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| | number = ML13030A401 | | | number = ML13030A401 |
| | issue date = 01/30/2013 | | | issue date = 01/30/2013 |
| | title = Request for Additional Information E-mail, Relief Request 49, Alternative to ASME Code Section Xi for Reactor Vessel Head Flange Seal Leak Detection Piping, Third 10-Year Inservice Inspection Interval (TAC MF0447-MF0449) | | | title = Request for Additional Information E-mail, Relief Request 49, Alternative to ASME Code Section XI for Reactor Vessel Head Flange Seal Leak Detection Piping, Third 10-Year Inservice Inspection Interval (TAC MF0447-MF0449) |
| | author name = Gibson L K | | | author name = Gibson L |
| | author affiliation = NRC/NRR/DORL/LPLIV | | | author affiliation = NRC/NRR/DORL/LPLIV |
| | addressee name = Roehler R | | | addressee name = Roehler R |
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| | docket = 05000528, 05000529, 05000530 | | | docket = 05000528, 05000529, 05000530 |
| | license number = NPF-041, NPF-051, NPF-074 | | | license number = NPF-041, NPF-051, NPF-074 |
| | contact person = Gibson L K | | | contact person = Gibson L |
| | case reference number = TAC MF0447, TAC MF0448, TAC MF0449 | | | case reference number = TAC MF0447, TAC MF0448, TAC MF0449 |
| | document type = E-Mail, Request for Additional Information (RAI) | | | document type = E-Mail, Request for Additional Information (RAI) |
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| =Text= | | =Text= |
| {{#Wiki_filter:Lent, Susan From: Gibson, Lauren Sent: Wednesday, January 30, 20132:40 PM To: 'Robert. Roehler@aps.com' | | {{#Wiki_filter:Lent, Susan From: Gibson, Lauren Sent: Wednesday, January 30, 20132:40 PM To: 'Robert. Roehler@aps.com' |
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| ==Subject:== | | ==Subject:== |
| RAls for RR49 Reactor Vessel Head Flange Seal Leak Detection Piping (TAC Nos. MF0447, 8,9) Attachments: | | RAls for RR49 Reactor Vessel Head Flange Seal Leak Detection Piping (TAC Nos. MF0447, 8,9) |
| MF0447 RAls.doc Rob, By letter dated December 19, 2012 (Agencywide Document Access and Management System (ADAMS) Accession No. ML 12361A256), Arizona Public Service Company (APS, the licensee) submitted "Reactor Pressure Vessel Head Flange Seal Leak Detection Piping -Relief Request No. 49" for U. S. Nuclear Regulatory Commission (NRC) review and authorization. | | Attachments: MF0447 RAls.doc Rob, By letter dated December 19, 2012 (Agencywide Document Access and Management System (ADAMS) |
| The licensee has proposed an alternative to the system leakage test of reactor pressure vessel (RPV) flange leak-off line that is required by the American Society of Mechanical Engineers (ASIVIE) Boiler and Pressure Vessel Code (Code), Section XI, Table 2500-1, Examination Category C-H, at Palo Verde Nuclear Generating Station (PVNGS), Units 1,2, and 3. Specifically, instead of pressurizing the subject lines to the system leakage test pressure required by IWC-5221, the licensee proposes to pressurize the line using the static pressure head of the refueling water prior to performing a VT-2 visual examination. | | Accession No. ML12361A256), Arizona Public Service Company (APS, the licensee) submitted "Reactor Pressure Vessel Head Flange Seal Leak Detection Piping - Relief Request No. 49" for U. S. Nuclear Regulatory Commission (NRC) review and authorization. The licensee has proposed an alternative to the system leakage test of reactor pressure vessel (RPV) flange leak-off line that is required by the American Society of Mechanical Engineers (ASIVIE) Boiler and Pressure Vessel Code (Code), Section XI, Table IWC 2500-1, Examination Category C-H, at Palo Verde Nuclear Generating Station (PVNGS), Units 1,2, and 3. |
| In order to complete our review, the staff requests the following additional information. | | Specifically, instead of pressurizing the subject lines to the system leakage test pressure required by IWC-5221, the licensee proposes to pressurize the line using the static pressure head of the refueling water prior to performing a VT-2 visual examination. In order to complete our review, the staff requests the following additional information. |
| The Nuclear Regulatory Commission (NRC) staff has reviewed the submitted information and determined that the additional information identified in the enclosure is needed to complete its review. On January 30, you confirmed a response date of February 22, 2013. Thank you, Lauren Lauren K. Gibson Project Manager Columbia Generating Station Palo Verde Nuclear Generating Station Division of Operatillg Reactor Licensing U.S. Nuclear Regulatory Commission (301) 415-1056 1 REQUEST FOR ADDITIONAL INFORMATION REACTOR VESSEL HEAD FLANGE SEAL LEAK DETECTION PIPING -RELIEF REQUEST NO. 49 ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1,2, AND 3 DOCKET NOS. SO-S28, SO-S29, AND SO-S30 By letter dated December 19, 2012 (Agencywide Document Access and Management System (ADAMS) Accession No. ML 12361A2S6), Arizona Public Service Company (APS, the licensee) submitted "Reactor Pressure Vessel Head Flange Seal Leak Detection Piping -Relief Request No. 49" for U. S. Nuclear Regulatory Commission (NRC) review and authorization. | | The Nuclear Regulatory Commission (NRC) staff has reviewed the submitted information and determined that the additional information identified in the enclosure is needed to complete its review. |
| The licensee has proposed an alternative to the system leakage test of reactor pressure vessel (RPV) flange leak-off line that is required by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code), Section XI, Table IWC-2S00-1, Examination Category C-H, at Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3. Specifically, instead of pressurizing the subject lines to the system leakage test pressure required by IWC-S221, the licensee proposes to pressurize the line using the static pressure head of the refueling water prior to performing a VT -2 visual examination. I n order to complete our review, the staff requests the following additional information. What are the scheduled end dates for the PVNGS, Unit 1,2, and 3 third inservice inspection The proposed alternative is being submitted pursuant to Title 10 of the Code of Federal Regulations, Part SO (10 CFR SO), paragraph SSa(g)(S)(ii), revised inservice inspection program for a facility conflicts with the technical specification for the facility, but cites the provisions of 10 CFR SO.SSa(a)(3)(ii), hardship without a compensating increase in the level of quality and safety. Please confirm that the relief request is being submitted pursuant to 10 CFR SO.SSa(a)(3)(ii). Provide a brief description of the operation of the RPV flange seal leak detection system, i.e., how the pressure in the leak-off line is measured and monitored, how the operators are alerted to a leakage condition and how they respond. If O-ring leakage trips the leak-off alarm and rapid depressurization of the leak-off line subsequently occurs, does the control room annunciator continue to show an indication? Are there other control room indications of O-ring leakage? Provide a piping and instrumentation diagram (P&ID) and a piping isometric drawing showing the RPV flange seal leak detection piping. What is the material of construction of the leak-off line? ENCLOSURE | | On January 30, you confirmed a response date of February 22, 2013. |
| -Describe PVNGS experience with degradation (corrosion, stress corrosion cracking, fatigue, etc.) of the RPV flange seal leak detection piping. Potential O-ring leakage during service is detected with a pressure element in the off line. The proposed alternative would utilize the static fluid head of the refueling water to pressurize the leak-off line prior to a VT-2 examination. What is the fluid head pressure that exists in the line when the refueling cavity has been filled to its normal refueling water level? What is the trip pressure for the O-ring leakage alarm indication in the control room? Discuss whether a system leakage test of the RPV flange seal leak detection piping could be performed at a pressure higher than that of the refueling water fluid head prior to removing the head at the beginning of the refueling outage. Describe any hardship associated with this sequence. In order for a fluid leak in a pressurized line to be observed with a VT-2 examination, sufficient time must have elapsed between the time that the line was pressurized and the time that the examination is performed. | | Thank you, Lauren Lauren K. Gibson Project Manager Columbia Generating Station Palo Verde Nuclear Generating Station Division of Operatillg Reactor Licensing U.S. Nuclear Regulatory Commission (301) 415-1056 1 |
| Specify the minimum time between the time that the line is pressurized and the time that the VT-2 examination is performed for both uninsulated lines and insulated lines (as appropriate). | | |
| Provide a technical justification based on the pressure in the leak-off line during the leakage test for the hold time.}} | | REQUEST FOR ADDITIONAL INFORMATION REACTOR VESSEL HEAD FLANGE SEAL LEAK DETECTION PIPING - RELIEF REQUEST NO. 49 ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1,2, AND 3 DOCKET NOS. SO-S28, SO-S29, AND SO-S30 By letter dated December 19, 2012 (Agencywide Document Access and Management System (ADAMS) Accession No. ML 12361A2S6), Arizona Public Service Company (APS, the licensee) submitted "Reactor Pressure Vessel Head Flange Seal Leak Detection Piping - Relief Request No. 49" for U. S. Nuclear Regulatory Commission (NRC) review and authorization. The licensee has proposed an alternative to the system leakage test of reactor pressure vessel (RPV) flange leak-off line that is required by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code), Section XI, Table IWC-2S00-1, Examination Category C-H, at Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3. |
| | Specifically, instead of pressurizing the subject lines to the system leakage test pressure required by IWC-S221, the licensee proposes to pressurize the line using the static pressure head of the refueling water prior to performing a VT-2 visual examination. In order to complete our review, the staff requests the following additional information. |
| | : 1. What are the scheduled end dates for the PVNGS, Unit 1,2, and 3 third 10-year inservice inspection interval? |
| | : 2. The proposed alternative is being submitted pursuant to Title 10 of the Code of Federal Regulations, Part SO (10 CFR SO), paragraph SSa(g)(S)(ii), revised inservice inspection program for a facility conflicts with the technical specification for the facility, but cites the provisions of 10 CFR SO.SSa(a)(3)(ii), hardship without a compensating increase in the level of quality and safety. Please confirm that the relief request is being submitted pursuant to 10 CFR SO.SSa(a)(3)(ii). |
| | : 3. Provide a brief description of the operation of the RPV flange seal leak detection system, i.e., how the pressure in the leak-off line is measured and monitored, how the operators are alerted to a leakage condition and how they respond. |
| | : a. If O-ring leakage trips the leak-off alarm and rapid depressurization of the leak-off line subsequently occurs, does the control room annunciator continue to show an indication? |
| | : b. Are there other control room indications of O-ring leakage? |
| | : 4. Provide a piping and instrumentation diagram (P&ID) and a piping isometric drawing showing the RPV flange seal leak detection piping. |
| | S. What is the material of construction of the leak-off line? |
| | ENCLOSURE |
| | |
| | - 2 |
| | : 6. Describe PVNGS experience with degradation (corrosion, stress corrosion cracking, fatigue, etc.) of the RPV flange seal leak detection piping. |
| | : 7. Potential O-ring leakage during service is detected with a pressure element in the leak off line. The proposed alternative would utilize the static fluid head of the refueling water to pressurize the leak-off line prior to a VT-2 examination. |
| | : a. What is the fluid head pressure that exists in the line when the refueling cavity has been filled to its normal refueling water level? |
| | : b. What is the trip pressure for the O-ring leakage alarm indication in the control room? |
| | : 8. Discuss whether a system leakage test of the RPV flange seal leak detection piping could be performed at a pressure higher than that of the refueling water fluid head prior to removing the head at the beginning of the refueling outage. Describe any hardship associated with this sequence. |
| | : 9. In order for a fluid leak in a pressurized line to be observed with a VT-2 examination, sufficient time must have elapsed between the time that the line was pressurized and the time that the examination is performed. Specify the minimum time between the time that the line is pressurized and the time that the VT-2 examination is performed for both uninsulated lines and insulated lines (as appropriate). Provide a technical justification based on the pressure in the leak-off line during the leakage test for the hold time.}} |
Letter Sequence RAI |
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MONTHYEARML12361A2562012-12-19019 December 2012
Request for Relief from the American Society of Mechanical Engineers (ASME) Code, Section XI, Reactor Vessel Head Flange Seal Leak Detection Piping - Relief Request No. 49
Project stage: Request
ML13009A0842013-01-0909 January 2013
Acceptance Review Email, Relief Request 49, Alternative to ASME Code Section XI for Reactor Vessel Head Flange Seal Leak Detection Piping, Third 10-Year Inservice Inspection Interval
Project stage: Acceptance Review
ML13030A4012013-01-30030 January 2013
Request for Additional Information E-mail, Relief Request 49, Alternative to ASME Code Section XI for Reactor Vessel Head Flange Seal Leak Detection Piping, Third 10-Year Inservice Inspection Interval (TAC MF0447-MF0449)
Project stage: RAI
ML13063A0622013-02-22022 February 2013
Response to Request for Additional Information (RAI) - Request for Relief from the American Society of Mechanical Engineers (ASME) Code, Section XI, Reactor Vessel Head Flange Seal Leak Detection Piping - Relief Request 49
Project stage: Response to RAI
ML13085A2542013-04-0404 April 2013
Relief Request 49, Alternative to ASME Code, Section XI, for Reactor Vessel Head Flange Seal Leak Detection Piping, Third 10-Year Inservice Inspection Interval
Project stage: Other
2013-01-09
[Table View] |
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Category:E-Mail
MONTHYEARML24297A6212024-10-22022 October 2024
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ML24248A2632024-09-0404 September 2024
Acceptance Review of Palo Verde Nuclear Generating Station, Units 1, 2, and 3, Relief Request (RR) No. 71: Re?Submittal of RR?30
ML24242A2812024-08-26026 August 2024
RR72 Acceptance 08/27/24 - La Jr
ML24221A2382024-08-0606 August 2024
Change in Estimated Review Schedule and Level of Effort for Palo Verde Units 1, 2, and 3
ML24143A1112024-05-20020 May 2024
Draft 2nd Round Request for RAIs Concerning LAR to Modify LCO for TS 3.5.2, LCO for TS 3.6.5, and Surveillance Requirements 3.5.1.2 and 3.5.2.2 for TS 3.5.1 and TS 3.5.2
ML24138A1112024-05-16016 May 2024
Draft 2nd Round Request for Additional Information (Rais) Concerning License Amendment Request (LAR) to Modify Limiting Condition for Operation (LCO) for Technical Specification (TS) 3.5.2
ML24123A2002024-05-0101 May 2024
(E-Mail) Draft 2nd Round Request for Additional Information Concerning License Amendment Request to Modify Limiting Condition for Operation (LCO) for Technical Specification (TS) 3.5.2, LCO for TS 3.6.5, 3.5.1.2 and 3.5.2.2 for TS 3.5.1, a
ML24120A2612024-05-0101 May 2024
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ML24114A2812024-04-19019 April 2024
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ML24103A1222024-04-11011 April 2024
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ML23243B0082023-08-31031 August 2023
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ML23233A0132023-08-18018 August 2023
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Acceptance Review of License Renewal Commitment for Pressurizer Surge Line Welds Inspection Program to Manage Environmentally Assisted Fatigue
ML23220A0512023-08-0303 August 2023
NRR E-mail Capture - Re Palo Verde 1, 2, and 3 - SUNSI Review of UFSAR, Rev. 22
ML23202A0162023-07-20020 July 2023
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ML23143A1332023-05-23023 May 2023
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ML23130A0132023-05-10010 May 2023
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Acceptance Review for Authorized Use of Mururoa Supplied Air Suits (Models V4F1 and MTH2) Pursuant to 10 CFR 20.1703 and 10 CFR 20.1705
ML23017A0932023-01-17017 January 2023
NRR E-mail Capture - Palo Verde - Acceptance of License Amendment Request Regarding Adoption of TSTF-107, Separate Control Rods That Are Untrippable Versus Inoperable (L-2022-LLA-0181)
ML23013A0632023-01-13013 January 2023
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ML22348A1672022-12-14014 December 2022
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ML22339A2372022-12-0505 December 2022
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ML22173A0682022-06-17017 June 2022
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ML22167A1872022-06-16016 June 2022
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ML22136A0922022-05-16016 May 2022
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ML22075A1902022-03-16016 March 2022
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ML22055A5842022-02-24024 February 2022
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ML22034A0132022-02-0202 February 2022
NRR E-mail Capture - Palo Verde, Unit 2 - Verbal Approval of RR-69 to Extend Containment Tendon Inspection from 2/8/22 to 6/8/22
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NRR E-mail Capture - Palo Verde 1, 2, and 3 - SUNSI Review of UFSAR, Rev. 21
ML21264A1352021-09-17017 September 2021
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ML21237A0762021-08-25025 August 2021
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ML21228A0082021-08-16016 August 2021
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ML21228A1042021-08-12012 August 2021
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ML21237A5172021-08-10010 August 2021
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ML21160A1442021-06-0909 June 2021
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ML21154A0082021-05-26026 May 2021
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ML21146A3342021-05-14014 May 2021
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ML21132A2372021-05-12012 May 2021
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ML21103A3632021-04-13013 April 2021
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ML21064A2372021-03-0303 March 2021
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ML21053A0262021-02-22022 February 2021
NRR E-mail Capture - Palo Verde 1, 2 and 3 - Acceptance Review of LAR Associated with Permanent Extension of Containment ILRT Frequency to 15 Years (Type a) and CIV Leak Rate Test Frequency to 75 Months (Type C)
ML21043A1462021-02-11011 February 2021
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official RAI for an Order Associated with Indirect License Transfer from Public Service Company of New Mexico to Avangrid, Inc
2024-09-04
[Table view]
Category:Request for Additional Information (RAI)
MONTHYEARML24297A6212024-10-22022 October 2024
Request for Additional Information Relief Request (RR) No. 72: Re-Submittal of RR-39/ASME Code X1 IWC-3420, IWA-3300
ML24257A1012024-09-11011 September 2024
Request for Additional Information License Renewal Commitment for AMP of Alloy 600 Components
ML24143A1112024-05-20020 May 2024
Draft 2nd Round Request for RAIs Concerning LAR to Modify LCO for TS 3.5.2, LCO for TS 3.6.5, and Surveillance Requirements 3.5.1.2 and 3.5.2.2 for TS 3.5.1 and TS 3.5.2
ML24123A2002024-05-0101 May 2024
(E-Mail) Draft 2nd Round Request for Additional Information Concerning License Amendment Request to Modify Limiting Condition for Operation (LCO) for Technical Specification (TS) 3.5.2, LCO for TS 3.6.5, 3.5.1.2 and 3.5.2.2 for TS 3.5.1, a
ML24114A2812024-04-19019 April 2024
Request for Additional Information (RAI-10150-R1)
ML24011A1002024-01-10010 January 2024
March 2024 Emergency Preparedness Program Inspection - Request for Information
ML23334A1612023-11-30030 November 2023
NRR E-mail Capture - Palo Verde 1, 2, and 3 - RAIs Associated with License Renewal Commitment for Pressurizer Surge Line Welds Inspection Program to Manage Environmentally Assisted Fatigue
ML23334A0072023-11-29029 November 2023
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official RAIs for LAR That Revises TSs 3.5.1, SITs - Operating; 3.5.2, SIT Shutdown; 3.6.5, Containment Air Temperature; and SRs for TS 3.5.1, SITs Operating
ML23298A1232023-10-25025 October 2023
NRR E-mail Capture - Palo Verde, Unit 1 - RAIs for Relief Request 70, Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle
ML23031A3392023-01-31031 January 2023
In-service Inspection Request for Information
ML23013A0632023-01-13013 January 2023
NRR E-mail Capture - Palo Verde Unit 1 -Request for Additional Information - U1R23 Inspection Summary Report for Steam Generator Tubing
ML22348A1672022-12-14014 December 2022
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ML22339A2372022-12-0505 December 2022
NRR E-mail Capture - Palo Verde Unit 1 Request for Additional Information - U1R23 Inspection Summary Report for Steam Generator Tubing
ML22272A3252022-09-29029 September 2022
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ML22209A1752022-07-28028 July 2022
Inservice Inspection Request for Information
ML22187A2632022-07-0606 July 2022
Notification of Inspection (NRC IR 05000528/2022004, 05000529/2022004 and 05000530/2022004) and Request for Information
ML22067A2292022-03-0202 March 2022
Inservice Inspection Inspection PWR Request for Information
ML22055A5842022-02-24024 February 2022
NRR E-mail Capture - Palo Verde, Unit 3 - Final RAIs for 22nd Refueling Outage (Spring 2021) Steam Generator Tube Inservice Inspection Report
ML22035A3302022-02-10010 February 2022
Requests for Confirmation of Information for Exemption to Delete Diverse Auxiliary Feedwater Actuation System Based on Risk-Informed Process for Evaluations
ML22025A4012022-01-0303 January 2022
March 2022 Emergency Preparedness Program Inspection - Request for Information
ML21245A2222021-09-0101 September 2021
Request for Information
ML21200A2392021-07-20020 July 2021
Docs Request AC - AA August 2021
ML21154A0082021-05-26026 May 2021
NRR E-mail Capture - Palo Verde 1, 2 and 3 - Official RAIs for LAR Associated with Permanent Extension of Containment ILRT Frequency to 15 Years (Type a) and CIV Leak Rate Test Frequency to 75 Months (Type C)
ML21064A2372021-03-0303 March 2021
ISI Request for Information Rls
ML21042B9692021-02-18018 February 2021
Notification of NRC Design Bases Assurance Inspection and Initial Request for Information
ML21043A1462021-02-11011 February 2021
NRR E-mail Capture - Palo Verde 1, 2, and 3 - Official RAI for an Order Associated with Indirect License Transfer from Public Service Company of New Mexico to Avangrid, Inc
ML21023A0212021-01-13013 January 2021
PVNGS PI&R Request for Information RA
ML21011A1972021-01-12012 January 2021
Unit 2, and Unit 3 - Notification of an NRC Fire Protection Baseline Inspection (NRC Inspection Report 05000528/2021012, 05000529/2021012 and 05000530/2021012) and Request for Information
ML20227A0992020-08-14014 August 2020
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ML20118D1362020-04-28028 April 2020
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ML20049A0992020-02-14014 February 2020
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ML20049A0252020-02-12012 February 2020
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ML20021A3172020-01-21021 January 2020
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ML19155A1842019-05-30030 May 2019
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ML19095A6552019-04-0404 April 2019
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2024-09-11
[Table view] |
Text
Lent, Susan From: Gibson, Lauren Sent: Wednesday, January 30, 20132:40 PM To: 'Robert. Roehler@aps.com'
Subject:
RAls for RR49 Reactor Vessel Head Flange Seal Leak Detection Piping (TAC Nos. MF0447, 8,9)
Attachments: MF0447 RAls.doc Rob, By letter dated December 19, 2012 (Agencywide Document Access and Management System (ADAMS)
Accession No. ML12361A256), Arizona Public Service Company (APS, the licensee) submitted "Reactor Pressure Vessel Head Flange Seal Leak Detection Piping - Relief Request No. 49" for U. S. Nuclear Regulatory Commission (NRC) review and authorization. The licensee has proposed an alternative to the system leakage test of reactor pressure vessel (RPV) flange leak-off line that is required by the American Society of Mechanical Engineers (ASIVIE) Boiler and Pressure Vessel Code (Code),Section XI, Table IWC 2500-1, Examination Category C-H, at Palo Verde Nuclear Generating Station (PVNGS), Units 1,2, and 3.
Specifically, instead of pressurizing the subject lines to the system leakage test pressure required by IWC-5221, the licensee proposes to pressurize the line using the static pressure head of the refueling water prior to performing a VT-2 visual examination. In order to complete our review, the staff requests the following additional information.
The Nuclear Regulatory Commission (NRC) staff has reviewed the submitted information and determined that the additional information identified in the enclosure is needed to complete its review.
On January 30, you confirmed a response date of February 22, 2013.
Thank you, Lauren Lauren K. Gibson Project Manager Columbia Generating Station Palo Verde Nuclear Generating Station Division of Operatillg Reactor Licensing U.S. Nuclear Regulatory Commission (301) 415-1056 1
REQUEST FOR ADDITIONAL INFORMATION REACTOR VESSEL HEAD FLANGE SEAL LEAK DETECTION PIPING - RELIEF REQUEST NO. 49 ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1,2, AND 3 DOCKET NOS. SO-S28, SO-S29, AND SO-S30 By letter dated December 19, 2012 (Agencywide Document Access and Management System (ADAMS) Accession No. ML 12361A2S6), Arizona Public Service Company (APS, the licensee) submitted "Reactor Pressure Vessel Head Flange Seal Leak Detection Piping - Relief Request No. 49" for U. S. Nuclear Regulatory Commission (NRC) review and authorization. The licensee has proposed an alternative to the system leakage test of reactor pressure vessel (RPV) flange leak-off line that is required by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code),Section XI, Table IWC-2S00-1, Examination Category C-H, at Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3.
Specifically, instead of pressurizing the subject lines to the system leakage test pressure required by IWC-S221, the licensee proposes to pressurize the line using the static pressure head of the refueling water prior to performing a VT-2 visual examination. In order to complete our review, the staff requests the following additional information.
- 1. What are the scheduled end dates for the PVNGS, Unit 1,2, and 3 third 10-year inservice inspection interval?
- 2. The proposed alternative is being submitted pursuant to Title 10 of the Code of Federal Regulations, Part SO (10 CFR SO), paragraph SSa(g)(S)(ii), revised inservice inspection program for a facility conflicts with the technical specification for the facility, but cites the provisions of 10 CFR SO.SSa(a)(3)(ii), hardship without a compensating increase in the level of quality and safety. Please confirm that the relief request is being submitted pursuant to 10 CFR SO.SSa(a)(3)(ii).
- 3. Provide a brief description of the operation of the RPV flange seal leak detection system, i.e., how the pressure in the leak-off line is measured and monitored, how the operators are alerted to a leakage condition and how they respond.
- a. If O-ring leakage trips the leak-off alarm and rapid depressurization of the leak-off line subsequently occurs, does the control room annunciator continue to show an indication?
- b. Are there other control room indications of O-ring leakage?
- 4. Provide a piping and instrumentation diagram (P&ID) and a piping isometric drawing showing the RPV flange seal leak detection piping.
S. What is the material of construction of the leak-off line?
ENCLOSURE
- 2
- 6. Describe PVNGS experience with degradation (corrosion, stress corrosion cracking, fatigue, etc.) of the RPV flange seal leak detection piping.
- 7. Potential O-ring leakage during service is detected with a pressure element in the leak off line. The proposed alternative would utilize the static fluid head of the refueling water to pressurize the leak-off line prior to a VT-2 examination.
- a. What is the fluid head pressure that exists in the line when the refueling cavity has been filled to its normal refueling water level?
- b. What is the trip pressure for the O-ring leakage alarm indication in the control room?
- 8. Discuss whether a system leakage test of the RPV flange seal leak detection piping could be performed at a pressure higher than that of the refueling water fluid head prior to removing the head at the beginning of the refueling outage. Describe any hardship associated with this sequence.
- 9. In order for a fluid leak in a pressurized line to be observed with a VT-2 examination, sufficient time must have elapsed between the time that the line was pressurized and the time that the examination is performed. Specify the minimum time between the time that the line is pressurized and the time that the VT-2 examination is performed for both uninsulated lines and insulated lines (as appropriate). Provide a technical justification based on the pressure in the leak-off line during the leakage test for the hold time.
