ML17313A184
| ML17313A184 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/12/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| NUDOCS 9801260133 | |
| Download: ML17313A184 (10) | |
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UNITEO STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055$ 4001 3anuary 12, 1998 Mr. James M. Levine Senior Vice President, Nuclear Arizona Public Service Company Post Office Box 53999 Phoenix, Arizona 85072-3999
SUBJECT:
SCHEDULE FOR REVIEWING IMPROVED TECHNICALSPECIFICATIONS (ITS)
Dear Mr. Levine:
I am responding to your letter to Mr. L. J. Callan, Executive Director for Operations, dated November 14, 1997, commenting on the change in the NRC schedule for issuing the Improved Technical Specifications (ITS) conversion for the Palo Verde Nuclear Generating Station. We share your concern about the need for timely completion of the ITS reviews to support utility implementation programs.
The NRC staff continues to believe that the conversion to the ITS has safety and operational benefits for licensees.
We recognize that Arizona Public Service Company (APS) has unique challenges in developing and implementing consolidated ITS for a three-unit site. We also recognize your timely application, your aggressive participation in the ITS conversion program, and your desire for a systematic, comprehensive implementation program.
Industry response to NRC's encouragement of this program has resulted in licensees for 30 sites, representing 51 nuclear units, submitting applications to date.
Fifteen of these applications, including the Palo Verde request, were submitted last year, compared with a total of only fifteen submitted during the previous three years.
This increase in the rate of applications to convert to the ITS has resulted in a backlog of requests requiring NRC staff review and approval.
In addition, as you noted in your letter of November 14, significantly more resources and time have been needed for the ITS conversion reviews than were originally estimated.
II 980i260i33 980ii2 PDR ADOCK 05000528 l iglllllllllllllllllllllllllllllllllllll In light of this situation, the staff recently reassessed its integrated review and licensee implementation schedule to arrive at a more realistic schedule for completing the ITS reviews.
The staff spoke with affected licensees to determine their desired implementation windows.
The staff then decided to either attempt to meet a particular implementation window by keeping to a very aggressive schedule for both the staff and the licensee, or the staff fet the particular licensee know that the staff could not meet the licensee's implementation window so that the licensee could adjust its plans accordingly. To date, one licensee has had to delay implementation plans by seven months to their next available implementation window due to our inabilityto meet the licensee's desired schedule.
A number of additional licensees have experienced lesser delays, due to our extended review which have not resulted in changes to their implementation windows.
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Mr. James M. Levine january 12, 1998 In the case of Palo Verde, you had requested final approval for your ITS for a planned July 1998 implementation.
Our understanding is that the implementation date was predicated on final approval for the ITS in November 1997, after which you would revise procedures and train staff for all three units to allow your plants'taffs to gain experience with the ITS before a September 1998 outage on Unit 3. Unfortunately, given the time constraints involving shorter implementation schedules for other licensees, we could not accommodate this schedule.
Experience shows that a number of licensees have successfully implemented the ITS soon after receiving final approval. This is done in part by using the draft safety evaluation report (SER) that is issued for comment during every ITS review as a baseline for making documentation and training modifications. The staff considered licensee implementation programs and implementation dates, including Palo Verde's, and established an overall review schedule that attempted to complete our draft SER three months prior to desired licensee implementation dates with amendment issuance one month prior to those implementation dates.
This would require many licensees to complete developing their implementation documentation based on the draft safety evaluation report. Although not as you desired, we believe that the revised schedule for Palo Verde, which would have the ITS draft SER issued by April 1998, would still allow implementation by July 1998. We recognize that it would, however, require a more aggressive implementation schedule.
We further realize that the current schedule gives you significantly less time than you originally requested, but given the considerations cited above, we feel this is the most reasonable approach we can take to support the overall industry efforts to implement this improvement in operational safety.
The staff has investigated various means to improve the efficiency ofthe review process.
In order to reduce resources needed for review and approval, the staff has developed a new, more concise safety evaluation format, which should significantly shorten the later stages of the approval process.
This new format was successfully used in a pilot ITS conversion amendment recently issued for the H. B. Robinson plant, and it willbe used for future approvals, including Palo Verde. This format includes use of a table that concisely summarizes the justification for each change being approved.
We have received your initial version of this table that willbe used by the staff to develop the safety evaluation.
In addition to improving the efficiencies of the review, the staff is reevaluating our resource utilization in an attempt to improve upon our current review schedule, including our April 1998 date for issuing the Palo Verde draft SER. To this end we have recently dedicated two additional staff members to reviewing ITS conversion submittals. As a result of these additional actions, we may be able to issue the draft SER in February 1998.
Sincerely, Samuel J. Collins, Director Office of Nucleai Reactor Regulation Docket Nos.: STN 50-528, STN 50-529 and STN 50-530 t
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Mr. 'James M. Levine january 12, 1998,.
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,, ".-,,We'hope this information gives you an understanding of the considerations that were applied,-
before'ny, schedules were changed and an appreciation that none of the schedules, including-'he Palo Ve'rde schedule, were changed without extensive consideration of potential impacts on,
~ affected licensees.
We willcontinue to work with your staff and keep them informed of our,--
," progress in'completing the Palo Verde review.
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J'j, Original Signed By g )J Roy P.
Zimmerman cc: See next page DOCUMENT NAME: GT970828.PV
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Mr. James M. Levine january 12, 1998 CC:
Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, Arizona 85007 Mr. David Summers Public Service Company of New Mexico 414 Silver SW, 00604 Albuquerque, New Mexico 87102 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 & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, Texas 76011-8064 Mr. Robert D. Bledsoe Southern California Edison Company 14300 Mesa Road, Drop D41-SONGS San Clemente, California 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdale, Arizona 85251 Terry Bassham, Esq.
General Counsel El Paso Electric Company 123 W. Mills El Paso, Texas 79901 Chairman, Board of Supervisors ATTN: Chairman 301 W. Jefferson, 10th Floor Phoenix, Arizona 85003 Mr. 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 Mr. John C. Home, Vice President Power Supply Palo Verde Services 2025 N. Third Street, Suite 220 Phoenix, Arizona 85004 Mr. Robert Burt Los Angeles Department ofWater & Power Southern California Public Power Authority 111 North Hope Street, Room 1255-B Los Angeles, California 90051
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DISTRIBUTION:
Docket Files (STN 50-528, STN 50-529 and STN 50-530)
PUBLIC PDIV-2 Reading EDO ¹970828 JCallan AThadani HThompson PNorry JBlaha SBurns EMerschoff, Region IV SCollins/FMiraglia BSheron WTravers RZimmerman JRoe EAdensam WBateman JClifford EPeyton NRR Mail Room (EDO ¹970828)
NOlson THarris
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