|
|
(2 intermediate revisions by the same user not shown) |
Line 3: |
Line 3: |
| | issue date = 08/20/1992 | | | issue date = 08/20/1992 |
| | title = Forwards Rev 1 to JCO-91-02-01, Justification for Continued Operation Steam Generator Tube Rupture Analysis Concerns. | | | title = Forwards Rev 1 to JCO-91-02-01, Justification for Continued Operation Steam Generator Tube Rupture Analysis Concerns. |
| | author name = LEVINE J M | | | author name = Levine J |
| | author affiliation = ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR | | | author affiliation = ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| | addressee name = MARTIN J B | | | addressee name = Martin J |
| | addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) | | | addressee affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| | docket = 05000528, 05000529, 05000530 | | | docket = 05000528, 05000529, 05000530 |
Line 17: |
Line 17: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:"0 Ik JAMES M.LEVINE VICE PRESIDENT NUCLEAA PRODUCTION RECEIVED RECEIVED REGION'/HRC NRC Arizona Public Service Company'EGION Y PALO VERDE NUCLEAR GENERATING STATION"""''"""'"""'"'"'""W P""~<<"'92-II 27 IO>Z 102-02251-JML/TR8/NLT | | {{#Wiki_filter:"0 Ik RECEIVED RECEIVED HRC NRC Arizona Public Service Company 'EGION REGION '/ Y |
| *August'20, 1992 Mr.John B.Martin Regional Administrator, Region V U.S.Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 t~g~~a><~~
| | """' '"""'"""'"'"'""WP"" ~<<"'92-II PALO VERDE NUCLEAR GENERATING STATION 27 IO >Z 102-02251-JML/TR8/NLT JAMES M. LEVINE August'20, 1992 VICE PRESIDENT NUCLEAA PRODUCTION Mr. John B. Martin Regional Administrator, Region V U. S. Nuclear Regulatory Commission t 1450 Maria Lane, Suite 210 ~ g~ ~a >< ~ ~ |
| | Walnut Creek, CA 94596-5368 |
|
| |
|
| ==Dear Mr.Martin:== | | ==Dear Mr. Martin:== |
|
| |
|
| ==Subject:== | | ==Subject:== |
| Palo Verde Nuclear Generating Station (PVNGS)Units 1, 2, and 3 Docket Nos.STN 50-528/529/530 Revision 1 to the Justification for Continued Operation-Steam Generator Tube Rupture Analysis Concerns (JCO-91-02-01) | | Palo Verde Nuclear Generating Station (PVNGS) |
| File: 92-056-026 Please find enclosed for your information a copy of Revision 1 to the Justification for Continued Operation (JCO)for Steam Generator Tube Rupture Analysis Concerns.Revision 1 to the subject JCO was issued for Palo Verde Units 1, 2, and 3 to administratively limit the Reactor Coolant System dose equivalent Iodine-131 to 0.6 pCi/gm.The need for this JCO, as detailed in the body of the JCO, was originally discussed with NRR PVNGS Senior Project Manager Charlie Trammell and Resident Inspector James Sloan in January 1992.A telecon was held with the NRC to discuss the issuance of Revision 1 in July 1992.If you have any questions, please contact Thomas R.Bradish at (602)393-5421.Sincerely, JML/TRB/NLT/pmm Enclosure cc: C.M.Trammell J.A.Sloan A.H, Gutterman A.C.Gehr Document Control Desk 040016 | | Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Revision 1 to the Justification for Continued Operation-Steam Generator Tube Rupture Analysis Concerns (JCO-91-02-01) |
| <<1 ENCLOSURE REVISION 1 TO THE JUSTIFICATION FOR CONTINUED OPERATION STEAM GENERATOR TUBE RUPTURE ANALYSIS CONCERNS (JCO-91-02-01) 21240CARev 2.99 Xl90.900r2l Iaxrggr COMPANY CORRESPONDENCE IO iran OATE: TO: Sia.a: Ext.: FROM Sia.<<Ext.102-02218-TRB/NLT July 29r 1992 (File T.R.Bradish y~~+'636 82-5421 FILE: SUBJECT.'2-177-419 Revision 1 to the Steam Generator Tube Rupture Analysis Concerns JustiTication for Continued Operation (JCO), JCO-91-02-01 (Units 1, 2 and 3)Revision 1 to the Steam Generator Tube Rupture Analysis Concerns Justification for Continued Operation increases the administrative control on dose-equivalent Iodine-131 from 0.4 pCi/gm to 0.6 pCi/gm.An evaluation performed subsequent to the initial issue of JCO (91-02-00) determined that an administrative limit of 0.6 pCi/gm will provide the'ecessary compensatory measure to ensure dose consequences will remain under the 10 CFR Part 100 dose limits of less than 30 Rem (GIS)during a postulated SGTR+LOP.The original limit of 0.4 pCi/gm required by Revision 0 of this JCO was chosen as the limit in January, 1992, because the limit was imposed on Unit 1 as a compensatory measure in support of the Interfacing System Loss of Coolant Accident (ISLOCA)JCO.On October 24, 1991, Arizona Public Service Company (APS)internal validation efforts for the upgraded Emergency Operating Procedures (EOPs)identified a concern that early (relative to no operator action for 30 minutes currently assumed)operator actions could result in more steaming during the first 30 minutes of a Steam Generator Tube Rupture (SGTR)than is currently reQected in UFSAR Section 15.6.3.1, and which could result in correspondingly higher offsite doses.This concern was documented in Condition Report/Disposition Request (CRDR)9-1-0236.Subsequent investigation determined that a Steam Generator Tube Rupture with Loss of Offsite Power (SGTR+LOP), without a single failure, could result in doses higher than those reported for a SGTR+LOP.in CESSAR Section 15.6.3.2.UFSAR Section 15.6.3 reports dose consequences resulting from a SGTR with offsite power available, and for a SGTR+LOP with a single failure (SF), but not for a SGTR+LOP.A review of the licensing submittals and corresponding safety evaluation reports (SERs)for SGTR events determined that, following NRC review of the CESSAR SGTR and SGTR+LOP analy'ses, Palo Verde Nuclear Generating Station (PVNGS)was required to reanalyze the SGTR+LOP event with a limiting single failure, as documented in UFSAR Section 15.6.3.2.The PVNGS FSAR originally referenced CESSAR for the Memo to File Page 2 SGTR and SGTR+LOP events.In 1988, UFSAR Section 15.6.3 was amended to replace the reference to CESSAR SGTR+LOP with the SGTR+LOP with single failure analysis from UFSAR Appendix 15A, although it is not clear why the SGTR+LOP case was removed.Hence, there exists some confusion as to the PVNGS licensing basis for a SGTR+LOP (without a single failure).In the absence of a clearly defmed PVNGS licensing basis for a SGTR+LOP, the Standard Review Plan 15.6.3 (SRP)acceptance criteria is deemed to apply.An engineering evaluation of the radiological consequences of the postulated SGTR+LOP, incorporating operator actions consistent with both current and upgraded EOPs, was performed. | | File: 92-056-026 Please find enclosed for your information a copy of Revision 1 to the Justification for Continued Operation (JCO) for Steam Generator Tube Rupture Analysis Concerns. |
| Using the CESSAR assumptions for steam generator flashing and partitioning, and dispersion factors consistent with the UFSAR Section 15.6.3.2 (SGTR+LOP+SF) analysis, the evaluation results are well within the SRP 15.6.3 criteria and 10 CFR Part 100'limits (refer to Table 2, Case 4 on page 16 of the attached JCO), though they exceed the corresponding values documented in CESSAR Section 15.6.3.The evaluation was also performed using the more conservative UFSAR assumptions for steam generator Gashing and partitioning, By applying the compensatory action of limiting Reactor Coolant System (RCS)dose equivalent Iodine-131 to 0.6 pCi/gm, the offsite doses were verified to be in compliance with the 10 CFR Part 100 dose limits and within the acceptance criteria of SRP 15.6.3 (refer to Table 2, Case 1 on page 16 of the attached JCO).Hence, continued operation of PVNGS Units 1, 2, and 3 under the current Emergency Operating Procedures is justified. | | Revision 1 to the subject JCO was issued for Palo Verde Units 1, 2, and 3 to administratively limit the Reactor Coolant System dose equivalent Iodine-131 to 0.6 pCi/gm. The need for this JCO, as detailed in the body of the JCO, was originally discussed with NRR PVNGS Senior Project Manager Charlie Trammell and Resident Inspector James Sloan in January 1992. A telecon was held with the NRC to discuss the issuance of Revision 1 in July 1992. |
| The 0.4 pCi/gm administrative limit is, therefore, increased to 0.6 p,Ci/gm for Units 1, 2, and 3, as set forth in Revision 1 to the SGTR JCO.The above limit does not supercede the more restrictive limit of 0.2 pCi/gm currently imposed on PVNGS Units 2 and 3 for the ISLOCA JCO.Attached is the Justification for Continued Operation; Steam Generator Tube Rupture Analysis Concerns, JCO-91-02-01, which documents the detailed safety evaluation and demonstrates that continued operation will not adversely affect the health and safety of the public.The compensatory action will remain in effect until it is demonstrated that the FSAR analyses envelope those actions that the operators may take in accordance with the EOPs.This may require changes to the EOPs, possible reanalysis and UFSAR changes.TRB/NLT/rit Attachment}} | | If you have any questions, please contact Thomas R. Bradish at (602) 393-5421. |
| | Sincerely, JML/TRB/NLT/pmm Enclosure cc: C. M. Trammell J. A. Sloan A. H, Gutterman A. C. Gehr Document Control Desk 040016 |
| | |
| | <<1 ENCLOSURE REVISION 1 TO THE JUSTIFICATION FOR CONTINUED OPERATION STEAM GENERATOR TUBE RUPTURE ANALYSIS CONCERNS (JCO-91-02-01) |
| | |
| | 21240CARev 2.99 Xl90.900r2l Iaxrggr COMPANY CORRESPONDENCE IO iran 102-02218-TRB/NLT OATE: July 29r 1992 |
| | ( |
| | TO: |
| | Sia. a: File Ext.: |
| | FROM Sia. << |
| | Ext. |
| | T. R. Bradish 82-5421 y ~~+'636 FILE: |
| | SUBJECT.'2-177-419 Revision 1 to the Steam Generator Tube Rupture Analysis Concerns JustiTication for Continued Operation (JCO), JCO-91-02-01 (Units 1, 2 and 3) |
| | Revision 1 to the Steam Generator Tube Rupture Analysis Concerns Justification for Continued Operation increases the administrative control on dose-equivalent Iodine-131 from 0.4 pCi/gm to 0.6 pCi/gm. An evaluation performed subsequent to the initial issue of JCO (91-02-00) determined that an administrative limit of 0.6 pCi/gm will provide the compensatory measure to ensure dose consequences will remain under the 10 'ecessary CFR Part 100 dose limits of less than 30 Rem (GIS) during a postulated SGTR + LOP. |
| | The original limit of 0.4 pCi/gm required by Revision 0 of this JCO was chosen as the limit in January, 1992, because the limit was imposed on Unit 1 as a compensatory measure in support of the Interfacing System Loss of Coolant Accident (ISLOCA) JCO. |
| | On October 24, 1991, Arizona Public Service Company (APS) internal validation efforts for the upgraded Emergency Operating Procedures (EOPs) identified a concern that early (relative to no operator action for 30 minutes currently assumed) operator actions could result in more steaming during the first 30 minutes of a Steam Generator Tube Rupture (SGTR) than is currently reQected in UFSAR Section 15.6.3.1, and which could result in correspondingly higher offsite doses. This concern was documented in Condition Report/Disposition Request (CRDR) 9-1-0236. Subsequent investigation determined that a Steam Generator Tube Rupture with Loss of Offsite Power (SGTR+LOP), without a single failure, could result in doses higher than those reported for a SGTR+LOP. in CESSAR Section 15.6.3.2. UFSAR Section 15.6.3 reports dose consequences resulting from a SGTR with offsite power available, and for a SGTR+LOP with a single failure (SF), but not for a SGTR+LOP. |
| | A review of the licensing submittals and corresponding safety evaluation reports (SERs) for SGTR events determined that, following NRC review of the CESSAR SGTR and SGTR+LOP analy'ses, Palo Verde Nuclear Generating Station (PVNGS) was required to reanalyze the SGTR+LOP event with a limiting single failure, as documented in UFSAR Section 15.6.3.2. The PVNGS FSAR originally referenced CESSAR for the |
| | |
| | Memo to File Page 2 SGTR and SGTR+LOP events. In 1988, UFSAR Section 15.6.3 was amended to replace the reference to CESSAR SGTR+LOP with the SGTR+LOP with single failure analysis from UFSAR Appendix 15A, although it is not clear why the SGTR+LOP case was removed. Hence, there exists some confusion as to the PVNGS licensing basis for a SGTR+LOP (without a single failure). In the absence of a clearly defmed PVNGS licensing basis for a SGTR+LOP, the Standard Review Plan 15.6.3 (SRP) acceptance criteria is deemed to apply. |
| | An engineering evaluation of the radiological consequences of the postulated SGTR+LOP, incorporating operator actions consistent with both current and upgraded EOPs, was performed. Using the CESSAR assumptions for steam generator flashing and partitioning, and dispersion factors consistent with the UFSAR Section 15.6.3.2 (SGTR+LOP+SF) analysis, the evaluation results are well within the SRP 15.6.3 criteria and 10 CFR Part 100'limits (refer to Table 2, Case 4 on page 16 of the attached JCO), |
| | though they exceed the corresponding values documented in CESSAR Section 15.6.3. |
| | The evaluation was also performed using the more conservative UFSAR assumptions for steam generator Gashing and partitioning, By applying the compensatory action of limiting Reactor Coolant System (RCS) dose equivalent Iodine-131 to 0.6 pCi/gm, the offsite doses were verified to be in compliance with the 10 CFR Part 100 dose limits and within the acceptance criteria of SRP 15.6.3 (refer to Table 2, Case 1 on page 16 of the attached JCO). Hence, continued operation of PVNGS Units 1, 2, and 3 under the current Emergency Operating Procedures is justified. |
| | The 0.4 pCi/gm administrative limit is, therefore, increased to 0.6 p,Ci/gm for Units 1, 2, and 3, as set forth in Revision 1 to the SGTR JCO. The above limit does not supercede the more restrictive limit of 0.2 pCi/gm currently imposed on PVNGS Units 2 and 3 for the ISLOCA JCO. |
| | Attached is the Justification for Continued Operation; Steam Generator Tube Rupture Analysis Concerns, JCO-91-02-01, which documents the detailed safety evaluation and demonstrates that continued operation will not adversely affect the health and safety of the public. The compensatory action will remain in effect until it is demonstrated that the FSAR analyses envelope those actions that the operators may take in accordance with the EOPs. This may require changes to the EOPs, possible reanalysis and UFSAR changes. |
| | TRB/NLT/rit Attachment}} |
|
---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML17313B0991999-10-14014 October 1999 Forwards LER 99-005-00 Reporting Findings & Corrective Actions Taken as Result of Out of Tolerance MSSV Condition in Unit 1 Which Was Discovered During pre-outage Testing ML17313B0881999-10-12012 October 1999 Forwards Response to NRC 990831 RAI Re Several Relief Requests That Accompanied Second ten-yr Interval ISI Program Submitted on 980317.Revised Relief Request 6 Is Provided in Encl 2 ML17300B3501999-09-29029 September 1999 Forwards Revised Bases Pages,Providing Addl Discussion of Options Available to Exit Required Action G of TS 3.8.1 & Revised Page for TS 3.3.7,in Response to NRC RAI Re Proposed Amend to TS 3.8.1 & 3.3.7 ML17300B3551999-09-28028 September 1999 Responds to Aministrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. Proposed Palo Verde Operator Licensing Exam Schedule & Estimated Number of Applicants Planning to Take Exams Encl ML17313B0851999-09-24024 September 1999 Requests Approval of Alternative to Repair Requirements of 10CFR50.55a,authorizing Alternative Use of Mechanical Nozzle Seal Assemblies,As Described in Encl,For RCS Hot Leg Instrumentation & Sampling Nozzles for Two Operating Cycles ML17313B0781999-09-20020 September 1999 Forwards Rev 22 to PVNGS Emergency Plan. Summary Description of Changes,Included ML17300B3331999-09-14014 September 1999 Forwards MOR for August 1999 & Revised MOR for Jul 1999 for Pvngs,Units 1,2 & 3 ML17300B3351999-09-0808 September 1999 Informs That Repairs to Plant EDG 2A Jacket Water Cooling sub-sys Were Completed & EDG Was Declared Operable on 990903 at Approx 21:45 Mst.Noed Was Not Necessary,Since 72 Hour Completion Time Was Met ML17313B0761999-09-0303 September 1999 Requests Enforcement Discretion to TS Section 3.8.1, AC Sources - Operating. Enforcement Discretion Would Allow,On One Time Basis,Extension of Completion Time in Required Action B.4 of TS 3.8.2 from 72 H to 108 H ML17313B0731999-08-31031 August 1999 Informs That RR Bean (License OP-50452-1) Has Been Permanently Reassigned to Position That Does Not Require License & Requests That Individuals License Be Expired Per 10CFR55.55 ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML17313B0581999-08-0606 August 1999 Forwards Rev 1 of Changes to TS Bases Implemented Between Aug 1998 & Jul 1999.Insertion Instructions & List of Affected Pages Included ML17313B0311999-08-0303 August 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001 ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML17313B0431999-07-30030 July 1999 Advises of Listed Senior Mgt Changes That Have Taken Place at Plant ML17313B0441999-07-30030 July 1999 Forwards Comments on Draft NRC Repts Evaluation of AOVs at Us Light-Water Reactors (1999) & Idaho Natl Engineering & Environ Lab Rept (INEEL)EXT-98-00383,Study of AOVs in Npps. ML17313B0151999-07-20020 July 1999 Submits Request to Obtain All Data Previously Sent by PVNGS & Currently in REIRS for OLs NPF-41,NPF-51 & NPF-74.Data Is Requested in Electronic Form (Ascii Format) as It Currently Exists in REIRS Sys ML17313B0091999-07-20020 July 1999 Forwards Requested Calculations Performed to Verify That Increase in Max Radially Averaged Enrichment for Fuel Assemblies from 4.3 Weight Percent to 4.8 Weight Percent Did Not Affect Requirements for TSs 3.7.15,3.7.17 & 4.3.1 ML17313B0171999-07-16016 July 1999 Forwards LER 99-005-00,re Automatic Rt Which Occurred on 990618,following Sensor Failure in Core Protection Calculators.Corrective Actions Described in LER Are Not Necessary to Maintain Compliance with Regulations ML17300B3111999-07-15015 July 1999 Forwards PVNGS Unit 2 ISI Rept for Eighth Refueling Outage. No Commitments Made to NRC by Ltr ML17300B3141999-07-15015 July 1999 Forwards Corrected Electronic Files for Individual Monitoring Repts for 1998.Original Electronic Files Were Found to Have Two Administrative Errors,Which Has Been Corrected.Encl Withheld,Per 10CFR2.790 ML20209G6771999-07-0808 July 1999 Forwards Supplemental Info to Confirm That Decommissioning Funding Plans of Public Service Co of Nm for Interests in PVNGS Have Been Reviewed by Nm Public Regulation Commission. Final Order & Recommended Decisions in Case 2742,also Encl ML17300B2931999-07-0202 July 1999 Submits Withdrawal of Relief 5 for Second ISI Interval for Units 1,2 & 3.Proposed Alternative Is Related to Exam Requirements for Component Supports for Second ISI Interval ML17313A9951999-06-26026 June 1999 Provides Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. ML17300B2831999-06-26026 June 1999 Requests NRC Approval of Proposed Alternative IAW Provisions of 10CFR50.55a(a)(3)(i) to 10CFR50.55a(g) & Requirements of ASME Boiler & Pressure Vessel Code Section XI for Repairs & Installation.Description of Proposed Alternative,Encl ML17313A9901999-06-15015 June 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. No Commitments Being Made to NRC by Ltr ML17313A9521999-05-24024 May 1999 Notifies NRC That Ja Proctor,License SOP-50314,has Been Permanently Reassigned to Position That Does Not Require License.License Should Be Expired,Per 10CFR55.55 ML20206Q3111999-05-18018 May 1999 Final Response to FOIA Request for Documents.Forwards App a Records Being Released in Entirety ML17313A9311999-05-13013 May 1999 Notifies NRC That Rev 2 to COLR for Unit 2 Remains Applicable Following Recently Completed Unit 2 Reload ML17313A9481999-05-12012 May 1999 Informs of Change Needed in Order to Update Current Mailing List.Future Mailings for J Horne Should Be Forwarded to Listed Address ML17313A9261999-05-0707 May 1999 Forwards LER 99-004-00,per 10CFR50.73.LER Repts Findings & Corrective Actions Taken as Result of Unit 2 Out of Tolerance Pressurizer Safety Valve (Psv) Condition Which Was Discovered During Outage Testing ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML17313A9091999-04-30030 April 1999 Forwards Proprietary Proposed Test Outlines for Initial License Exams to Be Administered at PVNGS in Aug/Sept 1999. No Commitments Are Contained in Ltr.Proprietary Info Withheld ML17313A9181999-04-30030 April 1999 Forwards Electronic File of Individual Monitoring Repts for 1998.Encl Withheld Per 10CFR2.790 ML17313A9191999-04-30030 April 1999 Forwards Special Rept 2-SR-99-001 Re SG Tube Plugging in PVNGS Unit 2,per TS Reporting Requirement 5.6.8.Complete Results of SG Tube Inservice Insp Will Be Submitted by 000422 ML17300B3751999-04-23023 April 1999 Forwards LER 99-003-00,reporting Condition Prohibited by TS 3.7.17 Where Spent Fuel Assembly Was Stored in Inappropriate Region in Spent Fuel Pool ML17313A9081999-04-23023 April 1999 Documents 990421 Telcon with E Emeigh,Which Requested Extension for Submitting Next Matl Balance Rept for Pvngs,As Required by 10CFR70.53 & 74.13.Required Info Will Be Submitted by 990531 ML20205T7421999-04-21021 April 1999 Forwards Partially Withheld Insp Repts 50-528/99-05, 50-529/99-05 & 50-530/99-05 on 990322-26.Determined That Security Program Properly Implemented.Insp Repts Details Withheld (Ref 10CFR73.21) ML17313B0271999-04-21021 April 1999 Forwards Proprietary Epec Pro Forma Cashflow Statement for 1999.Proprietary Info Withheld,Per 10CFR2.790.Affidavit Encl ML17313A9031999-04-21021 April 1999 Forwards Rev to Relief Request 12 Submitted 990420 to Second 10-yr ISI Interval.Revised Relief Request Discusses in More Detail Actions APS Will Take When There Is Identified Leakage from Bolted Connection ML17313A8971999-04-20020 April 1999 Requests Use of Alternatives to 10CFR50.55a(g) Inservice Insp Requirements.Proposed Alternatives Are Related to Visual Exam of Bolted Connections 05000529/LER-1999-002, Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing1999-04-19019 April 1999 Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing ML17313A8931999-04-14014 April 1999 Forwards LER 99-003,reporting Condition Prohibited by TSs That Existed When Surveillance Requirement to Verify Essential Chilled Water Sys Valve Positions Was Not Met ML20205Q0821999-04-13013 April 1999 Forwards Second ISI Interval Relief Request 10 from ASME Section XI & Applicable Addenda Re Visual Exams Performed Subsequent to Repair or Replacement of Component or Alteration of Item ML17313A8901999-04-13013 April 1999 Forwards LER 98-003-01 Re MSSV as-found Lift Pressures out- Side of TS Limits.Ler Suppl Provides Evaluation Findings from Unit 3 out-of-tolerance MSSVs Conditions Which Were Discovered During pre-outage Testing ML17313A8831999-04-0808 April 1999 Forwards 1998 Annual Radioactive Effluent Release Rept for Pvngs,Units 1,2 & 3 & Rev 13 to ODCM, for Pvngs,Units 1,2 & 3 IAW TS 5.6.3 ML20205F3491999-03-30030 March 1999 Forwards Proprietary & non-proprietary Info Re Status of Decommissioning Funding for Pvngs,Units 1,2 & 3,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per Requirements of 10CFR2.790(b)(1) ML17313A8671999-03-24024 March 1999 Submits Info Re Present Levels & Sources of Property Insurance Maintained for Pvngs,Per 10CFR50.54(w)(3) ML17313A8601999-03-16016 March 1999 Forwards Revised Relief Requests PRR-05,PRR-06 & PRR-11 to Clarify That Proposed Design Flow Testing for Lpsi,Hpsi & Containment Spray Pumps Will Be Performed Using Instruments That Comply with Code Requirements,Per 990226 Telcon ML17313A8551999-03-0505 March 1999 Requests Proposed Code Alternative IAW 10CFR50.55a(e)(3),as Acceptable Alternative to Requirements of 10CFR50.55a(e)(1), for Installation of in-line safety-related Flow Measurement Instrument in ASME Class 3 Pipe 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML17313B0991999-10-14014 October 1999 Forwards LER 99-005-00 Reporting Findings & Corrective Actions Taken as Result of Out of Tolerance MSSV Condition in Unit 1 Which Was Discovered During pre-outage Testing ML17313B0881999-10-12012 October 1999 Forwards Response to NRC 990831 RAI Re Several Relief Requests That Accompanied Second ten-yr Interval ISI Program Submitted on 980317.Revised Relief Request 6 Is Provided in Encl 2 ML17300B3501999-09-29029 September 1999 Forwards Revised Bases Pages,Providing Addl Discussion of Options Available to Exit Required Action G of TS 3.8.1 & Revised Page for TS 3.3.7,in Response to NRC RAI Re Proposed Amend to TS 3.8.1 & 3.3.7 ML17300B3551999-09-28028 September 1999 Responds to Aministrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams. Proposed Palo Verde Operator Licensing Exam Schedule & Estimated Number of Applicants Planning to Take Exams Encl ML17313B0851999-09-24024 September 1999 Requests Approval of Alternative to Repair Requirements of 10CFR50.55a,authorizing Alternative Use of Mechanical Nozzle Seal Assemblies,As Described in Encl,For RCS Hot Leg Instrumentation & Sampling Nozzles for Two Operating Cycles ML17313B0781999-09-20020 September 1999 Forwards Rev 22 to PVNGS Emergency Plan. Summary Description of Changes,Included ML17300B3331999-09-14014 September 1999 Forwards MOR for August 1999 & Revised MOR for Jul 1999 for Pvngs,Units 1,2 & 3 ML17300B3351999-09-0808 September 1999 Informs That Repairs to Plant EDG 2A Jacket Water Cooling sub-sys Were Completed & EDG Was Declared Operable on 990903 at Approx 21:45 Mst.Noed Was Not Necessary,Since 72 Hour Completion Time Was Met ML17313B0761999-09-0303 September 1999 Requests Enforcement Discretion to TS Section 3.8.1, AC Sources - Operating. Enforcement Discretion Would Allow,On One Time Basis,Extension of Completion Time in Required Action B.4 of TS 3.8.2 from 72 H to 108 H ML17313B0731999-08-31031 August 1999 Informs That RR Bean (License OP-50452-1) Has Been Permanently Reassigned to Position That Does Not Require License & Requests That Individuals License Be Expired Per 10CFR55.55 ML17313B0581999-08-0606 August 1999 Forwards Rev 1 of Changes to TS Bases Implemented Between Aug 1998 & Jul 1999.Insertion Instructions & List of Affected Pages Included ML17313B0311999-08-0303 August 1999 Submits Response to NRC AL 99-02, Operating Reactor Licensing Actions Estimates, for Fys 2000 & 2001 ML17313B0441999-07-30030 July 1999 Forwards Comments on Draft NRC Repts Evaluation of AOVs at Us Light-Water Reactors (1999) & Idaho Natl Engineering & Environ Lab Rept (INEEL)EXT-98-00383,Study of AOVs in Npps. ML17313B0431999-07-30030 July 1999 Advises of Listed Senior Mgt Changes That Have Taken Place at Plant ML17313B0151999-07-20020 July 1999 Submits Request to Obtain All Data Previously Sent by PVNGS & Currently in REIRS for OLs NPF-41,NPF-51 & NPF-74.Data Is Requested in Electronic Form (Ascii Format) as It Currently Exists in REIRS Sys ML17313B0091999-07-20020 July 1999 Forwards Requested Calculations Performed to Verify That Increase in Max Radially Averaged Enrichment for Fuel Assemblies from 4.3 Weight Percent to 4.8 Weight Percent Did Not Affect Requirements for TSs 3.7.15,3.7.17 & 4.3.1 ML17313B0171999-07-16016 July 1999 Forwards LER 99-005-00,re Automatic Rt Which Occurred on 990618,following Sensor Failure in Core Protection Calculators.Corrective Actions Described in LER Are Not Necessary to Maintain Compliance with Regulations ML17300B3111999-07-15015 July 1999 Forwards PVNGS Unit 2 ISI Rept for Eighth Refueling Outage. No Commitments Made to NRC by Ltr ML17300B3141999-07-15015 July 1999 Forwards Corrected Electronic Files for Individual Monitoring Repts for 1998.Original Electronic Files Were Found to Have Two Administrative Errors,Which Has Been Corrected.Encl Withheld,Per 10CFR2.790 ML20209G6771999-07-0808 July 1999 Forwards Supplemental Info to Confirm That Decommissioning Funding Plans of Public Service Co of Nm for Interests in PVNGS Have Been Reviewed by Nm Public Regulation Commission. Final Order & Recommended Decisions in Case 2742,also Encl ML17300B2931999-07-0202 July 1999 Submits Withdrawal of Relief 5 for Second ISI Interval for Units 1,2 & 3.Proposed Alternative Is Related to Exam Requirements for Component Supports for Second ISI Interval ML17313A9951999-06-26026 June 1999 Provides Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. ML17300B2831999-06-26026 June 1999 Requests NRC Approval of Proposed Alternative IAW Provisions of 10CFR50.55a(a)(3)(i) to 10CFR50.55a(g) & Requirements of ASME Boiler & Pressure Vessel Code Section XI for Repairs & Installation.Description of Proposed Alternative,Encl ML17313A9901999-06-15015 June 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs. No Commitments Being Made to NRC by Ltr ML17313A9521999-05-24024 May 1999 Notifies NRC That Ja Proctor,License SOP-50314,has Been Permanently Reassigned to Position That Does Not Require License.License Should Be Expired,Per 10CFR55.55 ML17313A9311999-05-13013 May 1999 Notifies NRC That Rev 2 to COLR for Unit 2 Remains Applicable Following Recently Completed Unit 2 Reload ML17313A9481999-05-12012 May 1999 Informs of Change Needed in Order to Update Current Mailing List.Future Mailings for J Horne Should Be Forwarded to Listed Address ML17313A9261999-05-0707 May 1999 Forwards LER 99-004-00,per 10CFR50.73.LER Repts Findings & Corrective Actions Taken as Result of Unit 2 Out of Tolerance Pressurizer Safety Valve (Psv) Condition Which Was Discovered During Outage Testing ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML17313A9191999-04-30030 April 1999 Forwards Special Rept 2-SR-99-001 Re SG Tube Plugging in PVNGS Unit 2,per TS Reporting Requirement 5.6.8.Complete Results of SG Tube Inservice Insp Will Be Submitted by 000422 ML17313A9181999-04-30030 April 1999 Forwards Electronic File of Individual Monitoring Repts for 1998.Encl Withheld Per 10CFR2.790 ML17313A9091999-04-30030 April 1999 Forwards Proprietary Proposed Test Outlines for Initial License Exams to Be Administered at PVNGS in Aug/Sept 1999. No Commitments Are Contained in Ltr.Proprietary Info Withheld ML17313A9081999-04-23023 April 1999 Documents 990421 Telcon with E Emeigh,Which Requested Extension for Submitting Next Matl Balance Rept for Pvngs,As Required by 10CFR70.53 & 74.13.Required Info Will Be Submitted by 990531 ML17300B3751999-04-23023 April 1999 Forwards LER 99-003-00,reporting Condition Prohibited by TS 3.7.17 Where Spent Fuel Assembly Was Stored in Inappropriate Region in Spent Fuel Pool ML17313B0271999-04-21021 April 1999 Forwards Proprietary Epec Pro Forma Cashflow Statement for 1999.Proprietary Info Withheld,Per 10CFR2.790.Affidavit Encl ML17313A9031999-04-21021 April 1999 Forwards Rev to Relief Request 12 Submitted 990420 to Second 10-yr ISI Interval.Revised Relief Request Discusses in More Detail Actions APS Will Take When There Is Identified Leakage from Bolted Connection ML17313A8971999-04-20020 April 1999 Requests Use of Alternatives to 10CFR50.55a(g) Inservice Insp Requirements.Proposed Alternatives Are Related to Visual Exam of Bolted Connections 05000529/LER-1999-002, Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing1999-04-19019 April 1999 Forwards LER 99-002-00 Re Findings & Corrective Actions Taken as Result of Plant Out of Tolerance MSSV Condition Which Was Discovered During pre-outage Testing ML17313A8931999-04-14014 April 1999 Forwards LER 99-003,reporting Condition Prohibited by TSs That Existed When Surveillance Requirement to Verify Essential Chilled Water Sys Valve Positions Was Not Met ML20205Q0821999-04-13013 April 1999 Forwards Second ISI Interval Relief Request 10 from ASME Section XI & Applicable Addenda Re Visual Exams Performed Subsequent to Repair or Replacement of Component or Alteration of Item ML17313A8901999-04-13013 April 1999 Forwards LER 98-003-01 Re MSSV as-found Lift Pressures out- Side of TS Limits.Ler Suppl Provides Evaluation Findings from Unit 3 out-of-tolerance MSSVs Conditions Which Were Discovered During pre-outage Testing ML17313A8831999-04-0808 April 1999 Forwards 1998 Annual Radioactive Effluent Release Rept for Pvngs,Units 1,2 & 3 & Rev 13 to ODCM, for Pvngs,Units 1,2 & 3 IAW TS 5.6.3 ML20205F3491999-03-30030 March 1999 Forwards Proprietary & non-proprietary Info Re Status of Decommissioning Funding for Pvngs,Units 1,2 & 3,per 10CFR50.75(f)(1).Proprietary Info Withheld,Per Requirements of 10CFR2.790(b)(1) ML17313A8671999-03-24024 March 1999 Submits Info Re Present Levels & Sources of Property Insurance Maintained for Pvngs,Per 10CFR50.54(w)(3) ML17313A8601999-03-16016 March 1999 Forwards Revised Relief Requests PRR-05,PRR-06 & PRR-11 to Clarify That Proposed Design Flow Testing for Lpsi,Hpsi & Containment Spray Pumps Will Be Performed Using Instruments That Comply with Code Requirements,Per 990226 Telcon ML17313A8551999-03-0505 March 1999 Requests Proposed Code Alternative IAW 10CFR50.55a(e)(3),as Acceptable Alternative to Requirements of 10CFR50.55a(e)(1), for Installation of in-line safety-related Flow Measurement Instrument in ASME Class 3 Pipe ML17313A8241999-02-23023 February 1999 Advises That Kp Jarvis,License OP-50287-1,no Longer Needs to Maintain License as Permanently Assigned to Position Requiring No License ML17313A8111999-02-18018 February 1999 Forwards PVNGS Unit 3 7th Refueling Outage, Which Provides Complete Results of SG Tube Inservice Insp Performed,Per TS 5.6.8 ML17313A8721999-02-16016 February 1999 Discusses Resolution of Generic Safety Issue 171, ESF Failures from Loss-of-Offsite Power Subsequent to Loca. Util Has Low Vulnerability to Loca/Grid Collapse/Loop Scenario ML17313A7611999-01-22022 January 1999 Forwards PVNGS Unit 3 Inservice Insp Rept Seventh Refueling Outage, Per 10CFR50.55a.Ltr Contains No New Commitments 1999-09-08
[Table view] |
Text
"0 Ik RECEIVED RECEIVED HRC NRC Arizona Public Service Company 'EGION REGION '/ Y
"""' '"""'"""'"'"'""WP"" ~<<"'92-II PALO VERDE NUCLEAR GENERATING STATION 27 IO >Z 102-02251-JML/TR8/NLT JAMES M. LEVINE August'20, 1992 VICE PRESIDENT NUCLEAA PRODUCTION Mr. John B. Martin Regional Administrator, Region V U. S. Nuclear Regulatory Commission t 1450 Maria Lane, Suite 210 ~ g~ ~a >< ~ ~
Walnut Creek, CA 94596-5368
Dear Mr. Martin:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Revision 1 to the Justification for Continued Operation-Steam Generator Tube Rupture Analysis Concerns (JCO-91-02-01)
File: 92-056-026 Please find enclosed for your information a copy of Revision 1 to the Justification for Continued Operation (JCO) for Steam Generator Tube Rupture Analysis Concerns.
Revision 1 to the subject JCO was issued for Palo Verde Units 1, 2, and 3 to administratively limit the Reactor Coolant System dose equivalent Iodine-131 to 0.6 pCi/gm. The need for this JCO, as detailed in the body of the JCO, was originally discussed with NRR PVNGS Senior Project Manager Charlie Trammell and Resident Inspector James Sloan in January 1992. A telecon was held with the NRC to discuss the issuance of Revision 1 in July 1992.
If you have any questions, please contact Thomas R. Bradish at (602) 393-5421.
Sincerely, JML/TRB/NLT/pmm Enclosure cc: C. M. Trammell J. A. Sloan A. H, Gutterman A. C. Gehr Document Control Desk 040016
<<1 ENCLOSURE REVISION 1 TO THE JUSTIFICATION FOR CONTINUED OPERATION STEAM GENERATOR TUBE RUPTURE ANALYSIS CONCERNS (JCO-91-02-01)
21240CARev 2.99 Xl90.900r2l Iaxrggr COMPANY CORRESPONDENCE IO iran 102-02218-TRB/NLT OATE: July 29r 1992
(
TO:
Sia. a: File Ext.:
FROM Sia. <<
Ext.
T. R. Bradish 82-5421 y ~~+'636 FILE:
SUBJECT.'2-177-419 Revision 1 to the Steam Generator Tube Rupture Analysis Concerns JustiTication for Continued Operation (JCO), JCO-91-02-01 (Units 1, 2 and 3)
Revision 1 to the Steam Generator Tube Rupture Analysis Concerns Justification for Continued Operation increases the administrative control on dose-equivalent Iodine-131 from 0.4 pCi/gm to 0.6 pCi/gm. An evaluation performed subsequent to the initial issue of JCO (91-02-00) determined that an administrative limit of 0.6 pCi/gm will provide the compensatory measure to ensure dose consequences will remain under the 10 'ecessary CFR Part 100 dose limits of less than 30 Rem (GIS) during a postulated SGTR + LOP.
The original limit of 0.4 pCi/gm required by Revision 0 of this JCO was chosen as the limit in January, 1992, because the limit was imposed on Unit 1 as a compensatory measure in support of the Interfacing System Loss of Coolant Accident (ISLOCA) JCO.
On October 24, 1991, Arizona Public Service Company (APS) internal validation efforts for the upgraded Emergency Operating Procedures (EOPs) identified a concern that early (relative to no operator action for 30 minutes currently assumed) operator actions could result in more steaming during the first 30 minutes of a Steam Generator Tube Rupture (SGTR) than is currently reQected in UFSAR Section 15.6.3.1, and which could result in correspondingly higher offsite doses. This concern was documented in Condition Report/Disposition Request (CRDR) 9-1-0236. Subsequent investigation determined that a Steam Generator Tube Rupture with Loss of Offsite Power (SGTR+LOP), without a single failure, could result in doses higher than those reported for a SGTR+LOP. in CESSAR Section 15.6.3.2. UFSAR Section 15.6.3 reports dose consequences resulting from a SGTR with offsite power available, and for a SGTR+LOP with a single failure (SF), but not for a SGTR+LOP.
A review of the licensing submittals and corresponding safety evaluation reports (SERs) for SGTR events determined that, following NRC review of the CESSAR SGTR and SGTR+LOP analy'ses, Palo Verde Nuclear Generating Station (PVNGS) was required to reanalyze the SGTR+LOP event with a limiting single failure, as documented in UFSAR Section 15.6.3.2. The PVNGS FSAR originally referenced CESSAR for the
Memo to File Page 2 SGTR and SGTR+LOP events. In 1988, UFSAR Section 15.6.3 was amended to replace the reference to CESSAR SGTR+LOP with the SGTR+LOP with single failure analysis from UFSAR Appendix 15A, although it is not clear why the SGTR+LOP case was removed. Hence, there exists some confusion as to the PVNGS licensing basis for a SGTR+LOP (without a single failure). In the absence of a clearly defmed PVNGS licensing basis for a SGTR+LOP, the Standard Review Plan 15.6.3 (SRP) acceptance criteria is deemed to apply.
An engineering evaluation of the radiological consequences of the postulated SGTR+LOP, incorporating operator actions consistent with both current and upgraded EOPs, was performed. Using the CESSAR assumptions for steam generator flashing and partitioning, and dispersion factors consistent with the UFSAR Section 15.6.3.2 (SGTR+LOP+SF) analysis, the evaluation results are well within the SRP 15.6.3 criteria and 10 CFR Part 100'limits (refer to Table 2, Case 4 on page 16 of the attached JCO),
though they exceed the corresponding values documented in CESSAR Section 15.6.3.
The evaluation was also performed using the more conservative UFSAR assumptions for steam generator Gashing and partitioning, By applying the compensatory action of limiting Reactor Coolant System (RCS) dose equivalent Iodine-131 to 0.6 pCi/gm, the offsite doses were verified to be in compliance with the 10 CFR Part 100 dose limits and within the acceptance criteria of SRP 15.6.3 (refer to Table 2, Case 1 on page 16 of the attached JCO). Hence, continued operation of PVNGS Units 1, 2, and 3 under the current Emergency Operating Procedures is justified.
The 0.4 pCi/gm administrative limit is, therefore, increased to 0.6 p,Ci/gm for Units 1, 2, and 3, as set forth in Revision 1 to the SGTR JCO. The above limit does not supercede the more restrictive limit of 0.2 pCi/gm currently imposed on PVNGS Units 2 and 3 for the ISLOCA JCO.
Attached is the Justification for Continued Operation; Steam Generator Tube Rupture Analysis Concerns, JCO-91-02-01, which documents the detailed safety evaluation and demonstrates that continued operation will not adversely affect the health and safety of the public. The compensatory action will remain in effect until it is demonstrated that the FSAR analyses envelope those actions that the operators may take in accordance with the EOPs. This may require changes to the EOPs, possible reanalysis and UFSAR changes.
TRB/NLT/rit Attachment