ML17304A855

Forwards Change to QA Program Described in FSAR for Approval Prior to Implementation.Change Will Substitute Two Diesel Fuel Oil Sampling Tests,Required by Reg Guide 1.137,w/two Equivalent Tests for Manually Sampling of Petroleum

ML17304A855
Person / Time
Site:	Palo Verde
Issue date:	12/23/1988
From:	Karner D ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-REGGD-01.137, RTR-REGGD-1.137 161-01581-DBL-L, 161-1581-DBL-L, NUDOCS 8901090268
Download: ML17304A855 (8)

Text

ACCE1ZRATED Dl HURON DEMO~S TION SYrrEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8901090268 DOC.DATE: 88/12/23

. NOTARIZED: NO DOCKET g

FACIL:STN-50-528 Palo Verde Nuclear Station, Unit -1, Arizona Publi 05000528 STN-50-529 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 KARNER,D.B.

Arizona Nuclear Power Project (formerly Arizona Public Serv RECIP.NAME RECIPIENT AFFILIATION R

NRC No Detailed AffiliationGiven

SUBJECT:

Forwards change to QA program described in FSAR for approval prior to implementation.

D DISTRIBUTION CODE:

IE43D COPIES RECEIVED:LTRl ENCL g SIZE:

TITLE: 50.54.a.3

& 50.55.f.3 Change to SAR QA Program NOTES:Standardized plant.

Standardized plant.

Standardized plant.

05000524 05000529 0500053 RECIPIENT

~ ID CODE/NAME PD5 LA DAVIS,M INTERNAL: ACRS NRR/DLPQ/QAB 10 EXTERNAL: DMB/DSS NRC PDR NOTES:

COPIES LTTR ENCL 1

0 1

1 6

0 1

1 1

1 1..'1 1

1 1

RECIPIENT ID CODE/NAME CHAN,T DAVIS,M.J.

ARM/DAF/LFMB NUDOCS-ABSTRACT RGN5 FILE 01 LPDR COPIES LTTR ENCL 1

- 1 1

1' 0

1 1

1 1

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NOTE 'Io ALL "RIES" RECZPZENIS PLEASE HELP US IO REDUCE'WASTE.'XÃI'ACT 'IHE DOQJMEÃZ CGNI'.ROL DESK, ROOM Pl-37 (EXZ. 20079)

KO EZJ2QXATE YMR NAME HKH DZSTIGBVZZON LISTS FOR DOCUMENIS YOU DOlN'T NEED>

D TOTAL NUMBER OF COPIES REQUIRED:

LTTR 19 ENCL 11

Arizona Nuclear Power Project P.O. BOX 52034

~

PHOENIX. ARIZONA85072-2034 161-01581-DBK/LJH December 23, 1988 Docket Nos.

STN 50-528/529/530 Document Control Desk U.S. Nuclear Regulatory Commission Hail'tation Pl-137 Washington, D.C.

20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3

Change to Quality Assurance Program in Accordance with 10CFR50.54(3),

Conditions of Licenses File:

88-005-419.05

'I In ac'cordance with 10CFR50.54 (a) (3),

Ari2.'Ona Public Service is submit ting for

approval, prior to implementation, a

change to the Quality Assurance Program described in the PVNGS Final Safety Analysis Report (FSAR).

The identification of this

change, the reason for the

change, the basis for concluding that the change continues to satisfy

10GFR50, Appendix B,

and the affected pages are attached to this letter.

In accordance with the requirements of 10CFR170.12(c),

an application fee of

$ 150.00 is attached.

If there are any questions which pertain to this submittal, please contact A. C. Rogers at (602) 371-4041.

Very truly yours, 4

D. B. Karner Executive Vice President DBK/L>f/pvk Attachment cc:

T. J. Polich (w/a) 890109v26"-88i2 3 Pot>>

Al.IOCK 0.. 000"=2':-:

P PDC

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IDENTIFICATION OF CHANGE The PVSGS

PSAR, Section

17. 21 ~Quallt Assurance Durln the 0 erations Phase.

contains by reference to Section 1.8, Conformance -to NRC Re ulator

Guides, a

commitment to comply with NRC Regulatory Guide 1.137, Position C.2, Fuel Oil S stems for Standb Diesel Generators, Revision 1.

Dependent upon approval, APS will incorporate into Section 1.8 of the PVNGS FSAR an exception to Revision 1.

This exception will substitute the two diesel fuel oil sampling tests required by the Guide with two equivalent tests.

They are as follows:

Substitute test ASTM D2276, Particulate Containment in Aviation Turbine Fuels for test ASTM D2274, Oxidation Stability of Distillate Fuel Oil (Accelerated Method).

and Substitute test ASTM D4057-81, Manual Sampling of Petroleum and Petroleum Products, for test ASTM D270-1975, Standard Method of Sampling Petroleum and Petroleum Products.

REASON FOR CHANGE Testing in accordance with ASTM D-2274 has only limited value. with regard to determining the acceptability of fueloil for use in diesel engines because test results are only an indication of the tendency of fuel oil to degrade duiing

storage, not the actual fuel oil condition.

In addition, the. accuracy of the test is questionable, and finally, the ASTM D-2274 test is more commonly used as a

means of quality assurance at refineries.

Testing in accordance with ASTM D-2276, however, will provide important information on the actual condition of the fuel in the storage tank.

Comparison of test results over time will provide an accurate indication of actual fuel degradation, if any, in sufficient time for corrective action and without impairing EDG operation.

The basis for the substitution of ASTM D4057-81 for ASTM D270-1975 is that ASTM D270 has been deleted as an ASTM Standard.

BASIS FOR HOW THE CHANGE CONTINUES TO SATISFY 10CFR50 APPENDIX B The quality of the diesel fuel oil will not be reduced by the use of these two'ests in lieu of the two tests recommended by Regulatory Guide 1.137.

Test ASTM D-2276 is better suited for satisfying the intent of Reg.

Guide 1.137, than ASTM D-2274.

Replacing test D270 which is no longer an ASTM standard with D4057-81 that performs a similar function and is an ASTM standard will maintain the controlled quality intended by Regulatory Guide 1.137.

PVNGS UPDATED FSAR CONFORMANCE TO NRC REGULATORY GUIDES

RESPONSE

~'bWS~+

REGULATORY GUIDE 1. 140:

Design.

Testing and Ma intenance Criteria for Normal Ventilation Exhaust System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants (Revision 0, March 1978)

RESPONSE

Information contained in Regulatory Guide 1.140 is utilized as discussed in sections 9.4 and 11.3, and in table 1.8-3.

REGULATORY GUIDE 1.141:

.Containment Isolation Provisions =foe Fluid Systems (Revision 0. April 1978)

RESPONSE

The position of Regulatory Guide 1.141 is accepted (refer to

=subsection 6.2.4) except for'he following.

An exception is taken to Regulatory Guide 1.141 for the CVCS charging line containment isolation valve CHA-HV-524.

This valve does not meet the guidance of Section 4.2.2'of ANSI N271-1976 which requires all power-operated isolation valves to be capable of remote manual actuation from the control room.

The power supply for this valve is removed by locking open its breaker at MCC PHA-M3520.

The restaration of the power supply requires local operatoc action at the MCC.

This exception to lock open valve CHA-HV-524 ensures that a flow path is available foc chacging oc auxiliacy spray flow by pceventing inadvertent 4

operation of the valve.

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Position C.? of ReguLatory Guide 1.137 is accepted with the xoLLowing exceptions to the Guide and the referenced standard (ANSI NX9$-.1976):

A-ASTM D2?76, Particulate Contaminant in Aviation Turbine FueLs,

~ will replace ASTM D2276-70, Oxidation Stability oa" Distillate Fuel Oil (Accelerated Method),

as outlined in Appendix B oE ANSI NX9S-1976 Fuel oi'3.

sampling will be in accordance with ASTM DCOS7-8X.

Manual Sampling oS Petroleum and Petroleum Products'.

This replaces ASTM D?70-1975, Standard Method oE Sampling Petroleum and Petroleum Products, which has been deleted as 'an, ASTM standard.