ML101050015
| ML101050015 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 04/02/2010 |
| From: | Mims D Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-06162-DCM/RAS/GAM | |
| Download: ML101050015 (7) | |
Text
Z-APS A subsidiary of Pinnacle West Capital Corporation Dwight C. Mims Mail Station 7605 Palo Verde Nuclear Vice President Tel. 623-393-5403 P.O. Box 52034 Generating Station Regulatory Affairs and Plant Improvement Fax 623-393-6077 Phoenix, Arizona 85072-2034 ID#: 102-06162-DCM/RAS/GAM April 2, 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 23, 2009, Request for Additional Information Regarding the Scoping and Screening Audit RAI 2.1-3, Issue (2), for the Review of the PVNGS License Renewal Application, and License Renewal Application Amendment No. 11 By letter dated December 23, 2009, the Nuclear Regulatory Commission Staff issued a request for additional information (RAI) related to the PVNGS license renewal application (LRA). With the exception of a response to RAI 2.1-3, Issue (2), Arizona Public Service Company (APS) submitted a response to the December 23, 2009, RAI in letter no. 102-06129, dated February 05, 2010. The response to the December 23, 2009, RAI 2.1-3, Issue (2), is provided in Enclosure 1.
A commitment in this letter is described in the LRA Amendment No. 11 change in. 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 4 //Z//t' (date)
Sincerely, DCM/RAS/GAM A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway Comanche Peak Diablo Canyon - Palo Verde, San Onofre. South Texas, Wolf Creek 4/
3*
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to December 23, 2009, Request for Additional Information RAI 2.1-3, Issue (2), for the Review of the Palo Verde Nuclear Generating Station License Renewal Application Page 2
Enclosures:
- 1.
Response to December 23, 2009, Request for Additional Information Regarding the Scoping and Screening Audit RAI 2.1-3, Issue (2), for the Review of the PVNGS License Renewal Application
- 2.
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 11 cc:
E. E. Collins Jr.
J. R. Hall L. K. Gibson R. I. Treadway L. M. Regner G. A. Pick NRC Region IV Regional Administrator NRC NRR Project Manager NRC NRR Project Manager NRC Senior Resident Inspector for PVNGS NRC License Renewal Project Manager NRC Region IV (electronic)
ENCLOSURE 1 Response to December 23, 2009, Request for Additional Information Regarding the Scoping and Screening Audit RAI 2.1-3, Issue (2), for the Review of the PVNGS License Renewal Application Response to December 23, 2009, Request for Additional Information RAI 2.1-3, Issue (2) for the Review of the PVNGS License Renewal Application NRC RAI 2.1-3
Background:
Pursuant to 10 CFR 54.4(a)(2), the applicant must consider all nonsafety-related SSCs, within the scope of license renewal, whose failure could prevent the satisfactory accomplishment of safety-related functions, as described in 10 CFR 54.4(a)(1).
Issue:
During the scoping and screening methodology audit, performed on-site October 19-22, 2009, the staff determined that the following nonsafety-related SSCs had not been included within the scope of license renewal:
(2)
Nonsafety-related, abandoned containment spray chemical addition tanks, located in containment along with safety-related SSCs, for which the associated piping had been cut and capped but the tanks had not been verified to be dry.
This applies to Units 1 and 3.
Request:
The staff requests that the applicant perform a review of these issues and provide the basis for not including nonsafety-related SSCs, attached or adjacent to safety-related SSCs, within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).
Indicate if the review concludes that use of the scoping methodology precluded the identification of nonsafety-related SSCs that could interact with safety-related SSCs, and which were not specifically exempted by your CLB, and therefore should have been considered within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).
Describe any additional scoping evaluations to be performed to address the (a)(2) criteria. As part of your response, list any additional SSCs included within the scope as a result of your efforts and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.
1 of 2 Response to December 23, 2009, Request for Additional Information RAI 2.1-3, Issue (2) for the Review of the PVNGS License Renewal Application APS Response to RAI 2.1-3, Issue (2)
The containment spray chemical addition tanks were taken out of service and abandoned in Units 1, 2, and 3. However, a residual amount of fluid containing a diluted solution of the original chemical was identified to be captured in the Units 1 and 3 tanks, and suspected in the associated piping in all three units. The following commitment is being added to LRA Table A4-1, License Renewal Commitments, as shown in Enclosure 2:
By August 30, 2010, APS will ensure that that the abandoned containment spray chemical addition tanks and associated piping components in PVNGS Units 1, 2, and 3 are drained to preclude any spatial interactions with safety related components.
When these actions are completed, the Units 1, 2, and 3 abandoned containment spray chemical addition tanks and the associated piping components will not be within the scope of license renewal.
(Note: The APS responses to RAI 2.1-3, Issues (1), (3), and (4), were provided in APS letter no. 102-06129, dated February 05, 2010.)
2 of 2
ENCLOSURE 2 Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 11
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 11 Source: RAI 2.1-03. Issue (2). ResDonse LRA Table A4-1, License Renewal Commitments (page A-59), is revised as follows (new text underlined):
Item Commitment LRA Section Implementation No.
2Sche~dule--
54 By August 30, 2010, APS will ensure that that the Response to 8/30/10 abandoned containment spray chemical addition RAI 2.1-03, tanks and associated piping components in PVNGS Issue (2), in Units 1, 2, and 3 are drained to preclude any spatial APS letter interactions with safety related components.
no. 102-(RCTSAI 3443855) 06162, dated 4/2/10