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Category:Letter
MONTHYEARML24019A2012024-01-19019 January 2024 Fourth 10-Year Interval, Second Period Owners Activity Report Number 1R24 ML24019A1362024-01-18018 January 2024 Inservice Inspection Request for Information ML24012A2452024-01-12012 January 2024 Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML24010A1532024-01-10010 January 2024 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection ML23341A0062023-12-21021 December 2023 Project Manager Assignment IR 05000528/20230112023-12-18018 December 2023 License Renewal Inspection Report 05000528/2023011 ML23335A0782023-11-30030 November 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23325A1602023-11-17017 November 2023 Supplemental Submittal - Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20234032023-11-13013 November 2023 NRC Security Inspection Report 05000528 2023403, 05000529 2023403, 05000530 2023403 (Full Report) ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23299A3052023-10-26026 October 2023 Response to Request for Additional Information Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20230032023-10-17017 October 2023 Integrated Inspection Report 05000528 2023003 and 05000529 2023003 and 05000530 2023003 ML23270B9232023-09-28028 September 2023 Notification of Age-Related Degradation Inspection (05000528/2024012, 05000529/2024012, and 05000530/2024012) and Request for Information ML23251A2332023-09-13013 September 2023 Notification of Post Approval Site Inspection for License Renewal and Request for Information Inspection (05000528/2023011) ML23241B0182023-09-13013 September 2023 Use of Honeywell Mururoa V4F1 and MTH2 Supplied Air Suits within Respiratory Protection Program IR 05000528/20243012023-09-0606 September 2023 Notification of NRC Initial Operator Licensing Examination 05000528/2024301; 05000529/2024301; 05000530/2024301 IR 05000528/20230102023-08-22022 August 2023 Biennial Problem Identification and Resolution Inspection Report 05000528/2023010, 05000529/2023010 and 05000530/2023010 IR 05000528/20230052023-08-21021 August 2023 Updated Inspection Plan for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Report 05000528/2023005 and 05000529/2023005 and 05000530/2023005) ML23222A2762023-08-10010 August 2023 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Transportable Storage Canister Identification Numbers AMZDFX175 and AMZDFX176 and Vertical Concrete Cask Identification Numbers AMZDNE175, and AMZDNE176 ML23199A2942023-08-0909 August 2023 Issuance of Amendment Nos. 221, 221, and 221, to Revise Technical Specifications to Adopt TSTF-107, Separate Control Rods That Are Untrippable Versus Inoperable IR 05000528/20230022023-08-0808 August 2023 Integrated Inspection Report 05000528/2023002 and 05000529/2023002 and 05000530/2023002 ML23207A2482023-07-26026 July 2023 License Renewal Pressurizer Surge Line Inspection ML23188A1872023-07-0707 July 2023 Fourth 10-Year Interval, Second Period Owners Activity Report Number 2R24 ML23166B0832023-07-0505 July 2023 Independence Spent Fuel Storage Installation - Issuance of Exemption ML23181A1602023-06-30030 June 2023 2 to Updated Final Safety Analysis Report, and Revision 3 to Operations Quality Assurance Program Description ML23180A2222023-06-29029 June 2023 Application to Revise Technical Specifications (TS) 3.5.1, Safety Injection Tanks (Sits) - Operating, TS 3.5.2, Safety Injection Tanks (Sits) - Shutdown, and TS 3.6.5, Containment Air Temperature ML23181A0772023-06-29029 June 2023 Program Review - Simulator Testing Methodology ML23157A1292023-06-0101 June 2023 Annual Report of Guarantee of Payment of Deferred Premium ML23144A3722023-05-24024 May 2023 Response to Regulatory Issue Summary (RIS) 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23143A3912023-05-23023 May 2023 Independent Spent Fuel Storage Installation - Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Batch 3 Design Requirements ML23145A2772023-05-17017 May 2023 10-PV-2023-05 Post-Exam Comments ML23132A3392023-05-12012 May 2023 Application to Revise Technical Specifications 3.3.11 to Adopt TSTF-266-A, Revision 3, Eliminate the Remote Shutdown System Table of Instrumentation and Controls IR 05000528/20230012023-05-0808 May 2023 and Independent Spent Fuel Storage Installation - Integrated Inspection Report 05000528/2023001 and 05000529/2023001 and 05000530/2023001 and 07200044/2023001 ML23128A0692023-05-0808 May 2023 Notification of Biennial Problem Dentification and Resolution Inspection and Request for Information ML23122A1822023-04-29029 April 2023 Transmittal of Technical Specification Bases Revision 76 ML23122A1912023-04-29029 April 2023 Unit 1 Core Operating Limits Report Revision 32, Unit 2 Core Operating Limits Report Revision 25, Unit 3 Core Operating Limits Report Revision 31 ML23116A2772023-04-26026 April 2023 Independent Spent Fuel Storage Installation, Annual Radioactive Effluent Release Report 2022 ML23115A4012023-04-26026 April 2023 Review of the 2022 Steam Generator Tube Inspections During Refueling Outage 23 ML23115A4982023-04-25025 April 2023 2022 Annual Environmental Operating Report IR 05000528/20230122023-04-19019 April 2023 Notification of Commercial Grade Dedication Inspection (05000528/2023012, 05000529/2023012, and 05000530/2023012) and RFI ML23108A0342023-04-18018 April 2023 NRC Initial Operator Licensing Examination Approval 05000528/2023301; 05000529/2023301; 05000530/2023301 ML23103A4642023-04-13013 April 2023 Annual Radiological Environmental Operating Report 2022 ML23103A4312023-04-13013 April 2023 Emergency Core Cooling System Performance Evaluation Models, 10 CFR 50.46(a)(3)(ii) Annual Report for 2022 IR 05000528/20224012023-04-13013 April 2023 Cyber Security Inspection Report 05000528/2022401 and 05000529/2022401 and 05000530/2022401 ML23102A3292023-04-12012 April 2023 Application for Authorized Use of Mururoa Single-Use, Supplied Air Suits, Models V4F1 and MTH2 ML23102A3242023-04-12012 April 2023 Supplement to Application to Revise Technical Specifications to Adopt TSTF-107-A, Separate Control Rods That Are Untrippable Versus Inoperable ML23089A4002023-03-30030 March 2023 Consolidated Decommissioning Funding Status Report - 2022 ML23088A4012023-03-30030 March 2023 Project Manager Assignment IR 05000528/20234022023-03-29029 March 2023 and 3 - NRC Security Inspection Report 05000528-2023402, 05000529-2023402, and 05000530-2023402, (Cover Letter Only) ML23080A3002023-03-21021 March 2023 Present Levels of Financial Protection 2024-01-19
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML24012A2452024-01-12012 January 2024 Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML23299A3052023-10-26026 October 2023 Response to Request for Additional Information Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle ML23048A3202023-02-17017 February 2023 Response to NRC Requests for Additional Information Regarding 2022 Unit 1 Steam Generator Tube Inspections ML22090A0802022-03-31031 March 2022 Response to NRC Requests for Additional Information Regarding 2021 Unit 3 Steam Generator Tube Inspections ML22053A2122022-02-22022 February 2022 Response to Requests for Confirmation of Information for Exemption from Certain Requirements of 10 CFR 50.62(c)(1) Using Risk-Informed Process for Evaluations ML21173A3602021-06-22022 June 2021 Response to Request for Additional Information for Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML21061A1562021-02-26026 February 2021 Spent Fuel Storage Installation, Response to Request for Additional Information Regarding Application for Order Approving Indirect Transfers of Control of Licenses ML21005A2712020-12-29029 December 2020 102-08208 PVNGS Communication Required by Confirmatory Order EA-20-054 ML20090L9442020-03-30030 March 2020 APS Response to Request for Additional Information- Relief Request 65 Unit 2, COVID-19, Request for Relief from Bottom Mounted Instrumentation Nozzles and a Pressurizer Nozzle to Surge ML20073R7532020-03-13013 March 2020 Independent Spent Fuel Storage Installation (ISFSI) - APS Response to Request for Additional Information for Changes to PVNGS Emergency Plan Staffing Requirements ML20054A2692020-02-19019 February 2020 Response to Request for Additional Information - Relief Request 64 - Unit 1 Impractical Examinations for the Third 10-Year Inservice Inspection Interval ML19340B2142019-12-0606 December 2019 Response to NRC Request for Additional Information Regarding 2019 Steam Generator Tube Inspections ML19331A3612019-11-26026 November 2019 Supplemental Response to NRC Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome CE16HTP Fuel ML19277J4572019-10-0404 October 2019 Response to NRC Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome CE16HTP Fuel ML19165A1402019-06-14014 June 2019 Response to Request for Additional Information - Relief Request 63 - Unit 3 Impractical Examinations for the Third 10-Year Inservice Inspection Interval ML19137A1182019-05-17017 May 2019 Response to NRC Staff Request for Additional Information from Reactor Assessment and Human Performance Branch Regarding License Amendment and Exemption Requests Related to the Implementation of Framatome High Thermal ML19074A1382019-03-14014 March 2019 Response to Request for Additional Information - Relief Request 62 - Third and Fourth 10-Year Inservice Inspection Intervals, Proposed Alternative - Pressurizer Heater Sleeve Repairs ML19031C9052019-01-31031 January 2019 Supplemental License Amendment Request to Revise Technical Specifications Regarding Response Time Testing of Pressure Transmitters and Request for Additional Information Response ML18296A4662018-10-18018 October 2018 Supplemental Information Regarding License Amendment Request and Exemption Request to Support the Implementation of Framatome High Thermal Performance Fuel ML18278A2952018-10-0505 October 2018 Response to Request for Additional Information for Risk-Informed Completion Times Supplemental Responses for Items 17.f and 21 ML18264A3182018-09-21021 September 2018 Response to Request for Additional Information for Risk-Informed Completion Times ML18194A9142018-07-13013 July 2018 Supplemental Response to Request for Additional Information 3.a for License Amendment Request to Adopt 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components ML18152B8742018-06-0101 June 2018 Response to Electrical Engineering Operating Reactor Branch (Eeob) Request for Additional Information for Risk-Informed Completion Times ML18138A4802018-05-18018 May 2018 Response to Request for Additional Information for Risk-Informed Completion Times ML18129A4482018-05-0909 May 2018 APS Response to Request for Additional Information for License Amendment Request to Adopt 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems, and Components ML17272B0332017-09-29029 September 2017 Response to Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests ML17153A3732017-06-0202 June 2017 Response to NRC Staff Request for Additional Information Regarding License Amendment and Exemption Requests Related to the Implementation of Next Generation Fuel ML17144A3762017-05-24024 May 2017 Supplemental Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis ML17002A0012017-01-0202 January 2017 Response to NRC Requests for Additional Information (Rais) Regarding Emergency License Amendment Request (LAR) to Extend Diesel Generator 3B Completion Time ML17066A1842017-01-0202 January 2017 Response to NRC Requests for Additional Information (Rais) Regarding Emergency License Amendment Request (LAR) to Extend Diesel Generator 3B Completion Time ML16358A7152016-12-23023 December 2016 Response to Request for Additional Information Regarding Emergency License Amendment Request for a One-Time Extension of the Diesel Generator Completion Time ML16340A9882016-12-0101 December 2016 Addendum to Supplemental Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors ML17167A2152016-11-23023 November 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised ... ML16321A0022016-11-0909 November 2016 Response to RAI, Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis - Revised Technical Specifications and Bases and WCAP-18030, Revision 1 ML16300A1562016-10-26026 October 2016 Response to NRC Electrical Engineering Branch Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay ... ML16286A2422016-10-0606 October 2016 Westinghouse Electric Company, WCAP-18030-NP Review, Suggested Response to Request for Additional Information ML16286A2402016-10-0606 October 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Criticality Safety Analysis ML16257A5442016-09-0909 September 2016 Response to NRC Instrumentation and Controls Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications ML16203A3812016-07-21021 July 2016 Response to NRC Staff Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Related to Degraded and Loss of Voltage Relay Modifications ML16182A5192016-06-30030 June 2016 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Incorporate Updated Critical Safety Analysis ML16147A0922016-05-20020 May 2016 Response to Request for Additional Information Regarding Relief Request 54, Alternative to Flaw Removal ML16133A6212016-05-12012 May 2016 ISFSI - Response to Request for Additional Information Regarding Proposed Changes to Emergency Action Levels ML16102A4632016-04-11011 April 2016 Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505 ML16029A5062016-01-29029 January 2016 Response to Request for Additional Information Regarding the Request to Change the Quality Assurance Program Description ML15273A4702015-09-30030 September 2015 IR 05000528/2015004, 05000529/2015004, and 05000530/2015004; 11/16/2015 - 11/20/2015; Palo Verde Nuclear Generating Station, Units 1, 2, and 3 - Notification of NRC Triennial Heat Sink Performance Inspection ML15258A8482015-09-15015 September 2015 Response to Request for Additional Information Regarding Exigent License Amendment Request to Amend Technical Specification Surveillance Requirement 3.1.5.3 ML15223A2062015-08-0606 August 2015 Response to Request for Additional Information Associated with Seismic Hazard and Screening Report ML16133A3262015-05-0101 May 2015 Response to NRC Request for Flood Hazard Reevaluation Model Files ML18192A3891975-12-31031 December 1975 Public Service Company of New Mexico 1974 Annual Report, as Response to Request for Additional Financial Information ML18192B2781975-10-21021 October 1975 Response to NRC Liquefaction Questions. Review of Liquefaction Analysis in Parallel with the Site Dewatering Program 2024-01-12
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10 CFR 50.55a Qaps MARIA L. LACAL Senior Vice President, Nuciear Reguiatory & Oversight 102-07589-MLIVMDD Palo Verde Nuclear Generating Station September 29, 2017 P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7605 U. S. Nuclear Regulatory Commission Tel 623.393.6491 ATTN: Document Control Desk Washington, DC 20555-0001
References:
- 1. Arizona Public Service Company (APS) letter number 102-07436, Fourth 10-Year Interval Pump and Valve InservIce Testing Program Relief Requests GRR-01, GRR-02, PRR-01, PRR-02, PRR-03, PRR-04, PRR-05, and PRR-06, dated February 23, 2017, [Agencywide Documents Access and Management System (ADAMS) Accession Number ML17054D687]
- 2. APS letter number 102-07459, Supplement Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests PRR-01, PRR-02, PRR-03, PRR-04, PRR-05, and PRR-06, dated March 10, 2017, (ADAMS Accession Number ML17069A319)
- 3. APS letter number 102-07563, Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests PRR-01, PRR-02, PRR-03, PRR-04, PRR-05, and PRR-06, Adoption of 2012 Edition of the American Society of Mechanical Engineers Operation and Maintenance Code dated August 16, 2017, (ADAMS Accession Number ML17228A795)
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Response to Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests In Reference 1, APS transmitted the relief requests for Palo Verde Nuclear Generating Station (PVNGS) pump and valve inservice testing (1ST) program for the fourth 10-year interval for Units 1, 2, and 3. In Reference 2, APS withdrew relief requests GRR-01 and GRR-02, of Reference 1, which related to the use of the 2012 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code and Code Case OMN-20, Inservice Test Frequency. At the time, rulemaking on the 2012 edition of the code was delayed. In Reference 3, APS requested that the remaining relief requests be reviewed pursuant to the 2012 ASME OM Code, after rulemaking on the 2012 code was complete.
The Nuclear Regulatory Commission (NRC) staff provided a request for additional information (RAI) to APS by email dated August 31, 2017. The enclosure to this letter contains the responses to the RAI.
A member of the STARS Alliance LLC Callaway
102-07589-MLI7MDD ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Response to Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Reiief Requests Page 2 No new commitments are being made in this submittal.
If you have any questions about this response, please contact Nuclear Regulatory Affairs Section Leader Matthew Cox at (623) 393-5753.
Sincerely, MLL/MDD/MSC/sma
Enclosure:
APS Response to NRC Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests cc: K. M. Kennedy NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS M. M. Watford O'Banion NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS
Enclosure APS Response to NRC Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests
Enclosure APS Response to NRC Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests Introduction By letter dated February 23, 2017 (Reference 1), and supplemented by letters dated March 10, 2017 (Reference 2) and August 16, 2017 (Reference 3), Arizona Public Service Company (APS) submitted relief requests for the Palo Verde Nuclear Generating Station (PVNGS) pump and valve inservice testing (1ST) program for the fourth 10-year interval for Units 1, 2, and 3.
These relief requests are required for the fourth 10-year 1ST interval. The majority of these relief requests were previously authorized for the PVNGS third 10-year interval by the Nuclear Regulatory Commission (NRC) staff in a letter dated April 24, 2008 [Agencywide Documents Access and Management System (ADAMS) Accession No. ML081050003]. The relief requests that were not previously authorized are GRR-01, GRR-02, and PRR-06. In Reference 2, APS formally withdrew relief requests GRR-01 and GRR-02 of Reference 1, which relate to the use of the 2012 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code and Code Case OMN-20, Inservice Test Frequency, which is an alternative to the test frequency specifications of the ASME OM Code. PRR-06 requests an alternative vibration measuring method from the requirements of the ASME OM Code.
Federal Register Notice (82 FR 136), dated July 18, 2017, published the relevant final rule that incorporated the 2012 Edition of the ASME OM Code into 10 CFR 50.55a, including Code Case OMN-20, with an effective date of August 17, 2017.
In Reference 3, APS requested authorization to use the 2012 Edition of the ASME OM Code fourth 10-year 1ST interval and requested that the remaining relief requests be reviewed pursuant to the 2012 ASME OM Code. The PVNGS fourth interval pump and valve 1ST program, which begins on January 15, 2018 for all three units, has been developed in accordance with the 2012 Edition of the ASME OM Code.
The NRC staff provided a request for additional information (RAI) by email dated August 31, 2017. This enclosure contains the clarifying information in response to the RAI. The NRC RAI is stated first, followed by the APS response.
RAI PRR-03-1 It is stated in the alternative request that the design flow for the Low Pressure Safety Injection (LPSI) pumps is 4,200 gallons per minute (gpm). The proposed alternative is to conduct the Group A test for the LPSI pumps at mini-flow conditions using the minimum flow recirculation line fixed resistance of approximately 180 gpm to establish the specified reference point. Please confirm that the flow rate of 180 gpm is above the manufacturer's minimum continuous stable flow for the LPSI pumps.
Response
LPSI pump operation at the miniflow condition is managed and controlled to preclude pump degradation during testing because flow is below the manufacturer's minimum continuous stable flow of 2400 gpm.
Letter 161-04032, dated July 1, 1991, (ADAMS Accession No. 9107120005) documents the APS response to NRC Bulletin 88-04, Potential Safety-Related Pump Loss. Action number 3 of the bulletin requested an evaluation of the adequacy of the minimum flow bypass lines
Enclosure APS Response to NRC Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests for safety-related centrifugal pumps with respect to damage resulting from operation and testing in the minimum flow mode. Attachment 1 to the letter states in part:
"The vendor's evaluation of the Safety Injection pumps indicated that the specified miniflow rates are below the minimum continuous stable flow point; however, the vendor never intended and recommends against running the pumps on miniflow for extended periods of time. At PVNGS, administrative controls and operating procedures are such that the Safety Injection pumps are not operated for extended periods of time at miniflow in accordance with the vendor technical manual recommendations." states in part:
"Ingersoll-Rand verified the Safety Injection miniflow rates are sufficient to ensure no pump damage from low flow operation for short periods of time."
The NRC staff commented that the APS response to Bulletin 88-04 is considered complete, as documented in a letter dated October 11, 1989 (ADAMS Accession No. 8910250222).
Current operating and inservice testing procedures, design calculations, and vendor technical guidance were reviewed to confirm the stated controls remain in effect. It was determined that the pumps continue to be operated and tested consistent with the Bulletin 88-04 response.
Under the 1ST program, the LPSI pump quarterly Group A test procedure limits pump operating time based on flow rate. Operation at the 180 gpm miniflow rate is limited to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, providing margin to the vendor guidance. The manufacturer's minimum flow for safe operation is 100 gpm for less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Operators ensure pump run-time limits are met during quarterly testing at the minimum flow condition.
APS procedures reflect awareness that LPSI pump minimum recirculation flow lines are sized to allow pump operation on a time-limited basis. Miniflow test flow rates are greater than the manufacturer-specified minimum flow for safe operation for a limited duration. Test procedures limit pump operation time at miniflow conditions, which meets manufacturer guidance to preclude pump degradation during testing. LPSI pump testing on minimum flow has been controlled in this manner since the 1990s. Relief requests identical to PRR-03 have been approved by the NRC staff for previous 1ST intervals. APS desires to continue testing at this condition to ensure future performance data can be trended with respect to more than 20 years of test data history.
RAl PRR-04-1 It is stated in the alternative request that the design flow for the High Pressure Safety Injection (HPSI) pumps is 815 gpm. The proposed alternative is to conduct the Group B test for the HPSI pumps at mini-flow conditions using the minimum flow recirculation line fixed resistance of approximately 170 gpm to establish the specified reference point. Please confirm that the flow rate of 170 gpm is above the manufacturer's minimum continuous stable flow for the HPSI pumps.
Response
HPSI pump operation at the miniflow condition is managed and controlled to preclude pump degradation during testing because flow is below the manufacturer's minimum continuous stable flow of 225 gpm.
Enclosure APS Response to NRC Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests As previously described in the response to RAI PRR-03-1, APS operating and inservice testing procedures, design calculations, and vendor technical guidance were reviewed to confirm implementation of the Bulletin 88-04 response statements. It was determined that the pumps continue to be operated and tested consistent with the Bulletin 88-04 response.
Under the 1ST program, the HPSI pump quarterly Group B test procedure limits pump operating time based on flow rate. Operation at the 170 gpm miniflow rate is limited to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, providing margin to the vendor guidance. The manufacturer's minimum flow for safe operation of less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is 85 gpm. Operators ensure pump run-time limits are met during quarterly testing at the minimum flow condition.
APS procedures reflect awareness that HPSI pump minimum recirculation flow lines are sized to allow pump operation on a time-limited basis. Miniflow test flow rates are greater than the manufacturer-specified minimum flow for safe operation for a limited duration.
Relief requests identical to PRR-04 have been approved by NRC in previous 1ST intervals.
APS desires to continue testing at this condition to ensure future performance data can be trended with respect to more than 20 years of test data history.
RAI PRR-05-1 It is stated in the alternative request that the design flow for the containment spray (CS) pumps is 3890 gpm. The proposed alternative is to conduct the Group A test for the CS pumps at mini-flow conditions using the minimum flow recirculation line fixed resistance of approximately 190 gpm to establish the specified reference point. Please confirm that the flow rate of 190 gpm is above the manufacturer's minimum continuous stable flow for the CS pumps.
Response
CS pump operation at the miniflow condition is managed and controlled to preclude pump degradation during testing because flow is below the manufacturer's minimum continuous stable flow of 2100 gpm.
As previously described in the response to RAI PRR-03-1, APS operating and inservice testing procedures, design calculations, and vendor technical guidance were reviewed to confirm implementation of the Bulletin 88-04 response statements. It was determined that the pumps continue to be operated and tested consistent with the Bulletin 88-04 response.
Under the Inservice Testing Program, the CS pump quarterly Group A test procedure limits pump operating time based on flow rate. Operation at the 190 gpm miniflow rate is limited to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, providing margin to the vendor guidance. The manufacturer's minimum flow for safe operation is 150 gpm for less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Operators ensure pump run-time limits are met during quarterly testing at minimum flow conditions.
APS procedures demonstrate awareness that CS pump minimum recirculation flow lines are sized to allow pump operation on a time-limited basis. Miniflow test flow rates are greater than the manufacturer-specified minimum flow for safe operation for a limited duration.
Relief requests identical to PRR-05 have been approved by NRC in previous 1ST intervals.
APS desires to continue testing at this condition to ensure future performance data can be trended with respect to more than 20 years of test data history.
Enclosure APS Response to NRC Request for Additional Information Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests References
- 1. Arizona Public Service Company (APS) letter number 102-07436, Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests GRR-01, GRR-02, PRR-01, PRR-02, PRR-03, PRR-04, PRR-05, and PRR-06, dated February 23, 2017 (ADAMS Accession Number ML17054D687)
- 2. APS letter number 102-07459, Supplement Regarding Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests PRR-01, PRR-02, PRR-03, PRR-04, PRR-05, and PRR-06, dated March 10, 2017 (ADAMS Accession Number ML17069A319)
- 3. APS letter number 102-07563, Fourth 10-Year Interval Pump and Valve Inservice Testing Program Relief Requests PRR-01, PRR-02, PRR-03, PRR-04, PRR-05, and PRR-06, Adoption of 2012 Edition of the American Society of Mechanical Engineers Operation and Maintenance Code dated August 16, 2017 (ADAMS Accession Number ML17228A795)