ML092670204
| ML092670204 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/17/2009 |
| From: | Mims D Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-06062-DCM/DFS | |
| Download: ML092670204 (8) | |
Text
10 CFR 50.90 AM A subsidiaryof Pinnacle West 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 102-06062-DCM/DFS September 17, 2009 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
References:
- 1. Arizona Public Service Company Letter No. 102-06041, "Response to Request for Additional Information on Request for Amendment to Technical Specification 5.5.16, Containment Leakage Rate Testing Program," dated July 31, 2009
- 2. Arizona Public Service Company Letter No. 102-05902, "Request for Amendment to Technical Specification 5.5.16, Containment Leakage Rate Testing Program," dated October 1, 2008, (Agencywide Document Access and Management System [ADAMS] Accession No. ML082820029)
Dear Sirs:
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 on Request for Amendment to Technical Specification 5.5.16, Containment Leakage Rate Testing Program This correspondence provides Arizona Public Service Company's (APS's) response to a request for clarification of the information provided in Reference 1 regarding the license amendment request for Technical Specification 5.5.16, Containment Leakage Rate Testing Program provided in Reference 2. During a teleconference on August 12, 2009, the NRC requested that APS clarify certain information regarding containment visual and tendon examinations, penetration test results and containment leak rate acceptance criteria. APS has provided the requested response in the enclosure to this letter.
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance A Callaway
- Comanche Peak 0 Diablo Canyon
- Palo Verde
- San Onofre
- South Texas 0 Wolf Creek
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to Request for Additional Information on Request for Amendment to Technical Specification 5.5.16, Containment Leakage Rate Testing Program Page 2 As part of this response, APS commits, during the requested extended ILRT interval, to perform a supplemental general visual examination of the accessible external concrete containment surfaces of each unit'in accordance with the guidance of Nuclear Energy Institute (NEI) 94-01, "Guidance for Implementing Performance Based Option of 10 CFR 50, Appendix J," Revision 2A, dated October 2008.
Should you need further information regarding this response, please contact Russell A.
Stroud, Licensing Sdion Leader, at (623) 393-5111.
Sincerely, DCM/RAS/DFS/gat
Enclosure:
Response to Request for Additional Information on Request for Amendment to Technical Specification 5.5.16, Containment Leakage Rate Testing Program cc: E. E. Collins Jr. NRC Region IV Regional Administrator J. R. Hall NRC NRR Project Manager R. I. Treadway NRC Senior Resident Inspector for PVNGS A. V. Godwin Arizona Radiation Regulatory Agency (ARRA) aqodwin(dbazrra.gov)
T. Morales Arizona Radiation Regulatory Agency (ARRA) tmorales(Dazrra.qov)
ENCLOSURE Response to Request for Additional Information on Request for Amendment to Technical Specification 5.5.16, Containment Leakage Rate Testing Program
Enclosure Response to RAI on Request for Amendment to TS 5.5.16 This document provides Arizona Public Service Company's (APS's) response to NRC questions provided during a conference call on August 12, 2009.
1.0 Clarification Regarding Request for Additional Information (RAI) 1.2 Response on Visual Examinations of Containment External Surfaces In the response to RAI Question 1.2 in Reference 2 of this enclosure, APS provided the inspections scheduled to be completed to meet the requirements of ASME Code,Section XI, Subsections IWE and IWL prior to the extended 15 year interval.
a) NRC Request:
Provide clarification regarding the 30th and 35th year tendon integrity examinations for Unit 1 in the response to RAI Question 1.2, which is different than the schedule provided in Relief Request (RR)-L4. The RR-L4 schedule for Unit 1 is the 25th and the 35th year. The NRC noted a similar issue with Units 2 and 3 tendon integrity examinations.
APS Response:
The 3 0 th and 3 5 th year tendon examinations provided in the RAI response (Reference 2 of this enclosure) were based on the standard IWL examination frequency. The approved tendon integrity examination schedule, with application of RR-L4, is:
Unit 1 Tendon Integrity Examinations
" 25th-year examination: completed December 20, 2008
- 35th-year examination: December 20, 2018 (examination window- December 20, 2017 through December 20, 2019)
Unit 2 Tendon Integrity Examinations
- 20th-year examination: completed February 5, 2006
- 25th-year examination: February 5, 2010 (examination window - February 5, 2009 through February 5, 2011)
- 35th-year examination: February 5, 2020 (examination window - February 5, 2019 through February 5, 2021) 1
Enclosure Response to RAI on Request for Amendment to TS 5.5.16 Unit 3 Tendon Integrity Examinations
" 15th-year examination: completed September 17, 2002
" 25th-year examination: September 17, 2011 (examination window - September 17, 2010 through September 17, 2012)
" 35th-year examination: September 17, 2021 (examination window - September 17, 2020 through September 17, 2022)
Each of the tendon integrity examinations includes a general visual inspection of the accessible portions of the containment surface in the area of the tendons.
b) NRC Request:
Provide clarification of the visual inspection schedule for Exterior Concrete Containment (IWL) Examinations. Specifically, the APS license amendment request (LAR) submittal, dated October 1, 2008, (Reference 1 of this enclosure), provided the IWL examination schedule based on the approved RR-L3. That schedule included examinations in the 5 th and 15th years for Unit 1, and the 1 0 th and 2 0 th years for Units 2 and 3. The schedule provided in the RAI response, dated July 31, 2009, (Reference 2 of this enclosure), included the 1 0 th and 1 5 th years for Unit 1 and the 1 0 th year and 1 5 th year for Units 2 and 3. Also provide information on how APS is going meet the guidance in Nuclear Energy Institute (NEI) 94-01, Guidance for Implementing Performance Based Option of 10 CFR 50, Appendix J, Revision 2A, dated October 2008 for the external concrete containment inspection requirements for the extended 15-year Integrated Leak Rate Test (ILRT) (Reference 3 of this enclosure).
APS Response:
The RAI response was based on the standard IWL program frequency. The approved IWL program schedule in accordance with TS 5.5.16 and with application of RR-13, is:
Unit 1 Exterior Concrete Containment (IWL) Examinations
" Baseline examination: completed September 2001
" 5th-year after baseline examination: completed September 2006
" 15th-year after baseline examination: September 8, 2016 (examination window -
September 8, 2015 through September 8, 2017) 2
Enclosure Response to RAI on Request for Amendment to TS 5.5.16 Unit 2 Exterior Concrete Containment (IWL) Examinations
- Baseline examination: completed September 2001
- 10th-year after baseline examination: September 8, 2011 (examination window -
September 8, 2010 through September 8, 2012) 20th-year after baseline examination: September 8, 2021 (examination window -
September 8, 2020 through September 8, 2022)
Unit 3 Exterior Concrete Containment (IWL) Examinations
- Baseline examination: completed September 2001 0 10th-year after baseline examination: September 8, 2011 (examination window -
September 8, 2010 through September 8, 2012)
- 20th-year after baseline examination: September 8, 2021 (examination window -
September 8, 2020 through September 8, 2022)
Each of the above IWL examinations include inspection of the accessible containment surface of the associated unit.
As noted in the following summary table, APS commits, during the requested extended ILRT interval, to perform a supplemental general visual examination of the accessible external concrete containment surfaces of each unit in accordance with the guidance of Nuclear Energy Institute (NEI) 94-01, "Guidance for Implementing Performance Based Option of 10 CFR 50, Appendix J," Revision 2A, dated October 2008.
3
Enclosure Response to RAI on Request for Amendment to TS 5.5.16 Summary Examination Schedule The schedules for general visual examinations of the external surfaces of the containment building within the 15-year ILRT interval to meet the NEI 94-01 guidance are as follows:
Previous 1 st IWL 2 nd IWL Supplemental Pre-ILRT ILRT Exam Exam General General Visual Visual Exam Exam Unit 1 Nov 1999 Sep 2001 Sep 2006 2011 Oct 2014 Unit 2 Nov 2000 Sep 2001 Sep 2011 2013 Oct 2015 Unit 3 Apr2000 Sep 2001 Sep 2011 2013 Apr2015 The examinations listed in the table above as IWL are the IWL examinations which have been completed or are currently scheduled within the extended 15-year ILRT interval. The pre-ILRT and supplemental general visual examinations listed in the table are general visual examinations which will be completed during the extended ILRT interval. The general visual examinations include a visual inspection of the accessible containment surfaces. The schedule dates for future examinations are approximate. This schedule meets the requirement of Regulatory Position C.3 of Regulatory Guide 1.163, which requires a visual examination before initiating a Type A test and two visual examinations between tests. It also is consistent with the guidance in section 9.2.3.2 of NEI 94-01 Revision 2A, which increased the number of visual examinations between ILRTs from two to three when the Type A test interval has been extended to 15 years.
2.0 Clarification Regarding RAI 1.5 Response, Fuel Transfer Tube Penetration Test Results a) NRC Request:
Provide clarification on what local leak rate tests are performed on the fuel transfer tube penetration, and the results of those tests.
APS Response:
The fuel transfer tube penetration discussed in the response to NRC Question 1.5 is designated as Containment Penetration (CP) 53. The blind flange on CP 53 receives a Type B local leak rate test (LLRT) every refueling outage. The LLRT results for CP 53 in Units 1, 2, and 3 are shown in Attachments 4, 5, and 6 of Reference 2 of this enclosure, respectively.
4
Enclosure Response to RAI on Request for Amendment to TS 5.5.16 3.0 Clarification Regarding Attachment 7, ILRT Acceptance Criteria a) NRC Request:
Provide clarification of the acceptance criteria for Attachment 7 of the RAI response.
APS Response:
In Attachment 7, the 0.75 La leakage rate acceptance criterion for Type A tests is the as-left criterion. The as-found criterion is 1.0 La.
4.0 References
- 1. Arizona Public Service Company Letter No. 102-05902, "Request for Amendment to Technical Specification 5.5.16, Containment Leakage Rate Testing Program," dated October 1, 2008, (Agencywide Document Access and Management System [ADAMS]
Accession No. ML082820029)
- 2. Arizona Public Service Company Letter No. 102-06041, "Response to Request for Additional Information on Request for Amendment to Technical Specification 5.5.16, Containment Leakage Rate Testing Program," dated July 31, 2009
- 3. Nuclear Energy Institute (NEI) 94-01, Guidance for Implementing Performance Based Option of 10 CFR 50, Appendix J, Revision 2A, dated October 2008 5