ML19270F615
| ML19270F615 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/28/1979 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| PVNGS245JMADBK, NUDOCS 7903020316 | |
| Download: ML19270F615 (2) | |
Text
j 4GIFI.tZMilA 1FJJiETlaHU !sGIif2&KD1Hi (C@TzTRA5371 P. O B O X 216 6 6 PHOENIX, A RIZON A 85036 February 28, 1979 PVNGS-245-JMA/DBK Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Mr. Harold R. Denton, Director
Reference:
Palo Verde Nuclear Generating Station Units 4 & 5, Docket No. STN-50-592/593
Dear Mr. Denton:
We have reviewed NUREG-0460 Volume 3, dated December 1978, and the summary of the Regulatory Requi ements Review Committee (RRRC) Meeting No. 81 dated January 2, 1979, in which the RRRC recommended a different ATWS modification for PVNGS Units 4 & 5 than for PVNGS Units 1, 2 & 3.
We understand that the RRRC was evenly divided as to whether PVNGS 4 & 5, which references an approved standard design and replicates PVNGS 1, 2 & 3, should be required to provide the modifications designated as Alternative 3 or those designated as Alternate 4 in NUREG-0460 Volume 3.
We further understand that the RRRC recommended that the Director, Office of Nuclear Reactor Regulation, decide on which alternate must be met by PVNGS 4 & 5.
Arizona Public Service Company supports the industry position that ATWS does not present a significant concern for the health and safety of the public and shares the recognition of ATWS as a licensing problem. We also supnort Combustion Engineering's recommendation to the Director, Office of Nuclear Reactor Regulation, that if design modifications are to be required of the CESSAR design, such modifications should consist of a Supolementary Protec-tion System (SPS) and be applied uniformly to all CESSAR plants.
Additionally, it is our position that if during the course of the NRC review of PVNGS, any changes are required for PVNGS 1, 2 & 3 and agreed upon by APS and the NRC staff, these changes would be repli, ted on PVNGS 4 & 5, main-taining all five units identical. This approac: is consistant with the NRC standardization policy and represents one of the major reasons why APS chose to support the NRC standardization policy by replicating PVNGS 1, 2 & 3 rather than submitting a custom application.
0
\\
70030203/(,
l Director of Nuclear Reactor Regulation PVNGS-245-JMA/DBK February 28, 1979 Page Two Arizona Public Service Company strongly objects to and wishes to appeal the conclusions and recommendations reach in the RRRC Meeting No. 81 dated January 2,1979, regarding the recommendation that Alternate 4 be applied to PVNGS Units 4 & 5.
We feel that if implemented, this approach would be an abanenment of the NRC standardization policy specifically as it relates to the replication of PVNGS Units 1, 2 & 3.
We would be happy to discuss this matter at any time.
Very truly rs,e i
O A L.,
D&
r i
E. E. Van Brunt, Jr.
APS Vice President Nuclear Projects ANPP Project Director EEVBJr/DBK/cjw
.