ML061710465

Request for Additional Information Regarding Technical Specification Amendment Submittal (TAC Nos. MC9425, MC9426, and MC9427)

ML061710465
Person / Time
Site:	Palo Verde
Issue date:	06/23/2006
From:	Fields M B NRC/NRR/ADRO/DORL/LPLG
To:	Levine J M Arizona Public Service Co
Fields M B , NRR/ADPT,415-3062
References
TAC MC9425, TAC MC9426, TAC MC9427
Download: ML061710465 (6)

Text

June 23, 2006Mr. James M. Levine Executive Vice President, Generation Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION AMENDMENT SUBMITTAL (TAC NOS. MC9425, MC9426, AND MC9427)

Dear Mr. Levine:

By letter dated December 23, 2005, Arizona Public Service Company submitted a licenseamendment request for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3. Therequest is to extend the allowed out-of-service time for one inoperable emergency diesel generator from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 10 days, add a clarifying note to Condition F of Technical Specification (TS) 3.8.1, "AC [alternating current] Sources - Operating," and revise TS 3.4.9,"Pressurizer," to delete the words which require that the two groups of pressurizer heaters be capable of being powered from an emergency power supply.The Nuclear Regulatory Commission (NRC) staff has reviewed the information provi ded anddetermined that additional information is required in order to complete the evaluation. The additional information being requested is enclosed. As discussed with Glenn Michael of your staff, the NRC staff is requesting a response within 30 days of the date of this letter.If you have any questions, please contact me at 301-415-3062.Sincerely,

/RA/Mel B. Fields, Senior Project ManagerPlant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos: STN 50-528, STN 50-529 and STN 50-530

Enclosure:

Request for Additional Information cc w/encl: See next page June 23, 2006Mr. James M. Levine Executive Vice President, Generation Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION AMENDMENT SUBMITTAL (TAC NOS. MC9425, MC9426, AND MC9427)

Dear Mr. Levine:

By letter dated December 23, 2005, Arizona Public Service Company submitted a licenseamendment request for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3. Therequest is to extend the allowed out-of-service time for one inoperable emergency diesel generator from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 10 days, add a clarifying note to Condition F of Technical Specification (TS) 3.8.1, "AC [alternating current] Sources - Operating," and revise TS 3.4.9,"Pressurizer," to delete the words which require that the two groups of pressurizer heaters be capable of being powered from an emergency power supply.The Nuclear Regulatory Commission (NRC) staff has reviewed the information provi ded anddetermined that additional information is required in order to complete the evaluation. The additional information being requested is enclosed. As discussed with Glenn Michael of your staff, the NRC staff is requesting a response within 30 days of the date of this letter.If you have any questions, please contact me at 301-415-3062.Sincerely,

/RA/Mel B. Fields, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos: STN 50-528, STN 50-529 and STN 50-530

Enclosure:

Request for Additional Information cc w/encl: See next pageDISTRIBUTION

PUBLICLPLIV ReadingRidsNrrDorlDpr RidsNrrDorlLpl4RidsRgn4MailCenter (TPruett)RidsAcrsAcnwMailCenterRidsNrrLALFeizollahi RidsNrrPMMFieldsRidsOgcRpADAMS ACCESSION NO: ML061710465OFFICELPL4/PMLPL4/LALPL4/BCNAMEMFieldsLFeizollahiDTerao DATE06/22/0606/22/0606/23/06OFFICIAL RECORD COPY REQUEST FOR ADDITIONAL INFORMATION ARIZONA PUBLIC SERVICE COMPANY, ET AL.PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530By letter dated December 23, 2005, Arizona Public Service Company submitted a licenseamendment request for the Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3. The request is to extend the allowed out-of-service time (AOT) for one inoperable emergency diesel generator (EDG) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 10 days, add a clarifying note to Condition F of Technical Specification (TS) 3.8.1, "AC [alternating current] Sources - Operating," and reviseTS 3.4.9, "Pressurizer," to delete the words which require that the two groups of pressurizerheaters be capable of being powered from an emergency power supply.The staff has reviewed the information provided and determined that the following additionalinformation is required in order to complete the evaluation. 1.Provide a qualitative or quantitative assessment of the following risk changes:-Information on risk-important components and configuration that will be affectedby the proposed extension, including Diesel Fuel Oil and Pressurizer Heaters.-Please provide a brief discussion and related information regarding the riskquantification tool.-Provide a discussion of the probabilistic risk assessment (PRA) quality, withemphasis on the system(s) and train(s) affected by the amendment. Thediscussion may include parametric uncertainty.-Please provide relative risk impact on incremental conditional core damageprobability (ICCDP) and incremental conditional large early release probability(ICLERP), using zero maintenance model versus regular model with baseline test/maintenance activities.-Are there any compensatory measures to mitigate the potential risk increasesdue to the amendment? If so, provide a discussion of the proposed compensatory measures and the associated benefit in both quantifiable and non-quantifiable terms.-Provide a brief discussion of the plant configuration control program and the on-line risk monitor.2.Your risk assessment in the submittal was based on internal events only. Discuss theimpact of potential external events and risk contributors, such as fire. 3.On page 17 of Enclosure 2 you state that your ICCDP would exceed the RegulatoryGuide (RG) guideline. The intent in making the comparison of the PRA results with RG 1.177 is to demonstrate, with reasonable assurance, that Principle 4 in the "Discussion" section of RG 1.177 is being met. Please discuss how Principle 4 is being met.4.In Table 3, Enclosure 2 of your request letter, you have recalculated internal event coredamage frequency based on your new reliability number. However, Table 2 of theenclosure clearly indicated that the plant risk (ICCDP) under the proposed amendmentwould increase by 6.44E-7 and 6.05E-7 for EDG A and EDG B, respectively. With this proposed TS change, it appears that the risk would increase by 6.44E-7/yr and 6.05E-7/yr, respectively, by annualizing the ICCDP for one year. Please explain these results.5.In your reliability recalculation presented in the second paragraph of page 17 ofEnclosure 2, the increase of the actual unavailability was assumed as 5.5 days insteadof the 10-day proposed extension. The 5.5 days of maintenance outage discussedimplies that the TS AOT will be used as a part of your routine online maintenanceactivities. Please explain.6.Please discuss the impacts of the uncertainties and risk contributors for both thoseexplicitly accounted for in the results and those that were not.7.According to your risk assessment, EDG A has higher risk importance than that ofEDG B. Please Explain.8.What are the risk assessment methodologies (such as FIVE) that you have employedfor fire? Have you considered providing fire watch during the proposed AOT period?9.As a part of maintenance activities associated with EDGs, is this extension a part of theroutine maintenance activities? Please elaborate.10.In diesel generator reliability, have you evaluated the Maintenance Preventable FunctionFailure (MPFF) under the 50.65 maintenance rule? If so, have you incorporated the MPFF in your EDG reliability? 11.How does this extension impact the station blackout (SBO) sequences? Please discussyour reliability program in general and specifically the ability and timing of the EDGs torecover from an SBO event.

Palo Verde Generating Station, Units 1, 2, and 3 cc:March 2006Mr. Steve OleaArizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007Mr. Douglas Kent PorterSenior Counsel Southern California Edison Company Law Department, Generation Resources

P.O. Box 800 Rosemead, CA 91770Senior Resident InspectorU.S. Nuclear Regulatory Commission

P. O. Box 40 Buckeye, AZ 85326Regional Administrator, Region IVU.S. Nuclear Regulatory Commission Harris Tower & Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064ChairmanMaricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003Mr. Aubrey V. Godwin, DirectorArizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040Mr. Craig K. Seaman, General ManagerRegulatory Affairs and Performance Improvement Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034Mr. Matthew BenacAssistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004Mr. John TaylorPublic Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224Mr. Thomas D. ChampSouthern California Edison Company 5000 Pacific Coast Hwy Bldg D1B San Clemente, CA 92672Mr. Robert HenrySalt River Project 6504 East Thomas Road Scottsdale, AZ 85251Mr. Jeffrey T. WeikertAssistant General Counsel El Paso Electric Company Mail Location 167 123 W. M illsEl Paso, TX 79901Mr. John SchumannLos Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100Mr. Brian AlmonPublic Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326Ms. Karen O'ReganEnvironmental Program Manager City of Phoenix Office of Environmental Programs 200 West Washington Street Phoenix AZ 85003