ML17313A117

Expresses Concern Over Change to NRC Schedule for Approval & Issuance of Improved TS Amend for Plant.Listing of Key Milestones from Implementation Plan Beginning W/Issuance of Final SER Encl

ML17313A117
Person / Time
Site:	Palo Verde
Issue date:	11/14/1997
From:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Callan L NRC
References
102-04039-JML-S, 102-4039-JML-S, NUDOCS 9711260157
Download: ML17313A117 (11)

Text

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 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

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

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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