ML083370163

Response to Request for Additional Information - Relief Request 38

ML083370163
Person / Time
Site:	Palo Verde
Issue date:	11/14/2008
From:	Mims D Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-05925-DCM/RJR
Download: ML083370163 (30)

Text

10 CFR 50.55a(g) 10 CFR 50.55a(g)(5)(iii)

LA-5 A subsidiaryofPinnacle W~est CapitalCorporation 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 102-05925-DCM/RJR November 14, 2008 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 Response to Request for Additional Information - Relief Request 38 By letter dated September 24, 2008, the Nuclear Regulatory Commission (NRC) requested additional information pertaining to APS' submittal dated March 14, 2008 (Agencywide Documents and Management System (ADAMS) Accession No. ML080920639). APS' response to the requested information is enclosed. Additionally, as stated in the response to Question 2.1(a), APS is withdrawing the portion of Relief Request 38 that discusses Category B-A, Item B1.22, Reactor Pressure Vessel Lower Meridional Weld.

APS makes no commitments in this letter. If you have questions regarding this submittal, please contact Russell A. Stroud, Licensing Section Leader, at (623) 393-5111.

Sincerely, DCM/RAS/RJR/gat

Enclosure:

Response to Request for Additional Information - Relief Request 38 cc: E. E. Collins Jr. NRC Region IV Regional Administrator B. K. Singal NRC NRR Project Manager R. I. Treadway NRC Senior Resident Inspector ,4oq A member of the STARS (strategic Teaming and Resource Sharing) Alliance Callaway

• Comanche Peak 0 Diablo Canyon 0 Palo Verde 0 San Onofre 0 South Texas 0 Wolf Creek

ENCLOSURE Response to Request for Additional Information - Relief Request 38

Enclosure Excerpt from the NRC's Request Part A, Examination Category B-A, Item B13.22. Pressure Retaining Welds in Reactor Vessel The licensee stated that the reactor pressure vessel (RPV) lower head meridional weld examination is limited to approximately 22 percent of the Code volume coverage, due to geometric constraints of the in-core instrumentation penetrations and flow skirt. The licensee provided a schematic of the subject (Figure 1) depicting in-core instrumentation penetrations and the flow skirt configuration depicting the interferences that create the limitations. The ASME Code states that essentially 100 percent of the "accessible length" of the subject weld must be volumetrically examined.

Note: The ASME Code Committees, when implementing the above requirement in the ASME Code, considered the various obstacles (e.g., control rod drives (in some cases), RPV support skirt, instrument lines, etc.) that prevent the volumetric examination of the full length of the subject weld. For this particular ASME Code requirement, the examinations are limited to the accessible length of the RPV lower head weld.

The licensee is requested to:

NRC Question 2.1(a)

Define the accessible length of the RPV bottom head meridional weld and state whether the reported 22 percent volumetric coverage represents essentially 100 percent of this accessible length. If the reported 22 percent volumetric coverage represents essentially 100 percent of this accessible length, provide reasons for requesting for the relief. If essentially 100 percent of the accessible weld length was not achieved, continue to question 2.1(b).

APS Response The accessible length of the reactor pressure vessel bottom head meridional weld is the length of weld not obstructed by the flow skirt and bottom mounted instrumentation. The reported 22 percent volumetric coverage represents essentially 100 percent of this accessible length. Therefore, relief is not required and APS withdraws this portion of the request.

NRC Question 2.1(b)

The licensee stated that, given presently available technology, no additional coverage can be obtained. In order to demonstrate impracticality, provide a brief description of the technology deployed and discuss the specific reasons that limit coverage using this technology.

Page 2

Enclosure APS Response APS response to 2.1(b) is not required because APS is withdrawing this portion of the request.

Excerpt from the NRC's Request Part B, Examination Category B-D, Item B3.110, Full Penetration Welded Nozzles in Vessels Please clarify the following statements regarding the examination of pressurizer nozzle-to-vessel welds 5-10 and 5-13:

Pressurizernozzle Zone 5 welds 5-10 and 5-13 were limited to an average of 83%

Code volume coverage because of limited access based on geometric constraints of the nozzle. The radiusportion of the nozzle and the curvature of the Pressurizer head limited some angles of sound to portionsof the inside diameter.

Note: General references to geometric constraints, nozzle radius portion, and curvature of the pressurizer head are not adequate to demonstrate impracticality. In addition, the impact of these conditions on ultrasonic beam propagation and coverage are not well defined.

The licensee is requested to:

NRC Question 2.2(a)

Provide detailed information to support the basis for the limited examinations of pressurizer nozzle-to-vessel welds 5-10, 5-13, and the basis for demonstrating impracticality. Include detailed descriptions (with sufficient explanation, and lay-out or cross-sectional drawings/sketches) to enable the staff to understand the causes of ultrasonic scan limitations and their impact on examination volume coverage.

APS Response The cross sectional sketches of welds 5-10 and 5-13 are included in Attachment A. These sketches show the weld configuration, material thickness, scan path limits, and ultrasound beam path. These sketches show that the area of code volume not examined is the portion of the upper volume of the nozzle forging material. In both cases, 100% of the weld filler material was examined.

Page 3

Enclosure NRC Question 2.2(b)

List the type of nozzles included in the subject request (e.g. surge, safety, relief, spray, etc.)

and describe the nozzle dimensions and the materials used in the fabrication of these nozzles.

APS Response Weld 5-10 is for the spray nozzle. The nozzle dimension is 4" nominal pipe size (NPS). The welded materials are:

" Pressurizer top head, carbon steel SA-533 Gr. B Class 1.

" Spray nozzle forging, carbon steel SA-541 Class 3.

" The weld filler material is carbon steel.

Weld 5-13 is for the associated safety nozzle. The nozzle dimension is 6" NPS. The welded materials are:

" Pressurizer top head, carbon steel SA-533 Gr. B Class 1.

• Safety nozzle forging SA-541 Class 3.

" The weld filler material is carbon steel.

Excerpt from the NRC's Request Part C, Examination Category B-H, Item B8.20, Integral Attachments for Vessels The licensee is requested to:

NRC Question 2.3(a)

Provide a cross-sectional sketch showing the pressurizer support skirt weld. Include in this sketch a depiction of how the volumetric technique was applied and coverage obtained.

APS Response Attachment B contains the cross sectional drawing of the pressurizer support skirt weld that was taken from Unit 2 ultrasonic examination report number UT-06-088. The drawing depicts the weld configuration and the portion of the attachment weld that could not be examined.

The 45 and 60-degree arrows represent the transducer exit point and sound propagation path.

NRC Question 2.3(b)

Confirm that 100 percent of the surface examination was performed on the outside surface of the pressurizer support skirt weld.

Page 4

Enclosure APS Response One hundred percent of the outside weld surface was examined by the magnetic particle technique.

ExcerDt from the NRC's Reauest Part D, Examination Category B-J, Items B9.11. Pressure Retaining Welds in Piping-It is not apparent that the following general statements demonstrate impracticality for the ASME Code,Section XI, Examination Category B-J piping welds.

Several [ASME Code, Section XI] category B-J and C-F-1 butt welds were only accessible from one side of the weld due to configuration. Only 50%

Code volume coverage was credited due to single sided examination of austeniticstainless steel welds e.g. obstructionfrom valves.

The licensee is requested to:

NRC Question 2.4(a)

Describe the configuration (e.g., pipe-to-valve, pipe-to-elbow, etc.), materials and dimensions of each of the ASME Code, Section XA, Examination Category B-J piping welds.

APS Response The following table lists the weld configuration, materials, and dimension of each B-J piping weld.

Item ID Configuration Material Dimensions 22-11 pipe-to-valve 300 series SS to 300 series SS 16" NPS 1.594" T 23-4 pipe-to-valve 300 series SS to 300 series SS 114" NPS 1.406" T 23-6 pipe-to-valve 300 series SS to 300 series SS 14" NPS 1.406" T 24-6 pipe-to-valve 300 series SS to 300 series SS 14" NPS 1.406" T 24-14 pipe-to-valve 300 series SS to 300 series SS 14" NPS 1.406" T 24-16 pipe-to-valve 300 series SS to 300 series SS 14" NPS 1.406" T 24-19 pipe-to-valve 300 series SS to 300 series SS 14" NPS 1.406" T 25-4 pipe-to-valve 300 series SS to 300 series SS 14" NPS 1.406" T 25-6 pipe-to-valve 300 series SS to 300 series SS 14" NPS 1.406" T 26-6 pipe-to-valve 300 series SS to 300 series SS 14" NPS 1.406" T 26-17 pipe-to-valve 300 series SS to 300 series SS 14" NPS 1.406" T 29-2 pipe-to-tee 300 series SS to 300 series SS 4" NPS .532" T 29-3 pipe-to-tee 300 series SS to 300 series SS 4" NPS .531" T Page 5 V

Enclosure NRC Question 2.4(b)

Provide detailed information to support the basis for each limited ASME" Code,Section XI, Examination Category B-J weld and, therefore, demonstrate impracticality. Include detailed descriptions (with sufficient explanation, and layout or cross-sectional drawings/sketches) to enable the staff to understand the causes of ultrasonic scan limitations and their impact on examination volume coverage.

APS Response All of the B-J piping welds were examined in accordance with the Performance Demonstration Initiative (PDI) generic procedure PDI-UT-2. No limitations to the procedural requirements were encountered. Attachment C contains a sketch of a typical weld profile (pipe-to-fitting, pipe-to-valve, pipe-to-pump, etc.) configuration. As shown in the sketch, these types of welds contain a taper as the connection transitions into the attached item. As a result of the slope of this taper and limited distance from the weld to the attached item, no meaningful axial scans can be performed from the tapered side of the weld as shown in Attachment C. The coverage plots from two B-J welds 22-11 and 23-4 are included to show the field application.

10 CFR 50.55a (b)(2)(xv)(A)(2) allows for full coverage credit to be claimed from a single side examination if a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld is successfully completed. However, the PDI procedure used by APS has not been qualified to detect flaws on the far side of single side access configurations as shown in Attachment C. Therefore, APS considers the B-J welds to be limited coverage.

NRC Question 2.4(c)

Describe the ultrasonic techniques (shear wave and angles, and refracted L-wave and angles) applied to maximize coverage when examining from a single side of these welds.

APS Response In accordance with PDI procedure PDI-UT-2, the table below lists the angle and mode of ultrasonic sound applied to maximize coverage of the single sided B-J piping welds.

Item ID Configuration Ultrasonic Technique Dimensions 22-11 pipe-to-valve 45 degree refracted L-wave 16" NPS 1.594" T 23-4 pipe-to-valve 45 degree refracted L-wave 14" NPS 1.406" T 23-6 pipe-to-valve 60 degree refracted L-wave 14" NPS 1.406" T 24-6 pipe-to-valve 60 degree refracted L-wave 14" NPS 1.406" T 24-14 pipe-to-valve 60 degree refracted L-wave 14" NPS 1.406" T 24-16 pipe-to-valve 60 degree refracted L-wave 14" NPS 1.406" T 24-19 pipe-to-valve 60 degree refracted L-wave 14" NPS 1.406" T 25-4 pipe-to-valve 60 degree refracted L-wave 14." NPS 1.406" T 25-6 pipe-to-valve 60 degree refracted L-wave 114" NPS 1.406" T Page 6

Enclosure Item ID Configuration Ultrasonic Technique Dimensions 26-6 pipe-to-valve 60 degree refracted L-wave 14" NPS 1.406" T 26-17 pipe-to-valve 60 degree refracted L-wave - 14" NPS 1.406" T 29-2 pipe-to-tee 60 degree refracted L-wave, 4" NPS .532" T 29-3 1 pipe-to-tee 60 degree refracted L-wave 14" NPS .531" T NRC Question 2.4(d)

In addition to the basis for impracticality, state whether any outside diameter surface feature, such as weld crown, diametrical weld shrinkage, or surface roughness conditions caused limited volumetric coverage during the subject piping weld examinations. Discuss the efforts that were used to address these conditions.

APS Response Ultrasonic examination reports for the single sided B-J piping welds indicate that there are no limitations or comments addressing weld crown, diametrical weld shrinkage, surface roughness, or other conditions that would cause limited volumetric coverage.

NRC Question 2.4(e)

Confirm that ASME Code-required surface examinations were completed for the subject welds.

APS Response APS has verified that ASME Code-required surface examinations were completed for the subject welds.

Excerpt from the NRC's Request Part E, Examination Category C-C, Items C3.20 and C3.30, Integral Attachments for Vessels, Piping, Pumps and Valves The licensee is requested to:

NRC Question 2.5(a)

Confirm that component support SI-1 07-H-022 is located on the safety injection system piping.

APS Response Page 7

Enclosure Component support S1-1 07-H-022 is located on the safety injection system piping and is shown on drawing 02-P-SIF-204.

NRC Question 2.5(b)

Provide a sketch or photograph depicting the stated configuration of welded attachments on component supports 116-11B and 116-1C. Also, list the high-pressure safety injection pump designation for the subject supports.

APS Response The High Pressure Safety Injection pump has four integrally attached support lugs. The zone drawing shown in Attachment D lists the support designation for the subject supports. Two support lugs are on the front of the pump and two support lugs are on the rear of the pump.

The limited lug-to-pump welds are the front lugs (weld numbers 116-1 B and 116-1C). The rear lugs (116-1A and 116-1 D) were not limited.

Also included are pictures of the front and rear support lugs. Access to the bottom side of the rear lug-to-pressure boundary welds (116-1A and 116-1 D) is provided when the insulation is removed. No access to the bottom side of the front lug-to-pressure boundary welds (116-1 B and 116-1C) is provided when the insulation is removed. Access to these welds (116-1 B and 116-1C) is limited by the structural steel member that supports each lug as seen in the following pictures.

All four lugs were liquid penetrant examined to the maximum extent allowable. The rear lug welds (116-1A and 116-1 D) were not limited and 100% coverage was obtained. The front lug welds (116-1 B and 116-1 C) were limited at the bottom side of the lug-to-pressure boundary weld. The examiner estimated the total coverage for all four lug welds to be 72%.

Based on the physical restrictions, APS considers the bottom surface of the front lug-to-pressure boundary weld to be impractical for examination.

Excerpt from the NRC's Request Part F. Examination Category C-F-1. Items C5.11 and Item C5.21. Pressure Retaining Welds in Austenitic Stainless Steel or High Alloy Piping It is not apparent that the following general statements demonstrate impracticality for the ASME Code,Section XI, Examination Category C-F-1 piping welds.

Several [ASME Code, Section Xl] categoryB-J and C-F-I butt welds were only accessible from one side of the weld due to configuration.'Only 50%

Code volume coverage was credited due to single sided examination of austeniticstainless steel welds e.g. obstruction from valves.

The licensee is requested to:

Page 8

Enclosure NRC Question 2.6(a)

Describe the configuration (e.g., pipe-to-valve, pipe-to-elbow, etc.), materials and dimensions of each of the ASME Code,Section XI, Examination Category C-F-1 piping welds.

APS Response The following Table lists the weld configuration, materials, and dimension of each C-F-1 piping weld. Weld 63-4, listed in Item 4 of the original submittal, was an error and does not require relief.

Item ID Configuration Material Dimensions 77-7 pipe-to-flange 300 series SS to 300 series SS 12" NPS .406" T 77-14 pipe-to-valve 300 series SS to 300 series SS 12" NPS 1.125" T 84-12 pipe-to-valve 300 series SS to 300 series SS 24" NPS .562" T 85-46 pipe-to-valve 300 series SS to 300 series SS 20" NPS .375" T 77-27 pipe-to-valve 300 series SS to 300 series SS 12" NPS 1.312" T 70-121 pipe-to-valve 300 series SS to 300 series SS 16" NPS 1.420" T 77-16 pipe-to-valve 300 series SS to 300 series SS 12" NPS 1.125" T 84-3 pipe-to-valve 300 series SS to 300 series SS 20" NPS .375" T 106-1 pipe-to-pump 300 series SS to 300 series SS 4" NPS .337" T 106-21 pipe-to-valve 300 series SS to 300 series SS 4" NPS .438" T 106-64 pipe-to-valve 300 series SS to 300 series SS 2" NPS .344" T 106-68 pipe-to-tee 300 series SS to 300 series SS 2" NPS .344" T 107-1 pipe-to-pump 300 series SS to 300 series SS 4" NPS .337" T 107-11 pipe-to-valve 300 series SS to 300 series SS 4" NPS .337" T 110-17 pipe-to-valve 300 series SS to 300 series SS 2" NPS .344" T 110-52 pipe-to-tee 300 series SS to 300 series SS 2" NPS .344" T 115-13 pipe-to-penetration 300 series SS to 300 series SS 3" NPS .438" T 115-20 pipe-to-valve 300 series SS to 300 series SS 3" NPS .438" T 118-49 pipe-to-valve 300 series SS to 300 series SS 3" NPS .438" T 119-52 pipe-to-valve 300 series SS to 300 series SS 3" NPS .438" T 119-53 pipe-to-valve 300 series SS to 300 series SS 2" NPS .344" T NRC Question 2.6(b)

Provide detailed information to support the basis for each limited ASME" Code,Section XI, Examination Category C-F-1 weld and, therefore, demonstrate impracticality. Include detailed descriptions (with sufficient explanation, and layout or cross-sectional drawings/sketches) to enable the staff to understand the causes of ultrasonic scan limitations and their impact on examination volume coverage.

APS Response All of the C-F-1 piping welds were examined in accordance with the Performance Demonstration Initiative (PDI) generic procedure PDI-UT-2. No limitations to the procedural Page 9

Enclosure requirements were encountered. Attachment C contains a sketch of a typical weld profile (pipe-to-fitting, pipe-to-valve, pipe-to-pump, etc.) configuration. As shown in the sketch, these types of welds contain a taper as the connection transitions into the attached item. As a result of the slope of this taper and limited distance from the weld to the attached item, no meaningful axial scans can be performed from the tapered side of the weld as shown in Attachment C. The coverage plots from two C-F-1 welds 77-14 and 85-46 are included to show the field application.

10 CFR 50.55a (b)(2)(xv)(A)(2) allows for full coverage credit to be claimed from a single side examination if a successful single-sided Appendix VIII demonstration using flaws on the opposite side of the weld is successfully completed. However, the PDI procedure used by APS has not been qualified to detect flaws on the far side of single side access configurations as shown in Attachment C. Therefore, APS considers the B-J welds to be limited coverage.

NRC Question 2.6(c)

Describe the ultrasonic techniques (shear wave and angles, and refracted L-wave and angles) applied to maximize coverage when examining from a single side of these welds.

APS Response In accordance with PDI procedure, PDI-UT-2, the table below list the angle and mode of ultrasonic sound applied to maximize coverage of the single sided C-F..1 piping welds. Weld 63-4, listed in Item 4 of the original submittal, was an error and does not require relief.

Item Configuration Ultrasonic Technique Dimensions ID 77-7 pipe-to-flange 70 degree shear wave 12" NPS .406" T 77-14 pipe-to-valve 45 degree refracted L-wave 12" NPS 1.125" T 84-12 pipe-to-valve 60 degree refracted L-wave 24" NPS .562" T 85-46 pipe-to-valve 70 degree shear wave 20" NPS .375" T 77-27 pipe-to-valve 60 degree refracted L-wave 12" NPS 1.312" T 70-121 pipe-to-valve 60 degree refracted L-wave 16" NPS 1.420" T 77-16 pipe-to-valve 60 degree refracted L-wave 12" NPS 1.125" T 84-3 pipe-to-flange 70 degree shear wave 20" NPIS .375" T 106-1 pipe-to-pump 70 degree shear wave 4" NPS .337" T 106-21 pipe-to-valve 70 degree shear wave 4" NPS .438" T 106-64 pipe-to-valve 70 degree shear wave 2" NPS .344" T 106-68 pipe-to-tee 70 degree shear wave 2" NPS .344" T 107-1 pipe-to-pump 70 degree shear wave 4" NPS .337" T 107-11 pipe-to-valve 70 degree shear wave 4" NPS .337" T 110-17 pipe-to-valve 70 degree shear wave 2" NPS .344" T 110-52 pipe-to-tee 70 degree shear wave 2" NPS .344" T 115-13 pipe-to -penetration 70 degree shear wave 3" NPS .438" T 115-20 pipe-to-valve 70 degree shear wave 3" NPS .438" T 118-49 pipe-to-valve 70 degree shear wave 3" NPS .438" T Page 10

Enclosure Item Configuration Ultrasonic Technique Dimensions ID 119-52 pipe-to-valve 70 degree shear wave 3" NPS .438" T 119-53 pipe-to-valve 70 degree shear wave 2" NPS .344" T NRC Question 2.6(d)

In addition to the basis for impracticality, state whether any outside diameter surface feature, such as weld crown, diametrical weld shrinkage, or surface roughness conditions caused limited volumetric coverage during the subject piping weld examinations. Discuss the efforts that were used to address these conditions.

APS Response A review of the ultrasonic examination reports for the single sided C-F-1 piping welds indicates that no limitations or comments were made addressing weld crown, diametrical weld shrinkage, surface roughness, or other conditions that would cause limited volumetric coverage.

NRC Question 2.6(e)

Confirm that ASME Code-required surface examinations were completed for the subject welds.

APS Response APS has verified that ASME Code-required surface examinations were completed for the subject welds.

Page 11

Attachment A Sketches for Question 2.2(a)

Attachment A i I.

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Attachment A Supplemental Report Report No.: UT-02-036 Page: 3 of 3 Summary No.: 2-005-010 Examiner Thomas, Wayne Level: III .Reviewer* ,0,Vj$ 0,.- Date:

Examiner: NIA Level: . WA Site Revl*ew ,,*.*,,_,.It- Date: .

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Attachment A Supplemental Report Report No.: UT-02-039

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Attachment A

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Page: 3 UT-02-037 of 3 Summary No.: 2-005-013 /4/7 Examiner. Thomas, W e -- evel: I.I Reviewer: L.U.V Date: .q-1-0.

Examnter. N/A Level: N/A Shte Review'. &I- Date:

Other N/A Level: N/A ANII RevIew: Date: 4-31 Comments:

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Attachment A Supplemental Report Report No.: UT.02-040 D S-- 3 Page: 3 of 3 Summary No.: 2-005-013 Examiner: ý ý Lv:II Reiwr ae _____an Examiner: MA Level: N/A Site Review, P Of& Date:

Other. IA Level: WA ANtIRe*view: Date: .- ,-

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Attachment A Supplemental Report S4ýr &J C~zo 5- / 3 Report No.:

Page: 3 UT-02-034 of 3

-.,ummary No.: 2-005-013 ' .* .

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Attachment B Drawing for Question 2.3(a)

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Attachment C Sketches for Question 2.4(b) and 2.6(b).

Attachment C PIPE TO FITTING JOINTS This distance does I'

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Page 3

Attachment D Drawing and Photos for Question 2.5(b)

Attachment D Page 1

Attachment D NH HPSI Pump Rear Lug HPSI Pump Front Lug Page 2