ML17312A630
| ML17312A630 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/26/1996 |
| From: | Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML17312A631 | List: |
| References | |
| RTR-NUREG-1432 102-03635-WLS-A, 102-3635-WLS-A, NUDOCS 9604020030 | |
| Download: ML17312A630 (17) | |
Text
CATEGORY 1 REGULATOR INFORMATION DISTRIBUTION . STEM (RIDS)
ACCESSION,NBR:9604020030 DOC.DATE: 96/03/26 NOTARIZED: YES DOCKET FACIL:S.N-50-5'29.,Palo-Verde Nuclear Station, Unit 2, Arizona Publi 05000529 AUTH. NAME AUTHOR AFFILIATION STEWART,W.L. Arizona Public Service Co. (formerly Arizona Nucle'ar Power RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk).
SUBJECT:
Appjication for amend to license NPF-5l,revising TS 3/4.9.6 to relocate refueling machine overload cut off limit from TS 3/4:9.6 to plant UFSAR per criteria in 10CFR50.36 & Rev 1 of NUREG-1432, "STS for Combustion Engineering Plants."
DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR l ENCL I SIZE: g TITLE: OR Submittal: General Distribution NOTES:Standardized plant. 05000529 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 E CENTER 0 1 1 NRR/DE/EMCB 1 1 RCH/ 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1
.1'OTE TO ALL NRIDSN RECIPIENTS PLEASE HELP,US TO REDUCE WASTEl CONTACT THB DOCUMENT CONTROL DESK, ROOM OWFN SD-S(EXT. 415-2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEEDl TOTAL SUMBER OF COPIES REQUIRED: LTTR 18 ENCL 17
T 10 CFR 50.90 Arizona Public Service 10 CFR 50.91 PALO VERDE NUCLEAR GENERATING STATION P,O. BOX 52034 PHOENIX, ARIZONA 85072-2034 102-03635-WLS/AKK/TNW WILLIAML, STEWART March 26, 1996 EXECUTIVE VICE PRESIDENT NUCLEAR U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station P1-37 Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 2 Docket No. STN 50-529 Proposed Amendment to Technical Specification (TS)
Section 3/4.9.6, "Refueling Machine,"
Under Emergency Circumstances Pursuant to 10 CFR 50.90 and 10 CFR 50.91(a)(5), Arizona Public Service Company (APS) submits herewith a request to amend Facility Operating License NPF-51 for Unit 2 of the PVNGS under emergency circumstances. The proposed amendment would revise TS 3/4.9.6 to relocate the refueling machine overload cut off limit from TS 3/4.9.6 to the PVNGS Updated Final Safety Analysis Report (UFSAR) in accordance with the criteria in 10 CFR 50.36, "Technical Specifications," and Revision 1 of NUREG-1432, "Standard Technical Specifications for Combustion Engineering Plants." The refueling machine overload cut off limit will be relocated to the PVNGS UFSAR upon approval of the amendment.
Approval to relocate the refueling machine overload cut off limit would allow APS to increase the cut off limit following appropriate engineering analysis for the purposes of withdrawing the stuck fuel assemblies. The refueling machine is currently unable to withdraw the fuel assemblies from core locations A-06 and A-07.
Provided in the enclosure to this letter are the following sections which support the proposed TS amendment:
A. Explanation of the Emergency Circumstances B. Description of the Proposed TS Amendment C. Purpose of the TS D Safety Analysis of the Proposed TS Amendment E No Significant Hazards Consideration Determination Environmental Impact Determination G. Marked-up TS Page 1
9b04020030 qb032b PDR'DQCK 0500052'II PDR
P U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Proposed Technical Specification Amendment Page 2 It is requested that this TS change be issued on March 26, 1996, in order to prevent further delay of Unit 2 core offload. Should issuance of this change not be possible by March 26, 1996, it is requested that consideration be given to issuance of a Notice of Enforcement Discretion in accordance with Section VII.C of Appendix C, General Statement of Policy and Procedure for NRC Enforcement Actions, to 10 CFR Part 2, Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders.
In accordance with TS Section 6.5, the Plant Review Board and Offsite Safety Review Committee have reviewed and concurred with this proposed amendment. By copy of this letter this request is being forwarded to the Arizona Radiation Regulatory Agency (ARRA) pursuant to 10 CFR 50.91(b)(1).
t Should you have any questions, please contact Scott A. Bauer at (602) 393-5978.
Sincerely, WLS/SAB/TNW/rv Enclosure cc: L. J. Callan (all with enclosure)
K. E. Perkins C. R. Thomas K. E. Johnston A. V. Godwin (ARRA)
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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 Thi~ Day Of~ 1996, Notary Public My Commission Expires Mmt CommlsstonExpirm Jun812, 1997
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ENCLOSURE PROPOSED AMENDMENT TO TECHNICAL.SPECIFICATION SECTION 3/4.9.6 "REFUELING MA'CHINE" UNDER EMERGENCY CIRCUMSTANCES
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A. EXPLANATION OF THE EMERGENCY CIRCUMSTANCES During the Palo Verde Nuclear Generating Station (PVNGS) current Unit 2 sixth refueling outage, refueling personnel were not able to withdraw fuel assemblies in core locations A-06 and A-07 during the course of normal refueling activities. The fuel assemblies were discovered to be stuck on March 22, 1996, at approximately 1430 MST, and March 24, 1996, at approximately 1500 MST, respectively. Subsequently, APS and Combustion Engineering personnel have been evaluating the condition in order to determine the proper course of action to free the stuck assemblies. These activities have included video taping of the assemblies to identify potential causes for the assemblies being stuck. The emergency circumstances exist because the fuel assemblies cannot be withdrawn using the current limits of LCO 3.9.6, thereby preventing completion of fuel movement and the resumption of power operations. The suspension of fuel movement would leave the core partially unloaded.
The emergency circumstances could not be avoided because the stuck fuel assembly condition in Unit 2 was unexpected.
The limiting condition for operation (LCO) of Technical Specification (TS) 3/4.9.6 currently specifies that the refueling machine be OPERABLE with an overload cut off limit of less than or equal to 1600 pounds. This request, under emergency circumstances, provides the justification to allow PVNGS Unit 2 to continue fuel movement by allowing PVNGS to relocate the refueling machine overload cut off limit from TS 3/4.9.6 to the PVNGS Updated Final Safety Analysis Report (UFSAR).
Subsequent to relocation, increasing the overload cut off limit for the purposes of withdrawing the stuck fuel assemblies will be evaluated in accordance with the provisions of 10 CFR 50.59.
1 B. DESCRIPTION OF THE PROPOSED TS AMENDMENT RE VEST Arizona Public Service Company (APS) proposes to relocate the overload cut off limit from TS 3/4.9.6 to the PVNGS UFSAR. This TS change will allow.APS to evaluate the potential to increase the overload cut off limit in accordance with the provisions of 10 CFR 50.59.
C. PURPOSE OF THE TS W 1
'I TS 3/4.9.6 identifies the overload cut off limit which protects the core internals (i.e., fuel assemblies, reactor vessel internals) and pressure vessel from possible damage in the Page 1 of 4 I
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event a fuel assembly becomes mechanically bound as it is withdrawn from the reactor vessel.
D. SAFETY ANALYSIS OF THE PROPOSED TS AMENDMENT The proposed TS amendment would relocate the refueling machine overload cut off limit from TS 3/4.9.6 to the PVNGS UFSAR. The refueling machine overload cut off limit ensures that the core internals and pressure vessel are protected from an excessive lifting force in the event they are inadvertently engaged during lifting operations.
Relocating the overload cut off limit is administrative in nature since it'does not impact the scope or intent of the TS for the refueling machine. Plant procedures contain acceptance criteria that reflect the overload cut off limit for the refueling machine.
I In August of 1995, 10 CFR 50.36, "Technical Specifications," was amended to include the criteria for determining if LCO's need to be included in the TS. The criteria is as follows:
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor, coolant pressure boundary.
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ii A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity, of a fission product barrier.
A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate'a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
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F A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
The refueling machine LCO (TS 3.9.6) does not satisfy any of the four criteria, and is not contained within Revision 1 of NUREG-1432, "Standard Technical Specifications for Combustion Engineering Plants." Changes to the overload cut off limit will be evaluated and controlled in accordance with the provisions of 10 CFR 50.59. Therefore, the relocation of the refueling machine overload cut off limit from TS 3/4.9.6 to the PVNGS UFSAR is acceptable since there is reasonable assurance that the health and safety of the public will not be adversely affected by the proposed change, and sufficient regulatory controls exist under 10 CFR 50.59.
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The cut off limit of 1600 pounds will be relocated to the UFSAR. Any changes to this limit will be based on engineering analysis in conjunction with the fuel manufacturer and will be subject to a safety evaluation in accordance with 10 CFR 50.59 E. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The Commission has provided standards for determining whether a significant hazards consideration 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 increase in the probability or consequences of an accident previously evaluated; or (2)
Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety. A discussion of standards as they relate to this amendment request follows: 'hese Standard 1 Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?,
The proposed change relocates the refueling machine overload cut off limit from TS 3/4.9.6 to the PVNGS UFSAR. The change is administrative in nature and does not involve any modifications to plant equipment or affect plant operation. Any changes to the limit will be based on engineering analyses in conjunction with the fuel manufacturer.
APS is currently analyzed for a design basis fuel handling accident inside containment which is described as the dropping of a single fuel assembly during fuel handling.
Engineering analyses performed to justify any increase in the limit will ensure that the revised limit will be within the structural capacity of the fuel assembly. Therefore, the proposed change does not involve a signiTicant 'increase in the probability or consequences of an accident previously evaluated.
Standard 2 -Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed change relocates the refueling machine overload cut off limit from TS 3/4.9.6 to the PVNGS UFSAR. The proposed change to the overload cut off does not introduce any new modes of plant operation or new accident precursors, involve any physical alterations to plant configurations, or make any changes to system setpoints which could initiate a new or different kind of accident. The proposed change does not affect the design or performance characteristics of the refueling machine or the fuel assembly. No new failure modes have been defined nor new system interactions introduced for any plant system or component, nor has any new limiting failure been identified as a result of the proposed change. The configuration and use of the refueling Page 3 of 4
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l machine will be maintained as described in CESSAR 9.1.4.2.2.1 and 9.1.4.3.4.b. This change involves the relocation of the refueling machine overload cut off limitation of TS LCO 3.9.6 to the UFSAR. Any changes to the-overload cut off limit would be analyzed to demonstrate that the load is well within the acceptable axial fuel assembly load described in the Updated FSAR 4.2.3.1.5.B. The consequences of a fuel handling accident as previously analyzed, bound any possible malfunction during fuel movement.
The only possible equipment that could malfunction are the fuel assembly and the refueling machine. The malfunction of this equipment has been previously analyzed.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Standard 3 Does the proposed change. involve a significant reduction in a margin of safety.
The proposed change relocates the refueling machine overload cut off limit from TS 3/4.9.6 to the PVNGS UFSAR. The change is administrative in nature, does not change or alter regulatory requirements, and does not affect the safety analysis. Plant procedures contain acceptance criteria that reflect the refueling machine overload cut off limit. Therefore, the proposed change does not involve a significant reduction in a margin of safety.
F. ENVIRONMENTALIMPACT DETERMINATION The proposed amendment relocates the refueling machine overload cut off limit from TS 3/4.9.6 to the PVNGS UFSAR. APS has determined that the proposed amendment involves no changes 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 Unit 2, in accordance with the proposed amendment, does not involve an unreviewed environmental safety question.
G. MARKED-UP TECHNICAL SPECIFICATION PAGES PVNGS Unit 2 page: 3/4 9-6 Page 4 of 4