ML19276E277

Opposes Suggested Changes in Stations' Design to Implement NUREG-0460,Vol 3.Requests Reconsideration in Light of Standardization Program & Industry Support

ML19276E277
Person / Time
Site:	Palo Verde
Issue date:	03/07/1979
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Parr O Office of Nuclear Reactor Regulation
References
PVNGS250-JMA-DB, NUDOCS 7903120255
Download: ML19276E277 (3)

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,v P. O. B O X 216 6 6 PH OE NI X, Af IZON A 8 5036 March 7. 1979 PVNGS-250-JMA/CBK Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Olan D. Parr, Chief Light Water Re'.ctor Branch No. 3 RE: Palo Verde Nuclear Generating Station Units 4 & 5 - Dockets Nos. STN-50-592/593

Reference:

(1) Letter PVilGS-245 dated Februery 28, 1979 (2) Letter from Olan D. Parr, USNRC, to E. E.

Van Brunt, Jr., Arizona Public Service Company, dated February 14, 1979

Dear Mr. Parr:

As stated in Reference (1) attached, Arizona Public Service Company strongly objects to the conclusions and recommendations reached in the Regulatory Requirements Review Committee Meeting No. 81 on January 2,1979. It is our position that PVNGS 4 & 5, as replicate units, should be identical to PVNGS 1, 2 & 3.

Your letter, Reference (2), asks that we provide a committment that PVNGS 4 & 5 will be deaigned such that implementation of NUREG-0460, Volume 3, Alternr.tive 4, will not be precluded. The design of PVNGS 4 & 5 is essentially complete in the areas of concern with ATWS, as the PVNGS 4 & 5 design is a replication of the PVNGS 1, 2 & 3 design. The PVNGS design does not include provisions for implementation of Alternative 4 of NUREG-0460 Volume 3. Modifications to the PVNGS 4 F. 5 design would be necessary to incorporate provisions for Alternative 4, making the PVNGS 4 & 5 design substantully different than the PVNGS 1, 2 & 3 design. The current PVNGS design does not, however, preclude these modifications.

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Director of Nuclear Reactor Regulation PVNGS-250-JMA/DBK March 7,1979 Page Two We strongly oppose this and any changes that would cause the PVNGS 4 & 5 design to be different than the PVNGS 1, 2 & 3 design. It is our hope that careful consideration be given to the implementation of NUREG-0460 Volume 3 with respect to the standardization program and industry support for it.

Very truly ours,

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• E. E. Van Brunt, Jr.

APS Vice President Nuclear Projects ANPP Project Director EEVBJr/DBK/cjw cc: List Attached

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Robert M. Lazo, Esq. , Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U. S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Commission Gilinsky Docketing and Service Section U. S. Nuclear Regulatory V. S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Cuentin J. Stober Vincent MacKenzie, Esq.

Research Associate Professor Janice E. Kerr, Esq.

Fisheries Research Institute J. Calvin Simpson, Esq.

University of Washington California Public Utilities 400 Northeast 15th Avenue Commission Seattle, Washington 98195 5066 State Building San Francisco, California 94102 Mr. Larry Bard Steven Schinki P. O. Box 793 Counsel for NRC Staff Tempe, Arizona 85281 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 George Campbell, Chairman Michael M. Grant Maricopa County Board of Assistant Attorney General Supervisors 200 State Capitol 111 South Third Avenue 1700 West Washington Phcanix, Arizona 85004 Phoenix, Arizona 85007 Donald G. Gilbert Kathryn Burkett Dickson Executive Director Mark J. Urban Arizona Atomic Energy Commission Counsels for the California 2929 West Indian School Road Energy Resources Conservation Phoenix, Arizona 85017 and Development Commission 111 Howe Avenue Sacramento, California 95825 Tom Diamond Allan R. Watts 1208 First National Bank Bldg. Rourke & Woodruff El Paso, Texas 79901 1055 N. Main Street, Suite 1020 Santa Anna, California 92701

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h EFnDul.1 y & PML2D u= Lev 2m=1 DwirPmtz k P. C. BOX 2f666 PH OE NI X. A AlZO N A BEO36 February 28, 1979 PVNGS-245-JMA/DBK Director of Nuclear Reactor Regulation U.S. iiuclear Regulatory Cc=1ission Washington, D.C. 20555 Attention: Mr. Harold R. Denton, Director

Reference:

Palo Verde Nuclear Generatino Station Units 4 & 5, Dc;:ket No. STN-50-592/593

Dear Mr. Denton:

We have reviewed MUREG-0250 Volume 3, dated December 1978, and the su=ary of the Regulatory Requirements Revie'.. Conmittee (RRRC) Meeting No. 81 dated January 2,1979, in which the RRRC recommended a different AT'.4S modification for PViiGS 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-04E0 Volume 3. He 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 Ccapany 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. He also support Combustion Engineering's recom .endation to the Director, Office of Nuc' ear Reactor Regulation, that if design modifications are to be required of the CESSAR design, such modifications should ccasist of a Supplerentary Protec-tion System (SPS) and be applied unifomly 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 agrecd upon by APS and the NRC staff, these changes would be replicatqd on PVNGS 4 & 5, main-taining all five units identical, This approach 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 sulaitting a custom application.

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Director of Nuclear Reactor Regulation PV"GS-245-JMA/E3K February 28, 1979 Page Two Arizona Public Service Ccmcany strongly objects to and wishes to appeal the conclusions and recomr.endations reached in the RRRC Meetina No. 81 dated January 2,1979, regarding the recommendation that Alternate 4 be applied to PVNGS Units 4 3 5. We feel that if implemented, this approach would be an abandonment 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,

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E. E. Van Brunt, Jr.

APS Vice President Nuclear Projects ANPD Project Director EEYBJr/D3K/cjw bcc: R. L. Robb A. C. Gehr D. B. Karner A. C. Rogers W. H. Wilson W. G. Bingham D. G. Keith F. W. Hartley C. E. Ferguson W. L. MacDonald W. F. Ouinn J. P. Shrewsb.erry *

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