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| | ACCESSION NBR:9711260157 DOC.DATE: 97/11/14 NOTARIZED: NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona-,'Publi 05000528 |
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| | e STN-i50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION LEVINE,J.MD Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME'ECIPIENT AFFILIATION NRC - No Detailed Affiliation Given |
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| | ==SUBJECT:== |
| | Expresses concern over change to NRC schedule for approval & |
| | issuance of improved TS amend for plant.PVNGS implementation plan encl. |
| | DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE: |
| | TITLE: OR Submittal: General Distribution NOTES:STANDARDIZED PLANT 05000528 g Standardized plant. 05000529 Standardized plant. 05000530 p R |
| | RECIPIENT COPIES,, RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD4-2 LA 1' PD4-2 PD 1 1 CLIFFORD,J 1 1 INTERNAL: ACRS 1 1 1 1 NRR/DE/ECGB/A 1 1 NRR/DE/EMCB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SCSB 1 0 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 D NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL: NOAC 1 0 |
| | 1 NRC PDR 1 1 C |
| | NOTE TO ALL "RIDS" RECIPZENTS: |
| | PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPZES RECEIVED BY YOU OR YOUR ORGANIZATION CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 15 ENCL 13 |
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| | James M. Levine TEL (602)393-5300 Mail Station 7602 Palo Verde Nuclear Senior Vice President FAX (602)3936077 P.O. Box 52034 Generating Station Nuclear Phoenix, AZ 65072-2034 102-04039 - JML/SAB/TNW November 14, 1997 Mr. L. J. Callan U.S. Nuclear Regulatory Commission Mail Station 5 E6 11555 Rockville, Pike Rockville, MD 20852-2738 |
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| | ==Dear Mr. Callan:== |
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| | ==Subject:== |
| | Palo Verde Nuclear Generating Station (PVNGS) |
| | Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Improved Technical Specifications (ITS) |
| | We would like to express our concern over a change to the NRC schedule for approval and issuance of the ITS Amendment for PVNGS. The NRC's Standard Technical Specification Conversion Schedule was revised on September 2, 1997 changing the scheduled date for issuance of the PVNGS ITS Amendment from November of 1997 to June of 1998. This is the second time the NRC has extended the schedule since the original submittal of the PVNGS ITS amendment |
| | . request. The extension of the schedule is of concern because the revised schedule significantly impacts our implementation plan. We met with NRC staff on Tuesday, September 16, 1997 to discuss our concern with the revised schedule and were told that the schedule we requested to support our implementation plan could not be met by the NRC. |
| | Our ITS amendment request was submitted to the NRC in October of 1996 making it fourth in order of the 17 current submittals with the NRC. Following submittal, PVNGS performed a sitewide impact review and developed a comprehensive ITS Implementation Plan. In our letter 102-03954 dated June 6, 1997, we requested NRC review and approval of the ITS prior to December of 1997. This request was predicated upon having an approved final document on which we could base final procedures, programs and, most significantly, training. Enclosed is a listing of key milestones from our implementation plan beginning with issuance of the final safety evaluation report. This schedule is not unreasonable in view of the Unit 1 refueling outage in March and April. |
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| | U.S. Nuclear Regulatory Commission Improved Technical Specifications Schedule Page 2 Our implementation plan incorporated lessons learned from our own internal experiences with major project efforts and from ITS experiences at other utilities. |
| | From these reviews we concluded that implementation is most efficient and has the least potential for error when all associated documents are in place prior to implementation. Additionally, we believe it is vitally important that training on the new Technical Specifications and associated documents be conducted with all documents in final form due to the significance of the change being made. |
| | The current scheduled date for PVNGS ITS implementation is July 15, 1998 for the three (3) units. This date was selected because all three units will be at power between refueling outages. With a three unit site, outages occur every six months placing unique limitations on the opportunities available for ITS implementation. |
| | The change in the NRC schedule for issuance of the ITS will result in at least a six month delay in implementation. |
| | APS agreed to converting to the ITS with full recognition of the cost and plant impact based on strong urging from the NRC. In turn, we expect support from the NRC to ensure the ITS can be implemented successfully. It troubles us to be told that resources will be taken off our amendment request, which is very nearly complete, to be redirected to other conversion efforts submitted well after ours. As noted above, our amendment request has been with the NRC for over a year now. |
| | We prepared a high quality submittal and have been responsive to NRC questions and requests for additional information. We are aware of and appreciate the efforts within Reactor Projects to support completion of the draft safety evaluation. |
| | We understand that the final safety evaluation will not be issued prior to the previously agreed upon date of December 31, 1997. We believe, however, that our efforts toward a successful implementation will not be adversely impacted if the draft safety evaluation is received by January 31, 1998. This schedule would be acceptable as we envision the draft safety evaluation would represent an essentially final product with no significant open items. |
| | We believe extending the schedule further will also result in even higher review costs. It was originally estimated by the NRC that review fees for ITS amendments would be approximately $ 150,000. To date, we have expended over $ 440,000. |
| | To extend the date further will only cause the cost to go even higher. |
| | Please contact me at (602) 393-5300 if you have any questions or would like additional information regarding this matter. |
| | Sincerely, JML/SAB/TNW/mah |
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| | Mr. L. J. Callan i |
| | U.S. Nuclear Regulatory Commission Improved Technical Specifications Schedule Page 3 cc: S. J. Collins E. W. Merschoff R. P. Zimmerman E. G. Adensam K. E. Perkins W. H. Bateman K. M. Thomas J. H. Moorman M. B. Field A. V. Godwin W. D. Beckner Document Control Desk |
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| | ENCLOSURE PVNGS Implementation Plan Key Milestones |
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| | L' PVNGS Implementation Plan Key Milestones Final Safety Evaluation Report Requested December 1997 Technical Changes to Procedures and Programs Finalized February 1998 Unit 1 Seventh Refueling Outage Schedule March - May 1998 ITS Training - 2 Operations Training Cycles May - June 1998 ITS Implementation Date July 15 1998 Unit 3 Seventh Refueling Outage Schedule September November 1998 |
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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
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CATEGORY REGULA RY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9711260157 DOC.DATE: 97/11/14 NOTARIZED: NO DOCKET FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona-,'Publi 05000528
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e STN-i50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION LEVINE,J.MD Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME'ECIPIENT AFFILIATION NRC - No Detailed Affiliation Given
SUBJECT:
Expresses concern over change to NRC schedule for approval &
issuance of improved TS amend for plant.PVNGS implementation plan encl.
DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR Submittal: General Distribution NOTES:STANDARDIZED PLANT 05000528 g Standardized plant. 05000529 Standardized plant. 05000530 p R
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James M. Levine TEL (602)393-5300 Mail Station 7602 Palo Verde Nuclear Senior Vice President FAX (602)3936077 P.O. Box 52034 Generating Station Nuclear Phoenix, AZ 65072-2034 102-04039 - JML/SAB/TNW November 14, 1997 Mr. L. J. Callan U.S. Nuclear Regulatory Commission Mail Station 5 E6 11555 Rockville, Pike Rockville, MD 20852-2738
Dear Mr. Callan:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Improved Technical Specifications (ITS)
We would like to express our concern over a change to the NRC schedule for approval and issuance of the ITS Amendment for PVNGS. The NRC's Standard Technical Specification Conversion Schedule was revised on September 2, 1997 changing the scheduled date for issuance of the PVNGS ITS Amendment from November of 1997 to June of 1998. This is the second time the NRC has extended the schedule since the original submittal of the PVNGS ITS amendment
. request. The extension of the schedule is of concern because the revised schedule significantly impacts our implementation plan. We met with NRC staff on Tuesday, September 16, 1997 to discuss our concern with the revised schedule and were told that the schedule we requested to support our implementation plan could not be met by the NRC.
Our ITS amendment request was submitted to the NRC in October of 1996 making it fourth in order of the 17 current submittals with the NRC. Following submittal, PVNGS performed a sitewide impact review and developed a comprehensive ITS Implementation Plan. In our letter 102-03954 dated June 6, 1997, we requested NRC review and approval of the ITS prior to December of 1997. This request was predicated upon having an approved final document on which we could base final procedures, programs and, most significantly, training. Enclosed is a listing of key milestones from our implementation plan beginning with issuance of the final safety evaluation report. This schedule is not unreasonable in view of the Unit 1 refueling outage in March and April.
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U.S. Nuclear Regulatory Commission Improved Technical Specifications Schedule Page 2 Our implementation plan incorporated lessons learned from our own internal experiences with major project efforts and from ITS experiences at other utilities.
From these reviews we concluded that implementation is most efficient and has the least potential for error when all associated documents are in place prior to implementation. Additionally, we believe it is vitally important that training on the new Technical Specifications and associated documents be conducted with all documents in final form due to the significance of the change being made.
The current scheduled date for PVNGS ITS implementation is July 15, 1998 for the three (3) units. This date was selected because all three units will be at power between refueling outages. With a three unit site, outages occur every six months placing unique limitations on the opportunities available for ITS implementation.
The change in the NRC schedule for issuance of the ITS will result in at least a six month delay in implementation.
APS agreed to converting to the ITS with full recognition of the cost and plant impact based on strong urging from the NRC. In turn, we expect support from the NRC to ensure the ITS can be implemented successfully. It troubles us to be told that resources will be taken off our amendment request, which is very nearly complete, to be redirected to other conversion efforts submitted well after ours. As noted above, our amendment request has been with the NRC for over a year now.
We prepared a high quality submittal and have been responsive to NRC questions and requests for additional information. We are aware of and appreciate the efforts within Reactor Projects to support completion of the draft safety evaluation.
We understand that the final safety evaluation will not be issued prior to the previously agreed upon date of December 31, 1997. We believe, however, that our efforts toward a successful implementation will not be adversely impacted if the draft safety evaluation is received by January 31, 1998. This schedule would be acceptable as we envision the draft safety evaluation would represent an essentially final product with no significant open items.
We believe extending the schedule further will also result in even higher review costs. It was originally estimated by the NRC that review fees for ITS amendments would be approximately $ 150,000. To date, we have expended over $ 440,000.
To extend the date further will only cause the cost to go even higher.
Please contact me at (602) 393-5300 if you have any questions or would like additional information regarding this matter.
Sincerely, JML/SAB/TNW/mah
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Mr. L. J. Callan i
U.S. Nuclear Regulatory Commission Improved Technical Specifications Schedule Page 3 cc: S. J. Collins E. W. Merschoff R. P. Zimmerman E. G. Adensam K. E. Perkins W. H. Bateman K. M. Thomas J. H. Moorman M. B. Field A. V. Godwin W. D. Beckner Document Control Desk
ENCLOSURE PVNGS Implementation Plan Key Milestones
L' PVNGS Implementation Plan Key Milestones Final Safety Evaluation Report Requested December 1997 Technical Changes to Procedures and Programs Finalized February 1998 Unit 1 Seventh Refueling Outage Schedule March - May 1998 ITS Training - 2 Operations Training Cycles May - June 1998 ITS Implementation Date July 15 1998 Unit 3 Seventh Refueling Outage Schedule September November 1998
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