ML050540254

Safety Significance Evaluation of ECCS Containment Sump Voided Piping

ML050540254
Person / Time
Site:	Palo Verde
Issue date:	02/15/2005
From:	Danni Smith Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-05213-DMS/SAB/GAM
Download: ML050540254 (5)

Text

ENCLOSURE 2 OF THIS LETTER AND ITS ATTACHMENTS (EXCEPT ATTACHMENT 2-F) CONTAIN PROPRIETARY INFORMATION AND SHOULD BE WITHHELD FROM PUBLIC A ssiIiar}Of Pinnacl f, c JULQSURE UNDER 10 CFR 2.390 Palo Verde Nuclear Generating Station David M. Smith Tel.

623-393-6116 Mail Station 7602 Plant Manager Fax.

623-393-6077 RO. Box 52034 Nuclear Production e-mail: DSMITH10@apsc.com Phoenix, AZ 85072-2034 102-05213-DMS/SAB/GAM February 15, 2005 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket Nos. STN 50-528, 50-529, and 50-530 Safety Significance Evaluation of ECCS Containment Sump Voided Piping In letter no. 102-05195, dated December 27, 2004, Arizona Public Service Company (APS) submitted to the NRC a Preliminary Safety Significance Evaluation of ECCS Containment Sump Voided Piping for PVNGS. The safety significance evaluation of ECCS containment sump voided piping has recently been completed, and is being provided as a proprietary report in Enclosure 2. APS requests the information in and its attachments (except Attachment 2-F) be withheld from public disclosure because of its commercial value to APS. The affidavit required by 10 CFR 2.390 is included as Enclosure 1.

The enclosed Evaluation is being provided to the NRC for consideration in determining the significance of the inspection findings in NRC Special Inspection Report 05000528/2004014; 05000529/2004014; 05000530/2004014, dated January 5, 2005.

There are no commitments in this letter. Should you have any questions, please contact Mr. Scott A. Bauer (623) 393-5978.

Sincerely, DMS/SAB/GAM all 2o(

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway [1 Comanche Peak El Diablo Canyon 0 Palo Verde if South Texas Project a Wolf Creek

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Safety Significance Evaluation of ECCS Containment Sump Voided Piping Page 2

Enclosures:

1. Affidavit for Information Sought to be Withheld from Public Disclosure

2.

Safety Significance (Proprietary) -A: -B: -C: -D: -E: -F:

cc:

B. S. Mallet A. T. Howell Ill, G. G. Warnick M. B. Fields Evaluation of ECCS Containment Sump Voided Piping FAI/04-65, Revision 0, Test Report for Phase 1 of Experimental Investigation of Post RAS Air Intrusion into ECCS Suction Piping for Palo Verde Nuclear Generating Station (Proprietary)

FAI/04-86, Revision 0, Test Report for Phase 2 of Experimental Investigation of Post RAS Air Intrusion Into ECCS Suction Piping for Palo Verde Nuclear Generating Station (Proprietary)

Test Report 10530R01 Test Report for Testing of a CA Pump and WDF Pump with a Void Fraction Inlet Fluid Condition (Proprietary)

FAI/05-06, Revision 0, Summary Report of MAAP4 LOCA Analysis in Support of Past Operability Assessment of Degraded HPSI Performance During Containment Recirculation at Palo Verde (Proprietary)

DAR-OA-05-3, Revision 0, Report of SBLOCA Analyses with Degraded ECCS Flow After RAS Performed for Arizona Public Service in Support of Palo Verde Nuclear Generating Station Units 1, 2, and 3 (Proprietary) 13-NS-C074, Revision 0. Significance Determination of Containment Sump Air Entrainment NRC Region IV Regional Administrator (all w/enclosures)

Director, Division of Reactor Projects, NRC Region IV NRC Senior Resident Inspector for PVNGS NRC NRR Project Manager

ENCLOSURE 1 Affidavit for Information Sought to be Withheld from Public Disclosure PI

UNITED STATES ON AMERICA NUCLEAR REGULATORY COMMISSION In the matter of

)

10CFR § 2.390

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Palo Verde Nuclear Generating Station )

Docket Nos. 50-528 Units 1, 2 & 3

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50-529

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50-530 AFFIDAVIT I, David M. Smith, Plant Manager, Nuclear Production, Palo Verde Nuclear Generating Station (PVNGS), do hereby affirm and state:

1.

I am authorized to execute this affidavit on behalf of Arizona Public Service Company (APS).

2.

APS is providing a copy of this Safety Significance Evaluation of ECCS Containment Sump Voided Piping and its attachments to the NRC in order to facilitate the NRC's inspection activities related to the NRC's review of the potential impact of an air void inside a section or piping in systems used to provide emergency cooling in the unlikely event of an accident at the plant. The development of the Safety Significance Evaluation of ECCS Containment Sump Voided Piping and its attachments (except Attachment 2-F) by APS and its vendors contains data, analysis, methodology and other information that is the proprietary confidential intellectual property of APS. Therefore, the Safety Significance Evaluation of ECCS Containment Sump Voided Piping and its attachments (except Attachment 2-F) constitutes proprietary commercial information that should be held in confidence from regulatory agencies of other countries and from the public by the NRC pursuant to the policy reflected in 10 CFR §§ 2.390(a)(4) and 9.17(a)(4), because:

i.

The information sought to be withheld from public disclosure is owned and has been held in confidence by APS and associated companies who participated in developing this information for APS.

ii.

This information is of a type that is customarily held in confidence by APS, and there is a rational basis for doing so because the information contains the proprietary confidential intellectual property of APS.

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iii.

This information is being transmitted to the NRC in confidence.

iv.

The information is not available in public sources or available information has not been previously employed in the same original manner or method to the best of my knowledge and belief.

v.

Public disclosure of this information would create substantial harm to the competitive position of APS by disclosure of APS' proprietary confidential intellectual property. Disclosure of this information to regulatory agencies in other countries would also create substantial harm to the competitive position of APS by disclosing information to governments with ownership and interest in competitors.

Da M. Smith STATE OF ARIZONA

)

) ss.

COUNTY OF MARICOPA )

• Subscribed and sworn to before me, a Notary Public, this

{ t Day of t

'.....l 2005, in and for the State of Arizona, by David M. Smith.

(M C itEtPublic My Commission Expires:

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