ML102810502
| ML102810502 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/29/2010 |
| From: | Hesser J Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-06259-JHH/GAM | |
| Download: ML102810502 (29) | |
Text
LA 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 102-06259-JHH/GAM September 29, 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 Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1,2, and 3 By letter dated August 6, 2010, the NRC staff provided to Arizona Public Service Company the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3, hereafter referred to as the Safety Evaluation Report (SER). The staff requested that APS review the SER, verify its accuracy, and provide comments within 45 days from the August 6, 2010, letter date. In response to an APS request for additional time to provide comments, Lisa Regner, NRC Senior Project Manager for the PVNGS license renewal safety review, allowed an additional 10 days to provide comments. Enclosed are the APS comments for staff consideration.
APS makes no new commitments in this letter. Should you need further information regarding this submittal, please contact Russell A. Stroud, Licensing Section Leader, at (623) 393-5111.
Sincerely, JHH/GAM
Enclosure:
Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1,2, and 3 A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway ° Comanche Peak - Diablo Canyon
- Palo Verde - San Onofre
- South Texas
- Wolf Creek
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Arizona Public Service Company. Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Page 2 cc:
E. E. Collins Jr.
J. R. Hall L. K. Gibson J. H. Bashore L. M. Regner G. A. Pick NRC Region IV Regional Administrator NRC NRR Senior Project Manager NRC NRR Project Manager NRC Senior Resident Inspector (acting) for PVNGS NRC License Renewal Project Manager NRC Region IV (electronic)
ENCLOSURE Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comme~nt
ýýPage No. and
~
CoMmn Sugse Reoution No.
.:SER Section.
Global Replace FatiguePro with FatiguePro.
Global replace FatiguePro with FatiguePro Replace FatiguePro is not a registered trademark.
Page 1-9, Revise the second sentence of Revise the sentence to read:
Confirmatory Confirmatory item 2.1.4.2-1 to replace The. associated piping was cut and capped for these tanks, but 2
Item 2.1.4.2-1 "verified to be dry" with "verified to be they had not been verified to be d&y-drained.
drained." A drained system will not have any effects of spatial interactions.
Page 2-3, Engineering drawings, license renewal Revise the statement as follows:
2.1.3.1.1, last position papers, and the plant equipment The applicant stated it used a variety of 4L--B documents paragraph database are not CLB. The statement including those listed above to apply scoping criteria, in following the list of documents in section determining and confirming SSC functions.
2.1.3.1.1 indicates they are part of the CLB.
Page 2-5, Correct typographical errors.
Delete a space in "between the three units."
2.1.3.1.2, third The drawing number should be "...CT-01-M-CTP-001." (Insert paragraph missing dash between M and CTP)
Page 2-5, Replace the double dash with a single Revise the sentence to read as follows:
2.1.3.1.2, dash in the fourth sentence of the last After in-scope license renewal boundaries were established on 5
last paragraph.
a plant system P&ID, each in-scope component on the P&ID paragraph was checked off, and scoping and screening information was entered into the LRDMT (component by component).
Page 2-6, Typographical error - the boundary The drawing number should be "...LR-PVNGS-CT-01 M-CTP-2.1.3.1.2, drawing number needs an additional 001." (Insert missing dash between M and CTP).
second dash.
paragraph Page 2-8, top Replace "staff" with "project personnel" Revise bullet to read:
of page, since "staff" is used to mean NRC staff License renewal project personnel completed training in 7
second bullet throughout the SER.
general license renewal requirements, license renewal project procedures, and discipline-specific areas. Mentoring was also provided by staff project personnel with license renewal project experience.
1
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3
~Comet ageNo ad-Comment SuggestedRslto No.,
SE ection 7v Page 2-8, Be consistent with the reference to 10 Reference 10 CFR 54.4(a)(1) and 10 CFR Part 54.
Sections CFR 54. Delete the word "Part" from 10 2.1.3.4 and CFR Part 54.4 (a)(1).
2.1.4 Page 2-8, The reference to "major" systems and Revise the following portion of the first paragraph to read:
Section 2.1.4 structures is not consistent with LRA.
LRA Section 2.1 describes the applicant's methodology used to scope SSCs pursuant to the requirements of the 10 CFR 54.4(a) criteria. The LRA states that the scoping process 9
categorized the entire plant in terms of majei systems and structures with respect to license renewal. According to the_ -
LRA, majo systems and structures were evaluated against-criteria provided in 10 CFR Part 54.4 (a) (1), (2), and (3) to determine whether the item should be considered within the scope of license renewal.
Page 2-16, A list of LRA sections is mentioned Recommend deleting the third paragraph:
third without showing the list. Recommend A6 a result of thc re evaluation pertfrmed, the LRA. sections paragraph deleting this paragraph. Addition of SSCs itcd below c b.e.
evis.d [to] include rOsaf*-
-elatcd 10 within the scope of LR in response to RAI SS*c iR the Auxiliar, Building, Control Building, Dic.el 2.1-2 is addressed in the prior paragraph; Generator Building, and Fuel Building within the scope of therefore the third paragraph can be liccnsc renewal in acrdane With criterion 10 CFR 54.4 (a)(2)7.
deleted.
Page 2-16, Revise item (2) on the list at the bottom of Revise item (2) to read:
Section the page to identify that the Spray (2) Nonsafety-related, abandoned containment spray chemical 2.1.4.2.2 Chemical Addition Tank is in the Auxiliary addition tanks, located in ecntaimient the Auxiliary Building Building.
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 PVNGS Units 1 and 3.
2
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3
- Cmment, Page. No.- and No SER Section
.Cmet
-SgetdRslto Page 2-20, Environmental Qualification section - the Revise the last two sentences to read as follows:
Section quote from LRA Section 2.1.2.3.2 is not The safety-related systems and components required to 2.1.4.3.1, complete. Revise the last two sentences mitigate the consequences of a design basis accident (DBA),
EQ section of the quote to indicate information is or to attain a safe shutdown of the reactor, are designed to LRA Quote missing.
remain functional during and after exposure to normal 12 operation environmental conditions and following the specific DBA which they are intended to mitigate.... All components within the scope of the PVNGS EQ program which demonstrate compliance with 10 CFR 50.49 and the systems containing those components were classified as satisfying criterion 10 CFR 54.4(a)(3) and were identified as within the scope of license renewal.
Page 2-21, Anticipated Transient Without Scram Revise the first sentence of the ATWS to read:
Section section - The title quoted for LRA Section LRA Section 2.1.2.3.4, "Anticipated Transients Without Scram 13 2.1.4.3.1, 2.1.2.3.4 would indicate the acronym (A,7PNS)," (ATWS) describes the scoping of systems and ATWS section
"(ATWS)" is a part of the LRA Section structures relied on in safety analyses or plant evaluations to Title when it is not.
perform a function in compliance with the ATWS criterion.
Page 2-21, Anticipated Transient Without Scram Revise the last two sentences to read as follows:
Section section - the quote from LRA Section The ATWS Rule required improvements in the design to 2.1.4.3.1, 2.1.2.3.4 is not complete. Revise the last reduce the probability of failure to shutdown the reactor 14 ATWS two sentences of the quote to indicate following anticipated transients, and to mitigate the Section information is missing.
consequences of an ATWS event.... The following equipment is required by the ATWS Rule for reduction of risk from an ATWS event at PVNGS:.
Page 2-21, Station Blackout section - The title quoted Revise the first sentence of the ATWS to read:
Section for LRA Section 2.1.2.3.5 would indicate LRA Section 2.1.2.3, Subsection 2.1.2.3.5, "Station Blackout 15 2.1.4.3.1 the acronym "(SBO)" is a part of the LRA
,SBO),"
(SBO) describes the scoping of systems and Section Title when it is not.
structures relied on in safety analyses or plant evaluations to perform a function in compliance with the SBO criterion.
3
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comment
'Page No. andComnSueedRsutn No.
-SER Section'g Page 2-22, Fire Protection Design Basis and Fire Revise the sentence as follows:
Section Protection Design Basis Manual are not The applicant used,=LB documents, such as the UFSAR, the 2.1.4.3.2, CLB documents. Delete the reference to Fire Protection Design Basis Calculations, and the Fire 16 third CLB.
Protection Design Basis Manual, to identify the SSCs within the paragraph, scope of license renewal for Fire Protection.
second sentence.
Page 2-23, The title of 10 CFR 50.61 is quoted as Revise the first sentence to read:
second "PTS Rule." It should be "Fracture The staff confirmed that the applicant's PTS scoping document paragraph, Toughness Requirements for Protection included the scoping methodology used to review the CLB 17 first sentence Against Pressurized Thermal Shock information to identify SSCs within the scope of license Events."
renewal to meet 10 CFR 50.61, "P-T-S-Rule Fracture Toughness Requirements for Protection Against Pressurized Thermal Shock Events."
Page 2-32, The word "In" is missing when quoting Revise the sentence to read:
18 first from the LRA.
In Mechanical systems, component screening was a paragraph, continuation of the component scoping activity.
first sentence Page 2-32, The first and second paragraphs are Revise the paragraph as follows:
The first and quoted from LRA. However, the
..... The active/passive component determinations documented second separation of paragraphs is not consistent in NEI 95-10, revision 6, Appendix B, provided guidance for-paragraphs with that of LRA.
this activity. In-scope components that were determined to be 19 passive and long-lived were identified in the license renewal database as subject to aging management review.
Each component that was identified as subject to an aging management review was evaluated to determine its component intended function(s)...
4
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comn'aeN.adCormment§,,,
Sggested' Resolution No.
SE Section Page 2-35, Delete the second AMR in the last Revise the last sentence to read:
Section sentence of first paragraph at the top of The LRA states that component-level intended function(s) were 20 2.1.5.4.1 the page.
determined for each in-scope passive electrical component type, identified in the license renewal database as being subject to AMRAMR and recorded in the license renewal database.
Page 2-35, In the list of long-lived passive Revise the eighth bullet to read:
Section components the eighth bullet should be Peet-eatien Penetrations Electrical 2.1.5.4.2 "Penetrations Electrical."
Page 2-39, The SER technical information introduces Revise the first sentence to read:
Section the information as "stated" in LRA 2.3.1.1 LRA Section 2.3.1.1 states-that describes the reactor is as a 2.3.1.1.1 and and it is not formatted consistent with PWR reactor with two reactor coolant loops.
22 page 40, first technical information sections that paragraph, reference an LRA statement. The SER first sentence technical information summary is based on LRA 2.3.1.1 and details extracted from PVNGS UFSAR Section 3.9.5.
Page 2-63, Typographical error in the first sentence -
Revise the sentence to read:
Section delete the period after UFSAR Section The staff reviewed the LRA Section 2.3.3.10, UFSAR Sections 23 2.3.3.10.3 9.3.4.
1.2.10.2, 3.11, 6.2.4, 8.3.1.1.10, and 9.3.4, RAI responses, and.
original and revised boundary drawings to determine whether the applicant failed to identify any components within the scope of license renewal.
Page 2-80, Typographical error in the first sentence -
Revise the sentence to read:
Section delete the period after UFSAR section The staff reviewed the LRA Section 2.3.3.21, UFSAR Sections 24 2.3.3.21.3 9.5.8.
7.4.1.1.1, 8.3.1.1.4, 9.5.4, 9.5.5, 9.5.6, 9.5.7, and 9.5.8, RAI responses, and original and revised boundary drawings to determine whether the applicant failed to identify any components within the scope of license renewal.
5
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comment
'Page6 No.,and' No.
ER Sctio Coment Suggested Resolu tion' Page 2-84, Delete the second LRA in the first Revise the sentence to read:
Section sentence of the 2.3.3.25.3 Conclusion The staff reviewed the L-RALRA Section 2.3.3.25, UFSAR 25 2.3.3.25.3 paragraph.
Sections 6.2.4, 9.3.6, and Table 6.4.2-1, RAI response, and original and revised boundary drawings to determine whether the applicant failed to identify any components within the scope of license renewal.
Page 2-104, In the fourth sentence, revise the name of Revise the sentence to read:
Section the main steam support structure to On the basis of its review, the staff concludes the applicant has 2.4.7.2 provide consistency in describing appropriately identified the main steam support structure 26 structures and to be consistent with the buildi.*gstructural components within the scope of license LRA.
renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the structural components subject to an AMR in accordance with the requirements stated in 10 CFR 54.21 (a)(1).
Page 2-105, In the fourth sentence, revise the name of Revise the sentence to read:
Section the SBO generator structures to provide On the basis of its review, the staff concludes the applicant has 2.4.8.2 consistency in describing structures and appropriately identified the SBO generator structures building 27 to be consistent with the LRA.
structural components within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the structural components subject to an AMR in accordance with the requirements stated in 10-CFR 54.21(a)(1).
Page 2-106, In the fourth sentence, revise the name of Revise the sentence to read:
Section the fuel building to provide consistency in On the basis of its review, the staff concludes the applicant has 2.4.9.3 describing structures and to be consistent appropriately identified the fuel st-UGtu-e-building structural 28 with the LRA.
components within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the structural components subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).
6
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Com en Pag No. ando "n
Su ggested Resolution, No.
SER SectionComn Page 2-107, In the fourth sentence, revise the name of Revise the sentence to read:
Section the water control structures to provide On the basis of its review, the staff concludes the applicant has 2.4.10.2 consistency in describing structures and appropriately identified the spray pond and associated water 29 to be consistent with the LRA.
control structures i;di~g §structural components within the scope:of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the structural components subject to an AMR in accordance with the requirements stated in 10 CFR 54.21 (a) (1).
Page 2-107, Revise the first sentenceto be consistent Revise the sentence to read:
Section with the LRA.
The appl.icant stated that the tank foundations and shells 2.4.11.1, provide support, shelter and protection for the CST and the second RWT. The CST is safety-related and provides the required 30 paragraph water storage for the auxiliary feedwater pumps, and the RWT is safety-related and provides the required volume of borated water for safety injection following a LOCA; therefore, they-the tank foundations and shells are within the scope of license renewal based on the criteria of 10 CFR 54.4(a)(1).
Page 2-109, In the fourth sentence, revise the name of Revise the sentence to read:
Section the transformer foundations and electrical On the basis of its review, the staff concludes the applicant has 2.4.12.3 structures to provide consistency in appropriately identified the transformer foundations and 31 describing structures and to be consistent electrical structures structural components,
,within with the LRA.
the scope of license renewal, as required by 10 CFR 54.4(a),
and that the applicant has adequately identified the structural components subject to an AMR in accordance with the requirements stated in 10 CFR 54.21 (a) (1).
Page 2-110, In the fourth sentence, revise the name of Revise the sentence to read:
Section the yard structures to provide consistency On the basis of its review, the staff concludes the applicant has 2.4.13.3 in describing structures and to be appropriately identified yard structures structural components 32 consistent with the LRA.
within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the structural components subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).
7
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Cp m nt PgeN.
n Commenti Su Oggestedd Re'sblution
, Page 2-1 11, In the last sentence revise the name of Revise the sentence to read:
- Section, the steam generator supports to provide The applicant further stated that the following RCS component 33 2.4.14.1, consistency in describing structures and supports are included with the ASME Class 1 piping and second to.be consistent with the LRA.
component commodity group: reactor vessel supports, paragraph pressurizer supports, steam geneFaters generator supports, and RCP supports.
Page 2-113, In the sixth bullet, revise the name of the Revise the bullet to read:
.Section SBO generator structure to provide concrete elements, concrete blocks (masonry wal!s),
34 2.4.15.2, consistency in describing structures and doors, seals, and coatings or wraps in the SBO seventh to be consistent with the LRA.
generator tWbi1ie structures (LRA Table 2.4-8);
paragraph Page 2-113, Editorial suggestion in the last sentence Revise the sentence to read:
Section for clarity.
..The applicant noted that ely-fire barrier coatings/wraps in the 35 2.4.15.2, main steam support structure are within the scope of license last renewal and subject to an AMR.
paragraph Page 2-114, Correct typographic error.
Revise the first sentence to read:
Section The electrical and I&C components that were identified by the 36 2.5.1.1, applicant to be within the scope of license renewal have been second grouped by the licensee 4;--W into component groups paragraph, regardless of their system association.
first sentence 8
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Pag-No and"
'No.
SESci com ment g sto Sougested sluonct Page2-115, The list of component groups at the top of Add component group "Terminal Blocks - electrical continuity" Section the page is consistent with the paragraph between the bullets for Switchyard Bus and Transmission 2.5.1.1 titles for electrical component groups in Conductors and Connections.
2.5.1 of the LRA with exception of the Bus bar and connections - electrical continuity component type "Ter 'minal Blocks" Bus enclosure - expansion, separation, and structural described in 2.5.1.9 which is missing.
support Bus insulation and insulators - insulation Penetrations Electrical - electrical continuity and insulation 37 Switchyard Bus and Connections - electrical continuity Terminal Blocks - electrical continuity Transmission Conductors and Connections - electrical continuity Electrical Equipment Subject to 10 CFR 50.49 EQ Requirements (TLAA)
Grounding Conductors - ground metal structures and equipment Cable Tie Wraps - installation aid and cable spacing Page 3-9, last For "Reactor Coolant System Revise the GALL Report Aging Management Programs column line of Table Supplement," delete the reference to the to read:
3.0.3-1 GALL Report AMP XI.M1 1A from the XI....A,
" Nickol Alloy Ponetatio.. Nozzle Welded to the 38 GALL Report Aging Management Uppc, Reacto*
Ves*el
.losure Programs column, because there are no Heads of Pre-SUrized Watr Reactr"*,
" "apd AI.*6 "PWR GALL Report AMPs applicable to the Vessel lntcrnats" Reactor Coolant System Supplement.
Not applicable Page 3-18, Revise "of components and materials" to Revise the sentence to read:
Section "in components with materials."
The applicant stated that this program manages loss of 39 3.0.3.1.3, first material of in components aPA1 with materials susceptible to paragraph, boric acid corrosion.
second sentence 9
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Page No. and Cmmn Sgese Resolution No'.
S§ER Section,;
Page 3-29, Penetrations Electrical are evaluated in Revise the first sentence as follows:
Section Table 3.6.2-1. Change the reference In their response dated February 19, 2010, the applicant stated 3.0.3.1.8, from Table 3.6.1 to Table 3.6.2-1.
that LRA Table,3.64 3.6.2-1 shows the Penetrations Electrical 40 last line being managed using the AMP Electrical Cables and paragraph, Connections Not Subject to 10 CFR 50.49 EQ Requirements.
first sentence Page 3-31, The first sentence of the summary Revise the first sentence to read as follows:
Section describes the new Inaccessible Medium LRA Section B2.1.26 describes the ne Inaccessible Medium 3.0.3.1.9, Voltage Cables Not Subject to 10 CFR Voltage Cables Not Subject to 10 CFR 50.49 EQ 41 first 50.49 EQ Requirements Program as a Requirements Program as a new program that is consistent paragraph ne.w program. The use of "new" is with the GALL Report AMP XI.E3, "Inaccessible Medium redundant. Delete the first new.
Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements."
Page 3-78, The first sentence of the Exception 3 Revise the sentence to read:
Section paragraph should refer to the monitoring Exception 3. LRA Section B2.1.14 identifies an exception to the 42 3.0.3.2.9, and trending program element instead of "p.,ve.tativc a.tien*
monitoring and trending" program Exception 3 the preventative actions program element.
paragraph
'element.
II 10
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comet ag N.
nd-Comment ugsed Resolution, No.,
SE ection Page 3-104, Revise the enhancements quoted at the Revise the enhancements to read as follows:
Section bottom of the page to match the Enhancements. In the LRA Electrical Cables and Connections 3.0.3.2.17 enhancements listed in LRA A1.25, Not Subject to 10 CFR 50.49 EQ Requirements Used in Commitment 27 in Table A4-1, and Instrumentation Circuits Program, the applicant stated that, B2,1.25 (Amendment 9) and Commitment prior to the period of extended operation, the following 27 in SER Appendix A, the Electrical enhancement will be implemented in the following program Cables and Connections Not Subject to elements:
10 CFR 50.49 Environmental Qualification Requirements Used in Scope of Program - Element 1, Parameters Monitored or Instrumentation Circuits Program.
Inspected - Element 3 Detection of Aging Effects -
43 Element 4, Acceptance Criteria - Element 6, and -
Corrective Actions - Element 7 Procedures will be enhanced to identify license renewal scope, require cable testing of ex-core neutron monitoring cables, and require an eneeFg evaluation of the calibration results for non-EQ area radiation monitors and te require that an action request be w.ittn wh.
,theloop cannotb.,alibrated to meet acceptance criteria for cable testing be established based on the type of cable and type of test performed.
Page 3-106, Editorial suggestion in the first sentence.
Revise the sentence to read:
Section In order to obtain the information necessary to verify whether 44 3.0.3.2.18, the LRA program element numbw "scope of program" is second consistent with the corresponding element of the GALL Report paragraph AMP, the staff issued RAI B2.1.27-2 in a letter dated December 29, 2009.
Page 3-108, To be consistent with other AMP Provide the staff's evaluation of the exceptions for the ASME Section evaluations in the SER, revise the Staff Section XI, Subsection IWE Program in the staff evaluation 3.0.3.2.18, Evaluation section to include the staff's section of SER section 3.0.3.2.18.
Staff evaluation of the exceptions for the ASME Evaluation Section XI, Subsection IWE Program.
section 11
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 CmetPgNoan 2
Comment SuggestedResolutio'n No.'
- SER,,Section; Page 3-107, Editorial suggestion in the first sentence.
Revise the sentence to read:
Section The staff finds the applicant's response to B2.1.27-2 3.0.3.2.18, acceptable because the applicant has revised the AMP to add 46 fifth pressure retaining bolts to the ASME Section Xl, Subsection paragraph IWE AMP te-the list of in-scope components.
Page 3-109, Revise the third sentence to be consistent Revise the sentence to read:
Section with the LRA and identify the structural The staff also notes that the applicant committed (Commitment 3.0.3.2.18, components whose aging is managed by No. 29) to ongoing implementation of the existing ASME 47 UFSAR the IWE AMP.
Section Xl, Subsection IWE Program for managing aging of the Supplement steel liner of the concrete containment building eeOeierte paragraph i1mcn:
nd p,, t ten.ioning system during the period of extended operation.
Page 3-1.13, Clarify the first sentence to indicate that Revise the sentence to read:
Section non-safety related structures are included By letter dated May 21, 2010, the applicant supplemented its 3.0.3.2.20, in Commitment No. 34.
response to RAI B2.1.32-1 to align the inspection frequencies last sf**.fo.
d st*r*uct.ure. s (structurFe within r*imary 48 paragraph on G"aif.meR.) with the guidance in ACI 349.3R, except for the page exterior surfaces of non-safety-related structures, for which the applicant maintained a ten-year inspection interval.
(Commitment No. 34) For non saft,* rolatcd structures thh appli*c* #
- aintained a tcn yea inpction,le,
! for cl cr.9 s&*4aGes, 12
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 ComntJPaeNo. andI No.
dSE.SecionCommen Suggestedl Resolution Page 3-115, Section 3.0.3.2.20, Enhancement paragraph Expand the description of the Enhancement paragraph to incorporate Commitment No. 34 in LRA Amendment 15 and SER Appendix A for the enhancement to the Structures Monitoring Program for inspection frequencies.
Revise the paragraph to read:
LRA Section B2.1.32 identifies an enhancement to "detection of aging effects" to specify ACI 349.3R-96 as the reference for qualification of personnel to inspect structures under the Structures Monitoring Program. The staff found this enhancement acceptable because when implemented the LRA Structures Monitoring Program will be consistent with the GALL Report Structures Monitoring Program relative to inspector qualifications being commensurate with industry codes, standards and guidelines to help provide assurance that the effects of aging will be adequately managed. The applicant also committed to aligqn inspection frequencies with the-guidance in ACI 349.3R, except for the exterior surfaces of non-safety-related structures, for which the applicant maintained a ten-year inspection interval. The staff reviewed 49 the applicant's supplemental responses and found them acceptable, because for safety-related structures the applicant has aligned the inspection frequency with the recommended guidance in ACI 349.3R. Further, the staff finds the ten-year inspection frequency acceptable for the non-safety-related structures exposed to an external environment, because the structure ex o
e bec..
site has a relatively benign environment. The applicant also committed to quantify the acceptance criteria and critical parameters for monitoring degradation, and to provide guidance for identifying unacceptable conditions requiring further technical evaluation or corrective action. Procedures will also be enhanced to incorporate applicable industry codes.
standards and guidelines for acceptance criteria. The staff reviewed the applicant's supplemental response and found it acceptable because the applicant committed to enhance the Structures Monitoring Program to include the acceptance criteria discussed in the GALL Report Structures Monitorina Program.
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Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comment.PageNo.,and C*
tment d
Sues Resolutin' No..
.1-SER, ection.
Page 3-117, Expand the description in the UFSAR Revise the paragraph to read:
Section supplement paragraph to incorporate In LRA Section A1.32, the applicant provided the UFSAR 3.0.3.2.20 Commitment No. 34 in LRA Amendment supplement for the Structures Monitoring Program. The staff 15 and SER Appendix A for the reviewed this UFSAR supplement section and notes that it enhancement to the Structures Monitoring conforms to the recommended description for this type of Program for inspection frequencies.
program as described in SRP-LR Table 3.5-2. The staff also notes that the applicant committed (Commitment No. 34) to enhance the Structures Monitoring Program prior to entering the period of extended operation. Specifically, the applicant committed to specify ACI 349.3R-96 as the reference for 50 qualification of personnel to inspect structures under the Structures Monitoring Program. The applicant also committed to align inspection frequencies with the guidance in ACI 349.3R. except for the exterior surfaces of non-safety-related structures, for which the applicant maintained a ten-year inspection interval. The Structures Monitoring Program will be enhanced to quantify the acceptance criteria and critical parameters for monitoring degradation, and to provide guidance for identifying unacceptable conditions requiring further technical evaluation or corrective action. Procedures will also be enhanced to incorporate applicable industry codes, standards and guidelines for acceptance criteria.
Page 3-121, Revise wording of the fifth sentence to be Revise the sentence to read:
Section consistent with Commitment No. 56.
The applicant further committed (Commitment No. 56) to 3.0.3.2.21, develop a repair plan for the spray pond wall degradation and UFSAR to implement the repairs beginning in 2011 and endig Supplement expected to be completed by 2015.
paragraph 14
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Com men't Page, No. and No. SERSecionCom ment'
&<:~
SugstdRsolution Page 3-125, Revise the first sentence to delete the Revise the sentence to read:
Section reference to Green's function to be During its audit, the staff reviewed the applicant's program 3.0.3.2.22 consistent with the following text from basis document and noted that the FatiguePr-e FatiquePro third page two of RIS 2008-30: "The Green's software, utilizes a &eeR'e one dimensional stress-intensity 52 paragraph (or influence) function methodology is not transfer function to calculate the fatigue effects of transient in question. The concern involves an cycles used by the Metal Fatigue of Reactor Coolant Pressure input in which only one value of stress is Boundary Program.
used for the evaluation of the actual plant transients".
Page 3-138, (1) Replace SCC with PWSCC to be Revise the first paragraph and add a second paragraph as Section consistent with the LRA and GALL.
follows:
3.0.3.3.1, (2) As noted in the LRA; add a paragraph Preventive Actions. LRA Section B2.1.34 states that several first to identify water chemistry AMP as a techniques are available to mitigate cracking due to SGG paragraph of "preventive action."
PWSCC. These techniques remove one or more of the "Preventive conditions necessary to cause cracking (i.e., susceptible Actions" material, tensile stress, specific environment). A specific list of components and potential preventive actions is provided.
LRA Section B2.1.34 also states that the Water Chemistry program (B2.1.2) provides preventative actions for monitoring and control of the supporting environment for PWSCC.
Page 3-138, Replace "stress corrosion cracking" with Parameters Monitored or Inspected. LRA Section B2.1.34 Section "PWSCC" to be consistent with LRA and states that the program monitors for cracking due to stress 3.0.3.3.1, GALL.
crr.....
cracking PWSCC through a combination of visual, 54 first surface, and volumetric exams. These exams directly detect paragraph of cracking or detect the presence of boric acid which may be "Parameter deposited on visible surfaces as a result of a through-wall Monitored..."
crack.
15
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comen Pae o. ndCommenit Suggested; Resolution' No`.
SER'Section Page 3-139, Replace "stress corrosion cracking" with Detection of A'uing Effects. LRA Section B2.1.34 states that Section "PWSCC" to be consistent with the LRA visual, surface, and volumetric exams are used to detect 3.0.3.3.1, and GALL.
cracking due to stress corroSion crcPking PWSCC in alloy 600 first components.' In this element the applicant also provides a list 55 paragraph of of components to be inspected, the inspection methods to be "Detection of used and reference to the document containing the inspection Aging requirement (CFR, ASME Code, ASME Code Case). These Effect..."
documents contain procedures for conducting the inspection as well as allowable inspection intervals.
Page 3-145, Revise the title of LRA Table 3. 1.1 to be Revise the sentence to read:
Section 3.1.1, "Summary of Aging Management LRA Table 3.1.1, "Summary of Aging Management Prgrms first Evaluations in Chapter IV of.NUREG-Evaluations for the Rcactor CoolaRt System Evaluatod in paragraph, 1801 for Reactor Vessel, Internals, and Chapter IV of NUREG-1801 [IG,-L-RepeF-for the Reactor 56 second Reactor Coolant System" to be consistent Vessel, Internals, and Reactor Coolant System" is a summary sentence with the LRA.
comparison of the applicant's AMRs with those evaluated in the GALL Report for the reactor vessel, reactor vessel internals, and reactor coolant system components and component groups.
Page 3-155, Revise the "AMP in LRA, Supplements, or Revise the "AMP in LRA, Supplements, or Amendments" Table 3.1.1-Amendments" column for item 3.1.1-36 to column for item 3.1.1-36 to read as follows:
36 read: 'Water Chemistry, One-Time "Water Chemistry, One-Time Inspection and ReactoriCoolant Inspection and Reactor Coolant Supplement."
57 Supplement" to be consistent with the amended Reactor Coolant Supplement in the LRA Amendment 13 and Commitment 23 Amendment 15 in SER Appendix A, Table A, Item 23.
16
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comment: *-Page6Nbo. and!-.-
No.SER: Section.'
Com'ment Sýugge sted ýRe6solution41 Page 3-166, Thestyle of "3.1.1.1," "3.1.1.2," and Replace "3.1.1.1," "3.1.1.2," and "3.1.1.4" with "3.1.1.01,"
Section "3.1.1.4" is not consistent with the Table "3.1.1.02," and "3.1.1.04."
3.1.2.1.1, 3.1.1 item numbers in LRA.
Similarly, replace "3.1.1.5" in page 171 with "3.1.1.05."
58 first and second paragraph Page 3-182, LRA Section 3.1.2.2.13 does not address Delete "and low alloy steel with nickel alloy cladding" following Section components with low alloy steel with "nickel alloy."
paragraph Delete this item - SRP & GALL table 3.1.1.31 addresses steel with nickel alloy cladding.
Page 3-193, Delete the line above the title of Section Delete the following line:
60 above the title 3.2.1.it is not applicable to Palo-Verde.
- 5. R*a*,t*
Building l,, lat,., Syt*tm (Subsection 2.3.2.5).
of 3.2.1.
Page 3-208, Delete "steel encapsulation components Revise the last sentence to read:
- bottom of the exposed to" following "no in-scope" to be The staff reviewed the applicant's UFSAR and confirmed that page consistent with the LRA and Palo Verde no in-scope steel encapsulation c*omepents exposed to cast 61 UFSAR.
austenitic stainless steel piping, piping components, and piping elements exposed to treated borated greater than 250 degrees C (greater than 482 degrees F) are present in these-ystems
- _and, therefore, finds the applicant's determination acceptable.
17
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 ComentPae N. ad omment Suggeted Resolution.-
NO.
.,SER'Se'ction Page 3-221, Page 3-221, fourth paragraph Revise the sentence to read:
fourth "By letter dated July 21, 2010, the "By letter dated July 21-30, 2010, the applicant submitted paragraph, applicant submitted confirmatory confirmatory information that the affected piping is jacketed Section information that the affected piping is with overlapping seams such the moisture intrusion is not a 62 3.2.2.3.4 jacketed with overlapping seams such the concern."
moisture intrusion is not a concern."
The confirmatory information was submitted by letter dated July 30, 2010.
Page 3-336, Revise the first sentence to delete the Revise the sentence to read:
Section reference to the moisture barrier. There The staff verified that the containment concrete is monitored for 63 3.5.2.2.1, is no moisture barrier in the Palo Verde cracks by the IWL AMP, th m,-eniSt barricr i, ;u..c.
to Last Containment.
inpecton in.
accrdance with IWE=.. quiF.mcnt, and that paragraph water ponding is not common on the containment floor.
Page 3-336, Revise the third sentence to include Revise the sentence to read:
Section references to other applicable SER The staffs reviews of the applicant's Structures Monitoring 3.5.2.2.1, sections.
Program, ASME Section Xl, Subsection IWE Program, and 64 Element (4),
Appendix J Program is-are documented in SER Sections last 3.0.3.2.20, 3.0.3.2.18, and 3.0.3.1.12, respectively.
paragraph on page Page 3-347, Correct the typographical error in the Revise sentence to read:
Section second sentence (incorrect quotation The staff noted that inspections of Group 6 structures are 65 3.5.2.2.2, mark).
performed under the Structures Monitoring Program that is Element (4)(c) consistent with and integrates the elements of RG 1.127,"
"Inspection of Water-Control Structures Associated with Nuclear Power Plants Program."
18
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 ComentPag NoMan Suggestedý Resolution No.
SER SectionCmmn Page 3-347, Correct the typographical error in the Revise the sentence to read:
Section second sentence (incorrect quotation The staff noted that inspections of Group 6 structures are 66 3.5.2.2.2, mark).,
performed under the Structures Monitoring Program that is Element (4)(c) consistent with and integrates the elements of RG 1.127,"
"Inspection of Water-Control Structures Associated with Nuclear Power Plants Program."
Page 3-350, Delete first and second paragraphs. They Section 3.5.2.3.1, first and second paragraphs:
Section refer to cementitious fire barriers, which In, LRA Tables 3.5.2 1, 3.5.2 2, and 3.5.-2 5, the applicant 3.5.2.3.1, are not credited in the containment stated that.ementitious f.. barrieFr catings and wrap.
first and building. Move this discussion to expocnnd t-air indoo*r u..O.trl..
d (oer*nal) a. o bei*g second 3.5.2.3.2.
af R
l-,- o f m..,
r,,
, and cr.cking b, the Fire paragraphs Preteet-e Program. The AMR ;n G48 g*
te idctgthtnierthe compoenet nr9 the mnateria;l ;And A.*oe-ntecmipnation is evalu ated in the GALL Report. T-e
~staff rcvimwd ;11 A MR rosult Iines YR the GALL Report-,w-the component and m"aterial iS m
.tifie.s coatig fire barriers or wraps and confirm*ed that there are no) entries for this component or materal where the aging effect is loss material due to cracking.
67 The staff reviewed the applicGat's Fire Protect*io Program and its evaluation is documnente-d in SER Sec-tionR 3-0-3.2.7. The staff noted that te alint's Fire Pro.tectin Prgram provides for visual inspectiGnR f 4re barriesf onco ever' 18 months for detecto Of cracking and less of material. The staff also noted that the Fire Protection Proram d f ethe
.... r,
- e~si....
G-RG.et -walls, floor., and ceilings, a rd that cemnentitiGus fie barrier coatings have similar aging effects to concrete. The staff finds the applicsant's proposal to mnanage agig uingthe Fir~e Protection Programn acceptable because the programn performns visual inspectfions of fire barrier-s that are capable of detecting loss of mnaterial for cementitious fire barrier coatings and wraps-.
19
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 C omment Page No'.' andComn No.CERmSctio Suggested Resolution' Page 3-350, Revise the first sentence to add a Revise the sentence to read:
Section reference to LRA Table 3.5.2-7 for In LRA Tables 3.5.2-1, and 3.5.2-2, and 3.5.2-7, the applicant 68 3.5.2.3.1, discussion of ceramic fiber and thermo-stated that ceramic fiber and thermo-lag fire barrier seals third lag fire barriers.
exposed to air - indoor uncontrolled (external) are being paragraph managed for loss of material and cracking by the Fire Protection Program.
20
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comment.Page.No.-and.Comment
- Suggested Resolution No.
I SER,,Sectionh Page 3-351, Replace first paragraph with discussion of Revise the first paragraph to read:
Section cementitious fire barriers. (See. comment The staff.s cvaluation for c.
.mc.ntiti9u. coating fic barrier 3.5.2.3.2, for page 3-350, Section 3.5.2.3.1 above),
coatings and wrap. expo. d to air indoor uncontrolled first (extercnal). with aging cffccts of loss of mnatcrial and cracking paragraph maag.d by the Fi-r P-rotccton PrFog*ra, with genc.ic note *,
is, doc*u.entcd in SER Sectio'R 3.5.2.3.41 In LRA Tables 3.5.2-2, 3.5.2-4, and 3.5.2-5, the applicant stated that cementitious fire barrier coatings and wraps exposed to air - indoor uncontrolled (external) are being managed for loss of material and cracking by the Fire Protection Program. The AMR items cite generic note J, indicating that neither the component nor the material and environment combination is evaluated in the GALL Report. The staff reviewed all AMR result lines in the GALL Report where the component and material is cementitious coating fire 69 "barriers or wraps and confirmed that there are no entries for 69" this component or material where the aging effect is loss of material due to cracking.
The staff reviewed the applicant's Fire Protection Program and its evaluation is documented in SER Section 3.0.3.2.7. The staff noted that the applicant's Fire Protection Program provides for visual inspection of fire barriers once every 18 months for detection of cracking and loss of material. The staff also noted that the Fire Protection Program is used for other fire barriers including concrete walls, floors, and ceilings, and that cementitious fire barrier coatings have similar aging effects to concrete. The staff finds the applicant's proposal to manage aging using the Fire Protection Program acceptable because the program -performs visual inspections of fire barriers that are capable of detecting loss of material for cementitious fire barrier coatings and wraps.
21
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3
ýCom'ment
-Page, No. and No.
ER SctioComent S ugg"ested Resolution Page 3-352, Change reference from 3.5.2.3.1 to Revise the paragraph to read as follows:
Section 3.5.2.3.2. (See comment for page 3-350 The staffs evaluation for cementitious coating fire barrier 70 3.5.2.3.4 section 3.5.2.3.1 above) coatings and wraps exposed to air-indoor uncontrolled (external) with aging effects of loss of material and cracking managed by the Fire Protection Program, with generic note J, is documented in SER Section 3-5.2-.3.-3.5.2.3.2.
Page 3-352, Change reference from 3.5.2.3.1 to Revise the paragraph to read as follows:
Section 3.5.2.3.2. (See comment for page 3-350 The staffs evaluation for cementitious coating fire barrier 3.5.2.3.5, section 3.5.2.3.1 above) coatings and wraps exposed to air-indoor uncontrolled 71 first (external) with aging effects of loss of material and cracking paragraph managed by the Fire Protection Program, with generic note J, is documented in SER Section 3.5.2.3.1 3.5.2.3.2.
Page 3-352, Replace first paragraph with reference to Revise the paragraph to read:
Section 3.5.2.3.1 for discussion of ceramic fiber In LRA Table 3.5.2 7, the applicant stated that therM. lag fir, 3.5.2.3.7, and thermo-lag barriers.
barrier seals e.. Fnally exposed to plant indoo air a.. being first managed for lo,, of material and cracking by the Fi,,
72 paragraph Protection Program. Tho staff's e*aluation ca*
be found in Section 3.0.3.2.7. The staff's evaluation for ceramic fiber and thermo-laq fire barrier seals exposed to air - indoor uncontrolled (external) with aging effects of loss of rmi-aterial and cracking managed by the Fire Protection Program With generic note J, is documented in SER Section 3.5.2.3.1.
Page 3-354, SER section 3.5.2.3.11 was truncated Revise section 3.5.2.3.11 to read:
Section and combined with 3.5.2.3.12.
The staff reviewed LRA Tables 3.5.2-11, which summarize the 3.5.2.3.11 Insert text to complete 3.5.2.3.11.
results of AMR evaluations for the tank foundations and shells component groups. The staff's review did not identify any items 73 with notes F through J. indicating that the combinations of component type, material, environment, and AERM for this system are consistent with the GALL Report.
SER Section 3.0.2.2 documents the staff's evaluation of the items with Notes A through E.
22
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1,2, and 3 C6mment' Page No.,and*
No..
SER Section Comment S~uggested Resolution Page 3-354, Insert paragraph break before 3.5.2.3.12 Revise section 3.5.2.3.12 as follows:
Section and the introduction for the first sentence.
3.5.2.3.12 (See comment for page 3-354 section 3.5.2.3.12 Transformer Foundations and Electrical Structures -
3.5.2.3.11).
Summary of Agqing Management Review - LRA Table 3.5.2-12 74 The staff reviewed LRA Tables 3.5.2-12, which summarize the results of AMR evaluations for the transformer foundations and electrical structures component groups. The staffs review did not identify any items with notes F through J, indicating thatthe combinations of component type, material, environment, and AERM for this system are consistent with the GALL Report.
Page. 3-359, Revise the "staff evaluation" column to Revise the "staff evaluation" column to read:
Table 3.6-1, read: a different AMP is credited.
Consistent with GALL for material, environment, aging effect, line 3.6.1-10 but a different AMP is Gredit credited (See Section 3.6.2.1.2).
Page. 3-365, Revise the last sentence of the second Revise the last sentence of the second paragraph of the Section paragraph of the quotation from LRA quotation to read:
76 3.6.2.2.3, Section 3.6.2.2.3 to read "...withstand The NESC also sets the maximum tension a conductor must under medium load requirements..." to be be designed to withstand heavy medium load requirements, consistent with the LRA.
which includes consideration of ice, wind, and temperature.
Page 4-28, Revise the first sentence to delete the Revise the sentence to read:
Section reference to Green's function to be In Regulatory Information Summary (RIS) 2008-30, the staff 4.3.1.2.2, consistent with the following text from raised technical concerns related to the conservatism of using last page two of RIS 2008-30: "The Green's one-dimensional stress (GFer- ' function) models for the 77 paragraph (or influence) function methodology is not evaluation of environmentally-assisted fatigue in limiting in question. The concern involves an environmentally-assisted fatigue locations.
input in which only one value of stress is used for the evaluation of the actual plant transients".
23
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Comment Page No. and CmetSgetdRslto No.
SER SectionComnSugse.Roltn Page 4-29, As written the second item could be Revise the second item to read:
Section-construed as-precluding use of future The amended basis does not credit FatigUePF FatiquePro 4.3.1.2.2,-,
versions of FatiguePro. Future versions Version 3.0 (which uses a one-dimensional stress-intensity second item of FatiguePro may incorporate sixr-..
term in lieu of a 6-element stress tensor) as the software basis 78 in list at.
element stress tensor software modeling, for SBF monitoring and instead addresses the need to bottom of Revise the second item to reference the implement a SBF monitoring software program and page current version of FatiguePro.
methodology that complies with the requirements in the ASME Code Section III, and conforms to the technical recommendations in RIS 2008-30 Page.4-30, Revise-the first sentence of the second--
Revise the sentence to read:
Section paragraph to identify the OBE is 0.10g.to The applicant states that for design purposes, the safe-79 4.3.1.3.1, be consistent with LRA section 4.3.1.3 shutdown earthquake (SSE) is based on a 0.20 gravity (g) second and Palo Verde UFSAR section 3.7.-
ground-motion stress, and the operating-basis earthquake paragraph (OBE) is based on a 045g qj10 ground motion stress.
Page 4-43, Revise, the last sentence delete the Revise the sentences to read:
Section reference to Table 4.3-7 footnote 4 and The fatigue analysis of the bottom head support skirt is, 4.3.2.4.2, change the disposition for the pressurizer. therefore, a TLAA, contrary to footnoto 4 of LRA, Table 4.3 7,
- fourth.
supportskirtto 10 CFR54.21(c)(1)(iii).
and is managed in accordance with 10 CF-5'1,21(,)(1....) 10 paragraph Footnote 4 has never been applied to CFR 54.21 (c)(1)(iii). The applicant states that for the purposes 80 Table 4.3-7 item 1. LRA section 4.3.2.4 of evaluating actual earthquake events, an SSE is defined as notes that the enhanced metal fatigue an earthquake that results in a categorization of 8 on-a Mercalli AMP will monitor the transient cycles for intensity scale -7 (i.e., that results in ground-motion ranging the pressurizer support skirt. Also revise stresses ranging from 0.15g to 0.33g) and that an OBE is the typographical error in the second defined as an earthquake that results in a categorization of 7 sentence (delete extra 7) on a Mercalli intensity scale (i.e., that results in ground-motion
_stresses ranging from 0.072g to 0.15g).
24
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3
~~_Comment PaeN.
ntSu-ggesteid Resoluti'on
'-No:-.
S-ER'Section.omme Page 4-53 Replace the SBF monitoring discussion.
In the Charging lines and nozzles section starting on page 4-thru 54, with a CBF-EP monitoring discussion.
53, replace the SBF monitoring discussion with a CBF-EP Section Charging lines and nozzles usage monitoring discussion.
81' 4.3.2.7.2, monitoring was revised in LRA Charging Amendment 16 to use CBF-EP Lines and monitoring.
Nozzles Section Page 4-64, Revise the second paragraph to be Revise the second paragraph to read:
Section consistent-with-LRA Amendment _16.
The applicant stated that the surge line elbow will be-is subject 4.3.2.9.2, to stress-based fatigue monitoring under the enhanced Metal Power Uprate Fatigue of Reactor Coolant Pressure Boundary program
- Section, (B3.1). The program maiRitcas will maintain a record of the second wcFst cGase CUF cumulative usage factor. This record will be 82 paragraph reviewed and evaluated at intervals specified by the program, at a frequency sufficient to ensure that appropriate corrective action is will be initiated if an action limit is reached. Action limits will be established to permit completion of corrective actions before the code limit is exceeded. The effects of fatigue in the Class 1 surge line will thereby be managed for the period of extended operation, in accordance with 10 CFR 54.21 (c)(1)(iii).
Page 4-68, Revise the second sentence to reference Revise the sentence to read:
Section LRA section 4.3.4 (Effects of the Reactor In this LRA Amendment, the applicant submitted its conforming 83 4.3.4.2, Coolant System Environment on Fatigue changes to LRA Section 4-3 4.3.4 to address staff concerns first Life of Piping and Components) to be regarding these sections that were discussed with the applicant paragraph consistent with staff evaluation provided in a public meeting dated May 6, 2010.
in this section.
25
Enclosure Arizona Public Service Company Comments on the Safety Evaluation Report With Open Items related to the License Renewal of PVNGS Units 1, 2, and 3 Com~ment Page No. and SgetdRslto No.
SER Section CmetSgetdRslto Page 4-71, Correct typographical errors in the first Revise the sentences to read:
Section and second sentence.
For the implicit fatigue analyses for the reactor coolant hot leg 4.3.5.1, sampling lines and the SG downcomer and feedwater second recirculation lines, the applicant states that the analyses have paragraph been projected through the end of the period of extended operation in accordance with the TLAA acceptance criteria in 10 CFR 54.21(c)(1 )(ii). For these implicit fatigue analyses, the 84, applicant states that the total number of full thermal range traeieoR transients that are applicable to the lines are projected to be in excess of 7000 cycle occurrences,:.and that for these components that applicable stress reduction factors were applied to maximum allowable stress limit criteria for the analyses in order to demonstrate that the existing stress loadings on the components would still be acceptable for the period of extended operation even under the reduced acceptance limit criteria for the analyses.
Page 4-72, Correct typographical errors in the first Revise the sentences to read:
Section and second sentence.
... Count for Allowable Secondary Stress Range Reduction 4.3.5.2, Faete Factor in ANSI B31.1 and AMSE III Class 2 and 3 paragraph at Piping. The applicant identified all implicit fatigue analyses for 85 the top of the ANSI B31.1 and ASME Class 2 and 3 piping components will page.
be remain valid for the period of extended operation except for the implicit fatigue analysis of reactor coolant system hot leg sampling lines and the recirculating SG downcomer and feedwater recirculation lines.
26