ML17313B065
| ML17313B065 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/30/1999 |
| From: | Kraninik A ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-64FR13832, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 102-04320-AKK-S, 64FR13832-00006, NUDOCS 9908240041 | |
| Download: ML17313B065 (6) | |
Text
CATEGORY 2 REGULA1 Y INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9908240041 DOC.DATE: 99/07/30 NOTARIZED: NO DOCKET I.
FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi 05000530 AUTH.NAME, AUTHOR AFFILIATION KRANINIK,A.'rizonaPublic Service Co.
(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Rules
& Directives Review Branch (Post 920323)
C
SUBJECT:
Comment on draft RG DG-'1076, "Service Level I,II & III Protective Coatings Applied to NPPS."
A D1'STR1BUTION CODE:
DS09D COPIES RECEIVED: LTR l ENCL Q SIZE:
T TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Notice;Reg G
E NOTES: STANDARDIZED PLANT 05000528 Standardized plant.
05000529G Standardized plant.
05000530 0 RECIPIENT ID. CODE/NAME INTERNAL ILE CE OGC/DR 15-B-18 RES/BERANEK,A.
RES/PMDAS/AMT EXTERNAL: NRC PDR COPIES LTTR ENCL 1
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1 RECXPIENT ID CODE/NAME NMSS/IMOB T8F5 RES DIR RES/DST COPIES LTTR ENCL D
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NOTE TO ALL'RIDS" RECIPIENTS:
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Commitment, Innovation, Energy Palo Verde Nuclear Generating Station Angela K. Krainik
- Director, Regutatory Affairs Tel. 623-393-5421 Fax 623-393-5442 Mail Station 7636 PO Box 52034 Phoenix, Arizona 65072-2034 Rules and Directives Branch Office ofAdministration U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 102-04320-AKK/SAB/JAP July 30, 1999
Dear Sirs:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Comments on Draft Regulatory Guide DG-1076, "Service Level I, II, and lll Protective Coatings Applied to Nuclear Power Plants."
Arizona Public Service Company (APS) submits the following comments in response to the Nuclear Regulatory Commission's (NRC) request for comments on Draft Regulatory Guide DG-1076, "Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants."
(Federal Receister: March 22, 1999, Volume 64, Number 54l, Arizona Public Service has participated in an industry effort with NEI to develop industry comments.
Additionally, APS submits the following comments on this proposed draff regulatory guide.
Section C. Regulatory Position, item ¹2, of this proposed change lists definitions. There are no definitions related to Immersion Service where the coating failure could adversely affect the operation of the plant.
Additionally, there should be a "Service Level IV" definition for Balance of Plant Coatings which are not covered in other service level definitions, willnot affect plant operation, and can be applied as commercial coating work (painting). The following are the recommended changes to the Service Level I, II, and III coating definitions:
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Rules anU Directives Branch Office of Administration U. S. Nuclear Regulatory Commission Comments on Draft Regulatory Guide DG-1076, "Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants" Page 2 (2) Service Level I, II, III, and IV coating applications are defined as:
~
Service Level I coating applications are used in areas where the coating failure could impair safe shutdown, or could adversely affect the operation of post-accident fluid systems.
. With few exceptions, Service Level 1 applies to coatings inside primary containment.
~
Service Level II coating applications are used to provide corrosion protection and to improve the ability to decontaminate those areas outside primary containment that are subject to radiation exposure and radionuclide contamination.
~
Service Level III coating applications are used on any expesed immersion surface area whose failure could adversely affect normal plant operation or orderly and safe plant shutdown.
~
Service Level IVor balance of plant coating applications are used for areas not covered in other Service Levels. These areas do not affect plant operations and coatings can be applied as commercial coating work (painting).
No commitments are being made to the NRC by this letter.
Ifyou have any questions, please contact Scott A. Bauer at (623) 393-5978.
Sincerely, AKK/SAB/JAP/rlh cc:
E. W. Merschoff N. Kalyanam J. H. Moorman
PFCF lVEG Iggg AUG10 t4'I 9:24 RULES 5 DiR. BRANCH US NRC