ML103280058
| ML103280058 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 11/10/2010 |
| From: | Hesser J Arizona Public Service Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 102-06279-JHH/GAM | |
| Download: ML103280058 (49) | |
Text
ZýA LI 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 102-06279-JHH/GAM November 10, 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 Draft Request for Additional Information for the Review of the PVNGS License Renewal Application (LRA), and LRA Amendment No. 26 In a conference call on October 28, 2010, the NRC staff discussed with APS a draft follow-up RAI B2.1.18-1 regarding buried piping inspections related to the PVNGS license renewal application (LRA). Enclosure 1 contains APS's responses to the draft RAIs. contains LRA Amendment No. 26 to reflect the following changes:
" Revised LRA Section 3.1.2.1.4, Tables 3.1.1 and 3.1.2-4, and Sections A1.8 and B2.1.8, to correct the aging effect for Steam Generator tubes to be consistent with Generic Aging Lessons Learned (GALL) Report line IV.D1-19.
Updated LRA Sections Al.10 and B2.1.10, and Commitment No. 12 in Table A4-1, to reflect the completion of the enhancement to the Closed-Cycle Cooling Water System aging management program.
" Revised LRA Sections A1.18 and B2.1 18, and Commitment No. 20 in Table A4-1, to specify that one of the cathodically-protected steel piping inspections will be performed on the diesel generator fuel oil piping. This is also discussed in the response to draft follow-up RAI B2.1.18-1 in Enclosure.1.
Clarified Commitment No. 34 in Table A4-1 to provide examples of industry codes, standards, and guidelines to be consistent with the APS Response to Follow-up RAI B2.1.32-2 in letter no. 102-06194, dated May 21, 2010.
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway Comanche Peak
- Diablo Canyon - Palo Verde - San Onofre
- South Texas
- Wolf Creek Ai
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to Draft Request for Additional Information for the Review of the PVNGS License Renewal Application (LRA), and LRA Amendment No. 26 Page 2 Updated Commitment No. 51 in Table A4-1 to reflect the completion of the reactor head replacement in all three PVNGS units.
" Updated Commitment No. 54 in Table A4-1 to reflect the completion of draining the abandoned spray chemical addition tanks in all three PVNGS units. contains an updated listing of the LRA Table A4-1 commitments reflecting all LRA amendments to date.
Should you need further information regarding this submittal, please contact Glenn Michael, Licensing Engineer for License Renewal, at (623) 393-5750.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on 11 i1o/1o (date)
Sir cerely, J HH/RAS/GAM/gat
Enclosures:
- 1.
Response to Draft Request for Additional Information for the Review of the PVNGS License Renewal Application
- 2.
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 26
- 3.
Updated Listing of the PVNGS License Renewal Application Table A4-1 Commitments cc:
E. E. Collins Jr.
NRC Region IV Regional Administrator J. R. Hall NRC NRR Senior Project Manager L. K. Gibson NRC NRR Project Manager J. H. Bashore NRC Senior Resident Inspector (acting) for PVNGS L. M. Regner NRC License Renewal Project Manager G. A. Pick NRC Region IV (electronic)
ENCLOSURE I Response to Draft Request for Additional Information for the Review of the PVNGS License Renewal Application Response to Draft Request for Additional Information for the Review of the PVNGS License Renewal Application NRC Draft Follow-up RAI B2.1.18-1
- 1.
Justify why the inspections of in-scope diesel fuel oil piping, discussed in a letter from APS dated October 13, 2010, is not included in the Updated Final Safety Analysis Report Supplement, Appendix A of the LRA?
- 2.
How many feet of in-scope buried fuel oil piping is located at each unit? How many feet of in-scope buried diesel fuel oil piping is not under concrete or asphalt?
- 3.
Justify how aging of underground buried fuel oil piping will be managed in the 30 -
40 year, 40 - 50 year, and 50 - 60 year license renewal periods?
APS Response to Draft Follow-up RAI B2.1.18-1 Response (1)
Response (2) to Follow-up RAI 82.1.18-1 in letter no. 102-06263, dated October 13, 2010, stated that as part of APS's participation in the Nuclear Energy Institute (NEI) 09-14 buried piping integrity initiative, a 10-foot section of diesel generator fuel oil piping at one of the three PVNGS units will be excavated and inspected prior to 2015. LRA Sections Al.18 and B2.1.18, and Commitment No. 20 in Table A4-1 have been revised, as shown in Enclosure 2, to include this inspection to be performed between January 1, 2012 and December 31, 2015.
Response (2)
Subsequent to submitting letter no. 102-06263, dated October 13, 2010, a more detailed estimate of the buried diesel generator fuel oil piping length was performed based on a review of underground utility drawings and a plant walk down. The following buried diesel generator fuel oil piping lengths are estimated (all values are approximate):
1697 feet of in-scope buried diesel generator fuel oil system piping in all three units.
0 633 feet in Unit 1.
637 feet in Unit 2.
- 427 feet in Unit 3.
95% of the in-scope buried diesel generator fuel oil system piping is under asphalt or concrete (65% [1112 feet] is under asphalt and the remaining 30%
[503 feet] is under reinforced concrete) 1 Response to Draft Request for Additional Information for the Review of the PVNGS License Renewal Application 5% (82 feet) of the in-scope buried diesel generator fuel oil system piping is not under concrete or asphalt.
22 feet of 21/22 inch pipe and 40 feet of 2 inch pipe in Unit 1.
None in Unit 2 (all piping under concrete or asphalt).
0 9 feet of 21/2 inch pipe and 11 feet of 2 inch pipe in Unit 3.
Response (3)
LRA Sections Al.18 and B2.1.18, and Commitment No. 20 in Table A4-1 have been revised, as shown in Enclosure 2, to specify that in one of the units, at least one of the two cathodically-protected steel piping inspections will be performed on diesel generator fuel oil piping. The initial diesel generator fuel oil piping inspection will be performed between January 1,2012 and December 31, 2015, which is intended to accommodate aging management of the underground buried fuel oil piping for the 30 - 40 year period (e.g., 2015 - 2025 for Unit 1). Aging of underground buried fuel oil piping will be managed in the 40 - 50 year, and 50 - 60 year license renewal periods by the commitment to perform at least one of the two cathodically-protected steel piping inspections in one unit in each of these periods on diesel generator fuel oil piping.
2
ENCLOSURE 2 Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 26 LRA Section Page No.
3.1.2.1.4 3.1-6 Table 3.1.1 3.1-37 Table 3.1.2-4 3.1-92 A1.8 A-5 A1.10 A-6 A1.18 A-9, 10 Table A4-1, Item 12 A-44 Table A4-1, Item 20 A-47 Table A4-1, Item 34 A-54 Table A4-1, Item 51 A-58 Table A4-1, Item 54 A-58 B2.1.8 B-28, 29, 30 B2.1.10 B-34,35, 36, 37, 38 B2.1.18 B-52,53, 54
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Revision to correct the aging effect for Steam Generator tubes to be consistent with GALL line IV.D1-19 Section 3.1.2.1.4, Steam Generators (page 3.1-6) is revised as follows (deleted text show with strikethrough)
Aging Effects Requiring Management The following steam generator aging effects require management:
Cracking Cumulative fatigue damage Loss of material Loss of preload Wall Thinning
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Revision to correct the aging effect for Steam Generator tubes to be consistent with GALL line IV.D1 -19 Table 3.1.1, Summary of Aging Management Evaluations in Chapter IV of NUREG-1801 for Reactor Vessel, Internals, and Reactor Coolant System, (page 3.1-37) is revised as follows (new text underlined and deleted text shown with strikethrough)
Table 3.1.1 Summary of Aging Management Evaluations in Chapter VII of NUREG-1801 for Auxiliary Systems (Continued)
Item:%
Component Type
.,Aging Effect / Mechanism Aging Management Further Discussion Number Program
'Evaluation
___________________Recommended 3.1.1.79 Nickel alloy steam Denting due to corrosion of Steam Generator Tube No Consistent with NUREG generator tubes steel tube support plate Integrity (B2.1.8); Water 1-80-1Not applicable. Palo exposed to secondary Chemistry (B2.1.2) and, for Verde does not have a feedwater/steam plants that could experience carbon steel tube support denting at the upper supports, system so denting is not an evaluate potential for rapidly applicable aging effect. The 1propagating cracks and then Palo Verde steam generator
!develop and take corrective tube support system is actions consistent with fabricated from 409 ferritic I Bulletin 88-02 stainless steel.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Revision to correct the aging effect for Steam Generator tubes to be consistent with GALL line IV.D1 -19 Table 3.1.2-4, Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Steam Generators, (page 3.1-92) is revised as follows (deleted text shown strikethrough and new text underlined)
Table 3.1.2-4 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation - Steam Generators Component Intended Material Environment Aging Effect Aging Management NUREG-,Table 1 Item Notes Type "Function
-.Requiring Program V1801Vol.,
I.-
.j,!
-Management
__2 Item SG Tubes
,*,T, -P N4Gkel-AIIy& S*c ady Wator tig Steam Gcneretor Tube 4VLD4--9 3.1.7 A
{E-)
integrity (B2. 1.8) dnd I
I
~WaeF ~GheR4is"y
Appendix A Updated Final Safety Analysis Report Supplement A1.8 STEAM GENERATOR TUBE INTEGRITY The Steam Generator Tube Integrity program includes the preventive measures, condition monitoring inspections, degradation assessment, repair and leakage monitoring activities necessary to manage cracking, deRtR, wall thinning, and loss of material. The aging management measures employed include: non-destructive examination, visual inspection, sludge removal, tube plugging, in-situ pressure testing, maintaining the chemistry environment by removal of impurities, and addition of chemicals to control pH and oxygen.
NDE inspection scope and frequency, and primary to secondary leak rate monitoring are conducted consistent with the requirements of the PVNGS Units 1, 2, and 3 Technical Specifications. PVNGS evaluates tube integrity in accordance with the structural integrity performance criteria specified in Technical Specifications which encompasses and exceeds the requirements of Regulatory Guide 1.121. In addition, Technical Specifications include accident induced leakage performance criterion and operational leakage performance criterion. The PVNGS steam generator management practices are consistent with NEI 97-06, "Steam Generator Program Guidelines".
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-5
Appendix A Updated Final Safety Analysis Report Supplement A1.10 CLOSED CYCLE COOLING WATER SYSTEM The Closed-Cycle Cooling Water System program manages loss of material, cracking, and reduction in heat transfer for components in closed cycle cooling water systems. The program includes maintenance of system corrosion inhibitor concentrations and chemistry parameters following the guidance of EPRI TR-107396 to minimize aging, and periodic testing and inspections to evaluate system and component performance. Inspection methods include visual, ultrasonic testing and eddy current testing.
Prior to th9 perioed of oxtondod operation, procGedueres will be enhanced to inorGGpoate the guidance of EPRI TR 1107-396 with Focpect to wate~r cheM~i~tr,' conrol for frequency of sampling and analysis, nor.mal operating imitS, action and. ti.me....
fo..r imRpl...emting correctiVe actions u1POn attainment Of action level..
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-6
Appendix A Updated Final Safety Analysis Report Supplement A1.18 BURIED PIPING AND TANKS INSPECTION The Buried Piping and Tanks Inspection program manages loss of material of buried components in the chemical and volume control, condensate storage and transfer, diesel fuel storage and transfer, domestic water, fire protection, SBOG fuel system, service gas and essential spray ponds systems. Visual inspections monitor the condition of protective coatings and wrappings found on carbon steel, gray cast iron or ductile iron components and assess the condition of stainless steel components with no protective coatings or wraps. The program includes opportunistic inspection of buried piping and tanks as they are excavated or on a planned basis if opportunistic inspections have not occurred.
The Buried Piping and Tanks Inspection program is a new program that will be implemented prior to the period of extended of operation. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.
Within the ten year period prior to entering the period of extended operation an opportunistic or planned inspection of buried tanks at the Palo Verde site will be performed.
The visual inspections noted below of piping in a soil environment within the scope of license renewal will be conducted within the ten-year period prior to entering the period of extended operation, and during each ten year period after entering the period of extended operation, except the initial diesel generator fuel oil piping inspection will be performed between January 1, 2012 and December 31, 2015. Each inspection will:
select accessible locations where degradation is expected to be high; 0
excavate and visually inspect the circumference of the pipe; and examine at least ten feet of pipe.
- a. Metallic Piping not Cathodically-Protected At least two excavations and visual inspections of stainless steel piping will be conducted in each unit. Stainless steel piping within the scope of license renewal exists in the following systems:
o Chemical and Volume Control (CH),
o Condensate Transfer and Storage (CT), and o
Fire Protection (FP).
- b. Steel Piping Cathodically-Protected At least two excavations and visual inspections of cathodically-protected steel piping will be conducted in each unit. In one of the units, at. least one of these inspections will be' performed on diesel generator fuel oil piping.
- c. Steel Piping with Potentially Degraded Cathodic Protection At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.
Palo Verde Nuclear Generating Station Amendment 26 Page A-9 License Renewal Application
Prior to the period of extended operation, the Buried Piping and Tanks Inspection program will include provisions to (1) ensure electrical power is maintained to the cathodic protection system for in-scope buried piping at least 90% of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE) cathodic protection system surveys are performed at least annually.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-10
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 26 LRA Table A4-1, License Renewal Commitment No. 12 is revised as follows (deleted text shown in strikethrough and new text underlined):
Item Commitment -
LRA Section implementation No.- -
Schedule 12 Existing Closed-Cycle Cooling Water System program is credited for A1.10 Prior to the perid* oe license renewal,-AND B2.1.10 etended operation 4 Prior to the period of extended
,peraton,,
procedures will be enhanced to Closed-Cycle Cooling Ongoing.
in cor.porate the guidance Of EPRI TR 1073.6 with respect to water Water System chemistry control for frequency of sampling and analysis, normal operating fimnits, action level concentrations, and times for im~plem:enting corrective actions upon attaffment of aGctio levels.
(RCTSAI 3246899)
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 26 LRA Table A4-1, License Renewal Commitment No. 20 is revised as follows (new text underlined):
Item' "Commitment I
LRA Section Implementation No.,
j I
Schedule 20 The Buried Piping and Tanks Inspection program is a new program that will be implemented prior to the period of extended operation.
Within the ten year period prior to entering the period of extended operation an opportunistic or planned inspection of buried tanks at the Palo Verde site will be performed.
The visual inspections noted below of piping in a soil environment within the scope of license renewal will be conducted within the ten-year period prior to entering the period of extended operation, and during each ten year period after entering the period of extended operation, except the initial diesel generator fuel oil piping inspection will be performed between January 1, 2012 and December 31, 2015. Each inspection will:
select accessible locations where degradation is expected to be high;
" excavate and visually inspect the circumference of the pipe; and examine at least ten feet of pipe.
- a. Metallic Piping not Cathodically-Protected At least two excavations and visual inspections of stainless steel piping will be conducted in each unit. Stainless steel piping within the scope of license renewal exists in the following systems:
o Chemical and Volume Control (CH).
A1.18 B2.1.18 Buried Piping And Tanks Inspection Perform the buried piping and tanks inspections within the ten year period prior to the period of extended operation1,
except the initial diesel generator fuel oil piping inspection will be performed between 1/1/12 and 12/31/15.
AND Perform the buried piping inspections during each ten year period after entering the period of extended operation.
AND Implement the additional Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-10
Item Commitment LRA Section Implementation No.
Schedule o Condensate Transfer and Storage (CT), and enhancements to the o
Fire Protection (FP).
buried piping and tanks inspection
- b. Steel Piping Cathodically-Protected program prior to the At least two excavations and visual inspections of cathodically-period of operation1.
protected steel piping will be conducted in each unit. In one of the units, at least one of these inspections will be performed on diesel qenerator fuel oil piping.
- c. Steel Piping with Potentially Degraded Cathodic Protection At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.
Prior to the period of extended operation, the Buried Piping and Tanks Inspection program will include provisions to (1) ensure electrical power is maintained to the cathodic protection system for in-scope buried piping at least 90% of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE) cathodic protection system surveys are performed at least annually.
(RCTSAIs 3246909 [Ul]; 3247263 [U2]; 3247264 [U3])
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-10
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 26 LRA Table A4-1, License Renewal Commitment No. 34 is revised as follows (new text underlined):
Item Commitment
.LSection
-Implementation N6.
S-hedule.
34 Existing Structures Monitoring Program is credited for license renewal, AND A1.32 Prior to the Prior to the period of extended operation:
B2.1.32 period of
" The Structures Monitoring Program will be enhanced to specify ACI 349.3R-96 Structures extended as the reference for qualification of personnel to inspect structures under the Monitoring operation1.
Structures Monitoring Program.
Program For structures within the scope of license renewal, the Structures Monitoring Program will be enhanced to establish the frequency of inspection for each unit at a 5 year interval, with the exception of exterior surfaces of the following nonsafety-related structures, below-grade structures, and structures within a controlled interior environment, which will be inspected at an interval of 10 years:
" Fire Pump House (Yard Structures)
Radwaste Building
" Station Blackout Generator Structures
- Turbine Building Non-Safety Related Tank Foundations and Shells
- , Non-Safety Related Transformer Foundations and Electrical Structures 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 (e.Q., ACI 349.3R-96, ANSI/ASCE 11-90, etc.) for acceptance criteria.
(RCTSAI 3246927)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-10
Palo Verde Nuclear Generating Station License Renewal Application Amendment No. 26 LRA Table A4-1, License Renewal Commitment No. 51 is revised as follows (deleted text shown in strikethrough and new text underlined):
Item
-LRA
- Section, Implementation.
No.
Commitment Schedule-:.
51 The original CUnit 3 reactor prsSure vessel (RPV) head is planred to be B2..34 121l s
n 0i rcPlaced during the fall refueling outage in 2010.
All componentS Nickel Alloy Aging penetrating the new heads and welds including the head Vent will be Management Program replaced with Alloy 690. The Unit 2 RPV head was replaced during 2R1 5 outage in fall 2000, and the Unit 1 RPV head was replaed duFi;*g SR! 5 in spring 2010.
Completed (RCTSAI 3410460)
LRA Table A4-1, License Renewal Commitment No. 54 is revised as follows (deleted text shown in strikethrough and new text underlined):
]tem' ~Comrnrftmenht LRA Secttio'n I mplemetation NoW t.-Shedule,.
54 By November 30, 2010, APS will ensure that the abandoned containment APS letter no). 102 1-14/30/i Q spray chemical addition tanks and a~ssocated pipin copoents in 06243, dated 8/27/10 PYNGS Units 1, 2, and 3 are drainedtprcueaystilneatos with safety related comTponents.
___Completed (RCTSAI 3443855)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-10
Appendix B AGING MANAGEMENT PROGRAMS B2.1.8 STEAM GENERATOR TUBE INTEGRITY Program Description The scope of the Steam Generator Tube Integrity program includes the preventive measures, degradation assessment, steam generator inspection, integrity assessment, primary and secondary chemistry controls, leakage monitoring, and required maintenance and repair activities necessary to manage cracking, dentig, wall thinning, and loss of material. The aging management measures employed include, non-destructive examination, visual inspection, sludge removal, tube plugging, in-situ pressure testing and maintaining the chemistry environment by removal of impurities and addition of chemicals to control pH and oxygen. Non-destructive Examination (NDE) inspection scope and frequency, and primary to secondary leak rate monitoring are conducted consistent with the requirements of PVNGS Technical Specifications.
PVNGS evaluates tube integrity in accordance with the structural integrity performance criteria specified in Technical Specifications which encompasses and exceeds the requirements of Regulatory Guide 1.121. In addition, Technical Specifications include accident induced leakage performance criterion and operational leakage performance criterion.
The steam generator management practices are consistent with NEI 97-06, "Steam Generator Program Guidelines".
Guidance for steam generator management is specified in station procedures. This guidance is consistent with the PVNGS Technical Specification requirements for steam generator tube integrity and primary to secondary leakage limits. The PVNGS steam generator inspection frequency is evaluated as part of the Degradation Assessment performed prior to each inservice inspection consistent with the Technical Specification requirements for the observed degradation mechanism. Plugging criteria for removing tubes from service are consistent with Technical Specifications.
Tube support degradation is monitored by the presence of normal support signals at expected tube locations and by visual inspection of the secondary side. The PVNGS steam generator management procedure specifies that steam generators will be visually inspected, as required, on the secondary side at the accessible portions of the following locations: tube sheet region, both hot and cold leg, tube supports, flow distribution plate, and upper steam drum internals.
Aging management activities for steam generator tubing integrity are controlled by station procedures.
The steam generators are also monitored under the Maintenance Rule (10 CFR 50.65) as implemented by station procedures. The Steam Generator Tube Integrity program was developed from and is consistent with NEI 97-06, "Steam Generator Program Guidelines". PVNGS procedural guidance includes performance criteria for tube structural integrity, operational leakage and accident induced leakage that are consistent with NEI 97-06 and the PVNGS Technical Specifications.
Procedural guidelines are also provided for monitoring and maintenance including plugging criteria, plug inspection requirements and inspection requirements for tube supports.
The training and qualification standards for personnel engaged in the acquisition and/or evaluation of steam generator NDE activities are specified in a station administrative procedure, and inspection practices are consistent with EPRI 1013706, "PWR Steam Generator Examination Guidelines".
PVNGS programmatic guidance also requires that each inspection be based on a degradation assessment that considers active, relevant and potential damage mechanisms.
Palo Verde Nuclear Generating Station Amendment 26 Page B-28 License Renewal Application
Appendix B AGING MANAGEMENT PROGRAMS NUREG-1801 Consistency The Steam Generator Tube Integrity program is an existing program that is consistent with NUREG-1801,Section XI.M19, "Steam Generator Tube Integrity".
Exceptions to NUREG-1801 None Enhancements None Operating Experience The Steam Generator Tube Integrity program has been developed to be consistent with NEI 97-06, and it benefits from the industry operating experience available when the initiative was issued as well as the EPRI guidelines it endorses. Station procedural guidance requires that the Steam Generator Degradation Assessment for PVNGS be updated every operating cycle to incorporate the latest industry and plant-specific experience regarding steam generator degradation mechanisms.
NRC Information Notice 97-88 addressed the importance of recognizing the potential for degradation in areas that have not previously experienced tube degradation and the importance of licensees to assess the significance of indications with respect to the qualification of the inspection techniques and the manner in which the indications were detected. The PVNGS Steam Generator Degradation Assessment evaluates industry experience as well as PVNGS experience to identify active, relevant and potential tube damage mechanisms. The inspection sample size, location and method are developed to fully address active mechanisms and provide assurance that relevant and potential mechanisms will be identified if they become active at PVNGS. The inspection expansion criteria take into account both increasing the area inspected when degradation is found and changing the technology used to accurately examine ambiguous or unexpected degradation.
PVNGS Units 1, 2 and 3 are two loop Combustion Engineering (CE) plants with two identical replacement steam generators designed by ABB/CE which are considered a modified CE System 80 design. The original steam generators were replaced in Units 1, 2, and 3 during the fall of 2005, 2003, and 2007, respectively. Each steam generator has a total of 12,580 Alloy 690 thermally treated tubes. The tubes are hydraulically expanded into the tubesheet for the entire tubesheet thickness. The tube support system is similar to the original design, and like the original design is fabricated from 409 ferritic stainless steel. To minimize the potential for stress corrosion cracking, in addition to the tubing material change, the U-bend region in the first 17 rows were stress relieved after bending.
Industry experience has shown that tube damage in replacement steam generators typically occurs from loose parts and support wear.
Wear is the only active damage mechanism in the PVNGS Replacement Steam Generators (RSGs) and specifically wear as the result of interaction of tubing with the tube supports. Most Palo Verde Nuclear Generating Station Amendment 26 Page B-29 License Renewal Application
Appendix B AGING MANAGEMENT PROGRAMS of the wear indications have been observed in a region around the stay cylinder and at either the Diagonal Supports or Vertical Supports (Primarily VS3).
As of the end of the U1R14, U2R15 and U3R14 outages no corrosion degradation has been detected in any of the PVNGS replacement steam generator tubes.
Due to certain historically observed wear phenomenon, PVNGS has employed conservative administrative plugging criteria related to support wear mechanisms.
For example, support wear indications are removed for wear rate greater than or equal to 35% for a normal operating cycle if no previous wear is identified. This plugging criterion is designed to ensure that the structural and accident leakage performance criteria specified in the PVNGS Technical Specifications are not exceeded in the subsequent operating cycle. It was expected, based on RSG redesign, that the conditions necessary to generate high wear rates in the Batwing Stay Cylinder (BWSC) and Cold Leg Corner (CLC) regions were eliminated. While this was clearly the case for CLC wear, the RSG inspection results during the initial inspection in Unit 2 (U2R12) indicated that the RSG's continued to exhibit similar wear conditions within the BWSC region.
As a result of these findings, a decision was made prior to Unit 1 and Unit 3 RSG installation to plug and stake all of the "frontline" BWSC tubes. The subsequent inspections during U2R13, U1R13, U2R14, U1R14, U3R14 and U2R15 have indicated that the BWSC wear issue exists in the RSG's of all 3 PVNGS units.
On February 19, 2004 Unit 2 was operating at full power when radiation monitors displayed indications of a low level primary to secondary leak.
Shortly thereafter the leak rate was calculated to be 11.8 gallons per day, even though grab samples indicated 3 gallons per day, and the decision was made to shut the unit down to find and repair the leak.
After cooling the plant down and performing tests, one SG tube was found to be leaking and was plugged. Further analysis showed that the cause of the leak was from a puncture received from a wood screw that was used in the construction of the shipping crates for the tubes when the steam generators were being manufactured. The tubes were placed in the crate and the crate assembled around them. One screw that was used near the outer diameter of the top of the tube bend protruded through the wood and began to puncture the tube material. The screw did not completely penetrate the tube and the unit was operated from its post-outage startup to this date when the tube finally began leaking.
Contamination to the secondary plant was minimal and the unit entered Mode 1 on March 9, 2004. Corrective actions put in place after the event prevented recurrence in the Unit 1 and 3 replacement steam generators.
Conclusion The continued implementation of the Steam Generator Tube Integrity program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
Palo Verde Nuclear Generating Station Amendment 26 Page B730 License Renewal Application
Appendix B AGING MANAGEMENT PROGRAMS B2.1.10 Closed-Cycle Cooling Water System Program Description The Closed-Cycle Cooling Water (CCCW) System program manages loss of material, cracking, and reduction in heat transfer for components in the following closed cycle cooling water systems:
Diesel Generator Jacket Water System Essential Chilled Water System Essential Cooling Water System Normal Chilled Water System Nuclear Cooling Water System The CCCW systems serve heat exchangers and related components that are within the scope of license renewal in the following interfacing systems:
Auxiliary Steam System Chemical and Volume Control System Spent Fuel Pool Cooling and Clean Up System Reactor Coolant System Secondary Chemical Control System Safety Injection and Shutdown Cooling System Nuclear Sampling System Auxiliary Building HVAC Containment Building HVAC Control Building HVAC The program includes (a) maintenance of system corrosion inhibitor concentrations to minimize aging effects and (b) periodic testing and inspections to evaluate system and component performance. The water chemistry aspect of the program maintains an environment within CCCW systems that is consistent with the parameters specified in EPRI TR-107396 for CCCW system.
Water chemistry is maintained through the addition of an iron corrosion inhibitor (nitrite), a copper corrosion inhibitor (tolyltriazole - TTA), pH control and biocide (glutaraldehyde). System corrosion inhibitor concentrations are maintained at levels described in EPRI TR-107396 to minimize aging effects. Testing and inspections are performed in accordance with guidance in EPRI TR 107396 for closed-cycle cooling water (CCCW) systems as appropriate for their license renewal intended functions; for example, components which do not have a license renewal heat transfer function, but which are evaluated as having a license renewal intended function of pressure boundary or leakage Palo Verde Nuclear Generating Station Amendment 26 Page B-34 License Renewal Application
Appendix B AGING MANAGEMENT PROGRAMS barrier are not subject to internal inspection or performance testing. The effectiveness of water chemistry control measures of these heat exchangers is verified by visual inspection of the internal surfaces of selected components fabricated of similar materials and exposed to closed-cycle water using the same corrosion inhibitor program. Inspection processes include visual, eddy-current and ultrasonic methods. Testing methods include functional demonstrations and monitoring, thermal and hydraulic performance testing.
NUREG-1801 Consistency The Closed-Cycle Cooling Water System program is an existing program that-,-fG,,4e,,1.
onhancomont, will be is consistent with exception to NUREG-1801,Section XI.M21, "Closed-Cycle Cooling Water."
Exceptions to NUREG-1801 Program Elements Affected Preventive Actions - Element 2 NUREG-1801,Section XI.M21, Element 2, requires materials used in CCCW systems to be appropriate to the type of service. The essential cooling water system for each unit is provided with two radiation monitors (one per train) that employ an aluminum "window" as a pressure boundary between the CCCW and the ionization detector within the flow-through sample chambers. The chemical treatment program at PVNGS does not include controls described in EPRI TR-107396 as appropriate for aluminum. Exception is taken to employ the NUREG 1801 AMP XI.M38 Internal Surfaces Monitoring Program to manage the aging of the aluminum "windows" of the radiation monitors. A review of plant operating experience reveals no instances where aging effects have led to the loss of the intended function of the subject components.
Parameters Monitored or Inspected - Element 3 and Monitoring and Trending - Element 5 NUREG-1801,Section XI.M21, Element 3 requires testing and inspection as described in EPRI TR-107396 and further states "For pumps, the parameters monitored include flow, discharge pressures, and suction pressures and for heat exchangers, the parameters monitored include flow, inlet and outlet temperatures, and differential pressure" and Element 5 states "visual inspections and performance/functional tests are to be performed to confirm the effectiveness of the program."
PVNGS monitors system parameters and performs a combination of visual inspections, non-destructive evaluations, performance and functional tests as well as thermal performance tests as described in EPRI TR-107396 Section 8.4 to confirm the effectiveness of the CCCW program in managing the aging of components and systems exposed to CCCW.
Plant configuration constraints and consideration of components which do not have a license renewal heat transfer function, but which are evaluated as having a license renewal intended function of pressure boundary or leakage barrier have led to several exceptions with respect to some measures set forth in NUREG-1801 with respect to testing and inspection specifics that together do not compromise the ability to monitor program effectiveness to ensure the component intended functions are maintained. Specific exceptions taken include:
a.) The essential cooling water, spent fuel cooling and cleanup, and shutdown cooling heat exchangers are not monitored for differential pressure. The program of periodic sampling and maintenance of system chemistry together with thermal performance testing in conformance with Palo Verde Nuclear Generating Station Amendment 26 Page B-35 License Renewal Application
Appendix B AGING MANAGEMENT PROGRAMS EPRI NR-7552, and, in the case of the essential cooling water heat exchanger, periodic ECT of the heat exchanger tubes and, in the case of the spent fuel cooling and cleanup heat exchanger, periodic NDE of the heat exchanger shell are adequate to ensure that component intended functions of pressure boundary and heat transfer are maintained.
b.) The essential chilled water and essential cooling water system circulating water pumps are not subject to periodic internal visual inspection or casing NDE. These pumps are monitored for flow, suction pressure and discharge pressure in accordance with the approved ASME Pump and Valve In-Service Testing Program. The performance monitoring of these pumps together with periodic sampling and control of water chemistry is adequate to ensure component intended function is maintained.
c.) The essential chilled water system chiller condenser, water cooler and lube oil cooler are not individually monitored for flow, inlet and outlet temperatures, and differential pressure.
During periodic surveillance testing, the heat load on the essential chilled water system is not reproducible from test-to-test. Plant procedures require that these components are subject to visual inspection when their respective chiller is rebuilt. Visual inspection together with the periodic sampling and control of system water chemistry is adequate to ensure the component intended functions are maintained.
d.) The individual ventilation cooling coils served by the essential chilled water system are not monitored for differential pressure and, additionally are not subject to visual inspection of their internal surfaces or NDE because the internal diameter and geometry of the coils preclude effective internal inspection.
The combination of chemistry control, preventive maintenance, air side inspection, and testing of a control room air filtration unit in each train provides reasonable assurance that essential auxiliary building HVAC and control building HVAC system cooling coil performance has not degraded. A review of plant operating experience reveals no instances where aging effects have led to the loss of the intended function of the subject components.
e.) The diesel generator jacket water engine-driven circulating water pump, the motor-driven circulating water pump, the jacket water heat exchanger, turbo air intercooler, turbocharger and governor lube oil cooler are not individually monitored for flow, inlet and outlet temperatures, and differential pressure and internal visual inspections are not performed on each component. At PVNGS, diesel generator performance parameters are monitored through periodic Technical Specification surveillance tests. Plant procedures require temperature and pressure parameters be compared to pre-established limiting values. From the comparison, overall heat exchanger and pump performance can be inferred collectively for the diesel generator under test. With respect to the motor-driven circulating water pump, the pump operates cyclically together with a heater to maintain jacket water temperature when the diesel generator is in standby; its functional performance is continuously monitored by measuring jacket water temperature. The diesel generator governor oil cooler, the engine-driven and motor-driven circulating water pumps and the turbocharger are not individually subject to periodic visual inspection.
The jacket water heat exchanger and the turbo air intercooler are periodically inspected visually as an indication of interior surface conditions throughout the diesel generator jacket water system. The surveillance tests together with periodic visual inspections and the periodic sampling and control of system water chemistry are adequate to ensure the component intended functions are maintained within the diesel generator jacket water system.
f.) The RC hot leg sample cooler is within scope of license renewal for 10CFR54.4 criteria a(3) fire protection considerations that identify the capability to obtain a RC hot leg sample for boron Palo Verde Nuclear Generating Station Amendment 26 Page B-36 License Renewal Application
Appendix B AGING MANAGEMENT PROGRAMS.
concentration as a means of reactivity control. Exception is taken for regular, periodic inspection and testing of this heat exchanger based on its variable heat load and on the fact that the design configuration of the RC hot leg sample cooler is a sealed unit not subject to opening for routine inspection or maintenance. The effectiveness of water chemistry control measures for this heat exchanger is verified by visual inspection of the internal surfaces of selected components fabricated of similar materials and exposed to closed-cycle cooling water using the same corrosion inhibitor program.
g.) Several heat exchangers are provided which do not have a license renewal heat transfer intended function and are not monitored for parameters pertaining to heat transfer nor subject to periodic performance monitoring and inspection to manage the aging effect of reduction in heat transfer. These heat exchangers include the letdown heat exchanger, which has the intended function of pressure boundary, and the following heat exchangers, which have the intended function of leakage barrier - spatial:
auxiliary steam vent condenser cooler for auxiliary steam radiation monitor aftercooler for gas stripper cooling coils for normal HVAC Units (containment, auxiliary, and control building HVAC).
steam generator hot leg, cold leg and downcomer blowdown sample coolers pressurizer steam space and surge line sample coolers safety injection sample coolers The effectiveness of water chemistry control measures for these heat exchangers is verified by visual inspection of the internal surfaces of selected components fabricated of similar-materials and exposed to closed-cycle cooling water using the same corrosion inhibitor program.
Enhancements None Priofr t the period ofext-ende operation, the followin g eenhancomonts will bei een n
the f oll owing program elements:
PrventWAvo Actions Element 2, Acceptance Critera Element 6, and AGceptance Criteria Procedur~es will be enhancePd_ to-incr0Fporate the guidance of EPRI T-R 1073 I.NoIth resGpect to water chem~istry conrol for frequlencY of sampling and analysis, nrGmal o)perating limits, actionR leve concentrations,' and times forF implemen8ting correctfive actions u1pon attainm~ent of action levels.
Operating Experience A review of the PVNGS plant-specific operating experience indicates that there has been no evidence of significant fouling or loss of material that has resulted in a loss of intended function observed in the following closed cycle cooling systems:
Palo Verde Nuclear Generating Station Amendment 26 Page B-37 License Renewal Application
Appendix B AGING MANAGEMENT PROGRAMS Diesel Generator Jacket Water System Essential Chilled Water System Essential Cooling Water System Normal Chilled Water System Nuclear Cooling Water System During the second half of 2001, water chemistry monitoring identified an elevated levels of chlorides and sulfates characteristic of leakage from the essential spray pond system into the essential cooling water system of Unit 3. Diagnostic water chemistry testing further localized the source of the leak to the B-train essential cooling water heat exchanger.
Visual inspection and Non-Destructive Evaluation (eddy current testing) were performed and localized the leak to a heat exchanger tube which was subsequently plugged. The cause was evaluated as a pit resulting from corrosion from the open-cycle cooling side of the heat exchanger into the closed-cycle side of the heat exchanger. An expanded testing program encompassing 100% of the essential cooling water heat exchanger tubes in all three units revealed no further degradation. This event demonstrates the effectiveness of managing the aging of the closed-cycle cooling water systems.
Conclusion The continued implementation of the Closed-Cycle Cooling Water program provides reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page B-38
Appendix B AGING MANAGEMENT PROGRAMS B2.1.18 Buried Piping and Tanks Inspection Program Description The Buried Piping and Tanks Inspection program manages loss of material on external surfaces of buried components in the following systems: chemical and volume control, condensate storage and transfer, diesel fuel storage and transfer, domestic water, fire protection, SBOG fuel system, service gas and essential spray ponds. Opportunistic visual inspections will monitor the condition of protective coatings and wrappings found on carbon steel, gray cast iron or ductile iron components and assess the condition of stainless steel components with no protective coatings or wraps. Any evidence of damaged wrapping or coating defects is an indicator of possible corrosion damage to the external surface of the components.
The Buried Piping and Tanks Inspection program is a new program that will be implemented prior to the period of extended operation.
Within the ten year period prior to entering the period of extended operation an opportunistic or planned inspection of buried tanks at the Palo Verde site will be performed.
The visual inspections noted below of piping in a soil environment within the scope of license renewal will be conducted within the ten-year period prior to entering the period of extended operation, and during each ten year period after entering the period of extended operation, except the initial diesel generator fuel oil piping inspection will be performed between January 1, 2012 and December 31, 2015. Each inspection will:
select accessible locations where degradation is expected to be high; excavate and visually inspect the circumference of the pipe; and examine at least ten feet of pipe.
- a. Metallic Piping not Cathodically-Protected At least two excavations and visual inspections of stainless steel piping will be conducted in each unit. Stainless steel piping within the scope of license renewal exists in the following systems:
o Chemical and Volume Control (CH),
o Condensate Transfer and Storage (CT), and o
Fire Protection (FP).
- b. Steel Piping Cathodically-Protected At least two excavations and visual inspections of cathodically-protected steel piping will be conducted in each unit. In one of the units, at least one of these inspections will be performed on diesel generator fuel oil piping.
- c. Steel Piping with Potentially Degraded Cathodic Protection At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.
Palo Verde Nuclear Generating Station Amendment 26 Page B-52 License Renewal Application
Appendix B AGING MANAGEMENT PROGRAMS Prior to the period of extended operation, the Buried Piping and Tanks Inspection program will include provisions to (1) ensure electrical power is maintained to the cathodic protection system for in-scope buried piping at least 90% of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE) cathodic protection system surveys are performed at least annually.
NUREG-1801 Consistency The Buried Piping and Tanks Inspection program is a new program that, when implemented, will be consistent with exception to NUREG-1801,Section XI.M34, "Buried Piping and Tanks Inspection".
Exceptions to NUREG-1801 Program Elements Affected Scope of Program - Element 1 and Acceptance Criteria-Element 6 NUREG-1801,Section XI.M34 scope only includes buried steel piping and components.
However, PVNGS also includes stainless steel in their buried piping program that will be managed as part of this aging management program.
Scope of Program - Element 1, Preventive Actions -
Element 2, and Acceptance Criteria-Element 6 NUREG-1801,Section XI.M34 relies on preventive measures such as coatings and wrappings.
However, portions of buried stainless steel piping may not be coated or wrapped. Inspections of buried piping that is not wrapped will inspect for loss of material due to general, pitting, crevice, and microbiologically influenced corrosion.
Enhancements None Operating Experience The Buried Piping and Tanks Inspection program is a new program.
Degradation of buried components was addressed at PVNGS during an inspection program in September 2002.
Observations of this inspection program include:
During the past several years, leaks developed in various buried piping segments, which potentially threaten the continuous operation of PVNGS. These leaks collectively indicated a negative trend in the overall integrity of the buried pipe.
Inspection and maintenance activities were implemented in order to address overall integrity of the buried pipe. Determination of system priorities and development of a draft inspection plan for each of the evaluated systems was developed.
Palo Verde Nuclear Generating Station Amendment 26 Page B-53 License Renewal Application
Appendix B AGING MANAGEMENT PROGRAMS The applicable systems with piping installed below grade were evaluated and assigned ranking based on priority. The majority of these evaluated buried piping systems have very little or no identified potential for degradation.
The majority of the systems evaluated in the inspection program are not within the scope of license renewal. The PVNGS corrective action documentation to date has shown that, for the systems within the scope of license renewal, degradation has been found primarily in the fire protection system.
Fire protection system has had localized degradation in excess of the minimum wall requirement of 40% nominal wall thickness.
The designated segments of the degraded ductile iron piping have been replaced by fiberglass reinforced plastic piping. The fire protection system has not experienced a failure that affected the ability of the plant to achieve and maintain safe shutdown in the event of a fire. To date, the actual pipe failures of the underground fire protection system have been isolated and repaired without adversely affecting any fire protection water suppression system.
Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.
Conclusion The implementation of the Buried Piping and Tanks Inspection program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page B-54
ENCLOSURE 3 Updated Listing of the PVNGS License Renewal Application Table A4-1 Commitments
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item C....I'ommitment
.Sectn Ilementation No.
Schedule 1
The summary descriptions of aging management programs, time-limited A0 The next 10 CFR aging analyses, and license renewal commitments contained in LRA 50.71(e) UFSAR Appendix A, "Updated Final Safety Analysis Supplement," as required by update following 10 CFR 54.21(d), will be incorporated in the Updated Final Safety issuance of the Analysis Report for PVNGS Units 1, 2, and 3 in the next update required renewed operating by 10 CFR 50.71 (e) following the issuance of the renewed operating licenses.
licenses.
(RCTSAI 3247244) 2 Existing Quality Assurance Program is credited for license renewal.
Al Ongoing (RCTSAI 3246887) 831.3 Summary Descriptions Of Aging Management 3
Existing ASME Section XI Inservice Inspection, Subsections IWB, IWC, A1.1 Ongoing and IWD program is credited for license renewal.
B2.1.1 (RCTSAI 3246890)
ASME Section XI Inservice Inspection, Subsections IWB, IWC, AND IWD 4
Existing Water Chemistry program is credited for license renewal.
A1.2 Ongoing (RCTSAI 3246891).
B2.1.2 Water Chemistry 5
Existing Reactor Head Closure Studs program is credited for license A1.3 Ongoing renewal.
B2.1.3 (RCTSAI 3246892)
Reactor Head Closure Studs 6
Existing Boric Acid Corrosion program is credited for license renewal.
A1.4 Ongoing (RCTSAI 3246893)
B2.1.4 Boric Acid Corrosion Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-42
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item
-Commitment LRA Section Implementation No.:
,Schedule 7
Existing Nickel-Alloy Penetration Nozzles Welded to The Upper Reactor A1.5 Ongoing Vessel, Closure Heads of Pressurized Water Reactors program is B2.1.5 credited for license renewal.
Nickel-Alloy (RCTSAI 3246894)
Penetration Nozzles Welded to The Upper Reactor Vessel Closure Heads of Pressurized Water Reactors 8
Existing Flow-Accelerated Corrosion program is credited for license A1.6 Ongoing renewal.
B2.1.6 (RCTSAI 3246895)
Flow-Accelerated Corrosion 9
Existing Bolting Integrity program is credited for license renewal.
A1.7 Ongoing (RCTSAI 3246896)
B2.1.7 Bolting Integrity 10 Existing Steam Generator Tube Integrity program is credited for license A1.8 Ongoing renewal.
B2.1.8 (RCTSAI 3246897)
Steam Generator Tube Integrity 11 Existing Open-Cycle Cooling Water System program is credited for A1.9 Prior to the period of license renewal, AND B2.1.9 extended operation1.
Prior to the period of extended operation, the program will be enhanced Open-Cycle Cooling to clarify guidance in the conduct of piping inspections using NDE Water System techniques and related acceptance criteria.
(RCTSAI 3246898) 12 Existing Closed-Cycle Cooling Water System program is credited for A1.10 Ongoing license renewal.
B2.1.10 (RCTSAI 3246899)
Closed-Cycle Cooling Water System Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-43
Appendix A Updated Final Safety Analysis Report Supplement
-I-*1-,1*
/t A "t
/I I dlJi: l If-I LIcenIIs r*llWdl u.,uIIuIIuIII IIL.e "
Item,,:
Commitment
-- LRASectiionon*-'
Im*ee on No.
Schedule 13 Existing Inspection Of Overhead Heavy Load And Light Load (Related To A1.11 Prior to the period of Refueling) Handling Systems program is credited for license renewal, B2.1.11 extended operation'.
AND Inspection Of Prior to the period of extended operation, procedures will be enhanced to Overhead Heavy Load inspect for loss of material due to corrosion or rail wear.
And Light Load (RCTSAI 3246900)
(Related To Refueling)
Handling Systems 14 Existing Fire Protection program is credited for license renewal, AND A1.12 Prior to the period of Prior to the period of extended operation procedures will be enhanced to B2.1.12 extended operation'.
perform the testing of the Electro-Thermal Links (ETLs) and functional Fire Protection testing of the halon and C02 dampers every 18 months or at the frequency specified in the current licensing basis in effect upon entry into the period of extended operation.
(RCTSAIs 3246901 and 3554175) 15 Existing Fire Water System program is credited for license renewal, AND A1.13 Prior to the period of Prior to the period of extended operation, the following enhancements will B2.1.13 extended operation'.
be implemented:
Fire Water System
" Specific procedures will be enhanced to include review and approval requirements under the Nuclear Administrative Technical Manual (NATM).
Procedures will be enhanced to be consistent with the current code of record or NFPA 25 2002 Edition.
Procedures will be enhanced to field service test a representative sample or replace sprinklers prior to 50 years in service and test thereafter every 10 years to ensure that signs of degradation are detected in a timely manner.
Procedures will be enhanced to be consistent with NFPA 25 Section 7.3.2.1, 7.3.2.2, 7.3.2.3, and 7.3.2.4.
(RCTSAI 3246902)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-44
Appendix A Updated Final Safety Analysis Report Supplement Tpkil AAl4 I
DcI0,nIAfic On
ýfý nl Item Commitment LRA Section Implementation No.
Schedule 16 Existing Fuel Oil Chemistry program is credited for license renewal, AND A1.14 Prior to the period of Prior to the period of extended operation:
B2.1.14 extended operation1.
" Procedures will be enhanced to extend the scope of the program to Fuel Oil Chemistry include the SBOG fuel oil storage tank and SBOG skid fuel tanks.
Procedures will be enhanced to include ten-year periodic draining, cleaning, and inspections on the diesel-driven fire pump day tanks, the SBOG fuel oil storage tank, and SBOG skid fuel tanks.
Ultrasonic testing (UT) or pulsed eddy current (PEC) thickness examination will be conducted to detect corrosion-related wall thinning if degradation is found during the visual inspections and once on the tank bottoms for the EDG fuel oil storage tanks, EDG fuel oil day tanks, diesel-driven fire pump day tanks, SBOG fuel oil storage tank, and SBOG skid fuel tanks. The onetime UT or PEC examination on the tank bottoms will be performed before the period of extended operation.
(RCTSAI 3246903)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-45
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments
- Item, Commitment 1LRA:Section 1Implementation, No.
Schedule' 17 Existing Reactor Vessel Surveillance program is credited for license renewal, AND Prior to the period of extended operation:
The schedule will be revised to withdraw the next capsule at the equivalent clad-base metal exposure of approximately 54 EFPY expected for the 60-year period of operation, and to withdraw remaining standby capsules at equivalent clad-base metal exposures not exceeding the 72 EFPY expected for a possible 80-year second period of extended operation. This withdrawal schedule is in accordance with NUREG-1801,Section XI.M31, item 6, and with the ASTM E 185-82 criterion which states that capsules may be removed when the capsule neutron fluence is between one and two times the limiting fluence calculated for the vessel at the end of expected life.
This schedule change must be approved by the NRC, as required by 10 CFR 50 Appendix H.
If left in the reactor beyond the presently-scheduled withdrawal, the next scheduled surveillance capsule in each unit will reach a clad-base metal 54 EFPY equivalent at about 40 actual operating EFPY (40, 39, and 42 actual EFPY in Units 1, 2, and 3, respectively).
Procedures will be enhanced to identify the withdrawal of the remaining standby capsules at 72 EFPY, at about 50 to 54 actual operating EFPY, near the end of the extended licensed operating period. The need to monitor vessel fluence following removal of the remaining standby capsules, and ex-vessel or in-vessel methods, will be addressed prior to removing the remaining capsules.
(RCTSAI 3246904)
A1.15 B2.1.15 Reactor Vessel Surveillance Prior to the period of extended operation1.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-46
Appendix A Updated Final Safety Analysis Report Supplement Tnhli
'AlLI I i'nQ,0 eP 0nt01A/IqI frmnMifmcnfQ-Item Commitment LRA Section Implementation
.No.
'Schedule 18 The One-Time Inspection program conducts one-time inrspections of plant A1.16 Within the ten year system piping and components to verify the effectiveness of the Water B2.1.16 period prior to the Chemistry program (A1.2), Fuel Oil Chemistry program (A1.14), and One-Time Inspection period of extended Lubricating Oil Analysis program (A1.23). The aging effects to be operation1.
evaluated by the One-Time Inspection program are loss of material, cracking, and reduction of heat transfer.
(RCTSAIs 3246906 [Ul]; 3247258 [U2]; 3247259 [U3])
19 The Selective Leaching of Materials program is a new program that will A1.17 Within the ten year be implemented prior to the period of extended operation. Industry and B2.1.17 period prior to the plant-specific operating experience will be evaluated in the development Selective Leaching Of period of extended and implementation of this program.
Materials operation1.
(RCTSAIs 3246908 [UL1]; 3247260 [U2]; 3247261 [U3])
20 The Buried Piping and Tanks Inspection program is a new program that A1.18 Perform the buried will be implemented prior to the period of extended operation.
B2.1.18 piping and tanks Buried Piping And inspections within the Within the ten year period prior to entering the period of extended Tanks Inspection ten year period prior operation an opportunistic or planned inspection of buried tanks at the to the period of Palo Verde site will be performed.
extended operation1,
except the initial The visual inspections noted below of piping in a soil environment within diesel generator fuel the scope of license renewal will be conducted within the ten-year period oil piping inspection prior to entering the period of extended operation, and during each ten will be performed year period after entering the period of extended operation, except the between 1/1/12 and initial diesel generator fuel oil piping inspection will be performed between 12/31/15.
January 1, 2012 and December 31, 2015. Each inspection will:
AND select accessible locations where degradation is expected to be high; Perform the buried excavate and visually inspect the circumference of the pipe; piping inspections and during each ten year examine at least ten feet of pipe.
period after entering Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-47
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item Commitment
-LRA Section Implementation No.
Schedule
.a. Metallic Piping not Cathodically-Protected At least two excavations and visual inspections of stainless steel piping will be conducted in each unit. Stainless steel piping within the scope of license renewal exists in the following systems:
o Chemical and Volume Control (CH),
o Condensate Transfer and Storage (CT), and o
Fire Protection (FP).
- b. Steel Piping Cathodically-Protected At least two excavations and visual inspections of cathodically-protected steel piping will be conducted in each unit.
In one of the units, at least one of these inspections will be performed on diesel generator fuel oil piping.
- c. Steel Piping with Potentially Degraded Cathodic Protection At least three excavations and visual inspections of fire protection steel piping with potentially degraded bonding straps will be conducted at the Palo Verde site.
Prior to the period of extended operation, the Buried Piping and Tanks Inspection program will include provisions to (1) ensure electrical power is maintained to the cathodic protection system for in-scope buried piping at least 90% of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and (2) ensure that the National Association of Corrosion Engineers (NACE) cathodic protection system surveys are performed at least annually.
(RCTSAIs 3246909 [Ul; 3247263 [U2]; 3247264 [U3])
the period of extended operation.
AND Implement the additional enhancements to the buried piping and tanks inspection program prior to the period of operation'.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-48
Appendix A Updated Final Safety Analysis Report Supplement T~hhk. A4-1 I ici~n~ R~n~w~I Cnmmitmpnt.q Item
-Commitment..
LRA Section Implementation, No.
'Schedule 21 The One-Time Inspection of ASME Code Class 1 Small-Bore Piping A1.19 Prior to the period of program is a new program that will be implemented prior to the period of B2.1.19 extended operation1.
extended operation. Industry and plant-specific operating experience will One-Time Inspection be evaluated in the development and implementation of this program.
of ASME Code Class 1 For ASME Code Class 1 small-bore piping, volumetric examinations on Small-Bore Piping selected butt weld locations will be performed to detect cracking. Butt weld volumetric examinations will be conducted in accordance with ASME Section XI with acceptance criteria from Paragraph IWB-3000 and IWB-2430. Weld locations subject to volumetric examination will be selected based on the guidelines provided in EPRI TR-1 12657. Socket welds that fall within the weld examination sample will be examined following ASME Section XI Code requirements. At least 10% of the socket welds in ASME Code Class 1 piping that is less than four inches nominal pipe size and greater than or equal to one inch nominal pipe size will be selected per unit for ultrasonic testing examination. The sample will be selected based on risk insights and those welds with the potential for aging degradation.
(RCTSAIs 3246910 [U1]; 3247265 [U2]; 3247266 [U3])
22 The External Surfaces Monitoring Program is a new program that will be A1.20 Prior to the period of implemented prior to the period of extended operation. Industry and B2.1.20 extended operation'.
plant-specific operating experience will be evaluated in the development External Surfaces and implementation of this program.
Monitoring Program (RCTSAIs 3246911 [U1]; 3247272 [U2]; 3247273 [U3])
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-49
Appendix A Updated Final Safety Analysis Report Supplement Tnhl0 AzldI I
it-,QnQM QnA31A/-ql (nMMifMd3nfC Item Commitment LRA Section Implementation No...
Schedule' 23 APS will:
A1.21 Not less than 24 A. Reactor Coolant System Nickel Alloy Pressure Boundary Components B2.1.21 months prior to the Implement applicable (1) NRC Orders, Bulletins and Generic Letters Reactor Coolant period of extended associated with nickel alloys and (2) staff-accepted industry guidelines, System Supplement operation1.
(3) participate in the industry initiatives, such as owners group programs and the EPRI Materials Reliability Program, for managing 3.1.2.2.16.2 aging effects associated with nickel alloys, (4) upon completion of Pressurizer spray these programs, but not less than 24 months before entering the head cracking period of extendedoperation, APS will submit an inspection plan for
.reactor coolant system nickel alloy pressure boundary components to the NRC for review and approval, and B. Reactor Vessel Internals (1) Participate in the industry programs for investigating and managing aging effects on reactor internals; (2) evaluate and implement the results of the industry programs as applicable to the reactor internals; and (3) upon completion of these programs, but not less than 24 months before entering the period of extended operation, APS will submit an inspection plan for reactor internals to the NRC for review and approval.
C. Pressurizer Spray Heads Comply with applicable NRC Orders and implement applicable (1)
Bulletins and Generic Letters, and (2) staff-accepted industry guidelines.
(RCTSAIs 3246912 [Ul]; 3247274 [U2]; 3247276 [U3])
24 The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting A1.22 Prior to the period of Components program is a new program that will be implemented prior to B2.1.22 extended operation1.
the period of extended operation. Industry and plant-specific operating Inspection Of Internal experience will be evaluated in the development and implementation of Surfaces In this program.
Miscellaneous Piping (RCTSAIs 3246914 [Ul]; 3247277 [U2]; 3247278 [U3])
And Ducting Components Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-50
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item Commitment LRA Section Implementation No.
Schedule 25 Existing Lubricating Oil Analysis program is credited for license renewal.
A1.23 Ongoing (RCTSAI 3246915)
B2.1.23 Lubricating Oil Analysis 26 The Electrical Cables and Connections Not Subject to 10 CFR 50.49 A1.24 Prior to the period of Environmental Qualification Requirements program is a new program that B2.1.24 extended operation'.
will be implemented prior to the period of extended operation. Industry Electrical Cables And and plant-specific operating experience will be evaluated in the Connections Not development and implementation of this program.
Subject to 10 CFR (RCTSAI 3246917) 50.49 Environmental Qualification Requirements 27 Existing Electrical Cables And Connections Not Subject To 10 CFR 50.49 A1.25 Prior to the period of Environmental Qualification Requirements Used In Instrumentation B2.1.25 extended operation'.
Circuits program is credited for license renewal, AND Electrical Cables And Prior to the period of extended operation:
Connections Not Procedures will be enhanced to identify license renewal scope, Subject To 10 CFR require cable testing of ex-core neutron monitoring cables, require an 50.49 Environmental evaluation of the calibration results for non-EQ area radiation Qualification monitors, and require acceptance criteria for cable testing be Requirements Used In established based on the type of cable and type of test performed.
Instrumentation (RCTSAI 3246919)
Circuits 28 The Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 A1.26 Prior to the period of EQ Requirements program is credited for license renewal, AND B2.1.26 extended operation'.
Prior to the period of extended operation procedures will be enhanced to:
Inaccessible Medium Extend the scope of the program to include low voltage (480V and Voltage Cables Not above) non-EQ inaccessible power cables and associated Subject To 10 CFR manholes.
50.49 Environmental Perform the cable inspections on at least an annual frequency Qualification and perform the cable testing on a six year frequency.
Requirements (RCTSAI 3246920)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-51
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item Commitment-LRA Section Irnmplementation)
No.,
,Schedule 29 Existing ASME Section X1, Subsection IWE program is credited for A1.27 Ongoing license renewal.
B2.1.27 (RCTSAI 3246921)
ASME Section XI, Subsection IWE 30 Existing ASME Section XI, Subsection IWL program is credited for A1.28 Ongoing license renewal.
B2.1.28 (RCTSAI 3246922)
ASME Section XI, Subsection IWL 31 Existing ASME Section XI, Subsection IWF program is credited for A1.29 Ongoing license renewal.
B2.1.29 (RCTSAI 3246923)
ASME Section XI, Subsection IWF 32 Existing 10 CFR 50, Appendix J program is credited for license renewal.
A1.30 Ongoing (RCTSAI 3246924)
B2.1.30 10 CFR 50, Appendix J 33 Existing Masonry Wall Program is credited for license renewal, AND A1.31 Prior to the period of Prior to the period of extended operation, procedures will be enhanced to B2.1.31 extended operation1.
specify ACI 349.3R-96 as the reference for qualification of personnel to Masonry Wall Program inspect structures under the Masonry Wall Program, which is part of the Structures Monitoring Program.
(RCTSAI 3246926)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-52
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item Commitment.
LRA Section Implementation No.
-Schedule 34 Existing Structures Monitoring Program is credited for license renewal, A1.32 Prior to the period of AND B2.1.32 extended operation1.
Prior to the period of extended operation:
Structures Monitoring The Structures Monitoring Program will be enhanced to specify ACI Program 349.3R-96 as the reference for qualification of personnel to inspect structures under the Structures Monitoring Program.
For structures within the scope of license renewal, the Structures Monitoring Program will be enhanced to establish the frequency of inspection for each unit at a 5 year interval, with the exception of exterior surfaces of the following nonsafety-related structures, below-grade structures, and structures within a controlled interior environment, which will be inspected at an interval of 10 years:
Fire Pump House (Yard Structures)
Radwaste Building Station Blackout Generator Structures
" Turbine Building Non-Safety Related Tank Foundations and Shells Non-Safety Related Transformer Foundations and Electrical Structures 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 (e.g., ACI 349.3R-96, ANSI/ASCE 11-90, etc.) for acceptance criteria.
(RCTSAI 3246927)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-53
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item.
Commitment LRA Section
-Implementation.
No..
-Schedule 35 Existing RG 1.127, Inspection Of Water-Control Structures Associated A1.33 Prior to the period of With Nuclear Power Plants program is credited for license renewal, AND B2.1.33 extended operation1.
Prior to the period of extended operation, procedures will be enhanced to RG 1.127, Inspection specify that the essential spray ponds inspections include concrete below Of Water-Control the water level.
Structures Associated (RCTSAI 3246928)
With Nuclear Power Plants 36 Existing Nickel Alloy Aging Management Program is credited for license Al.34 Ongoing renewal.
B2.1.34 (RCTSAI 3260208)
Nickel Alloy Aging Management Program 37 The Electrical Cable Connections Not Subject to 10 CFR 50.49 A1.35 Prior to the period of Environmental Qualification Requirements program is a new program that B2.1.35 extended operation'.
will be implemented prior to the period of extended operation. Industry Electrical Cable and plant-specific operating experience will be evaluated in the Connections Not development and implementation of this program.
Subject To 10 CFR (RCTSAIs 3246930 [Ul]; 3247228 [U2]; 3247231 [U3])
50.49 environmental qualification requirements 38 The Metal Enclosed Bus program is a new program and will be A1.36 Prior to the period of completed before the period of extended operation and once every 10 B2.1.36 extended operation years thereafter. Industry and plant-specific operating experience will be Metal Enclosed Bus and once every ten evaluated in the development and implementation of this program.
years thereafter.
(RCTSAIs 3246932 [U1]; 3247220 [U2]; 3247221 [U3])
39 No later than two years prior to the period of extended operation, the 4.3.1 No later than two following enhancements will be implemented Fatigue Aging years prior to the Cumulative usage factor tracking will be implemented for Management Program period of extended NUREG/CR-6260 locations not monitored by cycle counting (the A2.1 operation'.
reactor vessel shell and lower head (juncture) location will be B3.1 monitored by cycle counting). For PVNGS locations identified in Metal Fatigue of NUREG/CR-6260 and monitored by CUF, fatigue usage factor Reactor Coolant Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-54
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item
-,Commitment.
LRA Section Implementation1 No.-__ _
- -Schedule action limits will be required for including effects of the reactor coolant environment.
The Metal Fatigue of Reactor Coolant Pressure Boundary program will be enhanced to include a computerized program to track and manage both cycle counting and fatigue usage factor.
FatiguePro will be used for cycle counting and cycle-based fatigue (CBF) monitoring methods.
FatiguePro is an EPRI licensed product.
The enhanced Metal Fatigue of Reactor Coolant Pressure Boundary program will monitor plant transients as required by PVNGS Technical Specification 5.5.5. Cumulative usage factors (CUFs) will be calculated for a subset of ASME III Class 1 reactor coolant pressure boundary vessel and piping locations, and component locations with Class 1 analyses.
The following methods will be used:
- 1) The Metal Fatigue of Reactor Coolant Pressure Boundary program will be enhanced to use cycle based fatigue (CBF) and stress based fatigue (SBF) CUF calculations to monitor fatigue. FatiguePro will be used for cycle counting and cycle-based fatigue (CBF) monitoring methods. FatiguePro is an EPRI licensed product.
- 2) The SBF method will use a fatigue monitoring software program that incorporates a three-dimensional, six-component stress tensor method meeting ASME III NB-3200 requirements.
The enhanced Metal Fatigue of Reactor Coolant Pressure Boundary program will provide action limits on cycles and on CUF that will initiate corrective actions before the licensing basis limits on fatigue effects at any location are exceeded.
o In order to ensure sufficient cycle count margin to accommodate occurrence of a low-probability transient, Pressure Boundary Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-55
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments Item Commitment LRA Section-1' Implementation:-
No..
,Schedule corrective actions must be taken before the remaining number of allowable occurrences for any specified transient becomes less than 1.
o CUF action limits will be established to require corrective action when the calculated CUF (from cycle-based or stress-based monitoring) for any monitored location is projected to reach 1.0 within the next 2 or 3 operating cycles.
In order to ensure sufficient margin to accommodate occurrence of a low-probability transient, corrective actions will be taken while there is still sufficient margin to accommodate at least one occurrence of the worst-case design transient event (i.e., with the highest fatigue usage per event cycle).
(RCTSAI 3246934) 40 Existing Environmental Qualification program is credited for license A2.2 Prior to the period of renewal, AND B3.2 extended operation1.
maintaining qualification through the extended license renewal period Environmental requires that existing EQ evaluations (EEQDFs) be re-evaluated.
Qualification (EQ) Of (RCTSAI 3246935)
Electrical Components Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-56
Appendix A Updated Final Safety Analysis Report Supplement Tlhio AA_
u1 '
- 1 0
Dc nn ~t It('nl fi fnnn Item Commitment f
LRA Section Implementation No.
-zSchedule 41 Existing Concrete Containment Tendon Prestress program is credited for A2.3 Prior to the period of license renewal, AND B3.3 extended operation1.
The program will be enhanced to continue to compare regression Concrete Containment analysis trend lines of the individual lift-off values of tendons surveyed Tendon Prestress to date, in each of the vertical and hoop tendon groups, with the MRV and PLL for each tendon group, to the end of the licensed operating period, and to take appropriate corrective actions if future values indicated by the regression analysis trend line drop below the PLL or MRV. The regression analyses will be updated for tendons of the affected unit and for a combined data set of all three units following each inspection of an individual unit.
Prior to the period of extended operation, procedures will be enhanced to require an update of the regression analysis for each tendon group of each unit, and of the joint regression of data from all three units, after every tendon surveillance. The documents will invoke and describe regression analysis methods used to construct the lift-off trend lines, including the use of individual tendon data in accordance with Information Notice (IN) 99-10, "Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments."
The Tendon Integrity test procedure will be revised to extend the list 4.5 of surveillance tendons to include random samples for the year 45 Concrete Containment and 55 surveillances.
Tendon Prestress (RCTSAI 3246937) 42 APS will confirm the RCS Pressure-Temperature limits basis for 54 EFPY A3.1.3 Prior to operation prior to operation beyond 32 EFPY and will update documents in Pressure-Temperature beyond 32 EFPY1.
accordance with the provisions of 10 CFR 50.59. (RCTSAI 3246939)
Limits 43 Completed (RCTSAI 3246941) 44 Completed (RCTSAI 3253459) 45 See Item No. 46 (RCTSAI 3246943)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-57
Appendix A Updated Final Safety Analysis Report Supplement Tphlaz AAA I ifnCMDnn1t~AI/J inMMifM~,fc
-item Commitmen LRA Section Implementation, No.
Schedule 46 An extension of ISI Relief Request 31, Revision 1 authorization will be 4.7.4 Prior to the period of requested for the period of extended operation, supported by a Fatigue Crack Growth extended operation'.
continuation of the cold shutdown time monitoring program.
and Fracture (RCTSAI 3246945)
Mechanics Stability Analyses of Half-Nozzle Repairs to Alloy 600 Material in Reactor Coolant Hot Legs; Absence of a TLAA for Supporting Corrosion Analyses 47 Deleted (Note: this was in the PVNGS Environmental Report) 48 Deleted (Note: this was in the PVNGS Environmental Report) 49 Deleted (Note: this was in the PVNGS Environmental Report) 50 The Fuse Holder program is a new program that will be implemented A1.37 Prior to the period of prior to the period of extended operation and once every 10 years B2.1.37 extended operation thereafter. Industry and plant-specific operating experience will be Fuse Holder and once every 10 evaluated in the development and implementation of this program years thereafter.
(RCTSAI 3409443) 51 Completed (RCTSAI 3410460) 52 Deleted (Note: this was in the PVNGS Environmental Report) 53 Completed (RCTSAI 3429933) 54 Completed (RCTSAI 3443855) 55 Completed (RCTSAI 3469024) 56 The spray pond wall rework/repair methods are currently being Follow-up 12/31/15 determined, and the rework/repair is planned to begin in 2011. As Unit 1 Response to RAI spray ponds have the most degradation, work is planned to start there B2.1.33-2 (letter no.
followed by Units 2 and 3. It is expected that the work will be completed 102-06205, dated in all three units in 2015.
June 21, 2010)
(RCTSAI 3484623)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-58
Appendix A Updated Final Safety Analysis Report Supplement Table A4-1 License Renewal Commitments ItemNo Commitment LRA-Section I.,rmplementation, No.
-Schedule' 57 No later than two years prior to the period of extended operation, APS will Response to RAI 4.3-6 No later than two confirm the conservatism of the Fen value of 1.49 using the methods (letter no.
years prior to the specified in NUREG/CR-6909, and will use the Fen calculated using the 102-06210, dated period of extended NUREG/CR-6909 methods if it is more conservative than the 1.49 value.
June 29, 2010) operation1.
(RCTSAI 3488220) 58 No later than two years prior to the period of extended operation, APS will Response to RAI RAI No later than two perform a reanalysis of the pressurizer heater penetrations to consider 4.3-6 (letter no.
years prior to the EAF effects using the formulas and methodology given in NUREG/CR-102-06210, dated period of extended 6909.
June 29, 2010) operation1.
(RCTSAI 3488223) 59 As documented in CRAI 3337611, Engineering Study 13-MS-B089, Supplemental 06/30/12 "Cavitation in Safety Injection System," APS identified 26 components Response to RAI and associated piping in each PVNGS unit potentially susceptible to B2.1.19-3 (letter no.
cavitation under design basis maximum flow conditions. One location in 102-06233, dated each unit, the HPSI recirculation piping downstream of throttle valve 07/30/2010)
JSIBUVO667, has been confirmed to be susceptible to cavitation erosion, and a 7.5-year time-based replacement schedule described below has been established. All of the remaining 25 locations identified as potentially susceptible to cavitation in Unit 2, 20 of the locations in Unit 1, and 15 of the locations in Unit 3 have been inspected by ultrasonic testing (UT) and demonstrated no degradation. The remaining five locations in Unit 1 are scheduled to be inspected in the Unit 1 fall 2011 refueling outage. Of the remaining ten locations in Unit 3, five will be inspected in the Unit 3 fall 2010 outage and five will be inspected in the Unit 3 spring 2012 outage. Therefore, the inspections in all three units will be completed no later than June 30, 2012. If any of the remaining components and associated piping is found to be susceptible to cavitation or a form of flow-related degradation, it will be incorporated into a replacement plan similar to that for the HPSI recirculation piping downstream of throttle valve JSIBUVO667.
(RCTSAI 3497597)
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-59
Appendix A Updated Final Safety Analysis Report Supplement Tnhlgh IcdA_
1 0 n CNM OMMIAInI (nMMifMnnf0 Item Commitment LRA Section Implementation:
.No.
Schedule 60 The reactor coolant system transient and cycle tracking procedure Response to Draft RAI 11/30/10 73ST-9RC02 and UFSAR Section 3.9.1 will be enhanced to discuss 4.3-19 in APS letter corrective actions that need to be taken prior to ASME Section III fatigue no. 102-06263, dated design limits being exceeded and to state that corrective actions may be October 13, 2010 required for other fatigue-related analyses, such as certain ASME Section XI supplemental fatigue flaw growth or cycle-dependent fracture mechanics evaluations that are dependent on the number of occurrences of design transients.
___(RCTSAI 3531679)
(1)
"Prior to period of extended operation," "prior to operation beyond 32 EFPY," and "prior to the end of the current licensed operating period," is prior to the following PVNGS Operating License expiration dates: Unit 1: June 1, 2025; Unit 2: April 24, 2026; Unit 3: November 25, 2027.
Palo Verde Nuclear Generating Station License Renewal Application Amendment 26 Page A-60