ML071710636
| ML071710636 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 06/19/2007 |
| From: | Weber T Arizona Public Service Co |
| To: | Annette Vietti-Cook NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 102-05711-TNW/RJR, 72FR16731 00012, PR-50, RIN 3150-AH76 | |
| Download: ML071710636 (4) | |
Text
Thomas N. Weber Mail Station 7636 Palo Verde Nuclear Department Leader Tel. 623-393-5764 PO Box 52034 Generating Station Regulatory Affairs Fax 623-393-5442 Phoenix, Arizona 85072-2034 102-05711-TI1WIRJ R June 19,2007 DOCKETED Ms. Annette L. Vietti-Cook USNRC Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 June 20,2007 (10:15am)
ATTN: Rulemakings and Adjudications Staff OFFICE OF SECRETARY RLILEMAKINGSAND ADJUDICATIONS STAFF
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-52815291530 Comments on Proposed Rulemaking to Industry Codes and Standards, 10 CFR 50, RIN 3150-AH76
Dear Ms. Cook,
Arizona Public Service Company (APS) would like to take advantage of this opportur~ity to comment on the proposed rulemaking to Industry Codes and Standards noticed in the April 5, 2007, Federal Register (72 FR 16731). APS has reviewed the comments being submitted by the American Society of Mechanical Engineers (ASME) and the Strategic Teaming and Resource Sharing (STARS) Alliance and has additional comments for your review.
APS supports the comments being submitted by ASME and STARS. The additional APS comments are provided in the following table.
FR Page (g)(6)(ii)(D)(3) Recommend that a note be 16740 Requires that examination be "essentially 100 percent". added to document that Appendix I of the code case may be used when approved (g)(6)(ii)(D)(3) Recommend that this be Requires all J-Groove welds be surface examined. To changed to allow a UT "leak-do all these welds would add significant time and path" examination in lieu of radiological exposure to the RVHP examinations. APS the J-Groove surface has just spent 3 days doirlg 4 partial J-Groove weld examinations.
examinations.
(9)(6)(ii)(D)(4)(i) thru (iv) Recommend that (D)(4) in its NDE personnel, equipment, and techniques currently in entirety be deleted.
place to support the requirements of NRC Order EA-09-003 have been demonstrated and are being implemented without additional leaks being detected.
The proposed change will only add additional time and costs to the process with little, if any, increase to the health and safety of the public.
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway Comanche Peak Diablo Canyon Palo Verde South Texas Project Wolf Creek
Secretary, U. S. Nuclear Regulatory Commission Comments on Proposed Rulemaking to Industry Codes and Standards Page 2 FR Page (g)(6)(ii) D 6 It is recommended that the 16741 Appendix I allows for the examination coverage to be Code Case requirements in -
modified based on analysis. Until such time that 2500 be utilized as written.
PWSCC is identified in a resistant material head, it does not appear that the requirement to implement Appendix I only after NRC approval is warranted.
(g)(G)(ii)(E)(1) It is recommended that States that this Code Case does not apply to material nozzles and penetrations that not mitigated by weld overlay or stress improvement. have been mitigated by half-Numerous small nozzles and penetrations have been nozzle replacement or Alloy mitigated by half-nozzle replacement or Alloy 69015U152 weld pads should 690/52/152 weld pads. also be exempted from the requirements.
(g)@)(ii)(E)(3) Since there is a visual This section utilized the term "non-visual NDE." component of essentially all NDE methods, it is recommended that the terms surface or volumetric be utilized.
(Cl)(6)(ii)(E)(4) Since the component causing This paragraph imposes the rules of Appendix Vlll to the implementation of this components where qualification may not have been paragraph is leaking, the NDE performed (possibly due to size, thickness, etc). method and techniques utilized to characterize the leak in paragraph 2 should be sufficient qualification.
APS appreciates the opportunity to comment on the proposed rule.
If you have any questions, please contact Gler~nMichael at (623) 393-5750.
Sincerely,
1 SECY - E-Distribution of Letter 102-05711: PVNGS Units 1.2 , & 3 comments on Proposed Rulemaking to Industry Codes an(PSfJa.1 d
,,,,, -- /
From: Gail.Tabb@aps.com Date: Tue, Jun 19,2007 8:20 PM
Subject:
E-Distributionof Letter 102-05711: PVIVGS Units 1,2 , & 3 Comments on Proposed Rulemaking to Industry Codes and Standards, 10 CFR 50, RIN 3150-AH76 This is the e-distribution for the attached letter LETTER: 102-05711
SUBJECT:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, & 3 Docket Nos.: S I N 50-52815291530 Comments on Proposed Rulemaking to lndustry Codes and Standards, 10 CFR 50, RIN 3150-AH76
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If any questions, please contact:
Rich Rogalski 623-393-5806 Gail Tabb 623-393-5031 We SAFELY and efficiently generate electricity for the long term
1 c:\temp\GW)00001.TMP - -- v Page 1 1 Mail Envelope Properties (467872D5.1C0 : 21 : 373 12)
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E-Distribution of Letter 102-05711: PVNGS Units 1,2 , & 3 Comments on Proposed Rulemaking to Industry Codes and Standards, 10 Cl?R 50, RI[N 3150-AH76 Creation Date Tue, Jun 19,2007 8:20 PM From: Gail.Tabb @ aps.com Created By: Richard.Rogalslu@aps.com Recipients Files Size Date & Time MESSAGE 495 Tuesday, June 19,2007 8:20 PM TEXT.htm 1961 10205711 external.pdf 168760 Mime.822 236442 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed
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