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 NRC/NRR/ADRO/DORL/LPLG
To:	James M. Levine Arizona Public Service Co
Fields M , NRR/ADPT,415-3062
References
TAC MC9425, TAC MC9426, TAC MC9427
Download: ML061710465 (6)

Text

June 23, 2006 Mr. 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 license amendment request for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The request 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 provided and determined 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 Regulation Docket Nos: STN 50-528, STN 50-529 and STN 50-530

Enclosure:

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

June 23, 2006 Mr. 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 license amendment request for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3. The request 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 provided and determined 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 Regulation Docket Nos: STN 50-528, STN 50-529 and STN 50-530

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

PUBLIC LPLIV Reading RidsNrrDorlDpr RidsNrrDorlLpl4 RidsRgn4MailCenter (TPruett)

RidsAcrsAcnwMailCenter RidsNrrLALFeizollahi RidsNrrPMMFields RidsOgcRp ADAMS ACCESSION NO: ML061710465 OFFICE LPL4/PM LPL4/LA LPL4/BC NAME MFields LFeizollahi DTerao DATE 06/22/06 06/22/06 06/23/06 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION ARIZONA PUBLIC SERVICE COMPANY, ET AL.

PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530 By letter dated December 23, 2005, Arizona Public Service Company submitted a license amendment 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 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 staff has reviewed the information provided and determined that the following additional information 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 affected by the proposed extension, including Diesel Fuel Oil and Pressurizer Heaters.

- Please provide a brief discussion and related information regarding the risk quantification tool.

- Provide a discussion of the probabilistic risk assessment (PRA) quality, with emphasis on the system(s) and train(s) affected by the amendment. The discussion may include parametric uncertainty.

- Please provide relative risk impact on incremental conditional core damage probability (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 increases due 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 the impact 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 Regulatory Guide (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 core damage frequency based on your new reliability number. However, Table 2 of the enclosure clearly indicated that the plant risk (ICCDP) under the proposed amendment would 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 of Enclosure 2, the increase of the actual unavailability was assumed as 5.5 days instead of the 10-day proposed extension. The 5.5 days of maintenance outage discussed implies that the TS AOT will be used as a part of your routine online maintenance activities. Please explain.

6. Please discuss the impacts of the uncertainties and risk contributors for both those explicitly accounted for in the results and those that were not.

7. According to your risk assessment, EDG A has higher risk importance than that of EDG B. Please Explain.

8. What are the risk assessment methodologies (such as FIVE) that you have employed for 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 the routine maintenance activities? Please elaborate.

10. In diesel generator reliability, have you evaluated the Maintenance Preventable Function Failure (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 discuss your reliability program in general and specifically the ability and timing of the EDGs to recover from an SBO event.

Palo Verde Generating Station, Units 1, 2, and 3 cc:

Mr. Steve Olea Mr. John Taylor Arizona Corporation Commission Public Service Company of New Mexico 1200 W. Washington Street 2401 Aztec NE, MS Z110 Phoenix, AZ 85007 Albuquerque, NM 87107-4224 Mr. Douglas Kent Porter Mr. Thomas D. Champ Senior Counsel Southern California Edison Company Southern California Edison Company 5000 Pacific Coast Hwy Bldg D1B Law Department, Generation Resources San Clemente, CA 92672 P.O. Box 800 Rosemead, CA 91770 Mr. Robert Henry Salt River Project Senior Resident Inspector 6504 East Thomas Road U.S. Nuclear Regulatory Commission Scottsdale, AZ 85251 P. O. Box 40 Buckeye, AZ 85326 Mr. Jeffrey T. Weikert Assistant General Counsel Regional Administrator, Region IV El Paso Electric Company U.S. Nuclear Regulatory Commission Mail Location 167 Harris Tower & Pavillion 123 W. Mills 611 Ryan Plaza Drive, Suite 400 El Paso, TX 79901 Arlington, TX 76011-8064 Mr. John Schumann Chairman Los Angeles Department of Water & Power Maricopa County Board of Supervisors Southern California Public Power Authority 301 W. Jefferson, 10th Floor P.O. Box 51111, Room 1255-C Phoenix, AZ 85003 Los Angeles, CA 90051-0100 Mr. Aubrey V. Godwin, Director Mr. Brian Almon Arizona Radiation Regulatory Agency Public Utility Commission 4814 South 40 Street William B. Travis Building Phoenix, AZ 85040 P. O. Box 13326 1701 North Congress Avenue Mr. Craig K. Seaman, General Manager Austin, TX 78701-3326 Regulatory Affairs and Performance Improvement Ms. Karen O'Regan Palo Verde Nuclear Generating Station Environmental Program Manager Mail Station 7636 City of Phoenix P.O. Box 52034 Office of Environmental Programs Phoenix, AZ 85072-2034 200 West Washington Street Phoenix AZ 85003 Mr. Matthew Benac Assistant Vice President Nuclear & Generation Services El Paso Electric Company 340 East Palm Lane, Suite 310 Phoenix, AZ 85004 March 2006