ML100260951
| ML100260951 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/18/2010 |
| From: | Hesser J Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-06122-JHH/GAM | |
| Download: ML100260951 (107) | |
Text
ZA M
A subsidiary of Pinnacle West Capital Corporation John H. Hesser Mail Station 7605 Palo Verde Nuclear Vice President Tel: 623-393-5553 PO Box 52034 Generating Station Nuclear Engineering Fax: 623-393-6077 Phoenix, Arizona 85072-2034 102-06122-JHH/GAM January 18, 2010 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
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 December 3, 2009, Request for Additional Information Regarding Balance of Plant for the Review of the PVNGS License Renewal Application, and License Renewal Application Amendment No. 8 By letter dated December 3, 2009, the NRC issued a request for additional information (RAI) related to the PVNGS license renewal application (LRA). Enclosure 1 contains APS's response to the December 3, 2009, RAI. Enclosure 2 contains PVNGS LRA updates to reflect changes made as a result of the RAI responses.
In addition to LRA changes reflecting the RAI responses, the following changes are included in Enclosure 2, Attachment 1:
LRA Table 3.3.2-21, "Auxiliary Systems - Summary of Aging Management Evaluation - Diesel Generator System," is being changed to reflect a correction in the material for the diesel generator system pre-lube oil pump from stainless steel to carbon steel. This material difference was identified during a component-material-environment verification performed during the aging management program (AMP) audit.
LRA Section 3.3.2.1.24, "WRF Fuel System," and Table 3.3.2-24, "Auxiliary Systems - Summary of Aging Management Evaluation - WRF Fuel System," are being changed to reflect a change of environment and the associated Aging Management Program for the Water Reclamation Facility (WRF) fuel oil storage tank no. 2. The WRF fuel oil storage tank no. 2 is normally empty but remains available for use during the period of extended operation as a fuel storage tank A member of the STARS (Strategic Teaming and Resource Sharing) Alliance 36 Callaway ° Comanche Peak
- Diablo Canyon
- Palo Verde - San Onofre
- South Texas
- Wolf Creek
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to December 3, 2009, Request for Additional Information for the Review of the Palo Verde Nuclear Generating Station License Renewal Application Page 2 for the Station Blackout Generators (SBOGs) if conditions require. Accordingly, WRF fuel oil storage tank no. 2 is evaluated within the scope of license renewal for 10 CFR 54.4(a)(3) considerations. Since the tank is normally empty, the tank and portions of attached piping lines are subject to the internal environment of 'Wetted Gas" instead of "Fuel Oil." This environment change was identified during a component-material-environment verification performed in response to RAI 2.3.3.24-01.
APS makes no commitments in this letter. Should you need further information regarding this submittal, please contact Russell A. Stroud, Licensing Section Leader, at (623) 393-5111.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on JA"*a1uA4 IS, 2,1O)
(date)
Sincerely, JHH/RAS/GAM
Enclosures:
- 1. Response to December 3, 2009, Request for Additional Information Regarding Balance of Plant for the Review of the PVNGS License Renewal Application
- 2.
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 :
LRA Changes for RAI Responses Except for RAI 2.3.3.30-01 and 02 Responses :
LRA Changes for RAI 2.3.3.30-01 and 02 Responses 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 L. M. Regner NRC License Renewal Project Manager
ENCLOSURE 1 Response to December 3, 2009, Request for Additional Information Regarding Balance of Plant for the Review of the PVNGS License Renewal Application Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.2-01
Background:
LRA Section 2.1.1 states "The first step in the integrated plant assessment (IPA) process identified the plant SSCs within the scope of 10 CFR 54."
Issue:
The following UFSAR systems could not be located in LRA Table 2.2-1.
UFSAR Section System Table 12.2-11 Systems Used In Post-Post Accident Sampling System Accident Shielding Review 14.2.12 Individual Test Descriptions Post-Accident Monitoring System 7.2.5 Supplemental Protection System Supplementary Protection System 3.2 Classification of Structures, Equipment Building Components, and Systems, Table 3.2-1 Structures Request:
Provide the reasoning for not including the above systems/structures in Table 2.2-1.
APS Response to RAI 2.2-01 The Post Accident Sampling System, Supplementary Protection System, and Equipment Building were not included on LRA Table 2.2-1 for the reasons noted below.
Post Accident Sampling System (PASS)
Note PP to UFSAR Table 1.8-1, PVNGS Compliance with Regulatory Guide 1.97 (Revision 2) Requirements, identifies that APS has eliminated PASS as documented in CE-NPSD-1 157, as accepted by NRC Safety Evaluation Report dated May 16, 2000, for CEOG Topical Report CE-1 157 Revision 1. Palo Verde Units 1, 2, and 3 Operating License Amendment Nos. 136, 136, and 136, issued in NRC letter to APS, dated September 28, 2001, (Agencywide Document Access and Management System
[ADAMS] Accession No. ML012710441) documented acceptance of the request to remove PASS from the licensing and technical basis of the Palo Verde plant.
Post Accident Monitorina (PAM) System UFSAR Chapter 14 contains historical pre-operation test descriptions. The post accident monitoring system, specified for pre-operational testing as described in UFSAR 1
Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Sections 14.2.12 and 14B.29, refers to the post accident monitoring (PAM) instrumentation which is identified in UFSAR Table 1.8-1 and analyzed in UFSAR 7.5.2.5. UFSAR Table 1.8-1 identifies PAM instrumentation in 30 plant systems which perform the PAM function. These 30 systems are included in LRA Table 2.2-1, PVNGS Scoping Results.
Supplementary Protection System (SPS)
LRA section 2.1.2.3.3 identifies that the SPS is part of the equipment required by the ATWS Rule for reduction of risk from an ATWS event. LRA section 2.1.2.3.3 also identifies that all ATWS components are within the scope of license renewal. UFSAR section 7.2.5 identifies that the SPS is part of the Reactor Protection System (RPS) and augments the RPS for initiation of the reactor trip to satisfy the requirements of the ATWS Rule. The RPS is identified on LRA Table 2.2-1 as a system within the scope of license renewal.
Equipment Building UFSAR Table 3.2-1, Quality Classification of Structures, Systems, and Components, item 25, identifies that the Equipment Building is part of the Containment Building. Note (gg) of UFSAR Table 3.2-1, item 25, identifies the Equipment Building as the Containment Equipment Hatch. LRA Table 2.4-1 identifies the Equipment Hatch as one of the Containment Building components within the scope of license renewal and subject to aging management review (AMR). The Containment Building is identified on LRA Table 2.2-1 as a structure within the scope of license renewal.
NRC RAI 2.3-01
Background:
Portions of several systems have spatial interaction as non-safety affecting safety-related components in the fuel building and in the auxiliary building and are within the scope of license renewal as non-safety affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).
Issue:
The following spatial interaction terminations are shown as license renewal boundaries for 10 CFR 54.4(a)(2) piping. However, the basis for the spatial interaction termination cannot be determined, e.g. entering a building/room with no safety-related components, becoming buried pipe.
2
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Normal Chilled Water System (2.3.3.5)
LRA drawing LR-PVNGS-WC-01-M-WCP-001:
Location G-1 upstream of valve PSV-1 19.
Location D-15 lines 275-HBDB-4" and 015-HBDB-10".
Location 0-14 at valve V090.
Location C-13 near valve V016.
Location 0-13 line 001-HBDB-10".
Location C-1l1 near valve V089.
Location E-10 line 030-HBDB-21/2".
Location B-11 line 277-HBDB-4".
Location A-11 line 192-HBDB-1" Location 0-8 near valve V088.
Location E-7 lines 012-HBDB-4", 029-HBDB-4", 010-HBDB-8", and 031-HBDB-8".
Location A-6 lines 195-HBDB-1" and 014-HBDB-I".
Location E-5 lines 073-HBDB-1", 074-HBDB-1", 077-HBDB-4", and 078-HBDB-4".
Locations D-2 and D-3 line 239-HBDB-1".
Location B-2 lines 079-HBDB-4" and 090-HBDB-4".
Nuclear Cooling Water System (2.3.3.6)
LRA drawing LR-PVNGS-NC-01-M-NCP-001(D-4), 023-HBDB-1" and 028-HBDB-1" lines from equipment coolers.
LRA drawing LR-PVNGS-NC-01-M-NCP-002 (E-8 and F-8), lines to and from gas stripper package (N-065-HBDB-6" and N-066-HBDB-6").
LRA drawing LR-PVNGS-NC-01-M-NCP-002(F-4), line N-068-HBDB-8" upstream of valve HCV209.
LRA drawing LR-PVNGS-NC-01-M-NCP-003 (D-6 and G-6), downstream of valves V414, V415 and V412, V413 respectively.
Chemical Volume and Control System (2.3.3.10)
LR-PVNGS-CH-01-CHP-001:
Piping N-438-CCDA-1" upstream of valve V162 (E-14).
Piping N-426-HCDA-1" downstream of valve V004 (D-13).
Piping N-045-HCDA-1" downstream of valve V445 (F-1 0).
Piping N-475-HCDB-1" downstream of valve VM34 (G-6).
LR-PVNGS-CH-01-CHP-002, Sht. 1:
Piping N-1 92-HCDA-3" upstream of valve V1 95 (F-1 1).
3
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Piping N-466-HCDB-1" downstream of Charging Pump No. 3 (CHE-P01) (G-3).
Piping N-471-HCDB-1" downstream of valve V203 (F-2).
Piping N-465-HCDB-1" downstream of Charging Pump No. 2 (CHB-PO1) (E-3).
Piping N-469-HCDB-1" downstream of valve V204 (D-2).
Piping N-464-HCDB-1" downstream of Charging Pump No. 1 (CHA-P01) (C-3).
Piping N-467-HCDB-1" downstream of valve V205 (B-2).
Piping N-226-HCDA-1" downstream of valve VI1 7 (C-6).
LR-PVNGS-CH-01-CHP-003:
Piping N-393-HCDA-3" downstream of valve UV-511 (D-3).
Piping N-386-HCDA-3" downstream of valve V776 (C-2).
Piping N-386-HCDA-3" downstream and upstream of Reactor Makeup Water Filter (CHN-F05) (C-2).
Piping N-333-HCDB-3" upstream of valve V450 (A-9).
Piping N-332-HCDB-11/2" downstream of valve V662 (A-1 0).
Radioactive Waste Drains System (2.3.3.27)
Drawing LR-PVNGS-RD-01-M-RDP-001, location D-2, a portion of piping 086-HCDA21/2".
Drawing LR-PVNGS-RD-01-M-RDP-002, location D-12, the continuation of B-1i14-HCDA-4" pipe section to LR-PVNGS-01-N-LRP-001(F-8).
Drawing LR-PVNGS-RD-01-M-RDP-002, location H-12, the continuation of CH-N-538-HCDA-1" pipe section to LR-PVNGS-CH-01-M-CHP-001(A-15).
Miscellaneous Auxiliary Systems (2.3.3.30)
Drawing LR-PVNGS-LR-01-N-LRP-001:
" Locations F-i, E-i, and D-i, lines downstream of in-line instruments FG-40, 41,
& 42 to the non-ESF sump.
- Location B-2, a portion of line N-062-HCDA-2".
" Location C-5, a portion of line N-293-HCDC-2".
Drawing LR-PVNGS-LR-01-N-LRP-002-02:
Locations F-I, E-2, E-i, and E-2, four (4) lines N-194-HCDA-3, N-192-HCDA-3, N-193-HCDA-3, and N-184-HCDA-3.
Drawing LR-PVNGS-OW-01-M-OWP-001:
0 Location B-2, a section of line 146-HBDD-6".
4 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Drawing LR-PVNGS-OW-01-M-OWP-003:
Locations C-1, C-2, and C-8, two sections of drain lines 171-XBDA-4" (from the northeast and southeast comers) and two 164-XBDA-4" (from northwest and southwest corners).
Location D-3, a section of line 170-HGDH-4".
Drawing LR-PVNGS-SR-01-N-SRP-001:
0 Location C-3, line N-012-HCDA-2.
Drawing LP-PVNGS-CM-01-M-CMP-001:
Location C-7, line N-027-HBDB-2".
Location C-6, line N-024-HBDB-2".
Drawinq LP-PVNGS-CM-01-M-CMP-001:
Location F-7, two portions of line N-001-XCDA-4".
Drawinq LR-PVNGS-AS-01-M-ASP-001:
Location E-3, a portion of line 014-HBDB-8".
Location D-1, portions of lines 013-HBDB-6" & 018-HBDB-4".
Location G-1, a portion of line 025-ZZKC-3".
Location F-2, a portion of line 021-ZZKC-6".
Location E-7, a portion of line 035-HBDB-3".
Request:
Provide the bases (e.g., entering a building/room with no safety-related components, becoming buried pipe) for the spatial interaction terminations.
APS Response to RAI 2.3-01 Palo Verde spatial interaction terminations are associated with the following two situations:
- 1. Piping exits an area with safety-related components to an area with no safety-related components - the spatial interaction termination point is located where the piping leaves the safety-related area.
- 2. Piping has an open end to atmosphere - the termination point is located at the end of the pipe where it is open to atmosphere. It is a Palo Verde license renewal specific practice to not show a spatial interaction symbol for an open ended drain to reduce congestion on boundary drawings.
There is no specific spatial interaction termination associated with buried piping. The spatial interaction termination would be located at the point where the piping leaves the safety-related area and is not related to buried piping. It is also possible to have piping 5
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application enter and exit safety-related areas several times on the same boundary drawing such that the piping could alternate from red to black several times.
The specific cases identified in the RAI have been reviewed to confirm that the spatial interaction terminations were correct to be either leaving a safety-related area or associated with open ended drain/vent piping. Clarifications and corrections are discussed below.
Normal Chilled Water System (2.3.3.5)
License Renewal Boundary Drawing LR-PVNGS-WC-01-M-WCP-001, Location G-1 upstream of valve PSV-1 19:
Pipe line 229-HBDB-1" downstream of valve PSV-1 19 and the associated air handing unit pan drain line has been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2) for spatial interaction.
Chemical and Volume Control (2.3.3.10)
License Renewal Boundary Drawing LR-PVNGS-CH-01-CHP-001, Piping N-745-HCDB-1" downstream of valve VM34:
License renewal boundary drawing LR-PVNGS-CH-01-CHP-001 shows a spatial interaction termination and an interface continuation to license renewal boundary drawing LR-PVNGS-RD-01-M-RDP-003 for pipe line N-745-HCDB-1" downstream of valve VM34. License renewal boundary drawing LR-PVNGS-RD-01-M-RDP-003 also shows a spatial interaction termination symbol. License renewal boundary drawing LR-PVNGS-CH-01-CHP-001 has been revised to remove the termination symbol.
License Renewal Boundary Drawing LR-PVNGS-CH-01-CHP-002, Sht. 1, Piping N-466-HCDB-1" downstream of Charging Pump No. 3 (CHE-PO1):
The spatial interaction termination symbol is correctly shown and applies to line N-499-HCDB-1 and does not apply to piping N-466-HCDB-1" downstream of Charging Pump No. 3. Line N-466-HCDB-1 does not have a spatial interaction function. The internal environment is wetted gas. No changes required.
License Renewal Boundary Drawing LR-PVNGS-CH-01-CHP-002, Sht. 1, Piping N-465-HCDB-1" downstream of Charging Pump No. 2 (CHB-P01):
This is the same condition as pipe line N-466-HCDB-1" noted above for Charging Pump No. 3 (CHE-P01). No changes required.
6
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application License Renewal Boundary Drawing LR-PVNGS-CH-01-CHP-002, Sht. 1, Piping N-464-HCDB-1" downstream of Charging Pump No. 1 (CHA-POl):
This is the same condition as pipe line N-466-HCDB-1" noted above for Charging Pump No. 3 (CHE-P01). No changes required.
Radioactive Waste Drains (2.3.3.27)
License Renewal Boundary Drawing LR-PVNGS-RD-01-M-RDP-002, Piping CH-N-538-HCDA-1" continuation to license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-001:
Pipe line CH-N-538-HCDA-1" continuation to license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-001 is abandoned in place on license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-001. License renewal boundary drawing LR-PVNGS-CH-01-M-CHP-001 has been revised to include pipe line CH-N-538-HCDA-1" within the scope of license renewal based on criterion 10 CFR 54.4 (a)(2) for spatial interactions.
Miscellaneous Auxiliary Systems (2.3.3.30) - Liquid Radwaste License Renewal Boundary Drawing LR-PVNGS-LR-01-N-LRP-001, Locations F-i, E-1, and D-1, lines downstream of in-line instruments FG-40, 41, & 42 to the non-ESF sump:
The spatial interaction termination for FG-42 is shown correctly. The spatial termination symbols associated with piping to FG-40 and FG-41 are located correctly but the drawing is highlighted incorrectly. License renewal boundary drawing LR-PVNGS-LR-01-N-LRP-001 has been revised to indicate the short piece of pipe between the spatial termination symbol location and instruments FG-40 and FG-41 is not within the scope of license renewal (colored black).
Miscellaneous Auxiliary Systems (2.3.3.30) -Oily Waste and Non-Radioactive Waste License Renewal Boundary Drawing LR-PVNGS-OW-01-M-OWP-003, Location D-3, a section of line 170-HGDH-4":
See the response to RAI 2.3.3.30-02 7
Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3-02
Background:
License renewal rule 10 CFR 54.21 (a) requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.
Issue:
The following identifies license renewal drawings where the staff was unable to identify the license renewal boundary because: (1) continuations were not provided or are incorrect, or (2) the continuation drawing was not provided.
LRA Section/Drawing Issue Section 2.3.3.10 LR-PVNGS-CH Location F-6, line 509-HCDB-1/2" downstream of valve M-CHP-002, Sht. 1 V104, drawing SSP-001, Sht. 2.
LR-PVNGS-CH Location C-10, line N-341-HCDB-1/22" downstream of valve M-CHP-003 V458, drawing SSP-001, Sht. 2.
Section 2.3.3.21 LR-PVNGS-DG-M-Piping N-098-HBDA-2" at location E-5 and N-091-HBDB-2" at DGP- 001-03 location E-1 on drawing.
LR-PVNGS-DG-M-Overflow piping at locations G-1 and G-5 on drawing.
DGP- 001-04 LR-PVNGS-DG-M-Piping N-040-HBDA-3/4" at location B-5, N-038-HBDA-3/4" at DGP- 001-09 location D-5, N-042-HBDA-3/4" at location F-5, and N-044-HBDA-3/4" at location G-5 on drawing.
Section 2.3.3.22 LR-PVNGS-DS Zone D-3 shows continuation of line N-266-YDGA-1 to M-DSP-002 LRPVNGS-HJ-02-M-HJP-001 (Zone A-13).
Section 2.3.3.24 LR-PVNGS-FS-AO-Location BA, line 042-HBDB-8" attached to in-scope Fuel W-FSP-300 Oil Storage Tank (FSN-T02).
Location F-4, line 043-HBDB-8" attached to in-scope Fuel Oil Storage Tank (FSN-T01).
8
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application LRA Section/Drawing I Issue Section 2.3.3.25 LR-PVNGS-GA Zone E-8 shows continuations of a four (4) 10 CFR 54.4 (a)(3)
M-GAP-002 pipe sections (to NW accumulators) to drawing LR-PVNGS-SG-01-MSGP-001.
Request:
Provide additional information to locate the continuations described above.
APS Response to RAI 2.3-02 These continuation issues are addressed by the RAIs described below. Please refer to the referenced RAIs for the responses.
Section 2.3.3.10 - Chemical and Volume Control Refer to RAI 2.3.3.10-02 License Renewal Boundary Drawings:
- LR-PVNGS-CH-01-M-CHP-002, Sht. 1
- LR-PVNGS-CH-01-M-CHP-003 Section 2.3.3.21 - Diesel Generator Refer to RAI 2.3.3.21-02 License Renewal Boundary Drawings:
- LR-PVNGS-DG-M-DGP-001-03
- LR-PVNGS-DG-M-DGP-001-04
- LR-PVNGS-DG-M-DGP-001-09 Section 2.3.3.22 - Domestic Water Refer to RAI 2.3.3.22-02 License Renewal Boundary Drawing:
- LR-PVNGS-DS-01-M-DSP-002 Section 2.3.3.24 - WRF Fuel System Refer to RAI 2.3.3.24-02 License Renewal Boundary Drawing:
- LR-PVNGS-FS-AO-WFSP-300 Section 2.3.3.25 - Service Gases (N2 and H2)
Refer to RAI 2.3.3.25-01 License Renewal Boundary Drawing:
- LR-PVNGS-GA-01-M-GAP-002 9
Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.1-01 Back.ground:
In LRA Section 2.3.3.1 portions of the fuel handling and storage system are within the scope of license renewal based on criteria 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2).
License renewal rule 10 CFR 54.21(a) requires applicants to list all components that are subject to an AMR.
Issue:
In LRA Section 2.3.3.1, System Description, the control element assembly (CEA) change platform was listed as a component that is within the scope of license renewal. The CEA change platform is used to move the CEAs within the upper guide structure and the CEA elevator. The CEA change platform was not included as a component subject to AMR in Table 2.3.3-1 for the fuel handling and storage system.
Request:
Provide additional information explaining why the CEA change platform is not included as a component subject to an AMR in LRA Table 2.3.3-1.
APS Response to RAI 2.3.3.1-01 The CEA change platform consists of several major components, some of which are passive and subject to aging management review as well as some of which are active components and not subject to aging management review. The system description of LRA section 2.3.3.1 lists components of the Fuel Storage and Handling System and identifies the CEA Change Platform as within the scope of license renewal. The Palo Verde plant equipment list identifies the CEA Change Platform as four components:
CEA Change Platform - Bridge Structure, CEA Change Platform - Trolley Assembly, CEA Change Platform - Drive Assembly (North Truck) and CEA Change Platform -
Drive Assembly (South Truck).
LRA Table 2.3.3-1 presents the component types that are subject to AMR together with the license renewal intended functions evaluated. The CEA Change Platform - Bridge Structure is included in Table 2.3.3-1 with component type "crane." The rails associated with the CEA Change Platform - Bridge Structure are included in Table 2.3.3-1 with component type "crane - rails." The CEA Change Platform - Trolley Assembly is included in Table 2.3.3-1 with component type "trolley." The rails associated with the CEA Change Platform - Trolley Assembly are included in Table 2.3.3-1 with component type "crane-rails." The CEA Change Platform - Drive Assembly (North Truck) and CEA Change Platform - Drive Assembly (South Truck) are evaluated as active components and are not subject to an AMR.
10
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.2-01
Background:
In LRA Section 2.3.3.2 portions of the spent fuel pool cooling and cleanup system are within the scope of license renewal based on criteria 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). License renewal rule 10 CFR 54.21 (a) requires applicants to list all components that are subject to an AMR.
Issue:
On LRA drawing LR-PVNGS-PC-01-M-PCP-001 (G-2 and C-2) and in LRA Section 2.3.3.2, a component is described as being an ion-exchanger. It appears in LRA Table 2.3.3-2 the ion-exchanger is a demineralizer since an ion-exchanger is not listed.
Request:
Provide additional information explaining why the component described as an ion-exchanger on the LRA drawing and in LRA Section 2.3.3.2 appears to be identified as a demineralizer in LRA Table 2.3.3-2.
APS Response to RAI 2.3.3.2-01 Individual component names and component types in the LRA are consistent with the component names and component types as they appear in the Palo Verde plant equipment database. The ion exchanger shown on LRA drawing LR-PVNGS-PC-01-M-PCP-001 (G-2 and C-2), has a component name in the Palo Verde plant equipment database that includes the words "ion exchanger" and the component type of "demineralizer." When a specific component is described in Section 2.3.3.2, the component name is used for clarity and specificity. In LRA Table 2.3.3-2, component types are listed together with license renewal intended functions. Thus, the component type for the components depicted on LRA drawing LR-PVNGS-PC-01-M-PCP-001 (G-2 and C-2) are listed as component type "demineralizer" consistent with the component type assigned within the Palo Verde plant equipment database.
NRC RAI 2.3.3.3-01
Background:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
11 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Issue:
License renewal drawing LR-PVNGS-EW-01-M-EWP-001 (B-7 and F-7) show 1" lines N-020-HBDB-1" and N-079-HBDB-1" as within the scope of license renewal as non-safety affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2). However, parts of these lines continuing to the drain are shown as not within scope for license renewal.
Request:
Provide additional information explaining why the lines to the drains are not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).
APS Response to RAI 2.3.3.3-01 License renewal boundary drawing LR-PVNGS-EW-01-M-EWP-001 has been revised to identify that relief valve drain lines N-020-HBDB-1" and N-079-HBDB-1" have been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2).
LRA Table 3.3.2-3 was revised to add a leakage boundary spatial function for the relief valve drain lines to the carbon steel Essential Cooling Water piping in a wetted gas environment line as shown in LRA Amendment No. 8 in Enclosure 2, Attachment 1.
NRC RAI 2.3.3.4-01 Backgqround:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
Issue:
Drawing LR-PVNGS-EC-01-M-ECP-001 shows several lines in and out of the ACU's (listed below) within the scope of license renewal for license renewal for 10 CFR 54.4 (a)(2). However the ACU's are shown as not within the scope of license renewal.
Location G-8 CS pump room essential ACU HAA-Z03 QI M Location G-7 HPSI pump room essential ACU HAA-ZO1 Q1 M Location G-5 LPSI pump room essential ACU HAA-Z02 Q1 M Location F-8 ELEC penetration room essential ACU HAA-Z06 Q1 M Location F-7 ECW pump room essential ACU HAA-Z05 Q1 M Location F-5 aux feed water pump room essential ACU HAA-Z04 Q1 M 12 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Location D-8 control room essential ACU HJA-F04 QI M Location D-6 CS DC equipment room essential ACU HJA-Z04 QI M Location D-5 ESF switchgear room essential ACU HJA-Z03 QI M Location G-4 CS pump room essential ACU HAB-Z03 QI M Location G-3 HPSI pump room essential ACU HAB-ZO1 Q1 M Location G-2 LPSI pump room essential ACU HAB-Z02 QIM Location F-4 ELEC penetration room essential ACU HAB-Z06 QI M Location F-3 ECW pump room essential ACU HAB-ZO5 QI M Location F-2 aux feed water pump room essential ACU HAB-Z04 QI M Location E-4 control room essential ACU HJB-F04 QI M Location E-3 CS DC equipment room essential ACU HJB-Z04 QI M Location E-2 ESF switchgear room essential ACU HJB-Z03 Q1 M Request:
Provide additional information explaining why the ACU's are not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4 (a).
APS Response to RAI 2.3.3.4-01 The ACUs have been confirmed to be within the scope of license renewal and confirmed to be highlighted on license renewal boundary drawings LR-PVNGS-HA M-HAP-001 (Auxiliary Building HVAC) and LR-PVNGS-HJ-02-M-HJP-001 (Control Building HVAC). The ACUs are shown with dashed lines (phantom) on license renewal boundary drawing LR-PVNGS-EC-01-M-ECP-001 (Essential Chilled Water System),
which indicates that the units are in other plant systems. Dashed lines that indicate other plant systems are not highlighted on license renewal boundary drawing LR-PVNGS-EC-01 -M-ECP-001.
NRC RAI 2.3.3.4-02
Background:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
Issue:
License renewal drawing LR-PVNGS-EC-01-M-ECP-001 shows lines N-233-HBDB-2" (Zone A7), N-142-HBDB-1 Y2" (Zone C-6), N-224-HBDB-2" (Zone A-3), and N-079-HBDB-1 1/2" (Zone D-2) within the scope of license renewal as non-safety affecting safety-related components based on the criteria of 10 CFR 54.4(a)(2) (Spatial Interaction).
13
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application However, a portion of these lines downstream of seismic anchors are shown as not within the scope of license renewal for spatial interaction.
Request:
Provide additional information explaining why the sections of pipe identified above are not within the scope of license renewal.
APS Response to RAI 2.3.3.4-02 Portions of pipe lines N-233-HBDB-2" and N-224-HBDB-2" shown on license renewal boundary drawing LR-PVNGS-EC-01-M-ECP-001 are evaluated as within the scope of license renewal for 10 CFR 54.4(a)(2) (Structural Integrity [Attached]) extending from the Essential Chiller refrigerant loop safety-related pressure relief valves and safety-related solenoid valves PV580 and PV579 to the respective seismic anchors as marked on the license renewal boundary drawing LR-PVNGS-EC-01-M-ECP-001. These pipe lines are evaluated as not within the scope of license renewal for spatial interaction as they are dry and open-ended. Should any of the safety-related valves attached to pipe lines N-233-HBDB-2" and N-224-HBDB-2" leak-by into the piping, the leaking fluid would be dry gas (refrigerant), which poses no potential for spatial interaction. The portions of pipe lines N-233-HBDB-2" and N-224-HBDB-2" shown on license renewal boundary drawing LR-PVNGS-EC-01-M-ECP-001 extending from the seismic anchors downstream to the vent at the end of the pipe line are evaluated as having no license renewal intended functions and are not within the scope of license renewal.
Portions of pipe lines N-142-HBDB-11/2" and N-079-HBDB-11/2" shown on license renewal boundary drawing LR-PVNGS-EC-01-M-ECP-001 are evaluated as within the scope of license renewal for 10 CFR 54.4(a)(2) (Structural Integrity [Attached])
extending from the safety-related Essential Chilled Water Expansion Tank nitrogen-space pressure relief valves PSV-75 and PSV-76 to the respective seismic anchors marked on the license renewal boundary drawing LR-PVNGS-EC-01-M-ECP-001.
These pipe lines are evaluated as not within the scope of license renewal for spatial interaction as they are dry and open-ended. Additionally, should PSV-75 and PSV-76 leak-by into lines N-142-HBDB-11/2" and N-079-HBDB-11/22," the fluid leaked would be dry gas (nitrogen), which poses no potential for adverse spatial interaction. Pipe lines N-142-HBDB-11/2" and N-079-HBDB-11/2" are shown on license renewal boundary drawing LR-PVNGS-EC-01-M-ECP-001 as open and ending at a drain funnel. The portions of pipe lines N-142-HBDB-11/2" and N-079-HBDB-11/2"shown on license renewal boundary drawing LR-PVNGS-EC-01-M-ECP-001 extending from the seismic anchors downstream to the open end of the pipe line are evaluated as having no license renewal intended functions and are not within the scope of license renewal.
14 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.4-03 Back.ground:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
Issue:
License renewal drawing LR-PVNGS-CT-01-M-CTP-001 (C-2) shows valve V063 and the capped end upstream of valve V063 as within the scope of license renewal for 10 CFR 54.4(a)(1) and 10 CFR 54.4 (a)(2) respectively. However, a small portion of the line in between the valve and capped end is shown as out of scope for license renewal.
Request:
Provide additional information explaining why this section of pipe is not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).
APS Response to RAI 2.3.3.4-03 Highlighting of the pipe between valve V063 and the capped end of the pipe was inadvertently omitted on license renewal boundary drawing LR-PVNGS-CT-01-M-CTP-001. The pipe segment between valve V063 and the capped end of the pipe on license renewal boundary drawing LR-PVNGS-CT-01-M-CTP-001 has been confirmed to be within the scope of license renewal for criterion 10 CFR 54.4(a)(2). License renewal boundary drawing LR-PVNGS-CT-01-M-CTP-001 has been revised to show the pipe segment between valve V063 and the capped end of the pipe completely highlighted.
NRC RAI 2.3.3.4-04
Background:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
Issue:
License renewal drawing LR-PVNGS-EC-01-M-ECP-001 (Zone F-2) shows line N-122-HBDB-11/2" as within the scope of license renewal for 10 CFR 54.4(a)(2). The 15
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application continuation of this line on license renewal drawing LR-PVNGS-RD-01-M-RDP-002 (Zone F-9) is shown as not within the scope of license renewal.
Request:
Provide additional information explaining why LR-PVNGS-EC-01-M-ECP-001 (Zone F-2) shows N-122-HBDB-11/2" as in scope, and LR-PVNGS-RD-01-M-RDP-002 (Zone F-9) shows this line as out of scope.
APS Response to RAI 2.3.3.4-04 This issue was also addressed by RAI 2.3.3.27-01 for line N-1 22-HBD-1 Y2" on license renewal boundary drawing LR-PVNGS-RD-01-M-RDP-002. Refer to RAI 2.3.3.27-01 for resolution.
NRC RAI 2.3.3.5-01 Back-ground:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
Issue:
License renewal drawing LR-PVNGS-WC-01-M-WCP-001 shows several lines in and out of the ACU's and AHU's within the scope of licensed renewal for 10 CFR 54.4(a)(2). However the ACU's and AHU's (listed below) are shown as not within the scope of license renewal.
" Location G-15 and 0-16 containment normal ACU HCN-AO1A R9M Location G-13 containment normal ACU HCN-AO1 B R9M Location G-10 and G-11 containment normal ACU HCN-AO1 C R9M
" Location G-7 and G-8 containment normal ACU HCN-AO1 D R9M
" Location 0-2 and H-2 control building normal ACU HJN-AO1A S3M
" Location D-16 charging pump room normal ACU HAN-Z01C S3M
" Location D-14 charging pump room normal ACU HAN-ZO1 B S3M
" Location D-13 charging pump room normal ACU HAN-ZO1A S3M
" Location E-3 ESP switchgear room normal AHU HJN-A03 S3M Location E-2 and F-2 control room normal AHU HJN-A02 S3M
" Location G-3 CEDM control cabinet room normal AHU HAN-ZO2A S3M Location G/D-1 CEDM control cabinet room normal AHU HAN-ZO2A S3M 16 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Request:
Provide additional information explaining why these components are not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).
APS Response to RAI 2.3.3.5-01 The ACUs or AHUs have been confirmed to be within the scope of license renewal and confirmed to be highlighted on the license renewal boundary drawings noted below.
The ACUs or AHUs are shown with dashed lines (phantom) on license renewal boundary drawing LR-PVNGS-WC-01-M-WCP-001 (Normal Chilled Water System),
which indicates that the units are in other plant systems. Dashed lines that indicate other plant systems are not highlighted on license renewal boundary drawing LR-PVNGS-WC-01 -M-WCP-001.
- ACU HCN-A01A R9M - LR-PVNGS-HC-02-M-HCP-001 (Containment Building HVAC).
" ACU HCN-AO1B R9M - LR-PVNGS-HC-02-M-HCP-001 (Containment Building HVAC).
" ACU HCN-AO1C R9M - LR-PVNGS-HC-02-M-HCP-001 (Containment Building HVAC).
" ACU HCN-AO1 D R9M - LR-PVNGS-HC-02-M-HCP-001 (Containment Building HVAC).
" ACU HJN-AO1A S3M - LR-PVNGS-HJ-02-M-HJP-002 (Control Building HVAC).
" ACU HAN-Z01C S3M - LR-PVNGS-HA-02-M-HAP-002 (Auxiliary Building HVAC).
" ACU HAN-ZO1B S3M - LR-PVNGS-HA-02-M-HAP-001 (Auxiliary Building HVAC).
" ACU HAN-Z01A S3M - LR-PVNGS-HA-02-M-HAP-001 (Auxiliary Building HVAC).
" AHU HJN-A03 S3M - LR-PVNGS-HJ-02-M-HJP-002 (Control Building HVAC).
AHU HJN-A02 S3M - LR-PVNGS-HJ-02-M-HJP-001 (Control Building HVAC).
AHU HAN-Z02A S3M - LR-PVNGS-HA-02-M-HAP-004 (Auxiliary Building HVAC).
" AHU HAN-Z02A S3M - LR-PVNGS-HA-02-M-HAP-004 (Auxiliary Building HVAC).
NRC RAI 2.3.3.5-02
Background:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
17 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Issue:
On LRA drawing LR-PVNGS-WC-01-M-WCP-001 several lines (listed below) attached to 10 CFR 54.4(a)(2) lines are shown as not in-scope for license renewal.
Location G-14 line 267-HBDB-1" downstream of valve PSV-131.
Location 0-12 line 233-HBDB-1" downstream of valve PSV-1 32.
Location G-9 line 232-HBDB-1 "downstream of valve PSV-1 33.
Location G-6 line 231-HBDB-1" downstream of valve PSV-134.
Location F-2 line 271-HBDB-1".
Location E-1 line 228-HBDB-1" Location G-2 line 069-HBDB-1 Y".
Location C-1 line 131-HBDB-11/2".
Location E-2 line 234-HBDB-11/2".
Location C-3 line 153-HBDB-11/2".
Location E-3 line 274-HBDB-1 1/2".
Request:
Provide additional information explaining why these pipe sections are not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).
APS Response to RAI 2.3.3.5-02 License renewal boundary drawing LR-PVNGS-WC-01-M-WCP-001 has been revised to identify that the following relief valve drain lines or air handing unit pan drain lines have been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2) for spatial interaction:
" 267-HBDB-1" drain line downstream of valve PSV-131.
" 233-HBDB-1" drain line downstream of valve PSV-132.
" 232-HBDB-1" drain line downstream of valve PSV-133.
" 231-HBDB-1" drain line downstream of valve PSV-134.
" 271-HBDB-1" drain line downstream of valve PSV-143.
" 228-HBDB-1" drain line downstream of valve PSV-118.
" 069-HBDB-11/2" air handling unit pan drain line.
" 131-HBDB-11/2" air handling unit pan drain line.
" 234-HBDB-11/2" air handling unit pan drain line.
" 153-HBDB-11/2" air handling unit pan drain line.
" 274-HBDB-11/2" air handling unit pan drain line.
18 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Pipe line 229-HBDB-1" downstream of valve PSV-1 19 and the associated air handing unit pan drain line have also been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2) for spatial interaction.
NRC RAI 2.3.3.6-01 Backgiround:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
Issue:
Several portions of the nuclear cooling water system are within the scope of license renewal as non-safety affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2). However on the following drawings several lines attached to the 10 CFR 54.4(a)(2) lines are shown as not within the scope of license renewal.
LRA Drawing LR-PVNGS-NC-01-M-NCP-001:
Location F-i line 057-HBDB-1" downstream of valve PSV-51.
Location F-2, line 061-HBDB-1" downstream of valve PSV-53.
Location F-3, line 063-HBDB-1" downstream of valve PSV-54.
Location F-3, line 055-HBDB-1" downstream of valve PSV-50.
Location F-4 line 059-HBDB-1" downstream of valve PSV-52.
Location D-1, line 177-HBDB-1" downstream of valve PSV-137.
Location D-2, line 178-HBDB-1" downstream of valve PSV-138.
Location D-2, line 179-HBDB-1" downstream of valve PSV-139.
Location D-3, line 175-HBDB-1" downstream of valve PSV-135.
Location D-3, line 176-HBDB-1" downstream of valve PSV-136.
Location D-4, line 174-HBDB-1" downstream of valve PSV-134.
Location B-1, line 163-HBDB-1" downstream of valve PSV-269.
Location B-3, line 293-HBDB-1" downstream of valve PSV-149.
LRA drawinq LR-PVNGS-NC-01-M-NCP-002:
Location E-6, line N-096-HBDB-1" downstream of valve PSV-204.
LRA drawing LR-PVNGS-NC-01-M-NCP-003:
Location C-3, line 152-HBDB-1" downstream of valve PSV-417.
Location C-5, line 150-HBDB-1" downstream of valve PSV-416.
Location F-3, line 146-HBDB-1" downstream of valve PSV-415.
Location F-5, line 144-HBDB-1" downstream of valve PSV-414.
Location G-7, line 262-HBDB-1" downstream of valve PSV-499.
Location E-6, line 145-HBDB-1" downstream of valve PSV-450.
19
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application LRA drawing LR-PVNGSC- 01-M-SCP-006-01:
Location E-16 line N-221-DCDB-3/8" downstream of valve V233 (SC-638).
Location E-14, 3 line N-222-DCDB-3/8" downstream of valve V236 (SC-637).
Location E-13, line N-223-DCDB-3/8" downstream of valve V239 (SC-636).
Location E-1 1, line N-225-DCDB-3/8" downstream of valve V245 (SC-641).
Location E-9, line N-226-DCDB-3/8" downstream of valve V248 (SC-640).
Location E-8, line N-227-DCDB-3/8" downstream of valve V251 (SC-633).
Request:
Provide additional information explaining why these sections of pipe are not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).
APS Response to RAI 2.3.3.6-01 The following license renewal boundary drawings have been revised to reflect that the following relief valve drain lines or drain lines have been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2) for spatial interaction.
LRA Drawing LR-PVNGS-NC-01-M-NCP-001:
057-HBDB-1" drain line downstream of valve PSV-51.
061-HBDB-1" drain line downstream of valve PSV-53.
063-HBDB-1" drain line downstream of valve PSV-54.
055-HBDB-1" drain line downstream of valve PSV-50.
059-HBDB-1" drain line downstream of valve PSV-52.
177-HBDB-1" drain line downstream of valve PSV-1 37.
178-HBDB-1" drain line downstream of valve PSV-138.
179-HBDB-1" drain line downstream of valve PSV-1 39.
175-HBDB-1" drain line downstream of valve PSV-1 35.
176-HBDB-1" drain line downstream of valve PSV-1 36.
174-HBDB-1" drain line downstream of valve PSV-1 34.
163-HBDB-1" drain line downstream of valve PSV-269.
293-HBDB-1" drain line downstream of valve PSV-149.
LRA drawing LR-PVNGS-NC-01-M-NCP-002:
N-096-HBDB-1" drain line downstream of valve PSV-204.
LRA drawing LR-PVNGS-NC-01-M-NCP-003:
152-HBDB-1" drain line downstream of valve PSV-417.
150-HBDB-1" drain line downstream of valve PSV-416.
146-HBDB-1" drain line downstream of valve PSV-415.
144-HBDB-1" drain line downstream of valve PSV-414.
262-HBDB-1" drain line downstream of valve PSV-499.
145-HBDB-1" drain line downstream of valve PSV-450.
20 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application LRA drawing LR-PVNGSC- 01-M-SCP-006-01:
" N-221-DCDB-3/8" drain line downstream of valve V233 (SC-638).
N-222-DCDB-3/8" drain line downstream of valve V236 (SC-637).
N-223-DCDB-3/8" drain line downstream of valve V239 (SC-636).
N-225-DCDB-3/8" drain line downstream of valve V245 (SC-641).
N-226-DCDB-3/8" drain line downstream of valve V248 (SC-640).
N-227-DCDB-3/8" drain line downstream of valve V251 (SC-633).
In addition, LRA Table 3.3.2-6 was revised to add a leakage boundary spatial function for the relief valve drain lines to the carbon steel Nuclear Cooling Water piping in a wetted gas environment line, as shown in LRA Amendment No. 8 in, Attachment 1.
NRC RAI 2.3.3.6-02
Background:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
Issue:
Drawing LR-PVNGS-NC-01-M-NCP-003 (D-8 and G-8) show several lines in and out of the ACU's within the scope of license renewal for 10 CFR 54.4(a)(2). However the two ACU's (HCN-A02B and HCN-A02A) are shown as not within the scope of license renewal.
Request:
Provide additional information explaining why ACU's HCN-A02B and HCN-A02A are not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).
APS Response to RAI 2.3.3.6-02 The ACUs have been confirmed to be within the scope of license renewal and confirmed to be highlighted on license renewal boundary drawing LR-PVNGS-HC-02-M-HCP-002 (Containment Building HVAC). The ACUs are shown with dashed lines (phantom) on license renewal boundary drawing LR-PVNGS-NC-01-M-NCP-003 (Nuclear Cooling Water System), which indicates that the units are in another plant system. Dashed lines that indicate other plant systems are not highlighted on license renewal boundary drawing LR-PVNGS-NC-01-M-NCP-003.
21 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.6-03
Background:
LRA Section 2.3.3.6, Nuclear Cooling Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, leakage boundary, and structural integrity.
Issue:
Drawing LR-PVNGS-NC-01-M-NCP-003 (C-4) shows line 124-HBDB-8" as within the scope of license renewal for 10 CFR 54.4 (a)(3) whereas a small portion of the same line is shown as within the scope of license renewal for 10 CFR 54.4 (a)(2).
Request:
Provide additional information to clarify the scoping classification for this pipe section.
APS Response to RAI 2.3.3.6-03 Line 124-HBDB-6" (referred to as 124-HBDB-8" in RAI 2.3.3.6-03) extending from Reactor Coolant Pump 2B thrust bearing lube oil cooler to line 120-HBDB-6" is within the scope of license renewal based on 10 CFR 54.4 (a)(3) for fire protection requirements as described in LR Note 3 on license renewal boundary drawing LR-PVNGS-NC-01-M-NCP-003. The short segment of the line that is highlighted in red that appears on license renewal boundary drawing LR-PVNGS-NC-01-M-NCP-003 between line 120-HBDB-6" and line 116-HBDB-6" has been revised to highlight the line green and place the line within the scope of license renewal based on 10 CFR 54.4 (a)(3) for fire protection requirements.
NRC RAI 2.3.3.7-01
Background:
License renewal rule 10 CFR 54.21(a)(1) requires applicants to list all components subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.
Issue:
Drawing LR-PVNGS-SP-01-M-SPP-002 (D-3 and D-7) shows two 1-inch lines (N-075-HCDA-1" and N-042-HCDA-1") as within the scope of license renewal for 10 CFR 22 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application 54.4(a)(2). However the continuation of these lines, after the seismic anchor, to the drains is shown as not within the scope of license renewal.
Request:
Provide additional information explaining why portions of these lines are not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4(a).
APS Response to RAI 2.3.3.7-01 License renewal boundary drawing LR-PVNGS-SP-01-M-SPP-002 has been revised to reflect that relief valve drain lines N-075-HCDA-1" and N-042-HCDA-1" have been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2) for spatial interaction.
LRA Table 3.3.2-7 was revised to add a leakage boundary spatial function for the relief valve drain lines to the stainless steel Essential Spray Pond piping in a wetted gas environment line as shown in LRA Amendment No. 8 in Enclosure 2,.
NRC RAI 2.3.3.8-01
Background:
The nuclear sampling system is in-scope for license renewal based on criteria 10 CFR 54.4(a)(1). Portions are also in-scope as nonsafety-related affecting safety-related components for structural integrity and/or spatial interaction based on the criteria of 10 CFR 54.4(a)(2) and portions support fire protection and environmental qualification requirements based on the criteria of 10 CFR 54(a)(3).
Issue:
License renewal drawing LR-PVNGS-SS-01-N-SSP-001-1 (C-6) shows continuation of 10 CFR 54.4(a)(2) pipe section, DW-N-079-HCDA-1", to drawing LR-PVNGS-DW M-DWP-002 (H-3). On drawing LR-PVNGS-DW-01-M-DWP-002 the continuation is not within the scope of license renewal.
Request:
Provide additional information to justify why the continuation on drawing LR-PVNGS-DW-01-M-DWP-002 is not within the scope of license renewal.
23 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application APS Response to RAI 2.3.3.8-01 Line N-079-HCDA-1" is not within the scope of license renewal in the Nuclear Sampling System or the Demineralized Water System because it is not safety related, and neither connects to safety related equipment nor traverses areas occupied by safety related equipment. Highlighting of pipe line N-079-HCDA-1" was inadvertently colored on license renewal boundary drawing LR-PVNGS-SS-01-N-SSP-001-01. License renewal boundary drawing LR-PVNGS-SS-01-N-SSP-001-01 has been revised to remove the highlighting for pipe line N-079-HCDA-1" and add a spatial interaction termination flag at coordinate C-4 on line N-018-HCDB-3/8". There is no continuation to the Demineralized Water System.
NRC RAI 2.3.3.8-02
Background:
The nuclear sampling system is in-scope for license renewal based on criteria 10 CFR 54.4(a)(1). Portions are also in-scope as nonsafety-related affecting safety-related components for structural integrity and/or spatial interaction based on the criteria of 10 CFR 54.4(a)(2) and portions support fire protection and environmental qualification requirements based on the criteria of 10 CFR 54(a)(3).
Issue:
Drawing LR-PVNGS-SS-01-N-SSP-001-01 (B-I) shows a continuation of 10 CFR 54.4(a)(2) pipe section, N-46-XCDA-2", to "Hot Lab Sink Drain" on drawing LR-PVNGS-CM-01-M-CMP-001 (H-8). On drawing LR-PVNGS-CM-01-M-CMP-001 the continuation is not within the scope of license renewal.
Request:
Provide additional information to justify why the continuation on drawing LR-PVNGS-CM-01-M-CMP-001 is not within the scope of license renewal.
APS Response to RAI 2.3.3.8-02 Line N-046-XCDA-2" is within the scope of license renewal in the Nuclear Sampling System. Line N-046-XCDA-2" is not within the scope of license renewal in the Chemical Waste System. License renewal boundary drawing LR-PVNGS-SS-01-N-SSP-001-1 has been revised to add a spatial interaction termination flag on line N-046-XCDA-2" and to remove the highlighting downstream of the spatial interaction termination flag prior to the continuation to license renewal boundary drawing LR-PVNGS-CM-01-M-CMP-001. There is no continuation to drawing LR-PVNGS-CM-01-M-CMP-001.
24 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.8-03
Background:
License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.
Issue:
License renewal drawing LR-PVNGS-SS-03-N-SSP-003-01 (Zone D-3), shows a continuation of 10 CFR 54.4(a)(2) pipe section N-067-HCDA-1/2" to "Equipment Drain Tank" on license renewal drawing LR-PVNGS-CH-01-CHP-003 (Zone A-9). License renewal drawing LR-PVNGS-CH-01-CHP-003 (Zone A-9) contains a pipe section N-067-HCDA-1/2"; however, this pipe section is identified as coming from license renewal drawing LR-PVNGS-SS-N-SSP-002 (Zone D-5). A review of license renewal drawing LR-PVNGS-SS-N-SSP-002 (Zone D-5) identified the subject line going to license renewal drawing LR-PVNGS-CH-01-CHP-003 (Zone A-8). The staff is unable to identify the continuation of pipe section N-067-HCDA-1/2" from license renewal drawing LR-PVNGS-SS-03-N-SSP-003-01 (Zone D-3) to license renewal drawing LR-PVNGS-CH-01-CHP-003 (Zone A-9). The staff is also unable to find a link between license renewal drawings LR-PVNGS-SS-03-N-SSP-003-01 (Zone D-3) and LR-PVNGS-SS-N-SSP-002 (Zone D-5) for pipe N-067-HCDA-1/2" that ties them together.
Request:
Provide additional information to locate the continuation of pipe section N-067-HCDA-1/2" from LR-PVNGS-SS-03-N-SSP-003-01 (Zone D-3).
APS Response to RAI 2.3.3.8-03 Line N-067-HCDA-1/2" is continuous as depicted on the license renewal boundary drawings from LR-PVNGS-SS-03-N-SSP-003-and LR-PVNGS-SS-01-N-SSP-002-1 to LR-PVNGS-CH-01-CHP-003. The same pipe section of line N-067-HCDA-1/2A" is shown on both boundary drawings, LR-PVNGS-SS-01-SSP-002-1 (location D-5 is applicable to Unit 1 only) and LR-PVNGS-SS-03-SSP-003-1 (location D-3 is applicable to Units 2 and 3). The inconsistency in continuation grid coordinates (A-8 or A-9) on boundary drawings LR-PVNGS-SS-01-SSP-002-1 and LR-PVNGS-SS-03-SSP-003-1 is caused from using a Unit 3 P&ID to create license renewal boundary drawing LR-PVNGS-SS-03-N-SSP-003-1 with a continuation to a Unit 1 boundary drawing LR-PVNGS-CH CHP-003. License renewal boundary drawings LR-PVNGS-CH-01-CHP-003, and LR-PVNGS-SS-01-N-SSP-002-1 were created from Unit 1 P&IDs.
25 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.10-01 Back~ground:
LRA Section 2.3.3.10, Chemical Volume and Control System, states components are within the scope of license renewal for 10 CFR 54.4(a)(1),10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing structural integrity, insulation, and pressure and leakage boundary.
Issue:
Several portions of the chemical volume and control system are within the scope of license renewal as non-safety affecting safety-related components based on the criterion of 10 CFR 54.4 (a)(2). However on the following drawings several lines attached to 10 CFR 54.4(a)(2) lines are shown as not within the scope of license renewal.
Drawing LR-PVNGS-CH-01-M-CHP-001:
Location A-1 1, line N-544-HCDA-2" downstream of valve V916.
Location D-1 3, line N-526-HCDA-1" downstream of valve V004.
Location F-1 1, line N-046-HCDA-1" downstream of valve V445.
Drawing LR-PVNGS-CH-01-M-CHP-002, Sht. 1:
Location F-1 2, line N-1 70-HCDB-1" downstream of valve V1 21.
Location G-1 2, line N-444-HCDB-2" downstream of boric acid batching tank CHN-T03.
Location G-8, line N-215-HCDB-1" downstream of valve PSV-105 continued to GRP-001 (F-8).
Location G-6, line N-221-HCDB-1/2" downstream of valve V100.
Drawing LR-PVNGS-CH-01-M-CHP-003:
Location F-1 0, line N-322-HCDA-3" downstream of valve V655.
Location E-9, line N-218-HCDA-3" downstream of valve UV-567.
Location E-8, line N-331-HCDA-4" downstream of Pump No. 1 CHN-P05A.
Location D-8, line N-332-HCDA-4" downstream of Pump No. 2 CHN-P05B.
Location H-6, line N-363-HCCA-2" downstream of valve V-686.
Location G-1, line N-497-HCDB-1" downstream of valve VM61.
Location G-i, line N-498-HCDB-1" downstream of valve VM61.
Location G-1, line N-499-HCDB-1" downstream of valve VM61.
Location F-i, line N-402-HCDB-1i1/2" downstream of valve V762.
Location F-i, line N-432-HCCA-i11/2" downstream of valve V861.
Location E-i, line N-401-HCDB-1i" downstream of valve V692.
Location D-7, line (1 Y2" temporary injection conn. for s/u testing) downstream of valve V709.
26
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Drawing LR-PVNGS-SI-01-M-SIP-001:
0 Location E-8, line N-024-HCDA-2" downstream of valve V474.
Drawinq LR-PVNGS-RD-01-M-RDP-005:
Location G-l, line 134-HCDA-6" upstream of the hold-up tank sump.
Drawing LR-PVNGS-AS-01-M-ASP-001:
Location D-1, line 118-HBDB-4" downstream of valve V186.
Request:
Provide additional information explaining why these sections of pipe are not within the scope of license renewal and justify the boundary locations with respect to the applicable requirements of 10 CFR 54.4 (a).
APS Response to RAI 2.3.3.10-01 Drawing LR-PVNGS-CH-01-M-CHP-001:
The connected sections of the three cited instances on this drawing are in scope and should have been shown as (a)(2).
" Location A-11, line N-544-HCDA-2" downstream of valve V916.
Boundary drawing LR-PVNGS-CH-01-M-CHP-001 has been revised to show the continuation of N-544-HCDA-2" in scope for (a)(2), making it consistent with boundary drawing LR-PVNGS-CH-01-M-CHP-003.
Location D-1 3, line N-526-HCDA-1" downstream of valve V004.
Boundary drawing LR-PVNGS-CH-01-M-CHP-001 has been revised to show the continuation of N-526-HCDA-1" in scope for (a)(2), making it consistent with boundary drawing LR-PVNGS-RD-01-M-RDP-002.
Location F-11, line N-046-HCDA-1" downstream of valve V445.
Boundary drawing LR-PVNGS-CH-01-M-CHP-001 has been revised to show the continuation of N-046-HCDA-1" in scope for (a)(2), making it consistent with boundary drawing LR-PVNGS-RD-01-M-RDP-003.
Drawing LR-PVNGS-CH-01-M-CHP-002, Sht. 1:
Location F-12, line N-170-HCDB-1" downstream of valve V121, and Location G-12, line N-444-HCDB-2" downstream of boric acid batching tank CHN-T03.
27
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application The continuation of these lines is in scope and should have been shown as (a)(2) on the drawing. Boundary drawing LR-PVNGS-CH-01-M-CHP-002, Sht. 1 has been revised for the boric acid batching tank components making it consistent with boundary drawing LR-PVNGS-RD-01-M-RDP-003 (F16).
" Location G-8, line N-215-HCDB-1" downstream of valve PSV-105 continued to LR-PVNGS-GR-01-M-GRP-001 (F-8).
It was determined that drawing LR-PVNGS-GR-01-M-GRP-001 (F-8) showing N-215-HCDB-1" highlighted (a)(2) with a termination at a seismic anchor was not correct. Line N-215-HCDB-1" is not in scope for (a)(2). Drawing LR-PVNGS-GR-01-M-GRP-001 (F-8) was revised to remove the highlight of N-215-HCDB-1" and the seismic anchor termination symbol.
" Location G-6, line N-221-HCDB-1/2" downstream of valve V100.
It was determined that drawing LR-PVNGS-GR-01-M-GRP-001 (F-8) showing N-221-HCDB-1/2" highlighted (a)(2) with a termination at a seismic anchor was not correct. Drawing LR-PVNGS-GR-01-M-GRP-001 (F-8) was revised to remove the highlight of N-221-HCDB-1/2" and the seismic anchor termination symbol. The structural integrity function termination at a seismic anchor (G-6) on line N-221-HCDB-W" on drawing LR-PVNGS-CH-01-M-CHP-002, Sht. 1 is correct.
Drawing LR-PVNGS-CH-01-M-CHP-003:
" Location F-10, line N-322-HCDA-3" downstream of valve V655.
It was determined that the termination symbol on line N-322-HCDA-3" should be removed from downstream of valve V655. Instead, spatial interaction and structural integrity (attached) termination symbols should be shown on line N-322-HCDA-3" at the pipe tunnel and upstream of valve V656. The components between these termination symbols should be in scope for (a)(2). Boundary drawing LR-PVNGS-CH-01-M-CHP-003 has been revised accordingly.
" Location E-9, line N-218-HCDA-3" downstream of valve UV-567.
It was determined that the termination symbols for spatial interaction and structural integrity (attached) need to be added to line N-218-HCDA-3".
Boundary drawing LR-PVNGS-CH-01-M-CHP-002, area (G-7) was revised accordingly. Line N-218-HCDA-3" shown on drawing LR-PVNGS-CH-01-M-CHP-003 downstream of UV-567 is out of scope.
28 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application
" Location E-8, line N-331-HCDA-4" downstream of Pump No. 1 CHN-P05A and Location D-8, line N-332-HCDA-4" downstream of Pump No. 2 CHN-P05B.
Boundary drawing LR-PVNGS-CH-01-M-CHP-003 has been revised to show the lines downstream of these pumps to the new spatial interaction termination symbols that were added as in scope for (a)(2).
" Location H-6, line N-363-HCCA-2" downstream of valve V-686.
Line N-363-HCCA-2 and valve V-686 already are in scope for (a)(1) as pressure boundary and should have been designated (a)(1) on the drawing. Boundary drawing LR-PVNGS-CH-01-M-CHP-003 has been revised to show these components as (a)(1), and downstream components have been shown as (a)(2) as appropriate for spatial interaction and structural integrity.
Location G-1, line N-497-HCDB-1" downstream of valve VM61, Location G-1, line N-498-HCDB-1" downstream of valve VM61, and Location G-1, line N-499-HCDB-1" downstream of valve VM61.
Boundary drawings LR-PVNGS-CH-01-M-CHP-003 and LR-PVNGS-CH-01-M-CHP-002 have been revised to show lines N-497-HCDB-1", N-498-HCDB-1", and N-499-HCDB-1" downstream of valve VM61 as in scope for (a)(2).
Location F-I, line N-402-HCDB-1 /2" downstream of valve V762.
Boundary drawing LR-PVNGS-CH-01-M-CHP-003 (F-i) has been revised to show line N-402-HCDB-111/2" and downstream piping to the next termination symbols as in scope for (a)(2).
" Location F-I, line N-432-HCCA-I11/2" downstream of valve V861.
Line N-432-HCCA-11/2" and valve V861 are in scope for (a)(1). Boundary drawing LR-PVNGS-CH-01-M-CHP-003 (F-I) has been revised to show these components as (a)(1) and associated downstream components have been shown as (a)(2) as appropriate for spatial interaction and structural integrity.
" Location E-1, line N-401-HCDB-11/2" downstream of valve V692.
Boundary drawing LR-PVNGS-CH-01-M-CHP-003 (El) has been revised to show N-401-HCDB-11/2" in scope for (a)(2). Terminal components were identified for spatial interaction and structural integrity (attached) and LR-PVNGS-CH M-CHP-003 was revised accordingly.
29 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Location D-7, line (1%" temporary injection connection for startup testing) downstream of valve V709. (This line connects to line N-373-HCDB-2".)
Terminal symbols have been added to drawing LR-PVNGS-CH-01-M-CHP-002 (G-1 5), and line N-373-HCDB-2" downstream of the terminal point on drawing LR-PVNGS-CH-01-M-CHP-002 has been revised showing not in scope. The portions of line N-373-HCDB-2" on drawing LR-PVNGS-CH-01-M-CHP-003 remain out of scope, including the 11/2" temporary injection connection.
Drawing LR-PVNGS-SI-01-M-SIP-001:
0 Location E-8, line N-024-HCDA-2" downstream of valve V474.
Line N-024-HCDA-2" is in scope for (a)(2) spatial interaction and should have been shown as (a)(2). Boundary drawing LR-PVNGS-SI-01-M-SIP-001 has been revised to show the remainder of line N-024-HCDA-2" on LR-PVNGS-SI-01-M-SIP-001 as in scope for (a)(2).
Drawing LR-PVNGS-RD-01-M-RDP-005:
Location G-1, line 134-HCDA-6" upstream of the hold-up tank sump.
The function of structural integrity was extended to include line 134-HCDA-6" on drawing LR-PVNGS-RD-01-M-RDP-005 (G-1). Line 134-HCDA-6" on drawing LR-PVNGS-RD-01-M-RDP-005 (G-1) has been added as in scope for (a)(2) up to where line 134-HCDA-6" enters the concrete. The connecting line is labeled as line N-718-HCDA-6" on drawing LR-PVNGS-CH-01-M-CHP-002 (C-15), and the seismic anchor symbol was removed.
Drawing LR-PVNGS-AS-01-M-ASP-001:
Location D-1, line 118-H BDB-4" downstream of valve V1 86.
Line 11 8-HBDB-4" downstream of V1 86 is in scope for (a)(2) and should have been shown as in scope on the drawing. Boundary drawing LR-PVNGS-AS M-ASP-001 has been revised to show the remainder of line 11 8-HBDB-4" up to the drawing interface as in scope for (a)(2).
As a result of the changes described above and the associated aging management review updates, aging management evaluations summarized in LRA Table 3.3.2-10 have been revised as shown in Amendment 8 in Enclosure 2, Attachment 1.
30
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.10-02
Background:
License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.
Issue:
A continuation drawing was not provided in the license renewal package for the following piping continuations:
Drawing LR-PVNGS-CH-01-M-CHP-002, Sht. 1:
Location F-6, line 509-HCDB-1/2" downstream of valve V104, drawing SSP-001, Sht. 2.
Drawing LR-PVNGS-CH-01-M-CHP-003:
Location C-10, line N-341-HCDB-1/2" downstream of valve V458, drawing SSP-001, Sht. 2.
Request:
Provide additional information to locate the license renewal boundaries.
APS Response to RAI 2.3.3.10-02 Pipe line 509-HCDB-1/2" downstream of valve V104 is within the scope of license renewal based on criterion 10 CFR 54.4 (a)(2) with an intended function of structural integrity (attached). However, pipe line 509-HCDB-1/2" is terminated at the seismic support on license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-002, Sht. 1, (F-6) before continuing on to the Nuclear Sampling System.
Pipe line N-341-HCDB-1/2" is not within the scope of license renewal and is correctly shown on boundary drawing LR-PVNGS-CH-01-M-CHP-003 (C-10). Pipe line N-341-HCDB-1 is terminated at the seismic support downstream of V564 on license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003 (C-10) before continuing on to the Nuclear Sampling System.
31
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.10-03
Background:
LRA Section 2.3.3.10, Chemical Volume and Control System, states components are in-scope for license renewal for 10 CFR 54.4(a)(1),10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing a structural integrity, insulation, pressure and leakage boundary.
Issue:
License renewal drawings show several lines as not within the scope of license renewal yet are connected to piping and tanks which are shown as within the scope of license renewal as follows:
LR-PVNGS-CH-01-M-CHP-002, Sht.1:
Location F-15, line N-713-HCDA-8" attached to in-scope Refueling Water Tank (CHE-TO 1).
Location E-13, line N-171-HCDB-2" attached to in-scope Boric Acid Batching Eductor (CHN-J01).
LR-PVNGS-CH-01-M-CHP-003:
Location C-16, line SI-N-201-HCDA-1" attached to in-scope line 277-HCDA-3,.
Location D-16, line N-121-HCDA-2" attached to in-scope line 273-HCDA-3".
Location D-15, line N-281-HCDB-1" attached to in-scope Reactor Drain Tank (CHN-X02).
Location D-14, line N-278-HCDB-1" attached to in-scope Reactor Drain Tank (CHN-X02).
Location A-1 1, line N-339-HCCA-1" attached to in-scope Equipment Drain Tank (CHNX04).
Location B-9, line N-906-HCDB-1" attached to in-scope Receiving Vessel (Note 9).
Location C-5, line N-378-HCDA-3" attached to in-scope Reactor Makeup Water Tank (CHN-T02).
Location C-5, line N-727-HCDA-3" attached to in-scope Reactor Makeup Water Tank (CHN-T02).
Location D-5, line N-393-HCDA-3" attached to in-scope Reactor Makeup Water Tank (C H N-T02).
Location D-5, line N-381-HCDA-3" attached to in-scope Reactor Makeup Water Tank (C H N-T02).
Location D-5, line N-415-HCDB-11/2/2" attached to in-scope Reactor Makeup Water Tank (C H N-T02).
Location C-5, line N-384-HCDA-3" attached to in-scope valve V771.
Location D-5, line N-694-HCDB-3/4" attached to in-scope Reactor Makeup 32
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Water Tank (C H N-T02).
Location D-5, line N-380-HCDB-1" attached to in-scope Reactor Makeup Water Tank (C H N-T02).
Request:
Provide additional information to justify why these lines are not within the scope of license renewal.
APS Response to RAI 2.3.3.10-03 LR-PVNGS-CH-01-M-CHP-002, Sht.1
" Location F-1 5, line N-713-HCDA-8" attached to in-scope Refueling Water Tank (RWT) (CHE-T01).
Line N-713-HCDA is not safety related and is the vent line for the RWT. Line N-713-HCDA is located entirely within the RWT and is exposed to the RWT internal environment. Line N-713-HCDA does not have a spatial interaction with the refueling water storage tank and is not within the scope of license renewal.
Location E-13, line N-171-HCDB-2" attached to in-scope Boric Acid Batching Eductor (CHN-J01).
In response to RAI 2.3.3.10-01 regarding drawing LR-PVNGS-CH-01-M-CHP-002, Sheet 1, the license renewal boundary drawing has been revised to identify that the Boric Acid Batching Tank components, including line N-171-HCDB-2", have been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2).
LR-PVNGS-CH-01-M-CHP-003 Location C-16, line SI-N-201-HCDA-1" attached to in-scope line 277-HCDA-3".
License renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003 has been revised to identify that line SI-N-201-HCDA-1" for relief valves PSV-169 and PSV-755 has been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2). License renewal boundary drawing LR-PVNGS-SI-01-M-SIP-002 (location B-1 0) has also been revised to identify that this line has been added to the scope of license renewal.
33 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Location D-16, line N-121-HCDA-2" attached to in-scope line 273-HCDA-3".
License renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003 has been revised to identify that relief valve PSV-199 line N-121-HCDA-2" has been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2).
Location D-15, line N-281-HCDB-1" attached to in-scope Reactor Drain Tank (CHN-X02) and Location D-14, line N-278-HCDB-1" attached to in-scope Reactor Drain Tank (CHN-X02).
Lines CH-N-281-HCDB-1" and CH-N-278-HCDB-1" are not within the scope of license renewal because they are service gas (nitrogen) lines and are not fluid-filled lines. There is no structural integrity or spatial interaction functions for lines CH-N-281-HCDB-1" and CH-N-278-HCDB-1". Therefore, these lines are not within the scope of license renewal based on criterion 10 CFR 54.4(a)(2).
Location A-11, line N-339-HCCA-1" attached to in-scope Equipment Drain Tank (CHNX04).
Highlighting of Line N-339-HCCA and the associated valves, V830 and PCV831 was inadvertently omitted on license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003. Line N-339-HCCA and the associated valves V830 and PCV831 on license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003 have been confirmed to be within the scope of license renewal for criteria 10 CFR 54.4(a)(1). License renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003 has been revised to show line N-339-HCCA and the associated valves V830 and PCV831as completely highlighted. License renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003 has been revised to identify that the connected line GA-N-021-HBDA has also been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2).
Location B-9, line N-906-HCDB-1" attached to in-scope to in-scope Receiving Vessel (Note 9).
License renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003 has been revised to identify that line N-906-HCDB-1" (vent to the essential pipe density tunnel) has been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2).
Various lines connected to Reactor Makeup Water Tank (CHN-T02):
o Location C-5, line N-378-HCDA-3" attached to in-scope Reactor Makeup Water Tank (CHN-T02).
o Location C-5, line N-727-HCDA-3" attached to in-scope Reactor Makeup Water Tank (CHN-T02).
34
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application o
Location D-5, line N-393-HCDA-3" attached to in-scope Reactor Makeup Water Tank (CHN-T02).
o Location D-5, line N-381-HCDA-3" attached to in-scope Reactor Makeup Water Tank (CHN-T02).
o Location D-5, line N-415-HCDB-11/2" attached to in-scope Reactor Makeup Water Tank (CHN-T02).
o Location C-5, line N-384-HCDA-3" attached to in-scope valve V771.
o Location D-5, line N-694-HCDB-3/4" attached to in-scope Reactor Makeup Water Tank (CHN-T02).
o Location D-5, line N-380-HCDB-1" attached to in-scope Reactor Makeup Water Tank (CHN-T02).
Reactor Makeup Water Tank (CHN-T02) is within the scope of license renewal based on criteria 10 CFR 54.4(a)(3). License renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003 has been revised to identify that portions of the lines noted above have been added to the scope of license renewal based on criteria 10 CFR 54.4(a)(3) up to the isolation valves that support the intended function of the Reactor Makeup Water Tank (CHN-T02). Line N-381-HCDA-3" is an overflow line and its failure would not cause failure of the intended function of the Reactor Makeup Water Tank (CHN-T02) and is not included within the scope of license renewal. The lines noted above do not have a structural integrity function nor do the lines have a spatial interaction with safety related components and are not within the scope of license renewal based on criterion 10 CFR 54.4(a)(2).
As a result of the changes described above and the associated aging management review updates, aging management evaluations summarized in LRA Table 3.3.2-10 have been revised as shown in Amendment 8 in Enclosure 2, Attachment 1.
NRC RAI 2.3.3.20-01
Background:
LRA Section 2.3.3.20, License Renewal Drawings, provides the license renewal drawings for the diesel generator fuel oil storage and transfer system.
Issue:
Drawing LR-PVNGS-DF-01-M-DFP-001 could not be found in the LRA drawing package.
License renewal drawing LR-PVNGS-DF-02-M-DFP-001 was found in the LRA drawing package.
Request:
35 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Provide additional information to verify which drawing was the correct drawing to use during the scoping and screening review.
APS Response to RAI 2.3.3.20-01 License renewal boundary drawing LR-PVNGS-DF-02-M-DFP-001 is the correct drawing. The reference to license renewal boundary drawings in LRA Section 2.3.3.20 contained a typographical error and should read "LR-PVNGS-DF-02-M-DFP-001" instead of "LR-PVNGS-DF-01-M-DFP-001." The license renewal boundary drawing number in LRA section 2.3.3.20 has been corrected to identify license renewal boundary drawing LR-PVNGS-DF-02-M-DFP-001, as shown in LRA Amendment No. 8 in Enclosure 2, Attachment 1.
NRC RAI 2.3.3.21-01
Background:
In LRA Section 2.3.3.21 portions of the diesel generator system are in-scope based on criteria 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). License renewal rule 10 CFR 54.21 (a) requires applicants to list all component types subject to an AMR.
Issue:
The following license renewal drawing locations show components that are within the scope of license renewal for criteria 10 CFR 54.4(a)(1) or 10 CFR 54.4(a)(2) and not included in Table 2.3.3-21. The components and their drawing locations follow:
" Diesel air intake silencers at locations H-3 and H-7 and diesel exhaust silencers at locations H-2 and H-5 on drawing LR-PVNGS-DG-01-M-DGP-001-01.
" Local observation glasses, LG 344 and LG 343, at locations G-3 and G-7 on drawing LR-PVNGS-DG-01-M-DGP-001-01.
" Turbocharger housings at locations E-4 and E-7 on drawing LR-PVNGS-DG M-DGP-001-02.
" Diesel generator air intake manifolds at locations C-3, C-7, G-3, and G-7 and exhaust manifolds at E-3 and E-7 on drawing LR-PVNGS-DG-01-M-DGP-001-02.
" Starting air header in the Starting Air Subsystem at locations C-4, C-8, G-4 and G-8 on drawing LR-PVNGS-DG-02-M-DGP-001-06.
36
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Injector housings in the Fuel Oil Subsystem at location F-1, F-2, F-5, and F-6 on drawing LR-PVNGS-DG-01-M-DGP-001-07.
Request:
Provide additional information explaining why the components identified above are not included as component types subject to an AMR in LRA Table 2.3.3-21.
APS Response to RAI 2.3.3.21-01 Individual component names and component types in the LRA are consistent with the component names and component types as they appear in the Palo Verde plant equipment database as follows:
Diesel air intake silencers on drawing LR-PVNGS-DG-01-M-DGP-001-01 at locations H-3 and H-7 and diesel exhaust silencers at locations H-2 and H-5 are included in LRA Table 2.3.3-21 with the component type "filter" consistent with the Palo Verde plant equipment database.
Local observation glasses, LG 344 and LG 343, on drawing LR-PVNGS-DG M-DGP-001-01 at locations G-3 and G-7 are included in LRA Table 2.3.3-21 and subject to AMR with component type "sight gauge" consistent with the Palo Verde plant equipment database.
Turbocharger housings on drawing LR-PVNGS-DG-01-M-DGP-001-02 at locations E-4 and E-7 are included in LRA Table 2.3.3-21 and subject to AMR with component type "blower" consistent with the Palo Verde plant equipment database.
Diesel generator air intake manifolds on drawing LR-PVNGS-DG-01-M-DGP-001-02 at locations C-3, C-7, G-3, and G-7 and exhaust manifolds at E-3 and E-7 are depicted as boxes; do not have unique component identification numbers and, therefore, are evaluated as within scope of license renewal as integral parts of the Emergency Diesel Generator. NEI 95-10 Appendix B, line 56, identifies the Emergency Diesel Generator as not subject to AMR per 10 CFR 54.21(a)(1).
LRA Table 2.3.3-21 presents the component types that are subject to AMR together with the license renewal intended functions evaluated. Since these SSCs are not subject to AMR, they are not presented in LRA Table 2.3.3-21.
Starting air headers in the Starting Air Subsystem on drawing LR-PVNGS-DG-02-M-DGP-001-06 at locations C-4, C-8, G-4, and G-8 have been identified as generic piping component GC-DG028; and have been evaluated as within scope of license renewal and subject to AMR. The starting air headers are included in LRA Table 2.3.3-21 and subject to AMR with the component type "piping."
37
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.21-02
Background:
License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.
Issue:
The following pipelines lack drawing continuation information at the end locations of criterion 10 CFR 54.4(a)(2) pipe.
Piping N-098-HBDA-2" at location E-5 and N-091-HBDB-2" at location E-1 on drawing LR-PVNGS-DG-M-DGP-001-03.
Overflow piping at locations G-1 and G-5 on drawing LR-PVNGS-DG-M-DGP-001-04.
Piping N-040-HBDA-3/4" at location B-5, N-038-HBDA-3/4" at location D-5, N-042-HBDA 3/4" at location F-5, and N-044-HBDA-3/4" at location G-5 on drawing LR-PVNGS-DG-M-DGP-001-09.
Request:
Provide additional information to locate the license renewal boundary.
38
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application APS Response to RAI 2.3.3.21-02 The appropriate license renewal terminal component symbol has been added to the end locations of each of the following criterion 10 CFR 54.4(a)(2) pipes, as described below.
Piping N-098-HBDA-2" at location E-5 and N-091-HBDB-2" at location E-1 on license renewal boundary drawing LR-PVNGS-DG-M-DGP-001-03 does not show drawing continuation information because the piping is depicted as ending on license renewal boundary drawing LR-PVNGS-DG-M-DGP-001-03. As detailed in the project database, the criterion 10 CFR 54.4(a)(2) license renewal intended function ends where these lines end. For clarity, the appropriate license renewal terminal component symbol has been added to drawing LR-PVNGS-DG-M-DGP-001-03.
Overflow piping at locations G-1 and G-5 on drawing LR-PVNGS-DG-M-DGP-001-04 are uniquely identified as piping lines N-017-HBDA-21/2" and N-006-H-HBDA-21/2" and do not show drawing continuation information because the piping is depicted as ending on license renewal boundary drawing LR-PVNGS-DG-M-DGP-001-04. As detailed in the project database, the criterion 10 CFR 54.4(a)(2) license renewal intended function ends where these lines end. For clarity, the appropriate license renewal terminal component symbol has been added to drawing LR-PVNGS-DG-M-DGP-001-04.
" Piping N-040-HBDA-%" at location B-5, N-038-HBDA-%" at location D-5, N-042-HBDA-3/4" at location F-5, and N-044-HBDA-%" at location G-5 on license renewal boundary drawing LR-PVNGS-DG-M-DGP-001-09 does not show drawing continuation information because the piping is depicted as ending on license renewal boundary drawing LR-PVNGS-DG-M-DGP-001-09. As detailed in the project database, the criterion 10 CFR 54.4(a)(2) license renewal intended function ends where these lines end. For clarity, the appropriate license renewal terminal component symbol has been added to drawing LR-PVNGS-DG-M-DGP-001-09.
NRC RAI 2.3.3.22-01
Background:
LRA Section 2.3.3.22, Domestic Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure and leakage boundary.
39 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Issue:
Drawing LR-PVNGS-DS-01-M-DSP-002 (B-4) shows continuation of lines N-446-YDGA-11/2" and N-065-YDGA-11/2" as within the scope of license renewal. The continuations on LR-PVNGS-HD-01-M-HDP-001 are not within the scope of license renewal.
Request:
Provide additional information to clarify the scoping classification for these pipe sections.
APS Response to RAI 2.3.3.22-01 Highlighting of the continuation of pipe lines N-446-YDGA-1 1/2" and N-065-YDGA-1 1/2" was inadvertently omitted on license renewal boundary drawing, LR-PVNGS-HD-01-M-HDP-001. The continuations of pipe lines N-446-YDGA-1 1/2" and N-065-YDGA-11/2" on license renewal boundary drawing LR-PVNGS-HD-01-M-HDP-001 have been confirmed to be within the scope of license renewal. License renewal boundary LR-PVNGS-HD-01-M-HDP-001 has been revised to highlight the continuation of pipe lines N-446-YDGA-11/2" and N-065-YDGA-11/2". The continuation on drawing LR-PVNGS-DS-01-M-DSP-002 (B-4) is correct.
NRC RAI 2.3.3.22-02
Background:
License renewal rule 10 CFR 54.21 (a) requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.
Issue:
Drawing LR-PVNGS-DS-01-M-DSP-002 (D-3) shows continuation of line N-266-YDGA-1 to HJP-001 (A-13). The continuation on LR-PVNGS-HJ-02-M-HJP-001 could not be located.
Request:
Provide additional information to locate the license renewal boundary.
APS Response to RAI 2.3.3.22-02 Line N-268-YDGA-1 (referred to in RAI 2.3.3.22-02 and RAI 2.3-02 as line N-266-YDGA-1) has been cut and capped, and no longer continues on to license renewal boundary drawing LR-PVNGS-HJ-02-M-HJP-001.
License renewal boundary drawing 40 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application LR-PVNGS-DS-01-M-DSP-002 has been revised to show that line N-268-YDGA-1 is now cut and capped, and does not continue to drawing LR-PVNGS-HJ-02-M-HJP-001.
NRC RAI 2.3.3.22-03 Back.ground:
LRA Section 2.3.3.22, Domestic Water System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary and leakage boundary.
Issue:
Drawing LR-PVNGS-DS-13-P-KDE-002 (F-6) and LR-PVNGS-DS-13-P-KDE-003 (G-2 and C-7) show 13-MDSN-X02, 13-MDSN-X03 and 13-MDSN-X05 with reliefs and drain lines as not within the scope of license renewal. Note that similar components on LR-PVNGS-DS-13-P-KDE-001 (F-2), 13-M-DSN-XO1A and 13-M-DSN-XO1B, are within the scope of license renewal.
Request:
Provide additional information to explain why 13-MDSN-X02, 13-MDSN-X03 and 13-MDSN-X05 are not within the scope of license renewal.
APS Response to RAI 2.3.3.22-03 License renewal boundary drawings LR-PVNGS-DS-1 3-P-KDE-002 and LR-PVNGS-DS-13-P-KDE-003 have been revised to reflect that 13-MDSN-X02, 13-MDSN-X03 and 13-MDSN-X05 and their associated relief and drain lines have been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2).
LRA section 3.3.2.1.22 and LRA Table 3.3.2-22 were revised to add the Domestic Water relief drain lines to the scope of license renewal as shown in LRA Amendment No. 8 in Enclosure 2, Attachment 1. This revision resulted in the addition of copper alloy Domestic Water piping in a wetted gas environment to LRA Table 3.3.2-22 and the addition of a wetted gas environment to the list of Domestic Water environments in LRA section 3.3.2.1.22.
41 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application NRC RAI 2.3.3.24-01
Background:
LRA Section 2.3.3.24, Water Reclamation Facility Fuel System, states components are within the scope of license renewal for 10 CFR 54.4(a)(3) and have intended functions of providing a pressure boundary, filter, and pressure relief.
Issue:
License renewal drawing LR-PVNGS-FS-A0-W-FSP-300 shows two lines as not within the scope of license renewal that are connected to tanks which are shown as within the scope of license renewal as follows:
Zone C-5, line 042-HBDB-8" attached to in-scope Fuel Oil Storage Tank (FSN-T02), and Zone G-5, line 043-HBDB-8" attached to in-scope Fuel Oil Storage Tank (FSN-TO1).
There is also no indication where these lines go.
Request:
Provide additional basis for not including these lines in the scope of license renewal. Also, identify where these lines go.
APS Response to RAI 2.3.3.24-01 Pipe lines 042-HBDB-8" and 043-HBDB-8" were identified as not within the scope of license renewal, and are connected to Station Blackout generator (SBOG) fuel oil storage tanks that are in scope as shown on license renewal boundary drawing LR-PVNGS-FS-AO-FSP-300. The following LR Note has been added to license renewal boundary drawing LR-PVNGS-FS-AO-FSP-300, to clarify why the pipe lines are not in the scope of license renewal:
LR Note: The pipeline is above the minimum fuel oil level necessary to support SBOG operation. The minimum fuel oil level elevation is - 974'- 5" and the centerline elevation of the pipe is 987' - 1 5/8", therefore the piping is not required to maintain the tank pressure boundary. The pipe size is much smaller than the tank, and consequently has no structural impact. The tank penetration is not associated with venting. Pipe lines 042-HBDB-8" and 043-HBDB-8" are not within the scope of license renewal.
There is no continuation of the pipe lines 042-HBDB-8" and 043-HBDB-8" on license renewal boundary LR-PVNGS-FS-AO-FSP-300. Isometric drawing AO-W-FSG-0310, 42 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Section A, identifies the pipe lines have a "free end" that is open to atmosphere and discharges to the area enclosed by the dykes that surround the SBOG fuel oil storage tanks.
NRC RAI 2.3.3.24-02
Background:
License renewal rule 10 CFR 54.21(a) requires applicants to list all component types subject to an AMR. The staff confirms inclusion of all component types subject to an AMR by reviewing components within the license renewal boundary.
Issue:
On drawing LR-PVNGS-FS-AO-W-FSP-300 the following pipe lines lack drawing continuation information at the end locations of pipe.
Location B-4, line 042-HBDB-8" attached to in-scope Fuel Oil Storage Tank (FSN-T02).
Location F-4, line 043-HBDB-8" attached to in-scope Fuel Oil Storage Tank (FSN-T01).
Request:
Provide additional information to locate the license renewal boundary.
APS Response to RAI 2.3.3.24-02 There is no continuation of the pipe lines 042-HBDB-8" and 043-HBDB-8" on license renewal boundary LR-PVNGS-FS-AO-FSP-300. Isometric drawing AO-W-FSG-0310, Section A, identifies the pipe lines have a "free end" that is open to atmosphere and discharges to the area enclosed by the dykes that surround the SBOG fuel oil storage tanks.
NRC RAI 2.3.3.25-01 Back.ground:
The service gases system is within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1). Portions are within the scope of license renewal as non-safety-related affecting safety-related components for structural integrity and/or spatial interaction based on the criteria of 10 CFR 54.4(a)(2). Portions of the service gases 43
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application system support equipment qualification and station blackout requirements based on the criteria of 10 CFR 54.4(a)(3).
Issue:
Drawing LR-PVNGS-GA-01-M-GAP-002 (E-8) shows continuation of a 10 CFR 54.4(a)(3) pipe sections (to Nw accumulators) to drawing LR-PVNGS-SG-01-M-SGP-001. Review of drawing LR-PVNGS-SG-01-M-SGP-001-01 could not locate this continuation.
Request:
Provide additional information to locate the license renewal boundary.
APS Response to RAI 2.3.3.25-01 The continuations of the following pipe lines from license renewal boundary drawing LR-PVNGS-GA-02-M-GAP-001 (incorrectly identified as LR-PVNGS-GA-01-M-GAP-002) to license renewal boundary drawing LR-PVNGS-SG-M-SGP-001-02 are correctly identified as within the scope of license renewal on license renewal boundary drawing LR-PVNGS-SG-M-SGP-001-02. Note that the following locations are identified on license renewal boundary drawing LR-PVNGS-SG-M-SGP-001-02 which is sheet 2 of the license renewal boundary drawing.
Pipe line 175-GBDA-1" LR-PVNGS-SG-M-SGP-001-02 (B-5).
Pipe line 177-GBDA-1" LR-PVNGS-SG-M-SGP-001-02 (D-5).
Pipe line 178-GBDA-1" LR-PVNGS-SG-M-SGP-001-02 (E-5).
Pipe line 176-GBDA-1" LR-PVNGS-SG-M-SGP-001-02 (G-5).
NRC RAI 2.3.3.26-01
Background:
The gaseous radwaste system is within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1). Portions are within the scope of license renewal as non-safety-related affecting safety-related components for structural integrity and/or spatial interaction based on the criteria of 10 CFR 54.4(a)(2) and portions support the criteria of 10 CFR 54(a)(3).
Issue:
Drawing LR-PVNGS-GR-01-N-GRP-001 (F-8) shows continuation of 10 CFR 54.4(a)(2) pipe section CH-N-215-HCDB-1 " "to volume control tank relief" to drawing LR-PVNGS-CH-01-M-CHP-002. The staff noted that the pipe section on drawing LR-PVNGS-CH-01-M-CHP-002 was not within the scope of license renewal.
44 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Request:
Provide additional information to clarify the scoping classification for this pipe section.
APS Response to RAI 2.3.3.26-01 This issue was also addressed by RAI 2.3.3.10-01 for line CH-N-215-HCDB-1" on license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-002. Refer to RAI 2.3.3.10-01 for resolution.
NRC RAI 2.3.3.27-01
Background:
The radioactive waste drains system is within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1). Portions are also within the scope of license renewal as non-safety-related affecting safety-related components for structural integrity and/or spatial interaction based on the criteria of 10 CFR 54.4(a)(2) and portions are required to support environmental qualification based on the criteria of 10 CFR 54(a)(3).
Issue:
License renewal drawing LR-PVNGS-RD-01-M-RDP-002 (F-9) shows a section of piping continuing from LR-PVNGS-EC-M-ECP-001 (Essential ACU) as not within the scope of license renewal. This section is included in-scope for 10 CFR 54.4(a)(2) on LR-PVNGS-EC-M-ECP-001. Note similar piping section as included in-scope at F-12 (Essential ACU).
Request:
Provide additional information to justify why this section of the piping is included within the scope of license renewal on LR-PVNGS-EC-M-ECP-001 and not within the scope of license renewal on LR-PVNGS-EC-M-ECP-001.
APS Response to RAI 2.3.3.27-01 Line N-122-HBDB-11/22" shown on license renewal boundary drawing LR-PVNGS-EC M-ECP-001 is within scope of license renewal based criterion 10 CFR 54.4(a)(2) for spatial interaction and structural integrity (attached) license renewal intended functions.
The structural integrity (attached) license renewal intended function terminates at the seismic anchor identified on license renewal boundary drawing LR-PVNGS-EC-01-M-ECP-001. Beyond the seismic anchor, line N-122-HBDB-1Y" remains within the scope of license renewal for spatial interaction and is continued onto license renewal boundary drawing LR-PVNGS-RD-01-M-RDP-002. The portion of line N-122-HBDB-11/2" 45 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application extending onto license renewal boundary drawing LR-PVNGS-RD-01-M-RDP-002 has been revised to include line N-122-HBDB-11/22" within the scope of license renewal based on criterion 10 CFR 54.4(a)(2) for a spatial interaction intended function. Line N-122-HBDB-11/2" on license renewal boundary drawing LR-PVNGS-RD-01-M-RDP-002 has been highlighted red and a spatial interaction termination flag has been added.
NRC RAI 2.3.3.27-02
Background:
The radioactive waste drains system is within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1). Portions are also within the scope of license renewal as non-safety-related affecting safety-related components for structural integrity and/or spatial interaction based on the criteria of 10 CFR 54.4(a)(2) and portions are required to support environmental qualification based on the criteria of 10 CFR 54(a)(3).
Issue:
Drawing LR-PVNGS-RD-01-M-RDP-003 (F-15 and F-16) show continuations of 10 CFR 54.4 (a)(2) pipe sections, CH-N-444-HCDB-2" and CH-N 170-HCDB-1", to drawing LR-PVNGS-CH-01-M-CHP-002 (G-11 and F-11), respectively. On drawing LR-PVNGS-CH M-CHP-002 the continuations are not within the scope of license renewal.
Request:
Provide additional information to explain why the continuations on LR-PVNGS-CH-01-M-CHP-002 are not within the scope of license renewal.
APS Response to RAI 2.3.3.27-02 This issue was also addressed by RAI 2.3.3.10-01 for lines CH-N-444-HCDB-2" and CH-Ni70-HCDB-1" on license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-002. Refer to RAI 2.3.3.10-01 for resolution.
NRC RAI 2.3.3.27-03
Background:
The radioactive waste drains system is within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1). Portions are also in-scope as non-safety-related affecting safety-related components for structural integrity and/or spatial interaction 46 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application based on the criteria of 10 CFR 54.4(a)(2) and portions are required to support environmental qualification based on the criteria of 10 CFR 54(a)(3).
Issue:
Drawing LR-PVNGS-RD-01-M-RDP-005 (G-2) shows continuation of 10 CFR 54.4(a)(2) pipe sections, RD-N-331-HCDA-4" and RD-N-332-HCDA-4", to drawing LR-PVNGS-CH-01-M-CHP-003 (E-8 and D-8), respectively. On drawing LR-PVNGS-CH-01-M-CHP-003 these continuations are not within the scope of license renewal.
Request:
Provide additional information to explain why the continuations on LR-PVNGS-CH-01-M-CHP-003 are not within the scope of license renewal.
APS Response to RAI 2.3.3.27-03 This issue was also addressed by RAI 2.3.3.10-01 for lines RD-N-331-HCDA-4" and RD-N-332-HCDA-4" on license renewal boundary drawing LR-PVNGS-CH-01-M-CHP-003. Refer to RAI 2.3.3.10-01 for resolution.
NRC RAI 2.3.3.30-01
Background:
Portions of the oily waste and non-radioactive waste system that are located in the auxiliary building, diesel generator building and control building have effects of spatial interaction with safety-related components and are within the scope of license renewal as non-safety affecting safety-related components based on the criteria of 10 CFR 54.4(a)(2).
Portions of the floor drains in the diesel generator building and control building are credited for protection of safety-related equipment from flooding in an event of pipe break in the associated areas. They are included within the scope of licensing renewal for the criteria of 10 CFR 54.4(a)(2).
Portions of the oily waste and non-radioactive waste system attach to safety-related essential chilled water system piping through the demineralized water system such that the structural failure of the oily waste and non-radioactive waste system piping could prevent satisfactory accomplishment of safety-related essential chilled water system functions. These portions of the oily waste and non-radioactive waste system are within the scope of license renewal as nonsafety components affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).
47 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Issue:
Drawing LR-PVNGS-OW-01-M-OWP-002 (E-3 and E-6) shows sections of lines 193-XBDA-4" and 191-XBDA-4" not within the scope of license renewal. The two lines are connected to lines 101-XBDA-4" and 112-XBDA-4" which are shown within the scope of license renewal based on 10 CFR 54.4(a)(2).
Request:
Provide additional information to justify why lines 193-XBDA-4" and 191-XBDA-4",
attached to lines 101-XBDA-4" and 112-XBDA-4" are not within the scope for license renewal.
APS Response to RAI 2.3.3.30-01 Line 193-XBDA-4" and line 191-XBDA-4" are the drain lines from the fuel oil day tank floors. Palo Verde Updated Final Safety Analysis Report (UFSAR) Table 9B.3-1, Section F, Item 10, Diesel Fuel Oil Storage Areas, identifies that the fuel oil day tank floors have drains designed to remove oil and fire water to a safe location. Therefore, this piping has a 10 CFR 54(a)(3) function to remove oil and fire water. Boundary Drawing LR-PVNGS-OW-01-M-OWP-002 was revised to add this piping and associated components within the scope of license renewal.
As shown in LRA Amendment No. 8 in Enclosure 2, Attachment 2, LRA Table 2.2-1 and Section 2.3.3.30, Miscellaneous Auxiliary Systems in-scope ONLY for Criterion 10 CFR 54.4(a)(2), were revised to delete the Oily Waste and Non-Radioactive Waste System due to the addition of the fire protection intended functions. LRA Section 2.3.3.31, a line item for LRA Table 2.2-1, LRA section 3.3.2.1.31 and Table 3.3.2-31, were created to identify that Oily Waste and Non-Radioactive Waste System also supports fire protection requirements based on the criteria of 10 CFR 54(a)(3) in addition to non-safety affecting safety related component interactions based on criterion (a)(2). Conforming LRA changes were also made to LRA section 2.3.3, LRA Section 3.3.1, LRA Section 3.3.2, LRA Section 3.3.2.1.30, and LRA Table 3.3.2-30.
NRC RAI 2.3.3.30-02
Background:
Portions of the oily waste and non-radioactive waste system that are located in the auxiliary building, diesel generator building and control building have effects of spatial interaction with safety-related components and are within the scope of license renewal as non-safety affecting safety-related components based on the criteria of 10 CFR 54.4(a)(2).
48 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Portions of the floor drains in the diesel generator building and control building are credited for protection of safety-related equipment from flooding in an event of pipe break in the associated areas. They are included within the scope of license renewal for the criteria of 10 CFR 54.4(a)(2).
Portions of the oily waste and non-radioactive waste system attach to safety-related essential chilled water system piping through the demineralized water system such that the structural failure of the oily waste and non-radioactive waste system piping could prevent satisfactory accomplishment of safety-related essential chilled water system functions. These portions of the oily waste and non-radioactive waste system
.are within the scope of license renewal as non-safety components affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).
Issue:
Drawing LR-PVNGS-OW-01-M-OWP-003 (D-2 and D-7) shows lines 170-HGDH-4" and 165-HGDH-4" within the scope for license renewal based 10 CFR 54.4(a)(2). Several lines attached to lines 170-HGDH-4" and 165-HGDH-4", at the same location, are shown as not within the scope of license renewal for 10 CFR 54.4(a)(2).
Request:
Provide additional information to justify why the lines attached to 170-HGDH-4" and 165-HGDH-4" are not within the scope of license renewal.
APS Response to RAI 2.3.3.30-02 Drain line 170-HGDH-4" and drain line 165-HGDH-4" are completely contained within the Control Building. As depicted on license renewal boundary drawing LR-PVNGS-OW-01-M-OWP-003, drain line 170-HGDH-4" and drain line 165-HGDH-4" originate in the floor at the 100' elevation and connect to drain lines 244-XMGA-4" and 243-XMGA-4" respectively at the floor of the 74' elevation. They pass through the 74' elevation of the Control Building which contains safety-related components. One of the spatial interaction terminations for each of these is where the piping becomes encased in the concrete at the 100' elevation. The other termination for each of these is where the piping attaches to drain line 244-XMGA-4" and 243-XMGA-4" respectively and become encased in concrete at the 74' elevation.
Vent lines 212-HTDA-2", 213-HTDA-2", and 198-HTDA-3" are connected to drain line 170-HGDH-4" as shown on license renewal boundary drawing LR-PVNGS-OW-01-M-OWP-003. Portions of this vent piping are below the elevation of the downstream drain piping. The vent lines have a spatial interaction intended function and are within the scope of license renewal based on criterion 10 CFR 54.4(a)(2). Drain line 165-HGDH-4" and vent lines 214-HTDA-2", 215-HTDA-2", and 197-HTDA-3" are designed with a 49 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application similar configuration and, therefore, also have a spatial interaction intended function and are within the scope of license renewal based on criterion 10 CFR 54.4(a)(2). License renewal boundary drawing LR-PVNGS-OW-01-M-OWP-003 has been revised to show the vent lines within the scope of scope license renewal based on criterion 10 CFR 54.4(a)(2).
LRA section 3.3.2.1.31 and LRA Table 3.3.2-31 were revised to add the Oily Waste and Non-Radioactive System vent lines to the scope of license renewal as shown in LRA Amendment No. 8 in Enclosure 2, Attachment 2. This revision resulted in the addition of Polyvinyl Chloride (PVC) Oily Waste and Non-Radioactive System piping in a raw water environment to LRA Table 3.3.2-31 and the addition of a PVC material to the list of Oily Waste and Non-Radioactive System materials in LRA section 3.3.2.1.31.
NRC RAI 2.3.3.30-03
Background:
Portions of the oily waste and non-radioactive waste system that are located in the auxiliary building, diesel generator building and control building have effects of spatial interaction with safety-related components and are within the scope of license renewal as non-safety affecting safety-related components based on the criteria of 10 CFR 54.4(a)(2).
Portions of the floor drains in the diesel generator building and control building are credited for protection of safety-related equipment from flooding in an event of pipe break in the associated areas. They are included within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(2).
Portions of the oily waste and non-radioactive waste system attach to safety-related essential chilled water system piping through the demineralized water system such that the structural failure of the oily waste and non-radioactive waste system piping could prevent satisfactory accomplishment of safety-related essential chilled water system functions. These portions of the oily waste and non-radioactive waste system are within the scope of license renewal as non-safety components affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).
Issue:
Drawing LR-PVNGS-OW-01-M-OWP-003 (C-3) shows line DS-449-HBDD-4" not within the scope of license renewal. Several lines adjacent to DS-449-HBDD-4" on LRA drawing LR-PVNGS-OW-01-M-OWP-003, at the same location, are shown as within the scope for license renewal per 10 CFR 54.4(a)(2) for spatial interaction.
50
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Request:
Provide additional information to justify why line DS-449-HBDD-4" is not within the scope of license renewal.
APS Response to RAI 2.3.3.30-03 Highlighting of the continuation of pipe line DS-449-HBDD-4" was inadvertently omitted on license renewal boundary drawing LR-PVNGS-OW-01-M-OWP-003. Pipe line DS-449-HBDD-4" is identified on Domestic Water license renewal boundary drawing LR-PVNGS-DS-01-M-DSP-002 as within the scope of license renewal based on criterion 10 CFR 54.4(a)(2). License renewal boundary drawing LR-PVNGS-OW-01-M-OWP-003 has been revised to show pipe line DS-449-HBDD-4" continuation completely highlighted including pipe line 226-HBDD-6" where the piping connects to the sump cover.
NRC RAI 2.3.4.1-01
Background:
LRA Section 2.3.4.1, Main Steam System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1),10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing structural integrity, insulation and pressure and leakage boundary.
Issue:
License renewal drawings show several locations where the license renewal spatial interaction termination cannot be determined as follows:
LR-PVNGS-SG-01-M-SGP-002:
Piping N-007-DCDA-8" upstream of valve UV-172 (G-13)
Piping N-010-DBDB-8" upstream of valve UV-175 (C-13)
Piping E-039-DABA-6" downstream of valve UV-5000 (E-2)
Piping E-048-DABA-6" downstream of valve UV-5008 (B-2)
LR-PVNGS-SG-01-M-SGP-001 -02:
Piping N-335-HDDA-1" upstream of valve V346 (G-4)
Piping N-335-HDDA-1" upstream of valve V348 (G-4)
Piping N-321-HDDA-1" upstream of valve V358 (D-4)
Piping N-321-HDDA-1" upstream of valve V357 (D-4) 51
Enclosure I Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Request:
Provide additional information to locate the license renewal spatial interaction terminations.
APS Response to RAI 2.3.4.1-01 Spatial interaction for Piping N-007-DCDA-8", N-010-DBDB-8", E-039-DABA-6", and E-048-DABA-6" in the Turbine Building was determined not to be applicable. Each of the pipe lines is supported by a "five way whip restraint" at the Main Steam Support Structure (MSSS)/Turbine Building wall penetrations. Drawing note 2 identifies that the class break occurs after the restraint which is located at the MSSS/Turbine Building wall penetration. The support locations for the Steam Generator Blowdown lines (E-039-DABA-6" and E-048-DABA-6") are shown on UFSAR Figure 3.6-29. The support locations for the Downcomer Feedwater lines (N-007-DCDA-8", N-01 0-DBDB-8") are shown on UFSAR Figure 3.6-30. There is no safety related equipment located in the Turbine Building. License renewal boundary drawing LR-PVNGS-SG-01-M-SGP-002 was revised to highlight the pipe segment downstream of valve UV-172 (pipe N-007-DCDA-8") and the pipe segment downstream of valve UV-175 (pipe N-010-DBDB-8") as green to be consistent with the pipe class.
Spatial interaction for piping N-335-HDDA-1" and N-321-HDDA-1" on drawing LR-PVNGS-SG-01-M-SGP-001-02 was determined not to be applicable because the pipe lines internal environment is dry gas. The pipe lines provide nitrogen gas to the main steam atmospheric dump valve accumulators. The pipe lines are within the scope of license renewal for structural integrity (attached) only.
NRC RAI 2.3.4.1-02
Background:
LRA Section 2.3.4.1, Main Steam System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing structural integrity, insulation and pressure and leakage boundary.
Issue:
Drawing LR-PVNGS-SG-01-M-SGP-002 (D-8 and G-8) shows 2 flow nozzles out of each of the steam generators 1 & 2 (RCE-E01A & B) as not within the scope of license renewal.
52 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Request:
Provide additional information explaining why the flow nozzles out of steam generators 1 & 2 are not within the scope of license renewal.
APS Response to RAI 2.3.4.1-02 The Steam Generators and associated nozzles are evaluated in LRA Table 2.3.1-4 as components within the scope of license renewal based on criterion 10 CFR 54.4(a)(1).
License renewal boundary drawing LR-PVNGS-SG-01-M-SGP-002 has been revised to highlight the Steam Generators and associated nozzles and add a note stating that the Steam Generators and associated nozzles are evaluated as LRID SGR.
NRC RAI 2.3.4.1-03
Background:
LRA Section 2.3.4.1, Main Steam System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1),10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing structural integrity, insulation and pressure and leakage boundary.
Issue:
Drawing LR-PVNGS-SG-01-M-SGP-001-01 shows eight boxes on the main steam piping downstream of the main steam isolation valves that are not defined:
2 boxes on piping E-206-DLBB-28" downstream of valve UV-170 (G-9) 2 boxes on piping E-207-DLBB-28" downstream of valve UV-180 (E-9) 0 2 boxes on piping E-208-DLBB-28" downstream of valve UV-171 (D-9) 2 boxes on piping E-209-DLBB-28" downstream of valve UV-181 (B-9)
Request:
Provide additional information explaining this box symbol and if this component type is subject to an AMR.
APS Response to RAI 2.3.4.1-03 The box symbols on license renewal boundary drawing LR-PVNGS-SG-01-M-SGP-001-01 represent "five way whip restraints" and provide structural support at the Main Steam Support Structure/Turbine Building wall penetrations. The "five way whip restraints" are evaluated as structural component type "Supports ASME 2 and 3" and are identified in LRA Table 2.4-14 as components within the scope of license renewal and subject to 53 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application AMR. Only mechanical components within the scope of license renewal are highlighted on mechanical boundary drawings.
NRC RAI 2.3.4.1-04
Background:
LRA Section 2.3.4.1, Main Steam System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing structural integrity, insulation and pressure and leakage boundary.
Issue:
Drawing LR-PVNGS-SG-01-M-SGP-001-02 (D-8 and G-8) shows 2 drag resistors N-299-HBDB-54" and N-300-HBDB-54" as not within the scope of license renewal.
However, both the inlet piping E-059-DLBB-1 2" and E-084-DLBB-1 2" as well as the outlet piping N-306-GBDB-1" and N-312-GBDB-1" are within the scope of license renewal. Also, FX-178 & FX-179 are shown as within the scope of license renewal inside of the drag resistors.
Request:
Provide additional information explaining why the drag resistors are not within the scope of license renewal.
APS Response to RAI 2.3.4.1-04 License renewal boundary drawing LR-PVNGS-SG-01-M-SGP-001-02 has been revised to identify pipe shrouds N-299-HBDB-54" and N-300-HBDB-54" have been added to the scope of license renewal based on criterion 10 CFR 54.4(a)(2).
NRC RAI 2.3.4.2-01 BackQround:
LRA Section 2.3.4.2, Condensate Transfer and Storage System, states that components are within the scope of license renewal for 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3) and have intended functions of providing a pressure and leakage boundary, and structural integrity.
54 Response to December 3, 2009, Request for Additional Information for the Review of the PVNGS License Renewal Application Issue:
Drawing LR-PVNGS-CT-01-M-CTP-001 (C-2) shows line N-031-HCDA-3" not within the scope of license renewal for 10 CFR 54.4(a)(2). However, the continuation of this 3" line on drawing LR-PVNGS-PC-01-M-PCP-001 (H-11) shows this line is within the scope of license renewal for 10 CFR 54.4(a)(2).
Request:
Provide additional information explaining why there is a difference in the scope classification between drawing LR-PVNGS-CT-01-M-CTP-001 and the continuation on LR-PVNGS-PC-01-M-PCP-001.
APS Response to RAI 2.3.4.2-01 Highlighting of the continuation of pipe line N-031-HCDA-3" was inadvertently omitted on license renewal boundary drawing LR-PVNGS-CT-01-M-CTP-001 when updating the license renewal boundary drawing for the addition of Condensate Storage and Transfer System branch lines. The continuation of pipe line N-031-HCDA-3" on license renewal boundary drawing LR-PVNGS-CT-01-M-CTP-001 has been confirmed to be within the scope of license renewal. License renewal boundary drawing LR-PVNGS-CT-01-M-CTP-001 has been revised to show pipe line N-031-HCDA-3" continuation completely highlighted. The continuation on license renewal boundary drawing LR-PVNGS-PC M-PCP-001 is correct.
Due to the recent revision to add branch lines, LRA section 3.4.2.1.2 and LRA Table 3.4.2-2 were revised to add Condensate Storage and Transfer branch line components to the scope of license renewal as shown in LRA Amendment No. 8 in Enclosure 2,. This revision resulted in the addition of the following components to LRA Table 3.4.2-2:
Stainless steel piping in buried environment Stainless steel valves in an atmosphere/weather environment Stainless steel closure bolting in an atmosphere/weather environment As a result of these aging management evaluation changes to LRA Table 3.4.2-2, LRA Section 3.4.2.1.2 was revised to add "Buried" to the list of Condensate Storage and Transfer environments and add "Buried Piping and Tanks Inspection (B2.1.18)" to the list of Condensate Storage and Transfer AMPs.
55
ENCLOSURE 2 Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 LRA Changes for Component-Material-Environment Verification and RAI Responses Except for RAI 2.3.3.30-01 and 02 Responses Affected LRA Sections and Pages LRA Section Page Nos.
RAI No.
Table 3.3.2-3 3.3-85 2.3.3.3-01 Table 3.3.2-6 3.3-105 2.3.3.6-01 Table 3.3.2-7 3.3-110 2.3.3.7-01 Table 3.3.2-10 3.3-130 and 2.3.3.10-01 and 3.3-136 2.3.3.10-03 2.3.3.20 2.3-60 2.3.3.20-01 3.3.2.1.22 3.3-26 2.3.3.22-03 Table 3.3.2-22 3.3-203 2.3.3.22-03 3.4.2.1.2 3.4-3 and 2.3.4.2-01 3.4-4 Table 3.4.2-2 3.4-28 2.3.4.2-01 Table 3.3.2-21 3.3-196 Component-material-environment verification 3.3.2.1.24 3.3-28 and Component-3.3-29 material-environment verification Table 3.3.2-24 3.3-210 to Component-3.3-213 material-environment verification 1
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Source: RAI 2.3.3.3-01 Response LRA Table 3.3.2-3 Auxiliary Systems - Summary of Aging Management Evaluation - Essential Cooling Water System (page 3.3-85), is revised as follows (new text underlined):
Table 3.3.2-3 Ayxilpryystems - Summa of Agin Management Evaluation - Essential Cooling Water System Component, intended Material Environment Aging Effect Ag~ing Management NUREQG.
Table 1 Itm Notes Type; Function Requiring Program 1801 Vol.
omonen
_lte neManagement 2 Item Piping 1LBS, SIA Carbon Steel Wetted Gas (Int)
Loss of material Inspection Of Internal VIII.B1-7
.3.4.1.30 B
Surfaces In IMiscellaneous Piping
!And Ducting Components (B2.1.22)
_a
__i_
_I_
Source: RAI 2.3.3.6-01 Response LRA Table 3.3.2-6, Auxiliary Systems - Summary of Aging Management Evaluation - Nuclear Cooling Water System (page 3.3-105), is revised as follows (new text underlined):
Table 3.3.2-6 Auxiliary Systems - Summary of Aging Management Evaluation - Nuclear Coolingz Water System (Continued)
'Component 'Intended Material Environmen~t, Aging Effect' A'ging Management NUREG Table 1Item
~Notes" Type Functioni Requiring
~
Programn
-1801 Management Vo.
Piping SIA, LBS Carbon Steel IWetted Gas (Int)
'Loss of material Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2. 1.22___
VIII.1B1-7 3.4.1.30 B
2
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Source: RAI 2.3.3.7-01 Response LRA Table 3.3.2-7, Auxiliary Systems - Summary of Aging Management Evaluation - Essential Spray Pond System (page 3.3-110), is revised as follows (new text underlined):
TnIilo ~ ~ ~7 Aiiyilinri,.~ictomv -
.S~ummnrv nfAaina Aifanaciomont 1-~vnJjntinn -
Pv~ontiaI S~nrm,' Pnnd,SVvtom
. Inedd Maeil Eivrhm rt gn fec gn angm n UREG-1Table 1 lItem IiNoltes;**,
Type<
~Function
~Requiring Program 1801 Vol.
1nManagement g2ee m
Piping ISIA LBS Stainless Steel Wetted Gas (Int)
Loss of material Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
VII.F2-1 3.3.1.27 E
Source: RAI 2.3.3.10-01 and -03 Responses Table 3.3.2-10, Auxiliary Systems - Summary of Aging Management Evaluation - Chemical and volume control (page 3.3-130), is revised as follows (new text underlined):
Table 3.3.2-10 Auxiliary Systems - Summary of Aging Management Evaluation - Chemical and Volume Control (Continued)
Component Intended Material Environment AgingEffect Aging Management;,
NUREG-Table I Notes <
Tye Function~
Requiring Program 1801 Item
_aemn
_ol I2
_____Item__
Orifice LBS-PB Stainless
.Steel Cast iAustenitic LBS PB Stainless
,Steel Cast
.Austenitic Demineralized Water (Int)
Loss of material Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.16)
None VIII.E-29 13.4.1.16 A
Orifice Plant Indoor Air (Ext)
None VII.J-15 3.3.1.94 A
3
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Source: RAI 2.3.3.10-01 and -03 Responses Table 3.3.2-10, Auxiliary Systems - Summary of Aging Management Evaluation - Chemical and volume control (page 3.3-136), is revised as follows (new text underlined and deleted text crossed out):
Table 3.3.2-10 Auxiliary Systems - Summar Cbniponent Intended Material Type Functioann-
,Valve ILBS Carbon Steel
- Chemical and Volume Control (Continued) fect ng nent Aging -Management, Program NUIR03-1801 Vol. 2 Item Table"I Item Notes~
eiate LOSS (l.t)-Plant Indoor Air (Ext)
(132.1.2) and-One-Timne InspectionR (1324.16)
External Surfaces Monitoring Program (B2.1.20) iNone V11.-833.1.58 A
B Valve
'LBS, PB, iSIA Stainless Steel Borated Water None Leakage (Ext)
VII.J-16 3.3.1.99 JA Valve L-aBS iStainless Steel Stainless Steel Water It)
Treated Borated Water (Int)
Loss of Material Loss of Material Watr hemis"~
(B2.1.2) ad Onre Time Insection (
B12.16)
Water Chemistry (132.1.2)
Valve LBS, PB, SIA VNLFE 29 VII.El-17 V.D1-29 3.4.1.16 A
Valve LBS Stainless Steel Wetted Gas (Int)
Loss of Material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22) 3.2.1.08 E
4
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Source: RAI 2.3.3.20-01 Response LRA Section 2.3.3.20, Diesel Generator Fuel Oil Storage and Transfer System (page 2.3-60), is revised as follows (new text underlined and deleted text crossed out):
License Renewal Drawings The license renewal drawings for the diesel generator fuel oil storage and transfer system are listed below:
LR P'..NGS DF 01 M DFP 001 LR-PVNGS-DF-02-M-DFP-001 LR-PVNGS-DG-01 -M-DGP-001 -1 Source: RAI 2.3.3.22-03 Response LRA Section 3.3.2.1.22, Domestic Water System (page 3.3-26), is revised as follows (new text underlined):
Environment The domestic water system component types are exposed to the following environments:
" Atmosphere/ Weather
" Buried
" Plant Indoor Air
" Potable Water
" Raw Water
- Wetted Gas 5
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Source: Component-material-environment verification LRA Section 3.3.2.1.24 WRF Fuel System (pages 3.3-28 and 3.3-29), is revised as follows (new text underlined):
3.3.2.1.24 WRF Fuel System Materials The materials of construction for the WRF fuel system component types are:
" Carbon Steel
" Copper Alloy
" Glass
" Stainless Steel Environment The WRF fuel system component types are exposed to the following environments:
e Atmosphere/ Weather 0 Buried
- Encased in Concrete Fuel Oil
- Wetted Gas Aging Effects Requiring Management The following WRF fuel system aging effects require management:
Loss of material
" Loss of preload Aging Management Programs The following aging management programs manage the aging effects for the WRF fuel system component types:
Bolting Integrity (B2.1.7)
" Buried Piping and Tanks Inspection (B2.1.18)
" External Surfaces Monitoring Program (B2.1.20)
" Fuel Oil Chemistry (B2.1.14)
" One-Time Inspection (B2.1.16)
Internal Surfaces Monitoring (B2.1.22) 6
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Source: Component-material-environment verification LRA Table 3.3.2-24, Auxiliary Systems - Summary of Aging Management Evaluation - WRF Fuel System (pages 3.3-210 to 3.3-213), is revised as follows (new text underlined and deleted text crossed out):
7
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Table 3.3.2-24 Auxiliary Systems-Summary of Agqing Management Evaluation - WRF Fuel System (Continued)
Comfrponeit~ Intended Material EnviroIn Ime nt Aging Effect,.
Aging Managemnent~
N3REG-TablIe 1 Ite6m' Notes Tye Function
~Requiiring
- Program, 1801 M~a~nagemnent~
1~
Vol. 2
~
Ite~m Valve P Aluminu
.Wetted Gas (Int)
Loss of material Inspection of Internal VII.F4-Surfaces in Miscellaneous 10 Piping and Duct Components (B2.1.22) 3.3.1.27 E
Vent (Emergency)
Vent (Emergency)
PB PR Aluminum
.Wetted Gas (Int)
PB PR Carbon Steel.Wetted Gas (Int) i Loss of material Inspection of Internal IVII F4-Surfaces in Miscellaneous 10
--- I--
Piping and Duct Components (B2.1.22)
Inspection of Internal Rurf;;rP-in Miqr.Illn~niis.n 3.3.1.27 3.3.1.71 E
B8 Loss of material VII.-H2-21 I Piping and Duct COmponents (B2.1.22) 8
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Source: RAI 2.3.3.22-03 Response LRA Table 3.3.2-22, Auxiliary Systems - Summary of Aging Management Evaluation - Domestic Water System (page 3.3-207), is revised as follows (new text underlined):
Surfaces In Miscellaneous Pipingq and Ducting Components (132.1.22)
Notes for Table 3.3.2-22:
Standard Notes:
A Consistent with NUREG-1 801 item for component, material, environment, B
Consistent with NUREG-1 801 item for component, material, environment, E
Consistent with NUREG-1 801 for material, environment, and agingq effect, identifies a plant specific aging management program.
F Material not in NUREG-1 801 for this component.
G Environment not in NUREG-1801 for this component and material.
and aging effect. AMP is consistent with NUREG-1 801 AMP.
and aging effect. AMP takes some exceptions to NUREG-1801 AMP.
but a different aging management program is credited or NUREG-1801 I
I I Plant Specific Notes:
None 9
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Source: RAI 2.3.4.2-01 Response LRA Section 3.4.2.1.2, Condensate Storage and Transfer System (pages 3.4-3 and 3.4-4), is revised as follows (new text underlined):
Environment The condensate storage and transfer system components are exposed to the following environments:
Atmosphere/ Weather Buried Dry Gas Encased in Concrete Plant Indoor Air Secondary Water Wetted Gas Aging Management Programs The following aging management programs manage the aging effects for the condensate storage and transfer system component types:
Bolting Integrity (B2.1.7)
Buried Piping and Tanks Inspection (B.2.1.18)
External Surfaces Monitoring Program (B2.1.20)
Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
One-Time Inspection (B2.1.16)
Water Chemistry (B2.1.2) 10
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 Source: RAI 2.3.4.2-01 Response LRA Table 3.4.2-2, Auxiliary Systems - Summary of Aging Management Evaluation - Condensate Storage and Transfer System (page 3.4-28), is revised as follows (new text underlined):
Table 3.4.2-2 Auxiliary Systems - Summary of Agina Management Evaluation - Condensate Storage and Transfer System Component Intended 'Material Environment Aging Effect
>- Aging Managemient LNUREG-l Table 1 Gtem Notes I Type Fuunction/
Reqiring Program 1801 Vol.
T Managementi 2~ Itenc Closure Bolting PB
'Stainless Atmosphere/Weat Loss c Steel her (Ext) nISIA Stainless Buried (Ext)
Loss':
i iSteel Valve I PB I Stainless AtmosphereNWeat None Steel her (Ext) f preload 1
,f material Bolting Integrity (B2.1.7) None Buried Piping and Tanks IVIII.E-28 Inspection (B2.1.18)
None None None S3.4.1.17 1_E
ýGi None G
Source: AMP Audit Component-Material-Environment Walkdown LRA Table 3.3.2-21, Auxiliary Systems - Summary of Aging Management Evaluation - Diesel Generator System (page 3.3-196), is revised to remove the following line items (text strikethrough) associated with changing the material for the Diesel Generator system pre-lube oil pump from stainless steel to carbon steel.
11
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 8 LRA Changes for RAI 2.3.3.30-01 and 02 Responses Affected LRA Sections and Pages LRA Section Page Nos.
RAI No.
Table 2.2-1 2.2-4 2.3.3.30-01 and 02 2.3.3 2.3-20 and 21 2.3.3.30-01 and 02 2.3.3.30 2.3-76 to 2.3.3.30-01 and 02 2.3-83 2.3.3.31 2.3-83a and 2.3.3.30-01 and 02 (new) 83b 3.3.1 3.3-2 2.3.3.30-01 and 02 3.3.2 3.3-2 to 3.3-4 2.3.3.30-01 and 02 3.3.2.1.30 3.3-33 and 34 2.3.3.30-01 and 02 3.3.2.1.31 3.3-34a 2.3.3.30-01 and 02 (new)
Table 3.3.2-30 3.3-233 to 244 2.3.3.30-01 and 02 Table 3.3.2-31 3.3-245 to 248 2.3.3.30-01 and 02 (new)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Source: RAI 2.3.3.30-01 and 2.3.3.30-02 Responses
" Table 2.2-1 Plant-Level Scoping Results, page 2.2-4 is revised as shown in the following pages (delete strikethrough and new text underlined).
" Section 2.3.3 Auxiliary Systems, page 2.3-20 is revised as shown in the following pages (delete strikethrough and new text underlined)
" Section 2.3.3.30 Miscellaneous Auxiliary Systems in-scope ONLY for Criterion 10 CFR 54.4(a)(2), pages 2.3-76 through 2.3-83 is revised as shown in the following pages (delete strikethrough).
" Section 2.3.3.31 Oily Waste and Non-Radioactive Waste System is added as a new section after Section 2.3.3.30 as shown in the following pages (new text underlined).
Section 3.3.1 Introduction, page 3.3-2 is revised as shown in the following pages (delete strikethrough and new text underlined)
" Section 3.3.2 Results, page 3.3-4 is revised as shown in the following pages (new text underlined)
" Section 3.3.2.1.30 Miscellaneous Auxiliary Systems in-scope ONLY for Criterion 10 CFR 54.4(a)(2), pages 3.3-33 thru 3.3-34 is revised as shown in the following pages (delete strikethrough).
" Section 3.3.2.1.31 Oily Waste and Non-Radioactive Waste System is added as a new section after Section 3.3.2.1.30 as shown in the following pages (new text underlined).
" Table 3.3.2-30, Auxiliary Systems - Summary of Aging Management Evaluation -
Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2) is revised as shown in the following pages 3.3-233 through 3.3-244 (delete strikethrough).
" Table 3.3.2-31 Auxiliary Systems - Summary of Aging Management Evaluation -
Oily Waste and Non-Radioactive Waste System is added as a new table after LRA Table 3.3.2-30 as shown in the following pages 3.3-245 through 3.3-248 (new text underlined).
Section 2.2 PLANT-LEVEL SCOPING RESULTS Fuel handling and storage Yes 2.3.3.1 Fire protection Yes 2.3.3.19 Station blackout generator Yes 2.3.3.28 Gaseous radwaste Yes 2.3.3.26 Miscellaneous auxiliary systems in-scope ONLY for criterion Yes 2.3.3.30 10 CFR 54.4(a)(2, includes:
Auxiliary steam Chemical waste jj**j>
Liquid radwaste Oily-waste and non radioactive waste Solid radwaste Sanitary sewage and treatment Secondary chemical control, includes Ecodyne Graver Oily waste and non-radioactive waste Yes 2.3.3.31 Misc. Site Structures/Spray Pond Pump House HVAC Yes 2.3.3.18 Normal chilled water Yes 2.3.3.5 Nuclear cooling water Yes 2.3.3.6 Nuclear sampling Yes 2.3.3.8 Radioactive waste drains Yes 2.3.3.27 Radwaste building HVAC Yes 2.3.3.16 Service gases (N2 and H2)
Yes 2.3.3.25 Spent fuel pool cooling and cleanup Yes 2.3.3.2 Turbine building HVAC Yes 2.3.3.17 WRF fuel Yes 2.3.3.24 Chemical production, includes:
No N/A Hypochlorite subsystem Caustic subsystem Lube oil storage, transfer and purification No N/A Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 2.2-4
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS 2.3.3 Auxiliary Systems This section of the application addresses scoping and screening results for the following systems:
Fuel handling and storage
" Spent fuel pool cooling and cleanup
" Essential cooling water Essential chilled water Normal chilled water Nuclear cooling water Essential spray pond
" Nuclear sampling Compressed air Chemical and volume control Control building HVAC Auxiliary building HVAC Fuel building HVAC Containment building HVAC Diesel generator building HVAC Radwaste building HVAC Turbine building HVAC Miscellaneous site structures/spray pond pump house HVAC Fire protection Diesel generator fuel oil storage and transfer Diesel generator Domestic water Demineralized water WRF fuel system Service gases (N2 and H2)
Gaseous radwaste Radioactive waste drains Station blackout generator Cranes, hoists, and elevators Miscellaneous auxiliary systems in-scope only for criterion 10 CFR 54.4(a)(2):
o Auxiliary steam o
Chemical waste o
Liquid radwaste Oily waste and non radioactiVo waste o
Solid radwaste Palo Verde Nuclear Generating Station Page 2.3-20 License Renewal Application Amendment 8
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS o
Sanitary sewage and treatment o
Secondary chemical control Oily waste and non-radioactive waste 2.3.3.1 Fuel Handling and Storage System
System Description
The purpose of the fuel handling and storage system is to provide on site storage of new and spent fuel assemblies, provide manipulation of fuel assemblies and control element assemblies, provide radiation shielding for spent fuel and provide for the servicing of the reactor vessel closure head and internals.
Crane supports are evaluated with their appropriate structure. The system consists of cranes, elevators, fuel storage racks, lift rigs, machines, transfer systems and trolleys. The following components are within the scope of license renewal:
containment building polar crane 150/15 ton dry cask crane 10 ton new fuel handling crane spent fuel handling machine new fuel elevator refueling machine CEA change platform upper guide structure lift rig core support barrel lift rig reactor vessel head lift rig new fuel storage racks spent fuel storage racks fuel transfer carriage and trolley assembly (rails)
System Intended Function The fuel handling and storage system is within the scope of license renewal based on the criteria of 10 CFR 54(a)(1).
Portions of the fuel handling and storage system have spatial interaction as nonsafety affecting safety-related components in the fuel and the containment buildings and are in-scope based on the criterion of 10 CFR 54(a)(2).
PVNGS UFSAR References Additional details of the fuel handling and storage system are included in UFSAR Sections 9.1.1, 9.1.2, and 9.1.4.
License Renewal Drawings There are no license renewal drawings for the fuel handling and storage system.
Palo Verde Nuclear Generating Station Page 2.3-21 License Renewal Application Amendment 8
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS Table 2.3.3 Cranes, Hoists, and Elevators System Component Type Intended Functio Crane Non-S/R Structural Support Cranes - Rails Non-S/R Structural Support Hoist Non-S/R Structural Support Trolley Non-SIR Structural Support 2.3.3.30 Miscellaneous Auxiliary Systems in-scope ONLY for Criterion 10 CFR 54.4(a)(2)
Auxiliary systems within the scope of license renewal based upon the criterion of 10 CFR 54.4(a)(2) were identified using the methods described in Section 2.1.2.2. A review of each mechanical system was performed to identify nonsafety-related systems or nonsafety-related portions of safety-related systems with the potential for adverse spatial interaction with safety-related systems or components. Components subject to aging management review due only to scoping criterion 10 CFR 54.4(a)(2) are evaluated in this section.
The following auxiliary systems are within the scope of license renewal only based on the criterion of 10 CFR 54.4(a)(2):
Auxiliary steam Chemical waste Liquid radwaste
" Oily waste and non radioactive wa-ste Solid radwaste Sanitary sewage and treatment Secondary chemical control System Descriptions/System Intended Functions Auxiliary steam The purpose of the auxiliary steam system is to provide a source of steam for various nonsafety-related functions during plant startup, shutdown, normal operations, and testing evolutions.
The auxiliary steam system consists of an auxiliary boiler, transfer pumps, receivers, tanks, piping, and valves.
Portions of the auxiliary steam system in the auxiliary building contain nonsafety-related components that are spatially oriented such that their failure could prevent the satisfactory Palo Verde Nuclear Generating Station Page 2.3-76 License Renewal Application Amendment 8
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS accomplishment of a safety-related function associated with a safety-related component. The auxiliary steam system attaches to nonsafety-related auxiliary feedwater system piping such that the structural failure of the auxiliary steam system piping could prevent satisfactory accomplishment of safety-related auxiliary feedwater system functions. These-portions of the auxiliary steam system are within the scope of license renewal as nonsafety-related components affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).
Chemical waste The chemical waste system consists of five sub-systems:
(1) The radioactive chemical waste sub-system that collects the corrosive radioactive waste from the chemical laboratory and decontamination stations. The sub-system transports the liquid waste and drainage from decontamination room, sample hood and hot lab fume hoods, instrumentation respirator maintenance and issue room, cold lab fume hood, to the chemical drain tanks by gravity flow.
(2) The cooling water waste sub-system that collects the chemically treated cooling water from the auxiliary and radwaste buildings for reuse or disposal.
In addition to collecting leakage, the sub-system accepts drainage during maintenance of plant equipment containing chemically treated cooling water, and collects in the cooling water holdup tank by gravity flow.
The sub-system is normally aligned to transfer the contents to the chemical waste neutralizer tanks of the radwaste system. Branch lines are provided for diverting the contents of the cooling water holdup tank to the essential cooling water surge tanks or to the nuclear cooling water surge tanks, for use only during maintenance, to return the drainage from the equipment to the appropriate cooling water loop.
(3) The condensate polisher regeneration waste sub-system that collects the rinse washes from the condensate polisher demineralizers and neutralizes the waste for disposal to the retention basin if it is non-radioactive, or discharges to the liquid radwaste system if the waste exceeds the release limits.
(4) The spent regenerate waste sub-system that collects and neutralizes the rinse washes from the makeup demineralizers for disposal.
(5) The yard areas chemical tank drains sub-system. The yard area chemical tanks and pumps are installed on concrete slabs with retaining curbs. Small sumps are provided inside the curbs to collect equipment leakage.
All sub-systems of chemical waste system have no safety-related functions.
Portions of the chemical waste system in the auxiliary building and pipe tunnel contain nonsafety-related components that are spatially oriented such that their failure could prevent the satisfactory accomplishment of the safety-related functions associated with the surrounding safety-related components.
Portions of the chemical waste system attach to Palo Verde Nuclear Generating Station Page 2.3-77 License Renewal Application Amendment 8
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS safety-related essential cooling water system piping such that the structural failure of the chemical waste system piping could prevent satisfactory accomplishment of safety-related essential cooling water system functions. These portions of the chemical waste system are within the scope of license renewal as nonsafety-related components affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).
Liquid Radwaste The purpose of the liquid radwaste system is to collect, process, monitor and recycle or dispose of liquid radwaste. Liquid radwaste is sampled and analyzed for radioactivity. Based on the analysis, liquid radwaste is recycled for eventual reuse in the plant, retained for further processing or dispatched to the solid radwaste system or to the onsite evaporation pond under controlled conditions. Plant design precludes the release of radioactive liquids to the environment.
The liquid radwaste system is composed of instrumentation and process components such as piping, filters, pumps, tanks and an evaporator.
Portions of the liquid radwaste system have spatial interaction as nonsafety affecting safety-related components in the fuel building and in the auxiliary building and are within the scope of license renewal as nonsafety affecting safety-related components based on the criterion of 10 CFR 54(a)(2).
-A-d wigtean fI Fiu i FR*UIUaWZIVe Wdbttf T-he oily w-aste and non radioactive waste system collects and tranSPOrts liquild wasRte froim equipment and floor drains, of the tur~bine building, the coentrol buildin'g, the diesel generator buildings, the fire pumnp house, and the yard area. The system removes entrained oil fromR the wastew~a~ter fo-r disposal and conveys the oil4:R 1free ate to the evaporation pond.
The turbine building oil/water separator receives effluent fromA the turbine building Sumps, the control building sumps, and the diesel generator building sumps. A duplex retention basin is provided to act as a storage basin for the wastewater from the turbine building. oil/water separator. When the chemistr; of the waste in the retention basin is acceptable, thei waste in the retention basin is discharged to the evaporation pond. A connection for a portable ion exchanger is provided in the unlikely event that radioacstivity greater than the release limnits, are detected in one of the retention basinsb. The wa;;ste oil is sampl-d-to detec~t any activity before being manually transferred to the external waste oil container for disposal.
The oil" waste and noen-raddioac-tive waste systemn for the fire pump house is entirely separate fromn the other parts of the oily waste and non radioactive waste system. The collected waste fi s treated-in the fire pump house oil/water separator. The oily waste and non radioactive was~te system in the yard area receives drainage and liquid Waste from; the areas, associated with the demineralized water storage tank and pumps, the auxiliary boiler, and turbine building normnal air handling units. The collected waste from the yard area is discharged to the circulating water intake structure.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 2.3-78
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS Pretions *f the oily waste aRd n*on radi-oative waste systemr that are located in the aulx-iary building, diesel gener bIlding" and contro building have effects of spatial inter*ati*
n With safety relte comonets And are in scope as nonsafety affecting safety related compnent basdR the criteria of 1 0 CFIR 54.41(a)(2).
Portions Of th~e flooAr drains in the diesel generator building and control building are credited for proetection of safety related equipment from flooding in aeent of pipe break in the associated areas. The" are included in scope for the cria046 of 10 1\\644()(4-Portions of the oily waste and non radioactive waste system. atah to safety related essential chilled water system piping through demineralized water system such that the strugctral faiure -of the oil" waste and nons adioactive waste system piping could prevent satisfatfory accogplishment of safety related essertial chilled water system funcstions Thaese protionu of the ail" waste and non radioachtve waste system are within the scope of license renewal as nonsafety components affecting safety related components based OR the criterion Of 10 CFR 5 4.4 a) (2--
Solid Radwaste The purpose of the solid radwaste system is to provide processing and packaging capability for concentrated waste solutions and spent resins.
The system provides a means for packaging and disposal of spent radioactive cartridge filters and solid wastes from the liquid radwaste system and the chemical and volume control system.
Additionally, the solid radwaste system provides a means of compacting and packaging miscellaneous dry radioactive materials such as paper, rags, clothing and tools. The solid radwaste system is made up of multiple piping runs, valves, tanks and pumps and consists of the following subsystems: spent resin transfer subsystem, wet waste processing subsystem, dry waste disposal subsystem and the filter handling and disposal subsystem.
Portions of the solid radwaste system have spatial interaction as nonsafety affecting safety-related components in the auxiliary building. Portions of the solid radwaste system provide structural integrity attached to safety-related equipment in the fuel pool cooling and cleanup system and in the chemical and volume control system. These portions of the solid radwaste system are in-scope as nonsafety affecting safety-related components based on the criterion of 10 CFR 54(a)(2).
Sanitary Sewage and Treatment The sanitary sewage and treatment system collects the sanitary wastewater from facilities throughout the plant through drain piping and transports it through one wet well, one sewage lift station, one surge tank, to the three package sewage treatment units, where the waste is treated and clarified. The wastewater is then transported to the chlorine contact chamber for chlorination before being transported to the sanitary waste water sump. Two sump pumps, with automatic level control, pump the wastewater from the sanitary waste water sump to the water reclamation plant for further treatment and reuse.
Palo Verde Nuclear Generating Station Page 2.3-79 License Renewal Application Amendment 8
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS Portions of the sanitary sewage and treatment system that are located in the auxiliary building and control building have effects of spatial interaction with safety-related components and are within the scope of license renewal as nonsafety affecting safety-related components based on the criteria of 10 CFR 54.4(a)(2).
Secondary Chemical Control The secondary chemical control system is an integrated system comprised of a condensate demineralizer subsystem, a steam generator blowdown processing subsystem, the chemical monitoring and addition subsystem, and the online process sampling subsystem. These subsystems operating concurrently maintain the required operating water chemistry of the condensate and feedwater under all normal operating and upset or abnormal conditions.
The purpose of the condensate demineralizer subsystem is to maintain required water chemistry of the condensate/feedwater loop during upset or abnormal conditions. Dissolved solids are removed by ion exchange and suspended solids are removed by filtration. The demineralizer is normally on standby, and is placed in service only during startup, shutdown, excessive condenser leakage, or other condition requiring polishing of the condensate to maintain required chemistry.
The purpose of the steam generator blowdown subsystem is to compensate for the concentrating effect of the steam generators by continuous blowdown and processing for reuse of a portion of the fluid from each steam generator. This subsystem is also part of a system which maintains the steam generator in wet lay-up by providing the capability to adequately mix, sample and add chemicals to the steam generator.
The purpose of the chemical addition subsystem is to establish and maintain the proper chemistry within the condensate, feedwater, and steam generator secondary side water. The additives serve to control the pH, establish a reducing environment, and to scavenge any dissolved oxygen.
In addition, boric acid may be injected into the secondary system for mitigating denting and intergranular attack/stress corrosion cracking in the steam generator.
The chemical monitoring subsystem provides continuous indication of significant chemical parameters in the secondary system and to alert the operator of faulty chemistry or equipment malfunction.
Continuous online samples are taken from the main condenser, condensate demineralizers, main feedwater lines, steam generator blowdown lines and downcomer, and circulating water lines for analysis by the chemical monitoring system.
All components and piping associated with steam generator blowdown and blowdown sampling between the steam generator and the containment isolation valves are designed to seismic Category I with ASME Class 2 requirements and are assigned to and are evaluated with the main steam system.
Palo Verde Nuclear Generating Station Page 2.3-80 License Renewal Application Amendment 8
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS Portions of the secondary chemical control system in the auxiliary building and pipe tunnel contain nonsafety-related components that are spatially oriented such that their failure could prevent the satisfactory accomplishment of the safety-related functions associated with the surrounding safety-related components. Portions of the secondary control system attach to safety-related main steam system piping such that the structural failure of the secondary chemical control system piping could prevent satisfactory accomplishment of safety-related main steam system functions. These portions of the secondary chemical control system are within the scope of license renewal as nonsafety-related components affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).
PVNGS UFSAR References Details of the auxiliary steam system are not discussed in the UFSAR.
Additional details of the chemical waste system are included in UFSAR Section 9.3.3.
Additional details of the liquid radwaste system are included in UFSAR Section 11.2.2.3.
I irr' A u-~
SectionS 3.6 and 9.3.3&
Additional details of the solid radwaste system are included in UFSAR Section 11.4.
Additional details of the sanitary sewage and treatment system are included in UFSAR Section 9.3.3.
Additional details of the secondary chemical control system are provided in UFSAR Sections 9.3.2 and 10.4.6.
License Renewal Drawings The license renewal drawings LR-PVNGS-AS-01 -M-ASP-001 LR-PVNGS-CH-01-M-CHP-001 LR-PVNGS-CH-01 -M-CHP-005 LR-PVNGS-HA-02-M-HAP-001 The license renewal drawings LR-PVNGS-CM-01 -M-CMP-001 LR-PVNGS-CM-01 -M-CMP-002 LR-PVNGS-EW-01-M-EWP-001 The license renewal drawings LR-PVNGS-LR-01 -N-LRP-001 LR-PVNGS-LR-01 -N-LRP-002-02 Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 for the auxiliary steam system are listed below:
for the chemical waste system are listed below:
for the liquid radwaste system are listed below:
Page 2.3-81
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS Th" li",,R, renrewAl drawings for the oily waste and non radioactive waste system are 11stag belewý LR PVNGS QWA 01 M OP\\AI 001 1 03 DIM/1 f-%AAI A%-I RA (nIAID nAIV LR P)
DIc3S*_
OW*A 01 hM OAIP 003 The license renewal drawings for the solid radwaste system are listed below:
LR-PVNGS-SR-01-N-SRP-001 LR-PVNGS-LR-01 -N-LRP-002-02 The license renewal drawings for the sanitary sewage and treatment system are listed below:
LR-PVNGS-ST-1 3-P-ZAE-204 LR-PVNGS-ST-1 3-P-ZAE-205 LR-PVNGS-ST-1 3-P-ZAE-209-01 LR-PVNGS-ST-1 3-P-ZJE-304 The license renewal drawings for the secondary chemical control system are listed below:
LR-PVNGS-SC-01 -M-SCP-005-01 LR-PVNGS-SC-01 -M-SCP-006-01
.LR-PVNGS-SC-01 -M-SCP-006-02 LR-PVNGS-SG-01 -M-SGP-002 Component-Function Relationship Table The component types subject to aging management review are indicated in Table 2.3.3 Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2).
Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 2.3-82
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS Table 2.3.3-30 Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2)
CompConent Type
[
Intended Function Closure Bolting Leakage Boundary (Spatial)
____Structural Integrity (Attached)
Filter Leakage Boundary (Spatial)
Heat Exchanger (AS Condensate Vent Leakage Boundary (Spatial)
Condenser)____
Heat Exchanger (Sample Cooler)
Leakage Boundary (Spatial)
Orifice Leakage Boundary (Spatial)
Piping Leakage Boundary (Spatial)
S.....................................tru c tu ra l In te g rity..............................................
r u a er.t d...........................
(A tta c h e d)..
Pump Leakage Boundary (Spatial)
Sight Gauge Leakage Boundary (Spatial)
St~r _U_
_CtU_
_ 1ru al Integ rity (A ttach ed) -------
Strainer Leakage Boundary (Spatial)
Structura,,n.tgrt, eAttachd),_
Tank Leakage Boundary (Spatial)
.bing (a.....................
L.
- g.
.Bounda.y (Spat.....................
........k Valve I.........................
Leakage Boundary (Spatial) structural Integrity (Attached)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 2.3-83
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS 2.3.3.31 Oily Waste and Non-Radioactive Waste System
System Description
The oily waste and non-radioactive waste system collects and transports liquid waste from equipment and floor drains of the turbine building, the control building, the diesel generator buildings, the fire pump house, and the yard area. The system removes entrained oil from the wastewater for disposal and conveys the oil-free water to the evaporation pond.
The turbine building oil/water separator receives effluent from the turbine building sumps, the control building sumps, and the diesel generator building sumps. A duplex retention basin is provided to act as a storage basin for the wastewater from the turbine building oil/water separator. When the chemistry of the waste in the retention basin is acceptable, the waste in the retention basin is discharged to the evaporation pond. A connection for a portable ion exchanger is provided in the unlikely event that radioactivity greater than the release limits are detected in one of the retention basins. The waste oil is sampled to detect any activity before being manually transferred to the external waste oil container for disposal.
The oily waste and non-radioactive waste system for the fire pump house is entirely separate from the other parts of the oily waste and non-radioactive waste system. The collected waste is treated in the fire pump house oil/water separator. The oily waste and non-radioactive waste system in the yard area receives drainage and liquid waste from the areas associated with the demineralized water storage tank and pumps, the auxiliary boiler, and turbine building normal air handling units. The collected waste from the yard area is discharged to the circulating water intake structure.
System Intended Functions Portions of the floor drains in the diesel generator building are credited for removal of oil and fire water from the fuel oil day floors to a safe location. They are included in-scope based on the criteria of 10 CFR 54.4(a)(3).
Portions of the oily waste and non-radioactive waste system that are located in the auxiliary building, diesel generator building and control building have effects of spatial interaction with safety-related components and are in-scope as nonsafety affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).
Portions of the floor drains in the diesel generator building and control building are credited for protection of safety-related equipment from flooding in an event of pipe break in the associated areas. They are included in-scope for the criteria of 10 CFR 54.4(a)(2).
Portions of the oily waste and non-radioactive waste system attach to safety-related essential chilled water system piping through demineralized water system such that the structural failure of the oily waste and non-radioactive waste system piping could prevent satisfactory Palo Verde Nuclear Generating Station Page 2.3-83a License Renewal Application Amendment 8
Section 2.3 SCOPING AND SCREENING RESULTS:
MECHANICAL SYSTEMS accomplishment of safety-related essential chilled water system functions. These portions of the oily waste and non-radioactive waste system are within the scope of license renewal as nonsafety components affecting safety-related components based on the criterion of 10 CFR 54.4(a)(2).
PVNGS UFSAR References Additional details of the oily waste and non-radioactive waste are included in UFSAR Sections 3.6, 9.3.3, and Table 9B.3-1.
License Renewal Drawings The license renewal drawings for the oily waste and non-radioactive waste system are listed below:
LR-PVNGS-OW-01-M-OWP-001 LR-PVNGS-OW-01-M-OWP-002 LR-PVNGS-OW-01-M-OWP-003 Component-Function Relationship Table The component types subiect to agingq management review are indicated in Table 2.3.3 Oily Waste and Non-Radioactive Waste System.
Table 2.3.3-31 Oily Waste and Non-Radioactive Waste System Component_______
I nten dedFun'c'ti on Closure Bolting Pressure Boundary
_Leakage Boundary (Spatial)
Orifice Leakaqe Boundary (Spatial)
Piping Pressure Boundary Leakage Boundary (Spatial)
Structural Inteqrity (Attached)
Strainer Leakaae Boundary (Spatial)
Valve Structural Int-egrity (Atta-che-d)-
Pressure Boundary Leakaae Boundary (Soatiah IStructural Intearitv (Attached)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 2.3-83b
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS o
Liquid radwaste e
Oily waste and non radioactive waste o
Solid radwaste o
Sanitary sewage and treatment o
Secondary chemical control Oily waste and non-radioactive waste Table 3.3.1, Summary of Aging Management Evaluations in Chapter VII of NUREG-1801 for Auxiliary Systems, provides the summary of the programs evaluated in NUREG-1801 that are applicable to the component types in this section. Table 3.3.1 uses the format of Table 3.x.1 (Table 1) described in Section 3.0.
3.3.2 Results The following tables summarize the results of the aging management review for the systems in the Auxiliary Systems area:
Table 3.3.2-1 Auxiliary Systems Summary of Aging Evaluation - Fuel Handling and Storage System Table 3.3.2-2 Auxiliary Systems Summary of Aging Evaluation - Spent Fuel Pool Cooling and Cleanup System Table 3.3.2-3 Auxiliary Systems Summary of Aging Evaluation - Essential Cooling Water System Table 3.3.2-4 Auxiliary Systems Summary of Aging Evaluation - Essential Chilled Water System Table 3.3.2-5 Auxiliary Systems Summary of Aging Evaluation - Normal Chilled Water System Table 3.3.2-6 Auxiliary Systems Summary of Aging Evaluation - Nuclear Cooling Water System Table 3.3.2-7 Auxiliary Systems Summary of Aging Evaluation - Essential Spray Pond System Table 3.3.2-8 Auxiliary Systems Summary of Aging Evaluation - Nuclear Sampling System Table 3.3.2-9 Auxiliary Systems Summary of Aging Evaluation - Compressed Air System Table 3.3.2-10 Auxiliary Systems Summary of Aging Evaluation - Chemical and Volume Control System Table 3.3.2-11 Auxiliary Systems Summary of Aging Evaluation - Control Building HVAC System Management Management Management Management Management Management Management Management Management Management Management Page 3.3-2 Palo Verde Nuclear Generating Station License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-12 Auxiliary Systems Summary of Aging Management Evaluation - Auxiliary Building HVAC System Table 3.3.2-13 Auxiliary Systems Summary. of Aging Management Evaluation - Fuel Building HVAC System Table 3.3.2-14 Auxiliary Systems Summary of Aging Management Evaluation - Containment Building HVAC System Table 3.3.2-15 Auxiliary Systems Summary of Aging Management Evaluation - Diesel Generator Building HVAC System Table 3.3.2-16 Auxiliary Systems -
Summary of Aging Management Evaluation - Radwaste Building HVAC System Table 3.3.2-17 Auxiliary Systems -
Summary of Aging Management Evaluation - Turbine Building HVAC System Table 3.3.2-18 Auxiliary Systems -
Summary of Aging Management Evaluation -
Miscellaneous site structures/Spray Pond Pump House HVAC System Table 3.3.2-19 Auxiliary Systems Summary of Aging Management Evaluation - Fire Protection Systems Table 3.3.2-20 Auxiliary Systems Summary of Aging Management Evaluation - Diesel Generator Fuel Oil Storage and Transfer System Table 2.3.3-21 Auxiliary Systems Summary of Aging Management Evaluation - Diesel Generator System Table 3.3.2-22 Auxiliary Systems Summary of Aging Management Evaluation - Domestic Water System Table 3.3.2-23 Auxiliary Systems Summary of Aging Management Evaluation - Demineralized Water System Table 3.3.2-24 Auxiliary Systems Summary of Aging Management Evaluation - WRF Fuel System Table 3.3.2-25 Auxiliary Systems Summary of Aging Management Evaluation - Service Gases (N2 and H2) System Table 3.3.2-26 Auxiliary Systems Summary of Aging Management Evaluation - Gaseous Radwaste System Table 3.3.2-27 Auxiliary Systems Summary of Aging Management Evaluation - Radioactive Waste Drains System Table 3.3.2-28 Auxiliary Systems Summary of Aging Management Evaluation - Station Blackout Generator System Palo Verde Nuclear Generating Station Page 3.3-3 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-29 Auxiliary Systems Summary of Aging Management Evaluation - Cranes, Hoists, and Elevators System Table 3.3.2-30 Auxiliary Systems Summary of Aging Management Evaluation -
Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a) (2).
Table 3.3.2-31 Auxiliary Systems Summary of Aging Management Evaluation - Oily Waste and Non-radioactive Waste System.
These tables use the format of Table 2 discussed in Section 3.0.
3.3.2.1 Materials, Environment, Aging Effects Requiring Management and Aging Management Programs The materials from which the component types are fabricated, the environments to which they are exposed, the potential aging effects requiring management, and the aging management programs used to manage these aging effects are provided for each of the above systems in the following subsections.
3.3.2.1.1 Fuel Handling and Storage System Materials The materials of construction for the fuel handling and storage system component types are:
Carbon Steel Stainless Steel Environment The fuel handling and storage system components are exposed to the following environments:
Borated Water Leakage Plant Indoor Air Submerged (Structural)
Treated Borated Water Aging Effects Requiring Management The following fuel handling and storage system aging effects require management:
Cracking Loss of material Aging Management Programs The following aging management programs manage the aging effects for the fuel handling -
and storage system component types:
Palo Verde Nuclear Generating Station Page 3.3-4 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Environment The cranes, hoists, and elevator system component types are exposed to the following environment:
Plant Indoor Air Aging Effects Requiring Management The following cranes, hoists, and elevator system aging effect requires management:
Loss of material Aging Management Programs The following aging management program manages the aging effects for the cranes, hoists, and elevator system component types:
Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems (B2.1.11) 3.3.2.1.30 Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2)
Materials The materials of construction for the miscellaneous auxiliary systems in-scope ONLY based on Criterion 10 CFR 54.4(a) (2) component types are:
Carbon Steel Carboen Steel with Elastomner Lining Cast Iron Cast Iron (Gray Cast Iron)
Copper Alloy
" Copper Alloy (Brass Copper < 85%)
Glass
" Stainless Steel Environment The miscellaneous auxiliary systems in-scope ONLY based on Criterion 10 CFR 54.4(a)(2) component types are exposed to the following environments:
Borated Water Leakage Closed-Cycle Cooling Water Palo Verde Nuclear Generating Station Page 3.3-33 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Demnorealized Water Plant Indoor Air
" Potable Water Raw Water Secondary Water Treated Borated Water Wetted Gas Aging Effects Requiring Management The following miscellaneous auxiliary systems in-scope ONLY based on Criterion 10 CFR 54.4(a)(2) aging effects require management:
Cracking Loss of material Loss of preload Wall thinning Aging Management Programs The following aging management programs manage the aging effects for the miscellaneous auxiliary systems in-scope ONLY based on Criterion 10 CFR 54.4(a)(2) component types:
Bolting Integrity (B2.1.7)
Boric Acid Corrosion (B2.1.4)
Closed-Cycle Cooling Water System (B2. 1.10)
External Surfaces Monitoring Program (B2.1.20)
Flow-Accelerated Corrosion (B2.1.6)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
One-Time Inspection (B2.1.16)
Selective Leaching of Materials (B2.1.17)
Water Chemistry (B2.1.2)
Palo Verde Nuclear Generating Station Page 3.3-34 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS 3.3.2.1.31 Oily Waste and Non-Radioactive Waste System Materials The materials of construction for the oily waste and non-radioactive waste system component types are:
Carbon Steel Carbon Steel with Elastomer Lining Cast Iron Copper Alloy Stainless Steel Polyvinyl Chloride (PVC)
Environment The oily waste and non-radioactive waste system component types are exposed to the following environments:
Demineralized Water Encased in Concrete Plant Indoor Air Potable Water Raw Water Aging Effects ReQuiring Management The following oily waste and non-radioactive waste system aging effects require management:
Loss of material Loss of preload Aging Management Programs The following aging management programs manage the aging effects for the oily waste and non-radioactive waste system component types:
Bolting Integrity (B2.1.7)
External Surfaces Monitoring Program (B2.1.20)
Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B2.1.22)
One-Time Inspection (B2.1.16)
Water Chemistry (B2.1.2)
Palo Verde Nuclear Generating Station Page 3.3-34a License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a) (2)
Component I ntended
~Materia['
Environment, Aging EffectI Aging Management NUREiG-Table 1 Item iii Notes TypeQ Funiction ý Requiring:
Program,"
1801 Vol.
1)..Managret 2________
2lte~m Closure Bolting LBS Carbon Steel Borated Water Leakage (ExtL Borated Water Leakaae (Ext)
Loss of preload Bolting Integrity (B2.1.7) IV.C2-8 3.1.1.52 B
IClosure Bolting LBS
!Carbon Steel Loss of material B--
Closure Bolting LBS ICarbon Steel Plant Indo
_________________(Ext).
Closure Bolting LBS Carbon Steel Plant Indo i
(Ext)
Closure Boltingi CLBS, SIA Carbon Steel Plant Indo (Ext)
Closure Bolting LBS, SIA Carbon Steel Plant Indo H(Ext)
GeB 14P BS
'Copper Alle l~ InG Closure Bolting 1LBS iStainless Borated W L Steel Leakage(
Closure Bolting LBS, SIA Stainless Plant Indo(
ISteel (Ext) or Air Loss of material or Air Loss of preload or Air Loss of material or Air Loss of preload G-Ad Less-of-p eead ater Loss of preload Ext) or Air Loss of preload
-1 Boric Acid Corrosion V.E-2 3.2.1.45 (B2.1.4)
Bolting Integrity (B2.1.7) VII.I-4 3.3.1.43 Bolting Integrity (B2.1.7) VII.I-5 3.3.1.45 Bolting Integrity (B2.1.7) VIII.H-4 3.4.1.22 Bolting Integrity (B2.1.7) :VIII.H-5 3.4.1.22 Bolting Intgrit~"~"~*~7 I None Noe A
B B
B B
Bolting Integrity (B2.1.7)
Bolting Integrity (B2.1.7)
IV.C2-8 None V.F-13 3.1.1.52 None B
G,1 Filter Filter LBS Stainless Steel Borated Water Leakage _(Ext)
ýNone None 3.2.1.57 A
4
-1 LBS 1 Stainless Steel Treated Borated Loss of material Water (Int)
Water Chemistry (B2.1.2)
V.A-27 3.2.1.49 A
Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 3.3-233
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2) (Continued)
ý.Component Inteid'e'd Material
~Environment
~A610Effect~ AgnMngeet NUREG-al Ie oe Type
- Function,
'Requiring.
Program 1801 Vol.~
~
~
anagmn.
>2 Itein Heat LBS Exchanger (AS Condensate Vent Carbon Steel Closed-Cycle Cooling Water (Int)
Carbon Steel. Plant Indoor Air (Ext)
Loss of material Loss of material Condenser)-
Heat Exchanger (AS Condensate Vent Condenser)
Heat Exchanger (AS Condensate Vent Condenser)
Heat Exchanger (Sample Cooler)
Heat Exchanger (Sample Cooler)
LBS Closed-Cycle Cooling Water System (B2.1.10)
External Surfaces Monitoring Program
((B2.1.20)
VIII.A-1 3.4.1.24 B
VIII.H-7 3.4.1.28 B
LBS LBS LBS Carbon Steel. Secondary Water (Int)
Loss of material Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.16)
IVIII.E-37 13..1.3 1A Carbon Steel Closed-Cycle Loss of material Closed-Cycle Cooling xxCooling Water (I nt)l Water System (82.1.10)
Carbon Steel 'Closed-Cycle Loss of material Closed-Cycle Cooling
'Cooling Water (I nt)
Water System (82.1.10)
Carbon Steel Plant Indoor Air Loss of material External Surfaces (Ext) j Monitoring Program VIII.A-1 3.4.1.24 B
VIII.F-4 13.4.1.24 B
Heat Exchanger (Sample Cooler)
LBS VIII.1H-7 3.4.1.28 B
(B2.1.20)
Heat Exchanger (Sample Cooler)
LBS Stainless Closed-Cycle Steel 1 Cooling Water I(Ext)
Loss of material Closed-Cycle Cooling Water System (B2.1.10)
VIII.F-1 13.4.1.25 lB
.-.--L-Palo Verde Nuclear Generating Station Page 3.3-234 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2) (Continued)
Component
~Intended
~Materia,
~Environmenrt
' Aging Effect Aging Management NUIREG-Table 1 Item Noe Type Function P
~~~
Requiring
~
Program
~
1801 Vol.
MRIfanagment2Ite Heat LBS Stainless
'SecondaryWater Cracking Water Chemistry (B2.1.2) VIII.F-3 13.4.1.14 A
Exchanger Steel I(Int) and One-Time Inspection (Sample (B2.1.16)
Cooler)__
Heat LBS Stainless (Secondary Water Loss of material Water Chemistry (B2.11.2)
VIII.F-27 3.4.1.16 A
Exchanger Steel I(Int) and One-Time Inspection (Sample (B2.1.16)
Cooler)
Orifi e L-BS Garf*n-teelRPl*Antlndoo*rl Lo oef nmatel Ex=teal SurfaGe V--8 3
B Monitoring Program
_m42
/__
Ofine LBS CarbonlSeteclRaw
-Watery ate)
Loss of material IntChemion O 2f internal VII4-1-4 1
3E4.1.-6 Surfaces In Miscellaneous Piping And Ducting SB
)Components (B2.1.22 Orifice LBS Stainless PlantlIndoor Air None None VIII1-lO 3.4.1.41 A
S~~~Steel (Ext)_
Orifice LBS Stainless
{Secondary Water Loss of material Water Chemistry (B2.1.2)
VIII.B-54 3.4.1.16 1A Steel j(Int) and One-Time Inspection
_(B2.1.16)
Piping LBS, SIA Carbon SteeloPlant Indoor Ar rLoss of material External Surfaces VI1I.B1-8 3.3.1.58 A
I (Ext)
Monitoring Program (B2.1.216)
Piping LBS, SIA Carbon Steel Plant Indoor Air Loss of material External Surfaces VIII.H-7 3.4.1.28 B
(Ext)
Monitoring Program (B2.1.20)
Palo Verde Nuclear Generating Station Page 3.3-235 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a) (2) (Continued)
Component [Intended [ Material
[Envirobnmet A§gin Effect Aging jManagemnent NUREG-Table I Item Notes Type k Function R
]
equiring
~
Program.
1801 Vol.
Maaemn 2 2Item Piping LBS Carbon Steel Raw Water (Int)
Loss of material Inspection Of Internal VII.C1-19 3.3.1.76 JE, 2 Surfaces In Miscellaneous Piping And Ducting
_Components (B2.1.22)
Piping LBS Carbon Steel rRaw Water (Int)
Loss of material Inspection Of Internal VI1.C1-19 3.3.1.76 E, 2 Surfaces In Miscellaneous Piping And Ducting
_ _Components (B2.1.22)
Piping SIA Carbon Steel Raw Water (Int)
Loss of material Inspection Of Internal VII.C1-19 3.3.1.76 E, 2 Surfaces In Miscellaneous Piping And Ducting
_____Components (B2.1.22)
Piping LBS, SIA Carbon Steel Secondary Water Loss of material Water Chemistry (B2.1.2)
VIII.B1-8 3.4.1.37 A
j Intt)
Piping LBS, SIA Carbon Steel I Secondary Water Wall thinning Flow-Accelerated VIII.B1-9 3.4.1.29 B
_ (Int)
Corrosion (B2.1.6)
Piping LBS Carbon Steel Secondary Water Loss of material Water Chemistry (B2.1.2)
VIII.B1-1 1 3.4.1.04 A
(Int) and One-Time Inspection (B2.1.16)
Piping LBS Carbon Steel Wetted Gas (Int)
Loss of material Inspection Of Internal VIII.B1-7 3.4.1.30 B
Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
_h o R LB t P P teI Plant Indoo Ai
-r Loss of material E..ernia 1 Sur_1Ff a Ges V!!.!.8 2 -14 B
13 With i-EX)
Monitoring Program I
EIstm (92120~)
Piping L-BS GaF b i-Steei Raw-Water-(IPA) of mater)ial Inspection Of Internal VIbCI.
19 3.1.76 E -2 with 1rSufce; Ir iscellneou wlathem Pipng And Ducting L"
Components (-.22)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 3.3-236
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2) (Continued)
Component Intended.
Material E.nvironment Aging Effect
.NURE-.
Table 1 Item Notes+
Type Function Requiring Program 1801 Vol.
Piping LBS CoperloPantnManagem n
e VIII.I-2 It
.4.1.
A_
Piiping jLBS Copper Alloy Plant Indoor Air None None JVIII.I-2 13.4.1.41
ýA L-BS lGeppeF-AIle Potablc YWater (Int) ILoss of material I nspection Of Internal
' Surfaces In,Miscellaneo-us Piping And Ducting
.o m po....
(:B 2.1'..-2 2+/-":-
- + -
Noee 1 NIQ LBS Piping Piping Piping Piping Piping Piping
ý ipin g ICopper Alloy Raw Water (Int)
Loss of material Inspection Of Internal Surfaces In Miscellaneous
!Piping And Ducting Components (B2. 1.22).
VII.Cl-9 3.3.1.81
!V.F-13 3.2.1.57 LBS Stainless Steel 1=1S,-Sb4 Staondess LBS, SIA Stainless
'Steel LBS, SIA i Stainless Steel Borated Water Leakage_(Et)
.Water--(ine None
'None iE, 2 A
A 1A Plant Indoor Air (PExt)
Plant Indoor Air Loss of aterial iWater Che.istr (12..1.2) land One Time Inspection lip!") 1 41AN None None None None 1Vll.E 29 VII.J-15
'3.3.1.94 IV 11.1_-10 31-.4.1.41
!;M4--_
LBS LBS SIA Stainless Raw Water (Int)
Loss of material Inspection Of Internal Steel Surfaces In Miscellaneous Piping And Ducting
_Components (B1 2..22)_
Stainless Raw Water (Int)
Loss of material Inspection Of Internal Steel Surfaces In Miscellaneous Piping And Ducting Loss-.Components (B32.1.22)_
Stainless Raw Water (Int)
Loss of material Inspection Of Internal Steel Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
VII.C1-15 13.3.1.79 E, 2 VI1.C1-15 3E, 2
VII.C1-15 13.3.1.79 E, 2 Palo Verde Nuclear Generating Station Page 3.3-237 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope
... oONLY based on Criterion 10 CFR 54.4(a)(2) (Continued)
- Coiomponent r Intended Material Environment AgingEffect Aging Ma"nagement
,NUREG-Table I Item Notes SType FunctionI Requiring Program 1801l Vol.
U ~
IManageernet 2Ie i
Piping Piping Piping Piping IPiping Pump rPump Pump Pump Sight Gauge Sight Gauge Sight Gauge LBS LBS Stainless Secondary Water Steel (Int)
Stainless Steel Secondary Water (Int)
LBS, SIA Stainless Secondary Water I Steel (Int)
LBS, SIA IStainless Secondary Water Steel (Int)
Cracking Loss of m Cracking Loss of rm iaterial Water Chemistry (B2.1.2) and One-Time Inspection (132. 1. 16_
Water Chemistry (B2.1.2) and One-Time Inspection (B2-1-16).
naterial Water Chemistry (82.1.2)
.and One-Time Inspection
,Water Chemistry (B2.1.2)
,and One-Time Inspection naer2a
- 1.
- 16) r(
iaterial IWater Chemistry (132.1.2)
VIII.F-23 3.4.1.16 VIII.F-24 3.4.1.14 A
A iA A
LBS LBS LBS LBS LBS LBS Stainless Steel Cast Iron (Gray Cast
- ron)
ICast Iron
!(Gray Cast I*!ron).....
Cast Iron tGlass Treated Borated Water (Int)
Plant Indoor Air (Ext)
V.A-27 3.2.1.49 Loss of material External Surfaces SMonitoring Program (132.1.20)
Secondary Water 1Wall thinning Flow-Accelerated (Int)
Corrosion (B2.1.6)
VIII.H-7
{3.4.1.28 B
VII.B
-9 3..1.29 VIII.B1-11 3.4.1.04 A
VIII.E-23 3.4.1.36 B
Secondary Water (Int)
Secondary Water (Int)
Borated Water Leakage_(Ext)
Borated Water Leakage (Ext)
Plant Indoor Air (Ext)
Loss of material !Water Chemistry (B2.1.2) land One-Time Inspection i(B2.1.16)
Loss of material Selective Leaching of 1 Materials (82.1.17)
Loss of mateBrial Boric Acid Corrosion
,(82.1.4) i SNone N-one-V.E-9 None 3.2.1.45 A
None 1G LBS, SIA Glass None None VII.J-8 3.3.1.93 A
Palo Verde Nuclear Generating Station Page 3.3-238 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2) (Continued)
Comp~onent Intended.
Material Environment Aging Effect Ag Iing Management NUREG-Table 1 Item~ Notes Type Function Requiring Program
- 1801 Vol.
Managemient
~2Item Sight Gauge LBS Glass Plant Indoor Air INone INone VI.-
34140 A
'Sight Gauge LBS 1Sight Gauge LBS I Glass
- Glass Stainless Steel Stainless Steel Stainless Steel (Ext) i Ra Water (I nt)
None Secondary Water [None
[(I nt)
Treated Borated None Water (Int)
Borated Water None Leakage (Ext)
Plant Indoor Air None (Ext)e.o Raw Water (I nt)
Loss of materia None None None
- None VII.J-11 13.3.1.93 VIII1.I-8 13.4.1.40 V. F-9 3.2.1.52
!A JA A
Sight Gauge Sight Gauge Sight Gauge LBS, SIA LBS, SIA Loss of material None Inspection Of Internal SSurfaces In Miscellaneous Piping And Ducting
!Components (B2.1.22) i Water Chemistry (B32. 1.2)
VII.J-15 3.3.1.94 1ViIc-i-5 3.3.1.79
- E, 2 LBS Stainless Steel I-LBS, SIA !Carben Ste~elT Treated Borated Water (/nt)
Plan InoorAir V.A-27 3.2.1.49 A
ILBS, SIA lCarben Steel Raw-Water -Qnt)
Loss of material External Surfaces
'Monitoring Program Loss~~~
ofmtra nspection Of I nternal S Urf aGe s I n Mi sc -ella-neou PiigRd Ducting
___ ~
pmpnent'132.1.22) 4osof material External Surfaces
'Monitoring Program i(B2.1.20)
Wall thinning Flow-Accelerated Corrosion (B2.1.6)
V114-8 34148 B
Strainer Strainer LBS ILBS Cast Iron (Gray Cast Iron)
Plant Indoor Air (Ext)
Secondary Water (Int)
VIII.H-7 VIIIl.B1-9 3.4.1.28 B
3.4.1.29 IB Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 3.3-239
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a) (2) (Continued)
Component 1Intendecd Materiail Environment
~Function Strainer LBS Strainer LBS Cast Iron Secondary Water (Gray Cast
.(Int)
Iron)
Cast Iron Secondary Water (Gray Cast (Int)
Iron)
Carbon Steel Plant Indoor Air (Ext)
AigEffect Aginig Man~agement Requiring Program Management Loss of material Water Chemistry (B2.1.2) and One-Time Inspection L(B2.1.16)L Loss of material Selective Leaching of Materials (62.1.17) t5-1-Il-1A.5.4.1.U'+
VIII.E-23 3.4.1.36 113 VIII.H-7 13.4.1.28 B
Tank LBS Tank LBS Carbon Steel
!Carbon Steel Secondary Water (Int)
Loss of material Loss of material Loss of material External Surfaces Monitoring Program (B2.1.20)_
water Chemistry (B2.1.2) land One-Time Inspection
((B2.1.16)
External Surfaces Monitoring Program (B2.1.20)
Water Chemistry (B2.1.2) and One-Time Inspection (1B2.1.16)
VIII.B1-11 3.4.1.04 VIII.H-7 3.4.1.28 VIII.B1-11 13.4.1.04 A
B Tubing LBS Plant Indoor Air (Ext)
+
+
Tubing LBS
'Tubing Tubing LBS LBS LBS Carbon Steel. Secondary Water
,(Int)
Stainless Borated Water steel Leakage (Ext)
Stainless
.Treated Borated Steel
.Water (Int)
Carbon Steel Plant Indoor Air (Ext)
None 1None Loss of material A
V.F-13 3.2.1.57 A
3.2.1.49 A
Loss of material Water Chemistry (B2.1.2) IV.A-27 Valve Valve Loss of material Loss of material LBS Carbon Steel Plant Indoor Air (Ext)
LBS Carbon Steel Raw Water (Int)
External Surfaces Monitoring Program (1B2.11.20)
External Surfaces Monitoring Program (B2.1.20)
Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
VII.I-8 3.3.1.58 VIII.H-7 B
3.4.1.28 i
Valve Loss of material VII.C1-19 3.3.1.76 E,2 Palo Verde Nuclear Generating Station Page 3.3-240 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a) (2) (Continued)
Component Intended Material Environment Aging Effect Aging Management NUREG-TableI Item Notes
~jType IFunction Requiring
~
Program 1801 Vol.
Management 2 I 2tem lValve LBS Carbon Steel Raw Water (Int)
Loss of material Carbon Steel Secondary Water Loss of material Inspection Of Internal VII.C1-19 Surfaces In Miscellaneous Piping And Ducting WComponents (82.1.22) tWater Chemistry (82.1.2)
V~IIIBI-8" 3.3.1.76 E, 2 3.4.1.37 A
Valve Valve Valve Valve Valve iValve Valve Valve Valve LBS SLBS tCarbon Steel LBS Carbon Steel
.(Int).'
Secondary Water Wall thinning (I nt)
Secondary Water Loss of material
.(Int)
LBS LBS LBS LBS cb-s Carbon Steel Wetted Gas (Int)
Cast Iron Plant Indoor Air
!(Gray Cast (Ext)
Iron)
Cast Iron Secondary Water (Gray Cast (Int)
Ilron)
Cast Iron Secondary Water (Gray Cast (Int)
Iron)
Cast Iron Secondary Water (Gray Cast (Int)
I ro n)__
Copper Alloy Plant Indoor Air (Ext)
Loss of material Loss of material Wall thinning Loss of material Loss of material Flow-Accelerated Corrosion (B2.1.6)
Water Chemistry (B2.1.2) and One-Time Inspection (82.1.16)_
Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
External Surfaces Monitoring Program (132.1.20)
Flow-Accelerated Corrosion (82.1.6)
Water Chemistry (82.1.2) and One-Time Inspection (B2.1.16)
Selective Leaching of Materials (82.1.17)
VIIl.B1-9 3.4.1.29 VI11. B-1 -1 ~3.4.1.04 VIII.B1-7 3.4.1.30 VIII.H-7 3.4.1.28 B
VIII.B1-9 3.4.1.29 B
IB A
B 1VIII.B1-1 1 3.4.1.04,
ýA VIII.E-23 3.4.1.36 B
A None None VIII1.1-2 13.4.1.41 Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 3.3-241
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a) (2) (Continued)
Comjponenit. ýIntenided,
~Type Function.
Materia t
jAging Managireerit
~NUREG-Table 1 Item
~Notes~
Program 1 801Vol.
2K 1
Item>
Valve LBS GDppeAll Pat-l AleWateFr (lnt1 Lss; of material Copper Alloy Secondary Water Loss of material Valve Valve Valve Valve Valve Valve LBS I
LBS LBS I(Int)
Copper Alloy Plant Indoor Air (Zinc >15%) (Et))_
Copper Alloy Secondary Water (Zinc >15%).(Int)
LBS Copper Alloy Secondary Water (Zinc >15%)
(Int)
LBS Stainless Borated Water Steel Leakage (Ext)
LBS-SIA Stai*less em.neraized Steel None Loss of material tLoss of material None NIone of materi None Inspection Of Internal Piping And Ducting Water Chemistry (B2. 1.2) and One-Time Inspection (B2.1.16)_
None Water Chemistry (B2.1.2) and One-Time Inspection
((B2.1.16)___
Selective Leaching of Materials (B2.1.17)
None None INone VIII.A-5 VIII.I-2 3.4.1.41 3.4.1.15 VIII.A-5 3.4.1.15 VIII.E-21 3.4.1.35 V.F-13 3.2.1.57 G
A A
A B
A A
A E, 2 i
I~
Water Chemistr' (132. 1.2) and One Time Inspection (132..6.)
VIW!.F 29 Valve LBS, SIA Stainless Plant In Steel (Ex)
Valve LBS Stainless
!Plant In Steel (Ext)_
door Air door Air ater (Int)
None None None Valve LBS Stainless Steel
!Raw W Loss of material Valve LBS Stainless Steel Raw Water (Int)
ILoss of material Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)._
VII.J-15 13.3.1.94 VIII.I-10 3.4.1.41 VI1.C1-15 3.3.1.79 VII.C1-15 13.3.1.79 E, 2 Palo Verde Nuclear Generating Station Page 3.3-242 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-30 Auxiliary Systems - Summary of Aging Management Evaluation - Miscellaneous Auxiliary Systems In-Scope ONLY based on Criterion 10 CFR 54.4(a)(2) (Continued)
-Aging Managemient~
~Programn NUREG-1801 Vol.
2I Zteml Tablel Item
- Notes
- Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting
.Components (B2.1.22).
Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.16)
Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.16)....
Water Chemistry (B2.1.2)
VII.C1-15 3.3.1.79 E, 2 Vill. Fý-2_33 [a._.1.61IA VIII.F-24 3.4.1.14
!A 3.2.1.49 A
V.A-27 Palo Verde Nuclear Generating Station Page 3.3-243 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Notes for Table 3.3.2-30:
Standard Notes:
A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.
B Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP takes some exceptions to NUREG-1801 AMP.
E Consistent with NUREG-1 801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1 801 identifies a plant-specific aging management program.
F M ate rialI noet i n iUIR1E G 1 801Q forF thc6 O copon ent.
G Environment not in NUREG-1 801 for this component and material.
Plant Specific Notes:
1 Loss of Preload is considered to be applicable for all closure bolting.
2 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program (B2.1.22) is credited instead of Open-Cycle Cooling Water System program (B2.1.9) for aging management of the components of solid radwaste system, sanitary drains and treatment, and chemical waste,-4Iy waste systems.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 3.3-244
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.32-31 0il/
~Component
~ TypeW.
Intended Fuunction
'Agingq Management
//':?*Proglram i NUREG-
- TablI 1t*em 1801 Vol.
2 Item Notes *
.... *...... o...
Closure Bolting LBS, PB Bolting Integrity (B2.1.7)
VII.1-4 Closure Bolting Closure Bolting Closu Bolting Orifice i Orifice Piin Pi7bping-LBS, PB
! Carbon Steel FICdIIL IIIUUUI M11 Plant Indoor Air (Ext)
Loss of preload Bolting Integrity (B2.1.7)
.3.3.1.43 B
VII. 1-5
.3.3.1.45 B
LBS
'Copper Alloy LBS
'Stainless Steel Plant Indoor Air Plant Indoor Air Plant Indoor Air (Ext)
Loss of preload Bolting Integrity (B2.1.7)
Loss of preload Bolting Integrity (B2.1.7)
None None None None ILBS SLBS Carbon Steel
- Carbon Steel Raw Water (Int)
Loss of material Loss of material None
.Loss of material External Surfaces Monitoring Program (B2.1.20)
Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
None
.VII.I-8
.3.3.1.58 VI1.C1-19 3.3.1.76 F, 1 G, 1 B
E,2 Carbon Steel Encased in Concrete (Ext)
VII.J-21
.3.3.1.96 Carbon Steel Plant Indoor Air (Ext)
LBS
!Carbon Steel jPotable Water (Int);Loss of material External Surfaces
.V3..I-8 3.3.1.58 Monitoring Program (B2.1.20)
Inspection Of Internal None None Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
A B
G LBS PB
!Carbon Steel Raw Water (Ext)
Loss of material
-4i-External Surfaces Monitoring Program (R2 1 20)
VII.C1-19 3.3.1.76 E, 3 Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 3.3-245
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-31 0i# Waste and Comc6onert TVpe i
- liitended iMateriall F~unction Piping Nin LBS, PB Carbon Steel inspection ur internai Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
External Surfaces Monitoring Program (B2.1.20)
LBS Carbon Steel with Elastomer Linine Plant Indoor Air (Ext)
Loss of material VII.l-8 3.3.1.58 B
VI1.C1-19 3.3.1.76 E, 2
~LBS PpnLBS PipingLBS
.Carbon Steel with Elastomer Lining
.Cast Iron
,Cast Iron
.Copper Alloy Raw Water (Int)
Encased in Concrete (Ext)
Raw Water (Int)
.Loss of material None
.Loss of material Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
None Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
None Inspection Of Internal Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
None VII.J-21 3.3.1.96 VII.C1-19 3.3.1.76 VIII.I-2 3.4.1.41 Piping LBS Plant Indoor Air None Potable Water (Int) Loss of material A
-F4 LBS Copper Alloy None
!None Piping LBS Polyvinyl I Chloride (PVC)
Plant Indoor Air (Ext)
None None None Palo Verde Nuclear Generating Station Page 3.3-246 License Renewal Application Amendment 8
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-31 Oil Waste and Non-Radioactive Waste System (Continued)
Co nn Intended PlMateriali Environment Aging Effect Aging Management NUREG-Table I Item Notes I_
7eFnto Requiring Program 1
p801 Vol.
I Ty~
Fuctin I
~
pManagement 12 Items PiigLBS Polyvinyl Raw Water (Int)
None None None NoneF5 Chloride (PVC)
LBS, SlA Stainless Steel Strainer Strainer Valve
[Valve LBS, Sl LBS, Sl Stainless Steel Carbon Steel Demineralized Water (Int)
Plant Indoor Air P (Extn)
!Plant Indoor Air I( Ext)
Loss of material None L.oss of material LBS, SlI Carbon Steel f Raw Water (Int)
Loss of material LBS, PB Carbon Steel Plant Indoor Air (Ext)
Loss of material Loss of material Water Chemistry (B2.1.2) and One-Time Inspection (B2.1.16)
None E
ixternal Surface-s Monitoring Program (B2.1.20)
Inspection Of Internal
!Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
External Surfaces Monitoring Program (1B2.1.20)
Inspection Of Internal
!Surfaces In Miscellaneous Piping And Ducting Components (B2.1.22)
None I-nspection Of Internal Surfaces In Miscellaneous Piping And Ducting
'Components (B2.1.22)
Water Chemistry (B2.1.2) and One-Time Inspection (B2.1. 6)__
VIII.E-29 3.4.1.16 A
VI.J-15 i
4 I
VIl.l-8 3.3.1.58 VII. 1-8 VI I.C-9 3.3.1.58 1B
ýE2
'B LBS, PB Carbon Steel Raw Water (Int)
VII.C1-19
.3.3.1.76 E 2 Valve Valve LBS LBS
.Copper Alloy Copper Alloy Plant Indoor Air None (Ext)
[Pota-ble Water (Int) Loss of material VI1I.1-2
.3.4.1.41 None None A
G
_A Valve LBS, SIA Stainless Demineralized Steel iWater (Int)
Loss of material VIII.E-29 3.4.1.16 Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 3.3-247
Section 3.3 AGING MANAGEMENT OF AUXILIARY SYSTEMS Table 3.3.2-31 Oily Waste and Non-Radioactive Waste S Corhobnent FIntended Material Function Environment P A
~. NUREG-1801 V61.
2 Item Table 1 Itemi Noe Valve LBS, SIA Stainless
'Steel Plant Indoor Air (Ext)
VII.J-15
.3.3.1.94 A
Notes for Table 3.3.2-31:
Standard Notes:
A Consistent with NUREG-1801 item for component, material, environment, and aging effect. AMP is consistent with NUREG-1801 AMP.
B Consistent with NUREG-1801 item for comoonent material. environment, and aaina effect. AMP takes some exceptions to NUREG-1801 AMP.
E Consistent with NUREG-1801 for material, environment, and aging effect, but a different aging management program is credited or NUREG-1801 identifies a plant-specific aging management program.
F Material not in NUREG-1801 for this component.
G Environment not in NUREG-1801 for this component and material.
Plant Specific Notes:
1 Loss of Preload is considered to be applicable for all closure bolting.
2 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program (B2.1.22) is credited instead of Open-Cycle Cooling Water System program (B2.1.9) for aging management of the components of oily waste systems.
3 External Surfaces Monitoring program (B2.1.20) is credited instead of Open-Cycle Cooling Water System program (B2.1.9) for aging management of the comoonents of the oilv waste svstems.
4 PVC in an indoor air environment is relatively unaffected by water, concentrated alkalis, and non-oxidizing acids, oils, and ozone.
5 PVC in a raw water environment is relatively unaffected by water, concentrated alkalis, and non-oxidizing acids, oils, and ozone.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 8 Page 3.3-248