ML17313B072

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Forwards RAI Re Licensee 980317 Submittal of Second 10-year ISI Program for Plant,Units 1,2 & 3.Mutually Agreeable Target Date of within 30 Days of Date of Ltr for Response Was Established
ML17313B072
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 08/31/1999
From: Kalyanam N
NRC (Affiliation Not Assigned)
To: Overbeck G
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
TAC-MA3559, TAC-MA3560, TAC-MA3561, NUDOCS 9909030096
Download: ML17313B072 (9)


Text

August 31, 1999 MrsGreg/ R. Overbeck Senior Vice President, Nuclear Arizona Public Service Company P. O. Box 52034 Phoenix, AZ 85072-0234

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION UNITS 1, 2 AND3-SECOND 10-YEAR INTERVALINSERVICE INSPECTION - REQUEST FOR ADDITIONALINFORMATION(TAC NOS. MA3559, MA3560, AND MA3561)

Dear Mr. Overbeck:

By letter number 102-04095-WEI/AKK/MLG, dated March 17, 1998, Arizona Public Service Company submitted the Second 10-Year Inservice Inspection (ISI) Program for Palo Verde Nuclear Generating Station, Units 1, 2, and 3. Contained in the program were requests for relief from American Society of Mechanical Engineers (ASME)Section XI requirements RR1, RR2, RR3, RR4, RR5, RR6, RR7, RR8 and RR9. Subsequently, by your letter of July 2, 1999, you withdrew RR5, which proposed an alternative to the visual examination of component supports, including snubbers.

In its place, you requested the use of an alternative to

, categorizing component supports and performing VT-3 examination on a selected percentage of each category as specified in ASME Section XI, Table IWF-2500-1. The information in the enclosure is required to complete the evaluation of the subject requests for relief.

, The enclosed request was discussed with your staff on July 17, 1999. A mutually agreeable target date of within 30 days of the date of this letter for your response was established.

If circumstances result in the need to revise the target date, please call me at the earliest opportunity. Ifyou have any questions, please call me at 301-415-1480.

Sincerely,

/s/

N. Kalyanam, Project Manager, Section 2 Project Directorate IV 8 Decommissioning qq0903009'6 9'f0831 Division of Licensing project Management PDR ADQCK 0>000528 Office of Nuclear Reactor Regulation PDR

'i Docket Nos. STN 50-528,'STN 50-529, and I'TN 50-530

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&4001 August 31, 1999 Mr. Gregg R. Overbeck Senior Vice President, Nuclear Arizona Public Service Company P. O. Box 52034 Phoenix, AZ 85072-0234

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION UNITS 1, 2 AND3-SECOND 10-YEAR INTERVALINSERVICE INSPECTION - REQUEST FOR ADDITIONALINFORMATION(TAC NOS. MA3559, MA3560, AND MA3561)

Dear Mr. Overbeck:

By letter number 102-04095-WEI/AKK/MLG,dated March 17, 1998, Arizona Public Service Company submitted the Second 10-Year Inservice Inspection (ISI) Program for Palo Verde Nuclear Generating Station, Units 1, 2, and 3. Contained in the program were requests for relief from American Society of Mechanical Engineers (ASME)Section XI requirements RR1, RR2, RR3, RR4, RR5, RR6, RR7, RR8 and RR9. Subsequently, by your letter of July 2, 1999, you withdrew RR5, which proposed an alternative to the visual examination of component supports, including snubbers.

In its place, you requested the use of an alternative to categorizing component supports and performing VT-3 examination on a selected percentage of each category as specified in ASME Section XI, Table IWF-2500-1. The information in the enclosure is required to complete the evaluation of the subject requests for relief.

The enclosed request was discussed with your staff on July 17, 1999. A mutually agreeable target date of within 30 days of the date of this letter for your response was established.

If circur..stances result in the need to revise the target date, please call me at the earliest opportunity.

Ifyou have any questions, please call me at 301<15-1480.

Sincerely, N. Kalyanam, Project Manager, Section 2 Project Directorate IV 8 Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN 50-530

Enclosure:

Request for Additional Information ccw/encl: See next page

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i Palo Verde Generating Station, Units 1, 2, and 3 a

CC:

Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Mr. David Summers Public Service Company of New Mexico 414 Silver SW, ¹1 206 Albuquerque, NM 87102 Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800

Rosemead, CA 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box40 Buckeye, AZ 85326 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower 8 Pavillion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix; AZ 85003 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, AZ 85040 Mr. Jarlath Curran Southern California Edison Company 5000 Pacific Coast Hwy Bldg DIN San Clemente, CA 92672 Mr. Robert Henry Salt River Project 6504 East Thomas Road Scottsdaie, AZ 85251 Terry Bassham, Esq.

General Counsel El Paso Electric Company 123 W. Mills El Paso, TX 79901 Mr. John Schumann Los Angeles Department of Water 8 Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Michael T. Anderson INEEL, Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, ID 83415-2209 Ms. Angela K. Krainik, Director Regulatory Affairs Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034 Mr. John C. Horne Vice President, Power Generation El Paso Electric Company 2702 N. Third Street, Suite 3040 Phoenix, AZ 85004 Augusi 19, 1999

SECOND 10-YEAR INTERVALINSERVICE INSPECTION PALO VERDE NUCLEAR GENERATING STATION UNITS 1 2 AND 3 RE VEST FOR ADDITIONALINFORMATION TAC NOS. MA3559 MA3560 AND IVIA3561 1.

Request for Relief No. 1 proposes to use the 1992 Edition with the 1992 Addenda in lieu of the 1989 Edition, which is currently the latest Code approved in Title 10 of the Code ofFederal Regu/afions.

The licensee's basis stated that "A detailed itemized listing (provided by another utility) of the differences between Code years has been previously reviewed and found to be an acceptable level of quality and safety." To date, the staff is unaware of another utilitythat has been authorized to use the 1992 Edition with the 1992 Addenda (Entergy Operations, Inc., was allowed to use the 1992 Edition with portions of the 1993 Addenda), and it is required that each licensee submit a detailed comparison supporting the licensee's basis for this type of proposed alternative.

Therefore, provide a detailed comparison of the Code changes between the 1989 Edition and the 1992 Edition/Addenda and describe how each change provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i).

Request for Relief No. 3 proposed to use the 1992 Edition with the 1992 Addenda for the repair and replacement of Code items.

It appears that this proposed alternative is redundant and should be covered by Request for Relief No. 1, which generically proposes to use of the 1992 Edition/Addenda.

It is unclear why Request for Relief No. 3 is necessary.

Provide clarification regarding the scope of this request for relief. If it is determined that this request is necessary, provide a detailed comparison of the Code changes between the 1989 Edition and the 1992 Edition/Addenda and describe how each change provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i).

3.

Request for Relief No. 4 proposes to perform the Code-required VT-3 visual examination of component supports to the extent practical without removing insulation.

However, the proposed alternative is not adequately justified. To be found acceptable, describe how the proposed alternative provides an acceptable level of quality and safety.

Ifthe proposed alternative includes an expanded examination sample, confirm and describe the expanded examination sample.

Request for Relief No. 6 proposes an alternative to the pressure testing requirements of the Code and Code Case N-498-1 for containment penetrations.

The. proposed alternative appears to be similar to Code Case N-522 Pressure Testing of Containment Penetration Piping;- which specifies that 10 CFR Part 50, Appendix J testing may be used as an alternative to Section XI pressure tests for certain containment penetration piping. Other plants have been allowed to use Enclosure

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Code Case N-522 when the Appendix J testing is performed at no less than the peak calculated containment pressure, and procedures and techniques capable of detecting and locating through-wall leakage are used.

Is Code Case N-522 applicable for all of the subject piping'f Code Case N-522 is applicable, confirm that the Appendix J testing willbe performed at no less than the peak calculated containment pressure and willuse procedures and techniques capable of detecting and locating through-wall leakage.

IfCode Case N-522 is not applicable, describe why th8 Code requirements cannot be met, and how the use of Appendix J testing provides an acceptable level of quality and safety.

Request for Relief No. 9 proposes an alternative to the pressure testing requirements of the Code and Code Case NQ98-1 for a number of Class 1 piping segments downstream of the first isolation valve. Describe the size and extent of the piping segments contained in this request for relief.

Note:

Request for Relief No. 5 proposes an alternative to the visual examination of component supports, including snubbers.

However, this request was withdrawn by Arizona Public Service Company (APS) by letter dated July 2, 1999.

In its place, APS has requested the use of an alternative to categorizing component supports and performing VT-3 examination on a select percentage of each category as specified in ASME Section XI, Table IWF-2500-1.

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