Text

Application for Amends to Licenses NPF-41,NPF-51 & NPF-74, Modifying TS 3/4.8.1 for Purposes of Implementing Recommended Changes from NUREG-1432,GL 94-01 & GL 96-05
	ML17312A625
Person / Time
Site:	Palo Verde
Issue date:	03/22/1996
From:	Stewart W; ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17312A626	List: ML17312A625;
References
	RTR-NUREG-1432 102-06362-WLS-A, 102-6362-WLS-A, GL-94-01, GL-94-1, GL-96-05, GL-96-5, NUDOCS 9604010343
	Download: ML17312A625 (27)
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CATEGORY j.

'EGULATO~- INFORMATION DISTRIBUTION'%STEM (RIDE)

ACCESSION NBR:9604010343 DOC.DATE: 96/03/22 NOTARIZED: YES DOCKET I 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 STEWART,W.L. 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 a NPF-74, modifying TS 3/4.8.1 for purposes of implementing j

A recommended changes from NUREG-1432,GL 94-01 & GL 96-05.

DISTRIBUTION CODE AOOID COPIES RECEIVED LTR I ENCL OR Submittal: General Distribution SIZE'+'ITLE:

NOTES:STANDARDIZED PLANT 05000528 8 Standardized plant. 05000529 Standardized plant. 05000530 0 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 LA 1 1 PD4-2 PD 1 1 THOMAS,C 1 1 INTERNAL: ACRS 6 6 1 1 NRR/DE/EMCB NRR/DSSA/SPLB NUDOCS-ABSTRACT 1

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1 NRR/DRCH/HICB NRR/DSSA/SRXB OGC/HDS2 l.,

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0 D EXTERNAL: NOAC 1 NRC PDR 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP,US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT ~ 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL NUMBER OF COPIES REQUIRED: LTTR 18 ENCL . 17

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Arizona Public Service Company 10 CFR 50.90 P.O. BOX 53999 ~ PHOENIX. ARIZONA 85072-3999 WILLIAML. STEWART 102-03632-WLS/AKK/KR EXECUTIVEVICEPREEIOENT NUCLEAR March 22, 1996 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001

References:

1) Letter 102-03293, dated March 24, 1995, "Proposed Amendment to Technical Specification Section 3/4.8.1," from W. L. Stewart, Executive Vice President - Nuclear, APS, to USNRC

2) Letter 102-03472, dated September 10, 1995, "ModiTications to the Proposed Amendment to Technical Specification Section 3/4.8.1," from W. L. Stewart, Executive Vice President - Nuclear, APS, to USNRC,

Dear Sirs:

Subject:

Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Modifications to the Proposed Amendment to Technical Specification Section 3/4.8.1 In Reference 1, Arizona Public Service Company (APS) proposed modifications to Technical Specification Section 3/4.8.1 for the purposes of implementing recommended changes from NUREG 1432, "Standard Technical Specifications for Combustion Engineering Plants," Generic Letter (GL) 94-01, "Removal of Accelerated Testing and Special Reporting Requirements for Emergency Diesel Generators," and Generic Letter (GL) 93-05, "Line-Item Technical Specification Improvements to Reduce Surveillance Requirements for Testing During Power Operation." In Reference 2, APS proposed modifications to the proposal. Through recent conversations with the staff, APS has determined that additional modifications to the previous submittals are required to facilitate review and approval of the proposed amendment.

9604010343 960322 PDR ADOCK 05000528 P PDR

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. U. S. Nuclear Regulato Commission ATTN: Document Control Desk Modifications to the Proposed Amendment to Technical Specification Section 3/4.8.1 Page 2 Provided in Enclosure 1 to this letter are the following sections which support the pl oposed modification to the Technical Specification (TS) amendment:

L A Description of the Modifications to the Proposed Amendment to Technical Specification 3/4.8.1 B Safety Analysis for the, Proposed Technical Specification Amendment Request C No Significant Hazards Consideration Determination D Environmental Impact Determination Enclosure 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.

Due to the complex nature of the proposed amendment, APS requests 120 days from issuance of the amendment for implementation.

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

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

K. E. Perkins B. E. Holian K. E. Johnston A. V. Godwin (ARRA) 1

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STATE OF ARIZONA )

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COUNTY OF MARICOPA )

I, W. L. Stewart, represent that I am Executive Vice President - Nuclear, 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.

W. L. Stewart Sworn To Before Me ThiaA~ Day Of~, 1996.

Notary Public My Commission Expires hAJ CommIsslon Expires Juno 12, 1997

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ENCLOSURE 1 Modification to the Proposed Amendment to Technical Specification Section 3/4.8.1

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A. Descri tion of Modifications to the Pro osed Amendment to Technical S ecification 3/4/8.1

1. Replaced proposed SR 4.8.1.1.2.b with:

At least once per 31 days by verifying the fuel oil transfer system operates to automatically transfer fuel oil from the storage tank to the day tank.

The frequency of this surveillance is being reduced from the frequency required by the ASME XI program to 31 days., This frequency was determined in accordance with NUREG-1432.

2. Replace Note 2 on proposed page 3/4 8-3 with:

Performance of 4.8.1.1.2.c satisfies this SR.

A fuel limited EDG start may be used for the SR as recommended by the manufacturer. When the fuel limited start procedure is not used, the time, voltage, and frequency tolerances of 4.8.1.1.2.c must be met.

All EDG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading as recommended by the manufacturer.

The previous wording of "slow start" is being changed to "fuel limited" to better describe the method utilized. "Slow starts," in accordance with manufacturer's recommendations, are permitted in NUREG-1432 and GL 84-15.

3. Revise proposed SR 4.8.1.1.2.c as follows:

Replace the word "maintains" with "subsequently achieves" and add "Following the EDG start, perform SR 4.8.1.1.2.a.3" as the last sentence. Revise Note 1 of proposed page 3/4 8-4 to add "All EDG starts may be preceded by an engine prelube period and, followed by a warmup period prior to loading as recommended by the manufacturer."

Changing the wording from "maintains" to "subsequently achieves" does not change the intent of the proposed SR. The addition of guidance to perform SR 4.8.1.1.2.a.3 is editorial only. The addition of the prelube permissive is consistent with NUREG-1432.

4. Revise proposed SR 4.8.1.1.2.d.5.c as follows:

After the word "starts" add "from normal standby condition."

This is consistent with NUREG-1432.

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5. Replace proposed ACTION 3.8.1.3.1.b with:

With either EDG fuel oil storage system with stored fuel oil viscosity not within limits, restore fuel oil to within limits within 30 days or declare the associated EDG inoperable.'he Current Technical Specification SR 4.8.1.1.2.b requires verification of water, sediment, and viscosity. NUREG-1432 requires a 30-day action if viscosity is not within specification.

6. Add new ACTION 3.8.1.3.1.c as follows:

With either EDG fuel oil storage system with stored fuel oil water and sediment not within limits, immediately declare the associated EDG inoperable.'he Current Technical Specification SR 4.8.1.1.2.b requires verification of water, sediment, and viscosity. NUREG-1432 requires that the EDG be declared immediately inoperable if water and sediment do not meet specifications.

7. Replace the first paragraph of proposed Bases SURVEILLANCE REQUIREMENTS on page B 3/4 8-9 with:

The surveillance requirements for demonstrating OPERABILITY of the emergency diesel generators (EDG) are based on the recommendations of Regulatory Guide (RG) 1.9, "Selection of Diesel Generator Set Capacity for Standby Power Supplies," Revision 3, unless otherwise noted in the Updated.

FSAR, Section 1.8.

The previous submittals committed to revising UFSAR Section 1.8 to include and clarify APS'ommitment to RG 1.9. This change is editorial only.

8. Replace the second paragraph of proposed Bases SURVEILLANCE REQUIREMENTS on page B 3/4 8-9 with:

All planned EDG starts may be preceded by an engine prelube period as recommended by the manufacturer in order to minimize wear and tear on the EDGs during testing. The EDG capabilities (starting and loading) are required to be met from a variety of initial conditions such as EDG in standby with the engine hot (SR 4.8.1.1.2.d.8), EDG in standby with the engine at normal-standby conditions (SR 4.8.1.1.2.c and SR 4.8.1.1.2.d.5.c), and EDG operating in a particular test mode (SR 4.8.1.1.2.d.10). Although it is expected that most EDG starts will be performed from normal standby conditions, EDG starts, except as specified in the SR, may be performed with the jacket water cooling and lube oil temperatures within the lower to upper limits of EDG OPERABILITY. Lube oil and jacket water cooling within manufacturer's

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recommended temperatures constitutes normal standby condtion. Rapid cooling of the EDG down to normal standby conditions should be minimized.

References to the SRs which require specific starting conditions were added. This is an editorial change only.

9. Replace the second paragraph of proposed Bases for SR 4.8.1.1.2.a.2 with:

In order to reduce stress and wear on diesel engines, the EDG may be tested using a fuel limited start as opposed to a fast start (s 10 seconds) during the 31 day SR. A fuel limited start is an EDG start in which the amount of fuel is temporarily restricted during the start to cause a more gradual acceleration to rated frequency and voltage than would occur during a start in Emergency Mode; The fast start is required to be performed during the 184-day SR.

Reducing fast starts would avoid premature wear of the engine and lead to greater EDG reliability and availability. The change is consistent with GL 84-15 recommendations for changes to the TS to reduce the number of fast starts and improve reliability. Performing the fast start test every 184 days will adequately demonstrate the EDG's present level of reliability and availability.

However, if a fuel limited start is not used, the time, voltage, and frequency tolerances of SR 4.8.1.1.2.c must be met.

Generic Letter 84-15 and NUREG 1432 contain provisions for "slow starts" to minimize wear on the EDG. The PVNGS method for implementing "slow starts" is to minimize the fuel supplied to the EDG. The terminology used (i.e., "fuel limited start") is, therefore, editorial in nature.

10. Add the following after the first paragraph of proposed Bases for SR 4.8.1.1.2.b:

An OPERABLE fuel oil transfer system is required to ensure that the 7 days of inventory of fuel in the fuel storage system is capable of being transferred to the fuel oil day tank for utilization by the EDGs.

This is an editorial change only. Application of the CTS considers the fuel oil transfer system as a support system for EDG operability.

11. Replace the second paragraph of proposed Bases for SR 4.8.1.1.2.b with:

The frequency is based upon the rate of full load fuel oil consumption, the level control system, and the fuel oil transfer pump capability which transfers approximately hourly during full load operation.

The proposed Bases is based upon guidance contained in NUREG 1432.

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12. Relocated and reworded the following sentence from SR 4.8.1.1.2.c to the second paragraph of proposed Bases SURVEILLANCE REQUIREMENTS on page B 3/4 8-9:

"If a plant normally has in operation prewarm systems designed to maintain lube oil and jacket water cooling at certain temperatures, this would constitute normal standby conditions."

Reworded as "Lube oil and jacket water cooling within manufacturer's recommended temperatures constitutes normal standby condtion."

The proposed Bases is based upon guidance contained in NUREG 1432.

13. Revise proposed Bases for SR 4.8.1.1.2.d as follows:

Delete "RG 1.108 and" from the first paragraph.