / Time
Site:	Palo Verde
Issue date:	12/19/1995
From:	Overbeck G ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17311B314	List: ML17311B313
References
102-03567-GRO-A, 102-3567-GRO-A, NUDOCS 9512260249
Download: ML17311B313 (19)

Text

PRIORITY (ACCELERATED RIDS PROCESSIVG REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9512260249 DOC.DATE:

FACIL:STN-50-528 Palo Verde Nuclear Station, 95/12/19 NOTARIZED: YES DOCKET Unit 1, Arizona Publi 05000528 I

STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 P AUTH. NAME AUTHOR AFFILIATION OVERBECK,G.R. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amends to licenses NPF-41,NPF-51 & NPF-74, revising TS for implementation of 10CFR50,App J,Option B for determining test frequency for containment leakage rate 0 testing.

DISTRIBUTION CODE: A017D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: Append J Containment Leak Rate Testing I

NOTES:STANDARDIZED PLANT 05000528 Standardized plant. 05000529 Standardized plant. 05000530 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 LA 1 0 PD4-2 PD 1 1 HOLIAN, B 1 1 THOMAS,C 1 1 INTERNAL: ACRS 6 6 CENX~5R~ 1 1 NRR/DE/ECGB 1 1 NRR DSSA7SCSB 1 1 OGC/HDS2 1 1 RES/DE/SEB 1 1 D EXTERNAL: NOAC 1 1 NRC PDR 1 1 0

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N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE iVASTE! CONTACI'THE DOCUMENT CONTROL DESK, ROOM PI-37 (EXT. 504-2083 ) TO ELDIINATE YOUR iAME PRO%I DISTRIBUTION LISTS I'OR DOCUMENTS YOU DON"I'LED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 17 ENCL 16

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10 CFR 50.90 Arizona Public Service Company PALO VERDE NUCLEAR GENERATING STATION P.o. BOX 52034 ~ PHOENIX, ARIZONA 85072-2034 GREGG R.OVERBECK 102-03567-GRO/AKK/DR L VICE PRESIDENT NUCLEAR SUPPORT December 19, 1995 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Proposed Amendment for the Implementation of 10 CFR Part 50, Appendix J, Option B P

Pursuant to 10 CFR 50.90, Arizona Public Service Company (APS) submits herewith a request to amend Facility Operating Licenses NPFA1, NPF-51, and NPF-74 for PVNGS Units 1, 2, and 3 to allow the implementation of the recently approved Option B to 10 CFR Part 50, Appendix J (Option B). This new rule allows for a performance-based option for determining the test frequency for containment leakage rate testing. The proposed amendment would modify Technical Specifications 1.7, 3/4.6.1.1, 3/4.6.1.2, 3/4.6.1.3, 3/4.6.3, the bases of Technical Specification 3/4.6.1.2, and would add new Technical Specification 6.16.

APS has committed to implementation of the Improved Standard Technical Specifications which will include Technical Specifications written to utilize Option B. However, implementation of the Improved Standard Technical Specifications is currently scheduled for 1997. Until they are implemented, APS will require a revision to the current Technical Specifications in order to utilize Option B of Appendix J to 10 CFR Part 50.

This request meets the definition of a cost beneficial licensing action. Approval of this request is expected to save PVNGS approximately $ 41 million (approximately $ 6.5 million excluding replacement power costs) over the remaining life of PVNGS Units 1, 2, and 3.

Section 2.D of the current Operating Licenses for PVNGS Units 1, 2, and 3 authorizes an exemption to 10 CFR Part 50, Appendix J, Option A,Section III.D.2(b)(ii). This exemption was reviewed in Section 6.2.6, "Containment Leakage Testing," of the Safety Evaluation Report, Supplement 7. PVNGS will incorporate the provision allowed by the exemption into the Containment Leakage Rate Testing Program.

Provided in Enclosure 1 to this letter are the following sections which support the proposed Technical Specification (TS) amendment:

A. Description of the Proposed Technical Specification Amendment Request B. Purpose of the Technical Specification C. Need for the Technical Specification Amendment D. Safety Analysis for the Proposed Technical Specification Amendment Request E. No Significant Hazards Consideration Determination Environmental Impact Determination G. Revised Technical Specification Pages

~GQIjyg 95i2260249 'II'512i9 PDR ADGCK 05000528 P PDR

i U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Proposed Amendment for the Implementation of 10 CFR 50, Appendix J, Option B t

Page 2 provides the marked-up TS pages to support the proposed amendment.

By copy of this letter and its enclosures, the Arizona Radiation Regulatory Agency is being notified of this TS amendment request pursuant to 10 CFR 50.91(b)(1).

In accordance with Technical Specification Section 6.5, the Plant Review Board and the Offsite Safety Review Committee have reviewed and concurred with this request.

APS proposes to implement Option B to Appendix J of 10 CFR Part 50 during the next refueling outage of Unit 2 which will begin on March 16, 1996. Therefore, APS requests approvai of this submittal prior to March 1, 1996. APS requests'15 days for implementation. The Containment Leakage Rate Testing Program, as required by 10 CFR Part 50, Appendix J, Option B,Section V.B.4, and as identified in Section 6.16 of the proposed Technical Specifications, will be effective prior to implementation of the amendments.

Should you have any questions, please contact Scott Bauer (602) 393-5978.

Sincerely, GRO/AKK/DR L/rv Enclosures cc: L. J. Callan (all w/enclosures)

K. E. Perkins B. E. Holian K. E. Johnston A. V. Godwin (ARRA)

I STATE OF ARIZONA )

) ss.

COUNTY OF MARICOPA )

I, G. R. Overbeck, represent that I am Vice President Nuclear Support, Arizona Public Service Company (APS), that the foregoing document has been signed by me on behalf of APS with full authority to do so, and that to the best of my knowledge and belief, the statements made therein are true and correct.

G. R. Overbeck Sworn To Before Me This I 1 Day Of~ssenr04; 1995.

Notary Public My Commission Expires tb,ty COmmL9StonEXPIreS JUM12,1997

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ENCLOSURE 1 Proposed Amendment for the Implementation of 10 CFR 60, Appendix J, Option B

A. i 'of hePro o The proposed Technical Specification change involves revisions to multiple specifications in order to implement the new Option B to Appendix J of 10 CFR Part 50.

The new rule allows for a performance-based approach to containment leakage rate testing. Therefore, prescriptive language in the current Technical Specifications needs to be removed in favor of performance based terminology. The following changes are ploposed:

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'd'd I I th f "the Containment Leakage Rate Testing Program."

t gp if ti 3.6.3.2 d pl it ith

~ 1.1.: delete the specific details of the Type B testing and replace

~fd it with a reference to "the Containment Leakage Rate Testing Program."

d lt *pliit and replace it with a reference to the acceptance Containment Leakage Rate Testing Program."

ti tl kg t pt criteria provided in "the

'o 1 2 Ac i: replace the Action with "With containment leakage rates not within limits, restore containment leakage rates to within limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and at least COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."

4. I:dlt lit t to "the Containment Leakage Rate Testing Program."

qi t d pl th The Ih I pr'ovisions of Specification 4.0.2 remain "not applicable" to the testing.

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n 1: I delete all after the word "rate" and add "in accordance with the Containment Leakage Rate Testing Program."

in .6 replace airlock requirements and acceptance criteria with a reference to the Containment Leakage Rate Testing Program and delete the footnotes. Both criteria will be incorporated in the Containment Leakage Rate Testing Program.

c' ion 46.1 3 c: renumber as4.6.1.3.b.

3: delete all after "OPERABLE" and add "in accordance with the Containment Leakage Rate Testing Program." .

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B tt th d" q I t" dd" fdpq ~ ."

~ c'o 1: adds a new specification defining the "Containment Leakage Rate Testing -Program."

P 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants,"

Criterion 16, "Containment Design" requires that "[r]eactor containment and associated systems shall be provided to establish an essentially leak-tight barrier against the uncontrolled release of radioactivity to the environment and to assure that the containment design conditions important to safety are not exceeded for as long as postulated accident conditions require." Further, 10 CFR Part 50.54(o) requires that

"[p]rimary reactor containments for water cooled power reactors shall be subjected to the requirements set forth in appendix J to this part." The purpose of the testing required by 10 CFR Part 50, Appendix J, as described in its Introduction, is "to assure that (a) leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of containment, and systems and components penetrating primary containment." Technical Specifications 3/4.6.1.1, 3/4.6.1.2, 3/4.6.1.3, and 3/4.6.3 provide criteria for the required leakage rates necessary to comply with Criterion 16.

The Nuclear Regulatory Commission has recently amended.,10 CFR Part 50, Appendix J to provide a performance-based option for leakage rate testing of containment. This new Option B, may be adopted by licensees on a voluntary basis as a substitute for the requirements of 10 CFR Part 50, Appendix J, Option A. In order to implement the provisions of Option B, the Technical Specifications must be revised as required by 10 CFR Part 50, Appendix J, Option B,Section V.B.2.

D. inA d e The proposed TS change involves the replacement of the current, prescriptive method of leakage rate testing with a performance based approach for establishing the testing intervals recently. allowed by the new Option B to Appendix J of 10 CFR Part 50. This new option will significantly reduce the amount of personnel exposure through the reduction of 10 CFR Part 50, Appendix J, Type A, B, and C testing with only a marginal, potential increase in dose to the public. The longe'r testing intervals, as documented and approved by the NRC in NUREG-1493, result in a slight increase in the consequences of a malfunction of containment integrity.

No changes in the way that plant structures, systems, or components will be operated are being proposed, therefore, the proposed change will not affect the probability of previously evaluated accidents or malfunctions of equipment important to safety. No new failure modes or accident initiators will be introduced by the proposed change therefore, the possibility of accidents or malfunctions of a different type are not created.

I The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR Part 50.92. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility, in accordance with a proposed amendment, would not:

involve a significant increase in the probability or consequences of an, accident previously evaluated;

2. create the possibility of a new or different kind of accident from any previously evaluated; or

3. involve a significant reduction in a margin of safety.

A discussion of these standards, as they relate to this amendment request, follows.

Qfggi~~: Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed Technical Specification (TS) changes will result in generally increased intervals between containment leakage rate tests determined through a performance based approach. The interval between such tests are not related in any way to conditions which cause accidents. Plant structures, systems, and components will not be operated in a different manner as a result of the proposed TS change, therefore, the proposed changes will not increase the probability of an accident previously evaluated.

Containment leakage may result from accidents which are evaluated in the Updated Final Safety Analysis Report. The proposed TS changes may result in a small, but acceptable, increase in post-accident containment leakage. This increase is calculated as a statistical expectation using the probability that leakage through a penetration will exceed the administrative limit, and through the increased time needed to detect such excess leakage. NUREG-1493, which is the technical basis for 10 CFR Part 50, Appendix J, Option B, contains a detailed evaluation of the expected leakage and its consequences.

The increased risk due to the lengthening of the intervals between Type A, B, and C leakage rate tests is also evaluated in NUREG-1493. Using a statistical approach, NUREG-1493 determined that the increase in expected dose to the public, resulting from extending the testing interval, is extremely small. NUREG-1493 concluded that the small increase is justifiable due to the benefits which accrue from interval extension.

I The primary benefit is the reduction in occupational exposure. The reduction, on a per person basis, is orders of magnitude greater than the marginal, potential increase in dose to the public. The reduction in occupational exposure is a real reduction, while the small increase in dose to the public is statistically derived using conservative assumptions. Therefore, the proposed change does not significantly increase the consequences of an accident previously evaluated.

Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

C The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated. The proposed change only incorporates the ~

performance based approach authorized in the new Option B to Appendix J of 10 CFR Pa'rt 50. The interval extensions allowed, through this approach, do not have the potential for creating the possibility of new or different kinds of accidents from those p'reviously evaluated. Plant structures, systems, and components will not be operated in a different manner as a result of the TS change and, therefore, will not introduce any new or different failure modes or initiators.

Qg~~: Does the proposed change involve a significant reduction in the margin of safety?

The proposed Technical Specificatio does not alter the allowable containment leakage rate. The proposed change replaces the current, prescriptive testing requirements with a new performance based approach for establishing the testing intervals therefore, the proposed change does not involve a significant reduction in the margin of safety.

APS has determined, based on the research documented in NUREG-1493, that the proposed amendment involves no significant 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 amendment, does not involve an unreviewed environmental safety question.

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