ML17312B393

Forwards Request for Addl Info Re Section 5.0 of Proposed License Amend to Implement Improved Standard TS

ML17312B393
Person / Time
Site:	Palo Verde
Issue date:	04/25/1997
From:	Thomas C NRC (Affiliation Not Assigned)
To:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
Shared Package
ML17312B394	List: ML17312B393 ML20137R380
References
TAC-M96672, TAC-M96673, TAC-M96674, NUDOCS 9704300230
Download: ML17312B393 (25)

Text

April '25, 1997 Hr. James H. Levine Senior Vice President, Nuclear Arizona Public Service Company Post Office Box 53999

.Phoenix, Arizona 85072-3999

SUBJECT:

RE(VEST, FOR ADDITIONAL INFORMATION SECTION 5".0 OF THE PROPOSED LICENSE AMENDMENT TO IMPLEMENT IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR PALO VERDE NUCLEAR GENERATING STATION (PVNGS)

UNIT NO.

1 (TAC NO ~ H96672),

UNIT NO.

2 (TAC NO. 'M96673),

AND UNIT NO.

3 (TAC NO. H96674)"

Dear Hr. Levine:

1i By letter dated October 4,

1996, and supplemented by letter dated March 16, 1997, Arizona Public Service Company submitted a request to convert the current Technical Specifications (TSs) for PVNGS Units 1, 2, and 3, to make them consistent with NUREG-1432, Revision 1, "Standard Technical Specifications Combustion Engineering Plants,"

dated April 1995.

In order for the staff to complete its review, the additional information listed in the enclosed tables is requested.

The enclosure also reflects the staff's comments on Section 5.0.

To assist the staff in meeting its review schedule, it is requested that you respond to this request for additional information within 45 days of receipt of this letter.

If you have any questions, please, contact me at 301-415-1325.

Sincerely, Original Signed By Charles R. Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation

Enclosure:

Request for Additional Informati on cc w/encl:

See next page DOCUMENT NAME: PVRAI.50 Docket Nos.

STN 50-528, STN 50-529 and STN 50-530 DISTRIBUTION:

Docket File PUBLIC JRoe WBateman JClifford EPeyton CThomas TTjader

ACRS, TWFN PDIV-2 Reading

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DKirsch, WCFO CGrimes OFC NAME DATE 4/~97 4@@97 PDIV-2/PH PDIV-2/LA CThomas g-EPeyt n

NRR:TSB CGrimes 4/M 97 OFFICIAL RECORD COPY 9704300230 970425 PDR ADOCK 05000528 P

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205554001 April 25, 1997 Mr. James M. Levine Senior Vice President, Nuclear Arizona Public Service Company Post Office Box 53999 Phoenix, Arizona 85072-3999

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION SECTION 5.0 OF THE PROPOSED LICENSE AMENDMENT TO IMPLEMENT IMPROVED STANDARD TECHNICAL SPECIFICATIONS FOR PALO VERDE NUCLEAR GENERATING STATION (PVNGS)

UNIT NO.

1 (TAC NO. H96672),

UNIT NO.

2 (TAC NO. M96673),

AND UNIT NO.

3 (TAC NO. M96674)

Dear Mr. Levine:

By letter dated October 4,

1996, and supplemented by letter dated March 16, 1997, Arizona Public Service Company submitted a request to convert the current Technical Specifications (TSs) for PVNGS Units 1, 2, and 3, to make them consistent with NUREG-1432, Revision 1, "Standard Technical Specifications Combustion Engineering Plants,"

dated April 1995.

In order for the staff to complete its review, the additional information listed in the enclosed tables is requested.

The enclosure also reflects the staff's comments on Section 5.0.

To assist the staff in meeting its review schedule, it is requested that you respond to this request for additional information within 45'days of receipt of this letter.

If you have any questions, please contact me at 301-415-1325.

Sincerely, Docket Nos.

STN 50-528, STN 50-529 and STN 50-530

Enclosure:

- Request for Additional

.Information cc w/encl:

See next page har es R. Thomas, Project Manager Project Directorate IV-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation

t

Hr. James M. Levine April 25, 1997 CC:

Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, Arizona 85007 Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O.

Box 800

Rosemead, California 91770 Senior Resident Inspector USNRC P.

O.

Box 40 Buckeye, Arizona 85326 Regional Administrator, Region IV U. S. Nuclear Regulatory Commission Harris Tower 5 Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064

Chairman, Board of Supervisors ATTN:

Chairman 301 W. Jefferson, 10th Floor Phoenix, Arizona 85003 Hr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, Arizona 85040 Ms. Angela K. Krainik, Manager Nuclear Licensing Arizona Public Service Company P.O.

Box 52034 Phoenix, Arizona 85072-2034 Hr. John C. Horne, Vice President Power Supply Palo Verde Services 2025 N. Third Street, Suite 220 Phoenix, Arizona 85004 Mr. Robert Burt Los Angeles Department of Water 8 Power Southern California Public Power Authority 111 North Hope Street, Room 1255-B Los Angeles, California 90051 Hr. David Summers Public Service Company of New Mexico 414 Silver SW, 10604 Albuquerque, New Mexico 87102 Hr. Robert D. Bledsoe Southern California Edison Company 14300 Mesa Road, Drop D41-SONGS San Clemente, California 92672 Hr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251 Terry Bassham, Esq.

General Counsel El Paso Electric Company 123 W. Hills El Paso, Texas 79901

I

PVNGS ITS 5.1 RESPONSIBILITY ISSUE,:¹"",

DOC;.'¹ "or JFD,'TS/STS REF.;

"".,";."';DESCRIPTION:OF=ISSUE" ";:-

DATE..":.,

OPENED DATE::;

CLOSED COMMENTS 5.1-1 L.1 JFD 2 CTS 6.5.2.5 STS 5.1.1 CTS 6.5.2.5 requires the Vice President Nuclear Production or his designee review proposed tests and experiments which affect nuclear safety and are not addressed in the UFSAR or Technical Specifications.

ITS 5.1.1 requires the Department Leader, Operations, approve, prior to implementation, each proposed test or experiment that affects nuclear safety.

The justification does not explain why approval of proposed tests and experiments (which affect nuclear safety and are not addressed in the UFSAR or Technical Specifications) by a lower level of management is acceptable.

4/9/97 Provide additional discussion and justification for this change.

PVNGS ITS 5.1 RESPONSIBILITY DOC k, JFD; 0':.'.:.

LA.3

'CTS/STS'.'.:.

. REF;"

Cga "

CTS 6.2.2.e DESCRIPTION OF ISSUE "..

The justification for moving the Site Fire Team composition requirements from CTS 6.2.2.e to plant procedures does not identify the plant procedures that contain these requirements.

DATE:..

OPENED 4/15/97

DATE, CLOSED W

COMMENTS-Identify the plant procedures that will contain these requirements.

JFD 2 STS 5.2.2.e ITS 5.2.2.e adds the parenthetical "(this excludes the STA and the PVNGS Fire Department Working hours)" to the second paragraph of STS 5.2.2.e without addressing the validity of adding the exception.

4/15/97 Provide justification for this STS deviation based on current licensing basis, system design, and operational constraints.

M.1 CTS 6.2.2.1c See recommended work hours requirements in letter of April 9, 1997 from C.l. Grimes of the NRC to J. Davis of NEI. (See Attachment 1) 4/15/97 Review recommended requirements and consider incorporating in ITS.

PVNGS ITS 5.3 UNIT STAFF QUALIFICATIONS ISSUE 0,';;",.;;

,DOC. 4'.;:",

."JF.D'; 0,-':,:.

",'.CTS/STS:, '.,

i REF:";.; ':,.':.='.,.:.

DESCRIPTION OF ISSUE::.:":"': '.": ""':.-'::::::,;-':.;:,'.-::::::::::::::-;.:,:."',::.'-::::,'.;::::.":.'~-.".. DATE'"".

OPENED::

DATE...:-",

CLOSED',";-.

COMMENTS".:;,"'

5.3-1A JFD-2 CTS 6.3.1 See recommended Unit Staff Qualifications section, in letter of April 9, 1997 from C.l.

Grimes of the NRC to J. Davis of NEI. (See )

4/15/97 Review recommended changes and incorporate as appropriate.

~'a Y

~

I

7 PVNGS ITS 5A PROCEDURES 4

ISSUE ¹.,;:-..'",

yC c'.4-2A DOC"¹:

or'::.', '",.;:

JFD.¹";:;

LA.4 LA.6 LA.8 LA.12 LA.18 LA.20

. CTS/STS;

'REF;.."

CTS 6.2.3 6.5 6.8.1g 6.8.4 6.10 6.14b DESCRIPTION'OF'ISSUE:,:"':-" -';::-:.;;","-: '... ':-;:;:- -.: ',

The CTS 6.2.3 ISE Department requirements, the CTS 5.6 Training requirements, the 6.8.1.g and 6.14b requirements for PRB prior review and approval of modifications to the core protection calculator addressable constants and the ODCM, the 6.8.4 OSRC auditing requirements, and the 6.10 record retention requirements, are all to be relocated to the UFSAR/QAP.

These requirements must be relocated to the QAP.

DATE-'.,:.

OPENED'.,"

. 0 4/15/97 DATE CLOSED::

COMMENTS Relocate these requirements to the QAP.

Provide a revised copy of the QAP for NRC review prior to NRC issuance of the ITS license amendment.

I e

PVNGS ITS 6.6 PROGRAMS AND MANUALS 4

ISSUE':¹-",',.',.-'-:

\\

DOC¹;

"JFD'¹"'""'CTS/STS:::,".:,':;-;':.;DESCRIPTION.: OF;ISSUE:.:,:';;:,':;,::.:;;;.:;"',.'",:;;.,':-:;-;:; -':,DATE;."'"',",,"

OPENED "

DATE".i'.:

.CLOSED:,

C COMMENTS'.;;;;.",',-

'.5-1A 5.5-2A 5.5-3A JFD-2 LA.21 LA.13 CTS 6,16 CTS 4.0.5 CTS 6.8.4.b, 6.8.4.d, and 6.8.4.f CTS 6.16 requires the Containment Leakage Rate Testing Program satisfy the guidelines of ANSI/ANS-56.8-1994.

ITS 5.5.16 removes this requirement with no justification.

CTS 4.0.5.a references specific 10 CFR 50 and ASME Code requirements governing performance of the inservice inspection and testing.

These CTS requirements are moved to plant procedures.

The justification does not identify the plant procedures that contain these requirements.

CTS 6.8.4.b, 6.8.4.d, and 6.8.4.f require establishing programs for "In-Plant Radiation Monitoring", "Backup Method for Determining Subcooling Margin"; and "Spray Pond Monitoring," respectively.

These program requirements are not included in ITS 5.5.4.

The CTS requirements are moved to unidentified plant procedures.

The justification does not identify the plant procedures that contain these requirements.

The programs must be incorporated into the UFSAR.

4/15/97 4/15/97 4/15/97 Provide discussion and justification for this less restrictive removal of requirement.

Identify the plant procedures that will.

contain these requirements.

Move program and the associated procedures to the UFSAR, under 10 CFR 50.59 control.

PVNGS ITS 5.5 PROGRAMS AND MANUALS ISSUE ¹ DOC¹ or JFD¹;".-

CTS/STS REF::",':;-"-.'."

DESCRIPTION OF ISSUE... '.'.,;.'...

DATE, DATE

,'... OPENED,, CLOSED COMMENTS.

5.5-4A 5.5-5A LA.24 JFD-2 CTS 4.6.1.6.1, 4.6.1.6.2, 4.6.1.6.3, 4.6.1.6.4, and 4.6.1.6.5 CTS 4.6.4.3e CTS Surveillance Requirements 4.6.1.6.1, 4.6.1.6.2, 4.6.1.6.3, 4.6.1.6.4, and 4.6.1.6.5 provide detailed surveillance and reporting requirements for the structural integrity of the containment vessel

~

ITS 5.5 does not include these detailed requirements.

These CTS requirements are moved to plant procedures.

The justification does not identify that the plant procedures that contain these requirements are incorporated in the UFSAR.

CTS 4.6.4.3e requires inplace penetration and bypass testing of the hydrogen purge cleanup system after each complete or partial replacement of the HEPA filter bank.

CTS 4.6.4.3f requires inplace testing to ANSI-N510-1980 of the hydrogen purge cleanup system after each complete or partial replacement of a charcoal absorber.

ITS 5,5.11 does not specifically require this testing after complete or partial replacement of the HEPA filter bank or a charcoal absorber: it requires testing at the frequency prescribed in RG 1.52, Rev 2.

No justification is provided for this less restrictive change.

4/16/97 2/21/97 Provide additional discussion identifying that the plant procedures that contain these requirements are in the UFSAR and controlled by 10 CFR 50.59.

Provide discussion and justification for this less restrictive change.

C

1'VNGS ITS 5.5 PROGRAMS AND MANUALS ISSUE-: ¹::,".:::,":.

5.5-6A 5.5-7A DOC¹.:.,

'o',,:;::,"',:.,-

JFD¹ '":

JFD-2 None i:;CTS/STS;::,:.'";;,'.,

=REF:

CTS 4.7.7 CTS 3.7.8, footnote

'"'ESCRIPT.ION OF,:ISSUE "i '":;::;-"':;;: ':,:::-',::.:'-':,;::,.'::

CTS 4.7.7e requires inplace penetration and bypass testing of the control room essential filtration system (CREFS) after each complete or partial replacement of the HEPA filter bank.

CTS 4.7.7f requires inplace testing to ANSI-N510-1980 of the CREFS after each complete or partial replacement of a charcoal absorber.

ITS 5.5.11 does not specifically require this testing after complete or partial replacement of the HEPA filter bank or a charcoal absorber: it requires testing at the frequency prescribed in RG 1.52, Rev 2.

No justification is provided for this less restrictive change.

CTS 3.7.8, footnote '",'CAUTION-Reference Specification 3.9.12 page 3/4 9-14," is noted as an ITS 5 change (ITS 5.5.11?).

The referenced page is not part of the review package.

Therefore, the validity of the change is not verifiable.

'DATE, OPENED::,;

4/16/97 4/16/97

.DATE ',

CLOSED:

.COMMENTS '.

Provide discussion and justification for this less restrictive change.

Discuss this material in the review package, the change involved and justification for the change.

.~

p L

l v

't

PVNGS ITS 5.6 REPORTING REQUIREMENTS DOC ¹--

or.,':,;,:.;-':...':.

JF,D',¹,-""."

CTS/STS'.

,REF,,:.';.-;,,.', -,.

. DESCRIPTION OF ISSUE ':;,-;,.; ":..;.':;.";..

DATE:

OPENED DATE CLOSED COMMENTS LA.1 6 CTS 6.9.1.5 CTS 6.9.1.5 provides detailed requirements for the information required in annual reports, such as specific activity analysis if the primary coolant exceeds the limits of CTS 3A.7. The justification does not identify the procedures that contain these requirements.

4/18/97 Identify the plant procedures that contain these requirements.

0 t

PVNGS ITS 5.7 HIGH RADIATIONAREA ISSUE ¹ 5.7-1A

li c

.DOC,:

¹.'or

JFD

'¹,.;.-.'one

CTS/STS -,"

'EF -";"..'.

STS

5.7 DESCRIPTION

'OF-: ISSUE'",,-',-'.',::;;;:.-;:::;

DATE

.'.:::-'-'."":::-':.. '"'-::::.':.:,";-'3:::-'-

-'=.'..

OPENED..

See recommended STS High Radiation Area 4/18/97 section in letter of April 9, 1997 from C.I.Grimes of the NRC to J. Davis of NEI.

(See Attachment 1)

DATE, CLOSED COMMENTS pi Review recommended changes and incorporate as appropriate.

5.7-2A JFD-6 STS 5.7.2 STS 5.7.3 Editorial changes, per JFD-6, to STS sections 5.7.2 and 5.7.3 are unnecessary.

4/18/97 Submit desired editorial changes to STS via TSTF change request.

Attachment:

Letter to NEI dated 4/9/97