ML080660332
| ML080660332 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/29/2008 |
| From: | Mims D Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-05818-DCM/GAM | |
| Download: ML080660332 (6) | |
Text
10 CFR 50.90 LA LS A subsidiary of Pinnacle West Capital Corporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Vice President Tel. 623-393-5403 P.O. Box 52034 Generating Station Regulatory Affairs and Plant Improvement Fax 623-393-6077 Phoenix, Arizona 85072-2034 102-05818-DCM/GAM February 29, 2008 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Supplement to Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance With TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process By letter no. 102-05801, dated January 17, 2008, Arizona Public Service Company (APS) submitted a request for an amendment to the technical specifications (TS) for PVNGS Units 1, 2, and 3 to modify TS requirements related to control room envelope habitability in accordance with TSTF-448, Revision 3. The January 17, 2008, TS amendment request contained references to Revision 1 of NEI 99-03, Control Room Habitability Assessment (March 2003), in both Section 2.2 of Attachment 1, Description and Assessment, and in the References section of the proposed TS Bases B 3.7.11 changes in Attachment 3. Since Revision 1 of NEI 99-03 has not received NRC approval, APS is submitting this supplement to the January 17, 2008, TS amendment request to replace the references to Revision 1 of NEI 99-03. This change to the proposed TS Bases B 3.7.11 References section is consistent with the modification of TSTF-Revision 3 that was submitted to the NRC by the Technical Specification Task Force in a letter dated December 29, 2006 (ADAMS Accession No. ML063630467), and therefore does not affect the No Significant Hazards Consideration Determination provided in APS's January 17, 2008, submittal. contains a revised page 2 of Attachment 1 to APS Letter No. 102-05801, dated January 17, 2008. Attachment 2 contains revised proposed changes to Technical Specification Bases page 3.7.11-10 (mark-up). It is APS's understanding from discussions with the NRC Project Manager that the attached changes that replace the references to NEI 99-03, Revision 1, will allow the NRC to review the proposed amendment as a Consolidated Line Item Improvement Process (CLIIP) TS change.
A member of the STARS (strategic Teaming and Resource Sharing) Alliance 0
Callaway 0
Comanche Peak 0 Diablo Canyon 0 Palo Verde
- South Texas Project
- Wolf Creek
NRC Document Control Desk Supplement to Application to Revise Technical Specifications Regarding Control Room Envelope Habitability Page 2 No commitments are being made to the NRC by this letter. If there are any questions or if additional information is needed, please contact Glenn A. Michael at (623) 393-5750.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on __
(Date')
Sincerely, DCM/SAB/GAM/
Attachments:
- 1.
Revised Page 2 of Attachment 1 to APS Letter No. 102-05801, Dated January 17, 2008
- 2.
Revised Proposed Changes to Technical Specification Bases Page 3.7.11-10 (Mark-Up)-in Attachment 3 to APS Letter No. 102-05801, Dated January 17, 2008 cc:
E. E. Collins Jr.
M. T. Markley G. G. Warnick A. V. Godwin T. Morales NRC Region IV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector for PVNGS Arizona Radiation Regulatory Agency (ARRA) aqodwin(aazrra._cov)
Arizona Radiation Regulatory Agency (ARRA) tmorales@Dazrra.qov)
Revised Page 2 of Attachment 1 to APS Letter No. 102-05801, Dated January 17, 2008 Description and Assessment Section Variation. or. Deviation.
Justification TS 3.7.11 - Condition Proposed Condition D addresses The Condition "during movement of D, and associated TS Mode 5 and Mode 6 only, rather irradiated fuel assemblies" is Bases.
than Mode 5, Mode 6 and "during addressed in a separate Condition E movement of irradiated fuel in the Palo Verde TS 3.7.11 assemblies."
because the appropriate Required Action for "during movement of irradiated fuel assemblies" is different from the Required Action for Mode 5 or 6.
TS 3.7.11 - Required The change to the Note on "toxic The note on "toxic gas protection Action D.1, and gas protection mode" in Required mode" is not in the PVNGS TS associated TS Bases.
Action D.1 of TSTF-448 is not 3.7.11. Toxic Gas Protection is not proposed.
a mode of CREFS operation at PVNGS.
TS 5.5.17.d When referring to the trending of This variation establishes CRE pressure relative to consistency between proposed TS adjacent areas, "[18] month 5.5.17.c(ii) and TS 5.5.17.d. The assessment" has been replaced assessment frequency is specified with "periodic assessment" to in the proposed TS 5.5.17.c(ii) as "at describe the assessment interval, frequencies specified in Sections C.1 and C.2 of Regulatory Guide 1.197, Revision 0." RG 1.197, Revision 0 specifies an assessment frequency of every 6 years.
TS 5.5.17.e The last sentence regarding There are no quantitative limits for unfiltered air inleakage limits for hazardous chemicals. Additionally, hazardous chemicals meeting per the PVNGS licensing basis, the assumptions of the licensing hazardous chemicals are not stored basis has not been included in or used onsite in quantities sufficient TS 5.5.17.e.
to necessitate CRE protection, as required by Regulatory Guide 1.78.
Nearby industrial, military, and transportation facilities present no hazard to the operation of PVNGS, and there are no site-related design basis events due to accidents at these facilities.
TS Bases B 3.7.11, The description of outside air This is an editorial enhancement
Background
entering the CRE was revised to that does not impact the TSTF-448 clarify that it combines with changes.
recirculated air from the CRE prior to being filtered.
TS Bases B 3.7.11, The description of "normally open This is an editorial enhancement
Background
isolation dampers" has been that does not impact the TSTF-448 enhanced to clarify that these changes.
dampers are components of the normal Control Room HVAC System.
2 Revised Proposed Changes to Technical Specification Bases Page 3.7.11-10 (Mark-Up) in Attachment 3 to APS Letter No. 102-05801, Dated January 17, 2008
CREFS B 3.7.11 SURVEILLANCE REQUIREMENTS (continued)
- 3.
Re, latory Guide 1.52Re...-24 UFSAR, Section 2.2.3 4I.
NUREG 0800, Section Section 9.4
- 5.
UFSAR, Section 9.e.
6.1, Rey. 2, July-1981
- UFSAR, Regulatory Guide 1.52 (Rev.
2)
- 6.
UFSAR, Section 2.2.
- 7.
NEI 99-03, "Control Room Habitability Assessment,"
June 2001.
- 8.
Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability."
(ADAMS Accession No. ML040300694).
(
PALO VERDE UNITS 1,2,3 B 3.7.11 -10 REVISION 10