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Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 1
Page 44 of 46
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50

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment I
Page 45 of 46
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Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 1
Page 46 of 46
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PVNGS Steam Generator Degradation Management Program
81 DP-9RC01
Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 2
Page 1 of 6
NEI 97-06
Technical Justification
Number: 02-SGPG-TJ-0013
Revision:
Date:
0
04/05/02
Document: EPRI TR-102134-R5, PWR Secondary Water Chemistry Guidelines -
Revision 5
Subject: Deviation from Action Level Recommended Actions Due to Hideout
Return
Requirement:
EPRI PWR Secondary Water Chemistry Guidelines - Revision 5, Section 5.3
recommends immediate actions be taken to reduce power to a plant-specific level (40% for Palo Verde) and achieve that power level within eight hours of exceeding Action
Level 2 values, or as quickly as safe plant operation permits. Power de-escalation can be
terminated if the source of the impurity ingress is eliminated and parameter values are below Action Level 2. Escalation to full power can be resumed once Action Level 1 values are met.
The recommended action for exceeding Action Level 3 values is to shut down as quickly as safe plant operation permits and clean up by feed and bleed or drain and refill as appropriate until normal values are reached. Regardless of the duration of the excursion into Action Level 3, the plant should be taken to hot or cold shutdown.
Evaluation:
• The EPRI PWR Secondary Water Guidelines is referenced in NEI 97-06 as a directive guideline. NEI states that each utility shall have procedures for monitoring and controlling secondary-side corrosion-induced degradation in accordance with the EPRI PWR Secondary Water Guidelines.
The EPRI PWR Secondary Water Guidelines Table 5-5 lists 50 ppb as an Action
Level 2 for sodium, chloride and sulfate. The table also lists 1 µS/cm as an Action
53

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 2
Page 2 of 6
Level 2 for cation conductivity. The four parameters are listed as Control
Parameters.
The EPRI PWR Secondary Water Guidelines Table 5-5 lists 250 ppb as an Action level 3 for sodium, chloride and sulfate. The table also lists 4 µS/cm as an Action
Level 3 for cation conductivity. The four parameters are listed as Control
Parameters.
Palo Verde Unit One steam generators exhibit a high degree of hideout in the upper bundle region. This is known to a very high degree of confidence as evidenced by peak levels of sodium and sulfate hideout return occurring as reactor power is decreased from 100% power to 90% power. The hideout return is considered "super prompt" which indicates the original location of the contaminants is a region that has unrestricted access to the bulk water.
^ After the U2 steam generator tube rupture event, analyses were performed to determine steam generator conditions conducive to the damage mechanism observed. Based upon thermal hydraulic analysis results (ATHOS), a deposit parameter was calculated as a function of mass flux (density times velocity) and steam quality. This parameter correlated with eddy current trends with the majority of indications concentrated in the area of highest calculated deposit parameter. The empirical data suggested when the parameter is exceeded a transition to film boiling occurs (i.e. "dryout") and with that, an increased propensity for deposition. From this information it was determined that approximately 3800 tubes comprising an "arc" from the ls` vertical strap down to the 08H support bounded all the upper bundle axial indications including free span and support regions.
• Previous ATHOS modeling determined the dryout region, based upon the deposit parameter discussed above, disappears at 86% power.
• Taken together, the "super prompt" hideout return observed at 90% power, the calculated deposit parameter, the observed defects constituting an "arc" region and the disappearance of the dryout region calculated by ATHOS fully support a hypothesis that contaminants entering the Palo Verde steam generators selectively deposit to a very high degree on tube surfaces in the upper bundle.
• It is well known that steam generator bulk water impurities concentrate within the steam generator due to localized boiling processes. It is recognized that concentration factors on clean tube surfaces may be as low as 20. The EPRI PWR
Secondary Water Guidelines states that concentration factors of 50 - 100 can be achieved within 1 mil deposits and that experimental data suggests higher concentration factors of 13,000 can be reached. Concentration factors on the order of 104 are not sufficiently aggressive as to increase the likelihood of corrosion damage mechanisms. As an example, a bulk water concentration of 50 ppb
54

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 2 sodium, which may result from a downpower, would be expected to concentrate
Page 3 of 6 to 500 ppm on tube scale surfaces.
In contrast to the concentration mechanism occurring on tube surfaces which is kinetically limited to concentration factors on the order of 104, concentration factors in portions of the steam generator that are flow occluded (i.e. crevice regions) can reach 108. It is believed that concentrations of liquids in these regions are thermodynamically limited and concentrations will increase until the resultant solution reaches the temperature of the primary side. Therefore, concentrations will be less on the cold leg than on the hot leg of the steam generator, which is consistent with the observation of damage mechanisms attributed to water chemistry being essentially non-existent on the cold leg side.
A second mechanism which is contributing to the hideout observed in the upper bundle is the adsorption of sulfate. EPRI report TR-101106 quantified the adsorption of sulfate species onto Alloy 600 tubing in laboratory tests. A similar phenomena for sodium, chloride and potassium was shown to not exist. The adsorption of sulfate is believed to result from the tetrahedral nature of the sulfate ion and the ability to adsorb by either electrostatic or oxygen bonding mechanisms. The study also identified that sulfate adsorbed onto system surfaces could be quantitatively desorbed by pure water over a period of several days. It is important to note the difference between the adsorption/desorption of sulfate and sodium in the context of deviating from the recommended EPRI Action Level responses. The question should arise as to what is the expected behavior of sodium if power is increased and the sodium concentration is reduced as a result
of dryout (plus blowdown and hideout), as compared to the expected behavior of sulfate which will be reduced by both dryout and adsorption (plus blowdown and hideout). Empirical data collected during the Unit One Main Turbine Control
Valve test on 1/12/02 is useful in predicting the response of sodium and sulfate
when power is increased from 96.3% to full power with elevated sodium and sulfate levels. At 03:25 power was increased with SG12 sodium at 23 ppb (based upon Orion inline) with full power achieved at 03:53. At 04:00 the indicated
sodium value was 5.0 ppb. Sulfate (as indirectly measured by cation conductivity decreasing from 1.01 µS/cm to 0.46 µS/cm) decreased from approximately 100 ppb to 20 ppb in this same time period. Sodium decreased by a factor of 4.6 and sulfate decreased by a factor of 5.0 during the 34 minute period with power
increased (note a half-life cleanup curve with abnormal rate blowdown is on the order of 3 hours). This suggests that the hideout mechanism occurring in the upper bundle is predominantly due to restoring the dryout condition and precipitating the sodium and sulfate onto tube surfaces which are known to have
104 lower concentration factors than flow occluded regions.
• As a practical exercise, hideout return data observed during a downpower to 90% power in Unit One on 2/23/02 was analyzed using the EPRI MULTEQ code. The data suggested a localized pHt of 7.48 at a concentration factor of 104 assuming precipitates remained in the tube scale. The same data, simulating crevice
55

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 2
Page 4 of 6 conditions with only the liquid remaining suggested a localized pHt of 10.14. The data indicates that not only is the concentration 104 higher in the crevice, but that the pH is considerably more aggressive as well.
• A second exercise was conducted to quantitatively determine the exposure to the entire steam generator from hideout return occurring from the upper bundle during a typical Main Turbine Control Valve Test. In Case 1 it was assumed the
unit downpowered from 99% to 96% resulting in 50 ppb sodium. The unit then
downpowered to 90% power to fully rewet the upper bundle which increased the hideout return to 100 ppb. The unit then remained in abnormal blowdown until
sodium levels were less than Action Level 1 (5 ppb) with cleanup occurring at the calculated 3 hour half-life. The unit then returned to full power with a total event
duration of 14.5 hours. In Case 2 it was assumed the unit downpowered from 99% to 96% resulting in 50 ppb sodium. The unit remained at this power level until testing was complete, then returned to full power while above Action Level 1.
The total event duration was assumed to be 3.0 hours. The total tube exposure factor was compared for the two scenarios with Case 1 resulting in a 11 X higher exposure than Case 1. The tube exposure factor was calculated in accordance with
the methodology outlined in the PWR Secondary Water Guidelines Appendix A.
• This same approach was utilized to determine the increased "risk" of the Unit One
downpower event during December 2001 which resulted in Action Level 3 entry for sulfate. The increased risk, utilizing the tube exposure factor methodology was
increased by less than 5% for that event. It is very important to note that the
increased risk was only 5% due the fact that the unit had been operating for 8
months and had experienced hideout return due to weekly downpowers for high
rate blowdowns. As clearly shown in the PWR Secondary Water Guidelines
Appendix A, a contaminant increase that occurs late in a cycle results in a significantly lower increase in risk than an event early in a cycle. This is important to note in the context of deviating from the recommended EPRI Action
Level responses. This deviation will apply for Unit One for the remainder of cycle
10 at which time steam generator chemical cleaning is scheduled for U1R10.
Chemical cleaning will significantly reduce the iron deposition in the upper bundle and will result in significantly lower hideout.
• The above evaluation serves as the basis for deviating from the Action Level recommendation actions. The underlying belief is that by increasing power as soon as possible, the exposure to the entire steam generator from elevated impurities entering the bulk water from the upper bundle is reduced by greater than a factor of 10 as compared to holding power and cleaning up. The contaminants originate from a location of low concentration factor, and if power was maintained at 90% or less would be available to hideout in crevices (at high concentration factors) at all steam generator elevations. At power levels < 90% contaminants will not selectively return to the dryout region. It is important to note that the Palo Verde steam generators are susceptible to corrosion mechanisms at locations other than the upper bundle "arc" region. As of U1R9
4
56

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 2
Page 5 of 6
SGI had a total of 139 tubes removed from service for defects located at the tubesheet (axial plus circumferential indications) up to the 6th support. Upper bundle defects resulted in only 30 tubes removed from service. For SG2 the tubes removed from service for corrosion mechanisms number 312 (lower) and 97
(upper). Based upon previous experience in Unit One, increasing the exposure of contaminants to the lower bundle by greater than a factor of 10 is not the appropriate action level response. While future damage mechanisms can not be accurately predicted, an increase in lower eggcrate support IGSCC has been noted in several other CE steam generators of similar vintage to Palo Verde's. During the current U2R10 inspection, two in-situ candidates have been identified due to significant axial defects at the SG21 02H and 03H supports.
• The condition monitoring and operational assessment analyses are based on historical corrosion rates adjusted for temperature. This deviation will not adversely impact the corrosion rates for the reasons previously stated.
This deviation affects that portion of 74DP-9CY04 Systems Chemistry
Specifications which addresses Steam Generator Blowdown > 5% Power
Operation Specifications. This deviation allows for maintaining and increasing power level for hideout return events which result in sodium, chloride, sulfate
and/or cation conductivity exceeding up to and including Action Level 3. In all cases, consideration shall be given to the length of time the unit will be exposed to higher contaminant levels. If full power can not be resumed within 8 hours, then an expert team shall be convened to evaluate plant conditions and define the appropriate course of action, including determination of power levels and timing of power level changes.
• This deviation will be in force in Unit One for the duration of cycle 10, at which time steam generator chemical cleaning is scheduled.
• This deviation affects the Chemistry and Operations Departments with respect to procedures and decision making processes designed to respond to exceeding a steam generator Action Level.
• This deviation does not affect compliance with ANSI N45.2.11 or ANSI N18.7.
• This condition has been previously evaluated by the steam generator vendor and documented via 50.59 evaluation. Combustion Engineering concluded the Action
Level recommended actions do not apply if the source of the ingress is hideout return.
57

Prepared by: Chemistry Support, G J. Bucci
Approved by: Chemistry Dept. Site Director , J A Scott
Approved by: SGPG Section Leader, K. M. Sweeney
Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 2
Page 6 of 6
58

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 1 of 18
(PLEASEPRfNT, SBEBACKOFFORMFTIRlNSTRUCT/ONS
C r
^{
1) DESCRIPTION OF CONDITION/DISPOSITION REQUESTED:
In Unit 2, during a Steam Generator contamination event in May 1995, a System Chemistry Specification procedure
requirement (74AC-9CY04) to shutdown the plant was waived without completing the required documentation, either before or after the event. The waiver from the requirement was not documented on a Chemistry Control Instruction (CCI)
per procedure 74AC-9CY03, Chemistry Control Instructions. The waiver did not receive a 10 CFR 50.59 review as
required by the CCI procedure.
REFERENCES (ATTACH IF AVAH.ABLE):
See Attached
G',Q#,^Rs o
OO
® CONTINUATION
PAGES/ATTACHMENT
2) REQUIREMENT VIOLATED (Describe how or why the Condltloa Is a Problem):
Documentation requirements for waiving Chemistry Specifications and IOCFR50.59 screening were not met when
deviating from a procedurally required plant shutdown.
3) LOCATION (BLDGJELEVJROOM): 4) AFFECTED EQUIPMENT (TAG NO.): 5) UNIT NO.:
N/A N/A 2
6) DISCOVERY DATE:
10/29/95
TIME:
1200
7) CONDITION DATE:
10/10/95
TIME:
1200
8) ORIGINATOR (Please Print):
D. Elkinton
9) DEPARTMENT:
NAD
12) SUGGESTED ACTIONIRESOLUTION (INCLUDING NOTIFICATIONS MADE):
Complete required documentation
Implement appropriate corrective actions
10) EXT.:
5656
11) STA:
7996 q NO ACTION RECOMMENDED - CLOSE CRDR
13) ORIGINATOR'6 SIGN
^>^::-•:^^
.
> q ACTION TAKEN/COMPLETED - CLOSE CRDR
DATE: to to 9f
14) LEADER'S REVIEW, INCLUDING ACTIONS TAKEN/RECOMMENDED:
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ACTION RECOMMENDED
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ACTION TAKEN/COMPLETED -CLOSE CRDR
DATE: TIME:
P%Q -,_Ps- 113--
N E W
E§ ACTION REQUIRED - FURTHER EVALUATION
DELIVER TO:
CONTROL
-1 NAS q
ROOM
16) ACTIONS TAKEN/COMMENTS:
17) TECH SPEC ACTION ENTERED?
18) UNITS/ORGANIZATIONS NOTIFIED?
NO q YES q
19) NOTIFICATION REQUIRED?
NO
NO YES SECTIONS:
El q
NOTIFICATION MADE:
YES
CONTINUATION q
PAG&4/ATTACHMENT
7
IMMEDIATE REPORTABILITY REQUIRED?
q
YES q
NO
SH[FI' SUPERVISORS SIGNATURE
DATE: TIME:
NOTIFICATION MADE: I (DATE/fIME)
90AC-0IP04
59

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 2 of 18
)VERSE CRDR
ALUATION/RESPONSE/ACTIONS/APPROVAL
PREPARER:
1FFECTED SYSTEMS:
DEPARTMENT:
4) AFFECTED COMPONENT EQID
EVALUATION
/v/k&rL
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DAT : I EXT:
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60

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 3 of 18
►
PARER:
(^ i'"t-^
M
I ON( S) L D
TEXT OF ACTION COMPLETED
DEPARTMENT:
U.v , j Z CC-1- 07S-- 52 Z.
,) CRDR
PAGE ^`-
EXT:
OF
DATE: it 7 y
ACTION CLOSURE DOCUME"T
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ACCEPTED BY
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61

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 4 of 18
':1,11:11311 !!;111
:01 121N
0g6 O
-INUM q ISE Evaluation q Inspector Observation
Organization Evaluated: Unit 2 Chemistry (2B)
0 CRDR(s) Initiated:
4-5-0y,97 q
Other Documents Initiated:
Activity Codes: [PD.3.4-2B ] [ ) [ ) [ ] [ )
Key Word(s): Action Level 3 Secondary Chemistry Contaminant Ingress Intrusion
Unit: 91'
[ ]
PURPOSE/SCOPE:
NAP reviewed the significant event report 2-5-0227 to evaluate the decision not to shutdown Unit 2 following a contaminant intrusion event on May 10. Steam Generator (SG) sodium and sulfate concentrations exceeded 500 ppb for approximately one hour, which procedurally required a plant shutdown. NAP reviewed the report and discussed the events with Chemistry staff and management.
RESULTS SUMMARY:
NAP concluded the decision to continue operation of Unit 2 following the excursion to Action Level 3 was appropriate and justifiable because technical evaluations by Engineering determined no acute hazard would result from the event and no significant benefit would be realized beyond reducing power to 40%.
When manag,.ment
made the decision to reduce power, SG concentrations had decreased well below Action Level 3 and management believed they had identified the source of the ingress (Hotwell 1 A). Nonetheless, administrative requirements for documenting the decision to deviate from the Action Level 3 requirement (to shutdown the plant) via a Chemistry Control Instruction (CCI) and I OCFR50.59 review were not met.
CRDR F-5-Qyyjwas issued to the Chemistry Operations Department Leader to address corrective actions.
Evaluation Start Date:
Performed by:
10/6/95 pt-u^
SIGNAWIM
Results Discussed with:
Reviewed & Approved By:
-
`1-4^`
P. Guav
PkIN'r
IGNA'IVR Er
.4
C: q D. Elkinton ...................7996
q RC Fullmer ...................7996
q .....................................
q .................................
q JA Scott ................... ..7295
q .....................................
q ............................. ........
q .....................................
-
DEPARTMENT
Date: /0
Date: /o q
PA Guay....................... 7395 q .....................................
q ................................ ....
q .....................................
62

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 5 of 18
Report No. 9s 0 1?6 D
OBSERVATIONS/OBJECTIVE EVIDENCE:
NAP reviewed the significant event report 2-5-0227 to evaluate the decision not to shutdown Unit 2 following a contaminant intrusion event on May 10. Steam Generator (SG) sodium and sulfate concentrations exceede 500 ppb for approximately one hour, which procedurally required a plant shutdown. NAP reviewed the report and discussed the events with Chemistry staff and management.
Back round
The event investigation report contained the follow information and conclusions.
On May 10, Unit 2 experienced a contaminant ingress in the secondary which resulted in a power reduction to
40% and draining of the suspected circulating water train for leak testing. The report concluded the root cause was an introduction of contaminants from the Liquid Radwaste processing system via the auxiliary condensate return path to the condenser.
During that event, the sodium and sulfate concentrations briefly exceeded 500 ppb, an Action Level 3
specification, which by procedure requires a plant shutdown. The following table gives a condensed chronology:
SGl
Time Sodium
4:00 0.3
5:00
11:00
11:36
11:44
12:11
12:20
12:30
13:00
252
787*
12:18 390*
62
54
SG2
Sodium
SG1
Sulfate
1.21
SG2
Sulfate
SG1 Cation
Conductivity
0.51
SG2 Cation
Conductivi ty
0.27
83.1
508*
0.51
In-line sodium analyzers indicate SGs c© 100 ppb. Downpower
Commenced
350
1.21
573 3.3
4.8
584
In-line sodium anal yze s indicate both SG's <100 b
75
188
248 1.8
Unit at 40%
1 1:36 grab sample results obtained
14:00
21:00
1:00
1300 Grab sample results in, decision not to shutdown
92.8
95.1
*Dionex 8200 Ion Chromatograph readings, other values are grab sample results.
As the above chronology indicates, both SGs entered Action Level 3 for either sodium, and/or sulfate
(concentrations exceeding 500 ppb)
.
However
, b
> concentrations decreased below either in Action Level
2 (>100 ppb) or Action Level 1 (>20 ppb). The excursion into Action level 3 lasted approximately 1 hour and by
the time analytical results were available, the concentrations had decreased to Action Level 1 or 2.
Requirements
Procedure 74AC-9CY04, System Chemistry Specifications, Para. 3.2.4. requires Action Level 3 response when
SG sodium or sulfate concentrations exceed 500 ppb. Paragraph 4.1.8.3, which describes required actions for
Action Level 3, states the following:
63

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 6 of 18
Report No
. 9S-o 8 60
"Immediately shutdown as quickly as safe plant operation permits to Hot or Cold Shutdown, regardless of the duration of the Action Level excursion ..... The intent of Action Level 3 is to correct conditions which may result in rapid system degradation."
The secondary system chemistry specifications and action levels are based on EPRI TR-102134, Revision 3,
PWR Secondary Water Chemistry Guidelines. NAP reviewed the EPRI guidance and compared it to the related requirements (SG Action Level 3 specifications and definition) in the procedure. The Palo Verde procedure was consistent with the guideline and its basis. The EPRI guidelines serve as the basis for the PV program and are
endorsed by Combustion Engineering (UFSAR, Rev 7, Table 10.3-5).
Note: The Action Level 3 plant shutdown is NOT a Technical Specification or UFSAR requirement
Procedure 74AC-9CY02, Laboratory Operations, Para. 3.4.10 states that when an out of specification result is obtained and confirmed, a Chemistry Control Instruction (CCI) is issued, providing instructions for corrective action, as appropriate.
Procedure 74AC-9CY03, Chemistry Control Instruction, Para. 3.3 states that the Chemistry Operations
Department Leader, with the concurrence of the Operations Department Leader may supersede the authority of
procedure 74AC-9CY04 (non-technical specification requirements only). These are to be documented on the
CCI with an attached technical justification and 10CFR50.59 review. This process implements a temporary procedure change process as defined in para 5.2.2 of ANSI N18.7 - 1976. Temporary procedure changes require
the concurrence of the shift supervisor and documentation of the change (per ANSI 18.7). PV is committed to
ANSI 18.7 vis a vis the Technical Specification 6.8.1 commitment to Regulatory Guide 1.33.
Evaluation
NAP discussed the event with J. King, Incident Investigation Team Leader, P. Guay, Chemistry Operations
Department Leader, G. Bucci, SG Projects (Engineering), J. Shawver, Site Chemistry. J. Shawver, M. Melton, and G. Bucci provided technical advice to Chemistry and Operations management during the event and determined that the excursion posed no acute threat to SG integrity because of its short duration. Subsequently, the evaluation was documented under Letter 281-01754/MAR, dated May 30, 1995.
Management decided a plant shutdown was not warranted because:
• Concentrations increased Action Level 3 and decreased to Action 2 and I levels before analytical data was available to ascertain that Action Level 3 had even been entered.
• By the time results were obtained, on-line sodium analyzers indicated concentrations were less than 100 ppb.
• Chemistry and management believed the source of the contaminants had been identified (hotwe:l 1 A leak).
• Technical evaluation by e nginee;;ng department metallurgists and SG engineers determined no acute hazard to the SGs existed as a result of the excursion.
• No significant benefit in addition to that gained by the power reduction to 40% would be achieved.
Nuclear Assurance reviewed the technical justification and the reasons for not shutting down as the procedure requires and concluded continued operation was justified.
64

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 7 of 18
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.,^^t
'h;.<
Nuclear Assurance, however, also concluded the documentation requirements of the CCI procedure which incorporate ANSI -18.7 requirements, were not implemented as required because a CCI accompanied with a
10CFR50.59 review were not generated.
The investigation report noted that a CCI and 50.59 review were generated for the decision to reduce power only to 40% vice 30% as required for Action Level 2. These documents did not address the justification for shutting down for the more severe Action Level 3. (CCI 95-195)
CRDR 2-5-Q was issued to the Chemistry Operations Department Leader to address corrective actions.
REFERENCES:
Technical Specification 6.8.1
Regulatory Guide 1.33, Rev 2
ANSI 18.7 -1976
EPRI TR-102134, Revision 3, PWR Secondary Water Chemistry Guidelines
UFSAR Table 10.3-5, Rev. 7
Procedure 74AC-9CY04, System Chemistry Specifications, Rev 18
Procedure 74AC-9CY03, Chemistry Control Instruction, Rev 5
Procedure 74AC-9CY02, Laboratory Operations
Letter 281-01754/MAR, dated May 30, 1995
Unit 2 CCI 95-195
P. Guay
J. King
Name
Persons Contacted
Name
J. Shawver G. Bucci
Name
65

Docket No. 37690
Staff s 6th, Q. No. MA-1-4
Attachment 3
Page 8 of 18
ACTION Ulp p&VEyV;
'`^`
G r
/
L
OESCIPTION Of PROPOSED CNA
^8^-^-7tin
:
C
GrJ ?A^t^t I• 3 ^4•t^ 7'
1ACFR50.59
Evaluation Log No.:
Page 1 of 1z
/J' / ^^^/ (•^
•
^ S ^ J ^' ^. --1 ^
3 ( ^
OF 40^1 1T Z S7i4iO C-^.uc,L
** X_
50.59 REVISIO
'L
10CFR50.58 SCREENING (Provide References on Response Justification Page)
Does the proposed change:
1. Make changes in the facility as described in the Licensing Basis (refer to 1 4.1.4)
NOTE: Prior to the modification of radioactive waste systems, review the modification against the
specific criteria in IEC 80-18 (Appendix G).
2. Make changes in procedures as described in the Licensing Basis (refer to 1 4.1.4)
3. Involve test or experiments not described in the Licensing Basis (refer to 14.1.4)
4. Require a change to the technical specifications?
eontinue en Res onae Juctlfialion Pa e
NO YES
--
}r;
-
If any answer to questions 1 through 3 is 'YES," then a 10CFR50.59 evaluation is ; equired. When the Evaluation is completed, and prior to the review contact Document Control at ext. 82-6624 to obtain a tracking log number and enter the number in the
Evaluation Log number block above. An UFSAR Change Request per procedure 93AC=0LC01 may also be required.
If answer 4 is "YES," then a Technical Specification Change Request per rocedure 93AC-OLCOI and NRC approval is
required prior to implementation. (See the procedure for an explanation ofpexceptions to this)
^ H all answers 1 through 4 are "NO," no 10CFR50.59 Evaluation required or Technical Specification change is required, recommend action approval.
10CFR50.59 EVALUATION (Provide Response Justification with References)
5. May the probability of an accident previously evaluated in the UFSAR be increased?
6. May the consequences of an accident previously evaluated in the UFSAR be increased?
7. May the probability of a malfunction of equipment important to safety be increased?
8. May the consequences of a malfunction of equipment important to safety 1+e increased?
9. May the possibility of an accident of a different type than any previously evaluated in the UFSAR be created?
10. May the possibility of a different type of malfunction than any previously evaluated in the UFSAR be created?
11. Is the margin of safety as defined in the basis for any technical specification reduced?
Call NFM at Ext. 82-5339 (aft 8-50921 , Duty Pager 2W.
Review Requested by NFM and Completed Yes _ No Review Requested by NFM
If any answer to questions 5 through 11 is "YES," then an unreviewed safety question is identified.
NRC approval is required prior to implementation.
If answers 5 through 11 all are "N0," there is no unreviewed safety question and action approval is recommended.
If UFSAR Chapter 6 or 15 are potentially affected, forward a copy of evaluation to Nuclear Fuels
Management.
/ verity
PV21600 Rw 10-95
rng/eva/uation is adequate a„d accurate and that the undersigned are currently qualified ro dure_
7
7F .^^. „^,
//
7/Ps
DATE
10. 59 REVlE R(P Wt)
WAGONS01
66

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 9 of 18
10CFR50.5e SCREENING AND EVALUATION
RESPONSE JUSTIFtCATION
ACTION UNDER .aEVIEW; (MMMILE)
G - `yG
^ TG^st
PR CEOURE/PCP/fEM1OR R pIFICATION `;A f-7 fc,--1116cu p',u /I c.
^ lJrt
/
Page 4 ot
REVISION
I 9
C-01 r,+ IA? / v a iv 1 "V(0-4
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93AGONSO,
67

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 10 of 18
10CFRS0.59 SCREENING AND EVALUATION
Page 3- of -&
ACT'4N I,NDER REVIEW: (NAAFJ!/TLE^
^^A c -^G yP `' ,sr9vau C^^r i.s r /fr c# ri v•
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NO.:• 1-7
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68

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 11 of 18
PV216080A Rw 5.95
^a4^, 1^1
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69

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 12 of 18
212.CCG.1M. =.ft •.,q^17s 1&WW)
AM
Arizona Public Service Company
COMPANY CORRESPONDENCE
Ior:
DATE:
281-01754/MAR
5/30/95
TO:
Sts.i:
Ext.:
FROM: s1a.ta:
Ext.:
FILE:
SUBJECT:
Joe King, Chemistry Operations
7195
1075 ^f^^^ ^,^..-
Mike Meit'orn' / Guy Budci, J4iech-NSSS/SGP
7543 / 7696
6983 / 5013
95-202-419
Unit 2 Chemistry Excursion
GQ/^^Q dSo^O;
't ^
PS i F a
OF ^
The purpose of this memo is to formally document Engineering's and Steam Generator
Projects draft written evaluation of the May 10th, 1995 Unit 2 secondary side chemistry excursion event.
Mechanical/NSSS Engineering (Mike Melton) and Steam Generator Projects (Guy Bucci) reviewed the May 10th,1995 Unit 2 chemistry excursion data and agree that the sodium and sulfate excursion was due to a spike to the system. There were no indications of concurrent high levels of chlorides, indicating a potential leak source other than a condenser tube leak.
Review of chemistry sample data (calibrated) indicates a potential rapid spike exceeding 500 ppb Na, with a rapid decrease below Action Level 3 levels within a short period of time.
Based on this, corrective actions already reduced spiked levels for sodium and sulfates and the Unit was considered out of Action Level 3 and into Action Level 2 per procedure
74AC-9CY04.
Based on the above, Engineering recommended that the Unit remain in Action Level 2 and proceed to clean up remaining sodium and sulfate levels per the applicable procedure. Since corrective actions are taking place and the duration of the spike conditions was relatively short, no real benefit can be achieved by taking the unit out-of-service. Clean-up acceptance
levels should be per procedure 74AC-9CY04.
Engineering recommended a CRDR be initiated to address the following issues:
1) Identification of source of contamination.
2) Guidance for treatment of calibrated and uncalibrated chemistry samples.
3) Engineering criteria for minimum recovery times and contaminant levels to deal with future spike issues.
70

Page 2
Unit 2 Chemistry Excursion
Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 13 of 18
/^ftocL,^.,w^- ^r
4) Guidance for timing of achieving confirmatory samples and subsequent implementation of level 3 action requirements.
5) Review of procedure requirement to reduce power to 30% (paragraph 4.1.8.2) to ensure plant operation requirements and chemistry requirements are achieved.
Engineering has considered the potential detrimental effects of the Na/S excursion and believe that with levels over 500 ppb stress corrosion cracking rates can be significantly higher over a period of time, potentially leading to through wall cracking within a cycle of operation. Crack growth rates are stress dependent, however, and corrosion coupon stress levels used in the lab to produce cracking within weeks in 40 ppm Na are significantly higher than stress/strain levels in tubing at the top of tubesheet. Therefore, no immediate corrosion damage is believed to have occurred as a result of the brief excursion, but the longer term effects are less quantifiable. The short duration of the excursion and Immediate cleanup actions are believed to have minimized any long term effects as best as possible.
Engineering recommends that the Units continue to treat chemistry excursions with the same
level of urgency and commitment to correcting the problems as demonstrated by Unit 2.
Future chemistry excursions due to system changes or modifications may be unavoidable even with the best planning. Therefore it is important that rapid response measures be in
place ( Procedure 74AC-9CY04) and implemented to ensure a reduced risk of increased long term tube corrosion damage.
This completes our report. If you have any questions or comments please don't hesitate to let us know.
MAM/GJB/mm cc: J. A. Bailey
J. H. Hesser
J. A. Scott
D. R. Goodwin
L. D. Johnson
M. R. Karbassian
M. E. Powell
M. A. Radspinner
R. F. Schaller
K. M. Sweeney
M. D. Pachoike
7605
7546
7295
7295
7936
7548
7668
7543
7696
7696
7696
71

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 14 of 18
r
NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL Page 7 of 8
CHEMISTRY CONTROL INSTRUCTION
74AC-9CY03
5
Appendix A Page 1 of 2
Page 1
Date
Date
S
Time
:^f
Appendix A. Chemistry Control Instruction (Sample)
OPN 2.11
CODE CC01
Unit:
Time
Serial Number
-
(Year Number)
/
0,
'00
Rk4
-Z-
01
•.
Syst^m ;_
^o l fi ^
Parameter ia
Units
Feeulte
167
Specification
500
SoE5 cs&o
ALlion
Level
3
3
Remarlu x-t
s ^n-.^r ^. -
-
-
72

Docket No. 37690
Staff s 6th, Q. No. MA-1-4
Attachment 3
Page 15 of 18
NUCLEAR ADMINISTRATIVE AND TECHNICAL MANUAL
CHEMISTRY CONTROL INSTRUCTION
Page 8 of 8
74AC-9CY03
Revis
6
Appendix A Page 2 of 2
Page 2
OPN 1.21
CODE CCL
Serial Number 32 Z-
Unit:
CIP,
Date
Time l l :
7 7 V
Date
Signature : Commenb r•;
.
,^ .,.
.......^...aL
aLCV. ^
73

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 16 of 18
To:
TARGET/DUE DATE: ) t i^ 9 5^ CRDR Number q Audit Finding (Evaluation is due 14 days from issue date)
Enclosed, please find the CRDR which has been assigned to your organization by the CRDR Review
Committee. Please complete the Investigation / Evaluation by the date indicated above. The condition has been classified as: q
POTENTIALLY SIGNIFICANT - Additional information is required to further define or clarify the condition.
Return the CRDR, with the additional information, to CRDR Control, for Re-ClassiflcationlRe-Assignment by the due date. (See below comments for the specific required information) q SIGNIFICANT - Investigate per 90DP-01P06, 90DP-0IP07 or 70DP-0EE01.
Designated Senior Manager
(concurrence is required for SIGNIFICANT CRDR svaluation)
Nuclear Assurance Dept. Leader
(concurrence is required for SIGNIFICANT CRDR evaluation)
NAD Consultant
X ADVERSE - Evaluate per 90DP-0IP08.
Nuc ear Asaurance Dept. Leader k.
ru L
(concurrence is required for 0 CROP evaluation) q
REVIEW (Copy only) - Evaluate per 90DP-0IP08.(No Formal Response to Strategic Analysis Dept. rraquired)
Additional Direction/Comments:
SIGNIFICANT / POTENTIALLY SIGNIFICANT Criteria q 1. Severe or Unusual Plant Transient
O 2. Safety System Malfunctions or Improper
Operation
O 3. Major Equipment Damage
O 4. Fuel Handling or Storage Event o 5. Excessive Radiation Exposure or Severe
Personnel Injury q 6. Excessive Discharge of Radioactivity q 7. Conditions which result in Non- Routine
Reporting per 10CFR50.73 to the NRC
(LER's, etc.)
0 8. Any NRC Regulatory Violation (NOV) Severity Levels I-IV
0 9. Deficiencies in Design, Analysis, Testing Procedures.
Maintenance, Operation or Training p 10. Other Events Involving Nuclear Safety or Plant Reliability p 11. Significant Quality Issues
Signed:
Review Committe
•
OCT I 1 1995
/ Date
CRDR Control: Ezt. 5758/5788 -Located In Building 0, 3rd Floor
SIGNIFICANT Distribution.:
OSftC - 2 Co p ies (7616)
(R Younger)
NRC Resident (7393)
NAD Consultant
Distribution.:
Originator
NRA(7836)
• ^ ll -11
System Engineering (7585) q FDT (7646) oy wur-virvJ
74

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 17 of 18
CRDR NUMBER
Q q
YES NO N/A
1.
Does the Evaluation and/or conclusions NOW represent a potential significant condition?
q iCJ
If yes, the CRDR shall be re-presented to Senior Management as a potentially significant
CRDR,
2.
Do any of the Aw^tion(s) need to be entered into CATS?
3.
For the Action(s) that will be entered into CATS, is the Action Assignment information complete, i.e., Responsible Organization identified, Priority, Due Date, Scope of Action.
If item 2 is checked YES, provide appropriate instructions in item 6.
4.
Should any additional references be added to the CATS Data Base?
5.
Can the CRDR be closed in CATS, i.e., all of the required actions are complete?
6.
Actions/Information to Add; q ^ q q q
^
^` q
^
By CRDR Control a) Actions: Per Completed Evaluation
and/or Attached CATS Sheets q q ,
,
Added: b) References:
Added: c) Add Action As Noted:
Assigned Zb:
Action Test:
Due Date:
Action Accepted By: d) Additional instructions/changes:
NA Reviewer's Comments: ( ) check if N/A
Continuation Sheets Used q YES NO
Q-'-Standard Distribution - Completed Evaluations -
Completed q Standard Distribution - Closed CRDRa (If Item 5 is checked yes). q NA Point of contact (required for Significant and'Q' CRDRs) q Additional - Distribution:
Review completed by
Signature / Name
Date:
Completed
Completed
(02-95)
CantroU«I by foDP-01M
75

Docket No. 37690
Staffs 6th, Q. No. MA-1-4
Attachment 3
Page 18 of 18
(NAS USE ONLY)
CRDR #
Systems X x Quality Classification: Potentially Reportable: q NOR Pf OR a NO q YES
C C C C R R P P P 0 0 1 i 1
Descripti on
30
CASE
_ _ _
PROG ^ ORG Issue#
Dsseriptlon
30
." 30 y
CAUSE p
RESULT PROG
/^'
ORG !asuell
Description
CAUSE RESULT ORG tssueM
Description
30
CAUSE RESULT PROG ORG Issue#
Description
30
CAUSE RESULT PROG ORG Issue#
**70
**70
**70
**09
Source Doc's:
References:
Cross Reference To:
-
- X
X
X-
E] Linked CRDR
Keywords:
Completed by:
Distribution Consideration:
ERCFA's M. Oren(7535)
Equipment Failure (SPP/CPP) FDT
Emergency Planning
Radiation Prote•ctio.^. issues J.K.^.ox (7902;
K. Akers / G.Mobbs(799
Chemistry
R. Horton (7996)
D. Ellcinton/ C. Chavet (7996)
Chem. Department Leaders
Audit Findings Audit Team leader
Security J. Nielsen (7996)
Overtime/ FFD B.Whitney (7996)
STA Group (OPS EVAL) B. Rash
Maintenance Department Leaders
Operations Department Leaders
76

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-5
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
For the period June 1993 to June 2009, if the water chemistry limits for the reservoir ponds were exceeded and that the reservoir operated in violation of any procedures, please provide all reports and/or data.
RESPONSE:
The reservoir is operated with specifications for Ammonia and Phosphate. These specifications have not been exceeded, nor have there been any violations related to these specifications.
Preparer:
Sponsor:
Matthew Benac
Matthew Benac
Title: Director-Strategic Planning-APS
Title: Director-Strategic Planning-APS
77

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR §
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-6
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
For the period June 1993 to June 2009, if the water chemistry limits for the Cooling Towers were exceeded and that the Cooling Towers operated in violation of any procedures, please provide all reports and/or data.
RESPONSE:
The Circulating Water (CW) Canals are operated with specifications for pH, Silica, Sulfate,
Chloride, Total Dissolved Solids, Calcium Phosphate, Calcium Carbonate, Calcium Sulfate,
Calcium Fluoride, Silicon Dioxide, and Magnesium Silicate. These specifications have not been exceeded, nor have there been any violations related to these specifications.
Preparer: Matthew Benac
Sponsor: Matthew Benac
Title:
Title:
Director-Strategic Planning-APS
Director-Strategic Planning-APS
78

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-7
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Did Palo Verde operate on phosphate chemical control in the secondary side of the Steam
Generator? If not, please provide the dates when Palo Verde switched to a new process. Please explain the new process including the benefits and operation and maintenance costs as compared to the old chemical control process.
RESPONSE:
No, Palo Verde never operated on phosphate chemical control in the secondary side of the Steam
Generators, hence, did not switch to a new chemical control process. Palo Verde implements All
Volatile Treatment (AVT) for conditioning the whole steam-water system which is based on the addition of only volatile chemicals which will not highly concentrate in any part of the system.
All Volatile Treatment is consistent with the recommendations in EPRI PWR Secondary Water
Chemistry Guidelines.
Preparer: Matthew Benac
Sponsor: Matthew Benac
Title: Director-Strategic Planning-APS
Title: Director-Strategic Planning-APS
79

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-8
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Please provide information on all proactive processes that Palo Verde instituted in its operation and maintenance (O&M) programs that would have helped in longer life for the six capital projects.
RESPONSE:
The following is a list of the proactive processes that Palo Verde instituted that help to obtain a longer life for the six capital projects:
1.
Steam Generators (SGs): proactive process that would have helped in longer life for the
Steam Generators is described in responses to MA-1-2 and MA-1-19A.
2.
Low Pressure Turbines: proactive process that would have helped in longer life for the Low
Pressure Turbines is described in response to MA-1-2
3.
Power Up Rate: this is a new project, thus no measures taken to prolong life.
4.
Water Reclamation Facility reservoirs: proactive process that would have helped in longer life for the 80 acre reservoir is described in responses to MA-1-2 and MA-1-16.
Water Reclamation Supply System Conveyance Piping and Cooling Tower Makeup and
Blowdown: a number of operations and maintenance measures have been taken to prolong the life of these components.
For example, cathodic protection was added to reduce corrosion, modified and improved the conveyance line supply to reduce the transient surges on the pipe, developed and implemented routine coatings and inspections, performing ongoing eddy current inspection and repair of degraded pipe spools, implemented a program to seal manhole penetrations to prevent water intrusions into the pipeline manholes and proceduralized isolation of non flowing pipes to reduce pressure surges.
80

SOAH Docket No. 473-10-1677
Docket No. 37690
Staffs 6th, Q. No. MA-1-8
Page 2 of 2
6.
Dry Cask Storage: this is a new project, thus no measures taken to prolong life.
Preparer: Matthew Benac
Sponsor: Matthew Benac
Title: Director-Strategic Planning-APS
Title: Director-Strategic Planning-APS
81

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-9
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Did Palo Verde have copper components in the secondary side in the balance-of-plant system, i.e. main condenser, feedwater, moisture separator reheaters?
When were those components removed? And what material replaced the copper components? Please explain the benefits of the new material.
RESPONSE:
Palo Verde never had major components in the secondary side of the plant made of copper.
Palo Verde's main condenser tube sheet is constructed of aluminum bronze, which contains a small amount of copper. However, feedwater copper analysis has consistently shown to be less than 20 parts per trillion.
Preparer: Matthew Benac
Sponsor: Matthew Benac
Title: Director-Strategic Planning-APS
Title: Director-Strategic Planning-APS
82

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-10
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Please refer to page 26 lines 10-11 of direct testimony of Mathew Benac. Please provide all data/information and a summary of the extensive efforts that were undertaken to retard the corrosion process.
RESPONSE:
Referenced Matt Benac Testimony:
Q. WHEN WAS DEGRADATION FIRST DISCOVERED?
A.
The degradation was first discovered in the early 1990s.
In March of 1993,
Palo Verde Unit 2 experienced a Steam Generator tube rupture subsequently determined to be due to an axial crack in the upper elevation of the tube bundle caused by inter-granular stress corrosion cracking on the outer tube wall. Extensive testing, in the refueling outage following the tube rupture, identified an area of tubes in the upper elevation of the bundle where a significant number of axial cracks had occurred. Analysis identified the arc-shaped region as an area susceptible to dry-out and deposit formation, which then allowed concentrated chemicals to form corrosive bridging deposits that created crevice environments.
Despite extensive efforts to retard the corrosion process, this degradation mechanism continued to be responsible for upper bundle axial cracking and required additional tube plugging in
Palo Verde Steam Generators during subsequent operating cycles. This continued degradation resulted in a shorter expected operating life of the Steam Generators, and a projected loss of MW generation each year that would increase at an increasing rate.
83

SOAH Docket No. 473-10-1677
Docket No. 37690
Staffs 6th, Q. No. MA-1-10
Page 2 of 2
Response:
Please see Company response to Staff s Sixth Request for Information, Question No. MA-1-19A, which includes the description of the extensive efforts taken to retard the corrosion process (see response beginning on page 2, "To obtain this performance, PVNGS implemented a number of process changes and steam generator improvements in order to arrest and retard certain damage mechanisms.")
Preparer:
Sponsor:
Matthew Benac
Matthew Benac
Title: Director-Strategic Planning-APS
Title: Director-Strategic Planning-APS
84

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-11
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Please refer to page 26 lines 20-26 and Page 35 lines 3-6 of direct testimony of Mathew Benac.
Did Palo Verde provide the data as well as the tools for the economic analysis to all the owners?
RESPONSE:
Referenced Matt Benac Testimony:
Q.
WHAT TYPE OF ANALYSES DID THE OWNERS UNDERTAKE TO DETERMINE THEIR
ALTERNATIVES?
A.
The Owners undertook economic analyses, which determined that the most economical course of action was the replacement of the Steam Generators in all three units.
The component replacement economic analysis determined that the most economical course of action was the replacement of the Unit 2 Steam Generators in September 2003. Each owner conducted economic analyses to confirm that Steam Generator Replacement was the most economical option for its system and customers.
The analysis determined that plant operating and maintenance costs would be reduced; plant availability and reliability would be improved; continued operation of the plant through the end of the present operating license would be assured; plant license extension for another 20 years could be considered; and a Power Up Rate could be added as well.
Q. WHAT TYPE OF ANALYSES DID THE OWNERS DO TO DETEF.Y-n,vE THEIR
ALTERNATIVES?
A.
The economic analysis discussed above for the Steam Generators performed by
Palo Verde and its Owners also confirmed that the most economical course of action was the replacement of the low pressure turbines at the Station in 2003, 2005 and
2007. One of the considerations as to when replacement occurred was that each Unit
85

SOAH Docket No. 473-10-1677
Docket No. 37690
Staffs 6th, Q. No. MA-1-11
Page 2 of 2
was already scheduled to be off-line for Steam Generator Replacement - which would accommodate Low Pressure Turbine Replacement, thus avoiding a second, long outage at each Unit.
Similar to the Steam Generator project, timing of the replacement was well managed and deferred to the extent possible. Actions were taken at each Unit to maintain the old turbines.
While it was not practical to do so for all rows of turbine blades, new connections were machined and new (longer)
blades were procured and installed to prolong life until the new Low Pressure
Turbines could be fabricated, delivered and installed.
Also, in some instances,
portions of rows of blades were removed where connections were significantly degraded.
Evolutions such as these served to lengthen refueling outages at the
Station, prior to replacement and reduced output in subsequent operating cycles, but have been remedied by replacement in 2003, 2005 and 2007.
Response:
The Owners undertook economic analyses, which determined that the most economical course of action was the replacement of the Steam Generators in all three units.
The component replacement economic analysis determined that the most economical course of action was the replacement of the Unit 2 Steam Generators in September 2003.
Each owner conducted economic analyses to confirm that Steam Generator Replacement was the most economical option for its system and customers.
Yes, Palo Verde provided a Steam Generator Degradation model to the owners for their use. The model contained cost information and projected output figures owners could use for input to their respective analysis.
Preparer: Matthew Benac
Sponsor: Matthew Benac
Title: Director-Strategic Planning-APS
Title: Director-Strategic Planning-APS
86

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-12
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
For the economic analysis mentioned in MA-1-10, does El Paso Electric have the trained personnel and the necessary tools to do the evaluation? Please explain in details on the analytical process.
RESPONSE:
El Paso Electric has the trained personnel and the necessary tools to do the economic analysis referred to.
The trained personnel included EPE's Planning Department personnel, who have extensive experience in evaluating various resource planning alternatives and resource additions.
In addition, the results were reviewed by representatives of the Nuclear Oversight, Power
Generation Management, Board Sub-Committee, Power Marketing Management, Executive
Management and the Board of Directors.
An economic analysis was run in PROMOD using a base case "no replacement" option verses a
"replacement" scenario.
Models include production costs (including fuel), unit expected retirements, load forecasts, and capital additions for the two scenarios, then comparing the cost differences of the modeled results.
Preparer:
Sponsor:
Andres R. Ramirez
Andres R. Ramirez
Title: Vice President-Power Generation
Title: Vice President-Power Generation
87

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-13
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Please refer to page 27 lines 8-15 of direct testimony of Mathew Benac. Did Palo Verde replace its three generators that utilized Inconel 690? If not, please provide explanation why Incone1690 was not used.
RESPONSE:
The original Palo Verde Steam Generator generators utilized Inconel 600. Palo Verde Steam
Generator replacements utilized Inconel 690 material.
Preparer:
Sponsor:
Matthew Benac
Matthew Benac
Title: Director-Strategic Planning-APS
Title: Director-Strategic Planning-APS
88

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-14
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Please explain the concept, cause and remedy of inter-granular stress corrosion cracking.
RESPONSE:
The original steam generators at PVNGS Units 1, 2 and 3 were designed and fabricated by
Combustion Engineering (CE), and were of the System 80 design. Earlier versions of CE steam generators were installed at Millstone, Calvert Cliffs, St Lucie, Palisades, Waterford and San
Onofre.
Each PVNGS steam generator contained 11,012 - 3/4 inch OD, Alloy 600 tubes. The tubes had a nominal wall thickness of 0.042" and an average heated length of 57.75 feet. The tubes were expanded into the tubesheet for the entire tubesheet thickness. The tubing was manufactured to the requirements of ASME SB-167, referred to as Inconel, or Alloy 600.
In the Nuclear Industry, Alloy 600 tubing was found to be susceptible to many forms of corrosion degradation.
The corrosion of Alloy 600 tubing is generally characterized as either secondary side intergranular attack (IGA), outside diameter (secondary side) stress corrosion cracking
(ODSCC) or primary side initiated (water) stress corrosion cracking (PWSCC). Secondary side corrosion is a pervasive form of degradation, accounting for over half of the tubes requiring repair worldwide. The concept of IGA/SCC is the dissolution of grain boundaries of the metal that can either volumetrically or fracturally reduce the structural and leakage integrity of the tubing. It is typically caused by a concentration of contaminants, and can occur in both basic and acidic water environments. The tubing stress state and operating temperatures can also impact the initiation and growth rate of the corrosion. Additionally, the presence of ODSCC and IGA can be strongly correlated with the presence of designed crevice locations (tube/tube supports) and crevices formed by the deposition of iron deposits. The crack orientation is dependent on the stress direction, and can be either axial or circumferential or a combination thereof. The orientation of the degradation may dictate the inspection techniques used to detect the corrosion.
89

SOAH Docket No. 473-10-1677
Docket No. 37690
Staffs 6th, Q. No. MA-1-14
Page 2 of 2
Primary water stress corrosion cracking (PWSCC) unlike IGA/ODSCC is a pure water
phenomenon. Alloy 600 was a material developed for steam generators and was originally
believed to be immune to stress corrosion cracking in pure water. However, in 1976, PWSCC
was first identified at several US plants in locations of high residual stress (e.g., dented
intersections, Row 1 U-bends and at tubesheet expansion transitions). The initiation and growth of PWSCC is a function of environment (temperature) and stress state. Like ODSCC, crack
orientation is dependent on the stress direction. In 1991, PWSCC was found in the PVNGS
tubesheet expansion transitions and later in the Row 1-3 U-bends
In March of 1993, PVNGS Unit 2 experienced a steam generator (SG) tube rupture subsequently determined to be due to a free span axial crack in the upper elevation of the tube bundle caused by intergranular stress corrosion cracking (IGSCC) on the outer tube wall. Extensive eddy current testing in the refueling outage following the tube rupture identified an arc shaped area of tubes in the upper elevation of the bundle where a significant number of axial cracks occurred.
The empirical data led to a thermo-hydraulic analysis that identified a large area in the upper region of the steam generator that was susceptible to dryout and deposit formation which could concentrate corroding species and lead to bridging deposits that form crevice environments.
Numerous actions were taken to prolong life of the original Steam Generators and mitigate degradation, as addressed in Mr. Benac's testimony.
Despite these extensive efforts to retard the corrosion process, this degradation mechanism continued to be responsible for extensive upper bundle axial cracking.
A number of the remedies used are described in the response to MA 1-19A, and referenced by the response to MA 1-10. The remedy to eliminate the issue was replacement of the original PVNGS Steam Generators.
Preparer: Matthew Benac
Sponsor: Matthew Benac
Title: Director-Strategic Planning-APS
Title: Director-Strategic Planning-APS
90

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-15
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Please refer to page 36 lines 8-24 and page 37 lines 2-6 of direct testimony of Mathew Benac.
Was this Power Up Rate project required by any regulatory agency? Please explain the cost benefit on this project.
RESPONSE:
No, the Power Up Rate (PUR) project was not required by any regulatory policy. NRC approval to operate the plant at higher power was required, however. Changes in the operating license were necessary, and the NRC had to approve these changes.
Mr. Benac's direct testimony, page 37 lines 2-7, describes how the cumulative benefit of the replacement Steam Generators, Low Pressure turbine and Power Up Rate is 204 MWe. The incremental contribution of the PUR is approximately 117 MWe of the 204 MWe additional site generation.
This is a favorable cost benefit to the Palo Owners- $26.2M for an additional
117 MWe generation, or approximately $222/kW, which compares very favorably to the cost of alternative sources of capacity.
Preparer: Matthew Benac
Sponsor: Matthew Benac
Title:
Title:
Director-Strategic Planning-APS
Director-Strategic Planninb APS
91

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-16
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Please refer to page 37 lines 21-23 of direct testimony of Mathew Benac. Please explain in detail on the O&M process in place and whether Palo Verde operated the reservoir pond within the process limits. Also, if it occurred, include data that showed operations of the pond outside of the process limits.
RESPONSE:
Palo Verde did not operate the reservoir outside of the process limits, or operational parameters of flow into the reservoir and level of the reservoir.
As for the operational process, Palo Verde operated the reservoir under an Aquifer Protection
Permit (APP) issued by the Arizona Department of Environmental Quality (ADEQ).
For maintenance of the liner, Palo Verde performed inspection of the visual portions (basically at or above the water level) of liner on a weekly basis and repaired any deficiencies found. This action, required by the APP, was more conservative than that required by the liner manufacturer. During outages (two times a year) Palo Verde would lower the reservoir down to approximately 50% level.
During these times the liner would be visually inspected down to the water level and repairs to any deficiencies were made prior to refilling the reservoir. Potential leakage from the lower portions of the liner was monitored through ground water observation wells located around the perimeter of the reservoir. These wells were monitored by the Palo Verde Environmental group which initially alerted the station to the possible leakage from the lower portion of the reservoir. Underwater inspection by divers confirmed that actual failure of the liner. Notifications were made to ADEQ upon confirmation of the liner failure.
Water chemistry specifications were addressed in response to Staffs Sixth Request for Information, Question No. MA-1-5.
Preparer: Matthew Benac
Sponsor: Matthew Benac
Title:
Title:
Director-Strategic Planning-APS
Director-Strategic Planning-APS
92

SOAH DOCKET NO. 473-10-1677
PUC DOCKET NO. 37690
APPLICATION OF EL PASO ELECTRIC
COMPANY TO CHANGE RATES, TO
RECONCILE FUEL COSTS, TO ESTABLISH
FORMULA-BASED FUEL FACTORS, AND
TO ESTABLISH AN ENERGY EFFICIENCY
COST RECOVERY FACTOR
§
§
§
§
§
§
BEFORE THE STATE OFFICE
OF
ADMINISTRATIVE HEARINGS
EL PASO ELECTRIC COMPANY'S RESPONSE TO
COMMISSION STAFF'S SIXTH REQUEST FOR INFORMATION
QUESTION NOS. MA-1-1 THROUGH MA-1-22
COMMISSION STAFF'S MA-1-17
The following questions concern the Palo Verde Nuclear Generating Station (Palo Verde):
Please refer to page 37 line 22 of direct testimony of Mathew Benac. Please provide the manufacturer's specifications or other data that showed the liner life was 20-year.
RESPONSE:
The manufacture specifications are attached. Please refer to page 1 paragraph 2, and the attached warranty bond.
Preparer:
Sponsor:
Matthew Benac
Matthew Benac
Title: Director-Strategic Planning-APS
Title: Director-Strategic Planning-APS
93

Docket No. 37690
Staffs 6th, Q. No. MA-1-17
Attachment
Page 1 of 28
4 ) r
AZ a 3/JV JW-4. paoma_
^llnu^i^
Engineers - Constructors
AC'b-
Palo Verde Nuclear Generating Station
P.O. Box 49
Palo Verde. Arizona 85343
December 20, 1982
B/AEO-29-S r^^OR^?i^}aA521
Arizona Nuclear Power Project
P. 0. Box 21666
Phoenix, Arizona 85036
'83 JAN -5 llb:52
Attention:
Mr. G. C. Andognini
Vice President Electrical Operations
Subject:
Palo Verde Nuclear Generating Station
Bechtel Job 10407
Subcontract 10407-13-CM-020
Construction of Ponds and Appurtenances
File;
13-CM-020
Dear Mr. Andognini:
This is to advise you that the Evaporation Pond and Make up Water Reservoir were transferred for start-up and operation purposes as part of subsystems
OW-02 and ITB-O1 respectively.
Future correction of liner deficiencies, if any, should be performed under the terms of the 20 year warranty supplied by the Subcontra,!tor.
Information related to the 20 year warranty and the original warranty bonds are attached for your information and use.
Very truly yours,
BECHTEL Pow_ co
ION
W. J. Stu bl field
Fiel Constr ction Manager
WJS:p:bac cc:
J. R. Bynum
E. E. Van Brunt, Jr.
D. B. Fasnacht
D. B. Hansen
W. H. Wilson
A. K. Priest
J. Vorees
A. G. Peterson
,.
^
^ *: . , . . _ .
94

co
Docket No. 37690
Staffs 6th, Q. No. MA-1-17
Attachment
Page 2 of 28 all-46c
^. sNo
DATE:
TO:
Ste. 1
FROM:
Sts. N
Ext. #
SUBJECT:
^^
^^ ^G%MpAaS"
COMPANY CORRESPONDENCE
January 26, 1983
ANPM-15473 - latJ/KW
Contract Audit/Central Files
1565
E. E. Van Brunt, Jr.
30U3
7597
Information related to Ponds and Appurtenances
Construction 20 Year Warranty and Warranty Bonds
File:
CM-020; 83-003-214
Attached for the "Important Papers" file is information regarding the 20 Year Warranty and the original Warranty Bonds.
EEVBJr/iQi/av
Attachment cc: A. C. Gehr
(F_^ _^^ ,,
TO: E.
E.
Van Brunt, Jr.
Station 3003
This acknowledges receipt of information related to Ponds and Appurtenances Construction 20 Year W4rranty and the
Original Warranty Bonds, File;
CH-020; 83-903-214.
Bate
Centra Files
95

Docket No. 37690
Staffs 6th, Q. No. MA-1-17
Attachment
Page 3 of 28 r
Information Related to the 20 year
Warranty of the Evaporation Pond and the Make up Water Reservoir linings.
Subcontract 10407-13-C24-020
To comply with the Subcontract Exhibit "C" paragraph C.2.2.a.4, Granite
Construction Company submitted two 20 year warranty bonds, one covering the rubberized asphalt membrane in the amount of $4,714,000.00 and one covering the hypalon liner in the amount of $1,169,000.00.
The warranty applies to the Evaporation Pond and the Makeup Water Reservoir linings.
The applicable warranty period commences with acceptance of the liner installation.
Bechtel recognized completion of the Evaporation Pond with letter to
Granite dated January 5, 1982 and completion of the Makeup Water Reservoir with letter dated March 18, 1982.
The Subcontract Exhibit "D" par-igraph D.18 indicates that the planned filling rate of the Evaporation Pond is 4500/1000 (max./min.) gallons per minute and that most of the pond area will be dry and exposed to the local environment factors for a period of two to four years. Paragraph D3.1.2 indicates that the Reservoir is designed to be kept full of treated sewage effluent water.
The construction subcontract was closed on November lst, 1982.
Deficiencies found in the future on either pond should be brought to the attention of Granite by the APS Operations Office for the necessary corrections within the frame work of the 20 year warranty now in effect.
Attachments:
Original 20 year warranty bonds.
Comments on a suggested pond inspection requirements, with copies of pertinent sections of the subcontract documents.
96

Docket No. 37690
Staffs 6th, Q. No. MA-1-17
Attachment
Page 4 of 28
INSPECTION
In order to comply with the warranty it is necessary that the lined areas be inspected and the result of inspections transmitted
Construction to Granite
Company or to whom Granite may designate.
The rates of fill, particularly the two types area.
at the Evaporation pond, of areas to be inspected: will determine the dry area and the underwater
The large lined areas will require maintenance inspection, with several
(10 to 12) qualified persons periodically or with a smaller number (2 to
3) in an almost continuous cycle in such a way that all areas are inspected every 15 days.
It is recommended that the liner repairs, or not, be performed by Granite or it's whether covered by the warranty designees, to avoid any disputes or voiding of warranty during the 20 year period.
Inspection of Dry Areas:
The use of vehicles inside the ponds could produce damages to the liner depending on the weight of the vehicle and the temperature of the day.
The persons inspecting the liner could use spray can type paint to mark defective areas.
The specific type of paint to be used should be determined by Granite in order to avoid chemical incompatiblity of the hypalon and or the rubberized asphalt.
The following typical rubberized-asphalt defects have been noticed and repaired on the liner before transfer:
1)
2)
3)
4)
Liner perforation caused by ants.
Liner perforation
Gas or air bubbles. caused by plants.
Liner placed over small rocks showing a thinned coAring.
To correct defect Nos. 1 and 2 Granite supplied a repair procedure, a copy of which is attached.
Granite has corrected defects 3 and 4 by direct cut and patch of the affected areas. Arizona Refining
(ARCO) was
Granites subtier contractor on the rubberized asphalt.
No defects have been noticed
Goodrich bulletin EL-4-477 submitted
10407-13-CM-020-1-1 provides on the installed hypalon liner.
The B. F.
as part of Granite's document No.
information on care and maintenance of hypalon.
Inspection of Underwater Areas:
Areas covered by small amounts of water are still subject to visual inspection of person perforate underwater wearing rubber boots.
Whether liner remains to be seen.
ants and plants will graphs D2.2.10 outlines the method
The specification paraized asphalt liner.
to vent gases from underwater rubber-
97

Docket No. 37690
Staffs 6th, Q. No. MA-1-17
Attachment
Page 5 of 28
Inspection
Page two
Monitoring of Leakage
Paragraph D2.2.4 of the specification indicates the permeability of the ponds.
In the case of the Evaporation Pond, leakage, if any, would be observed at the seven inspections sumps discharging into the gunited ditch.
Other
Venting of soil gases from beneath the hypalon have been provided through flap type vents installed by Granite. B. F. Goodrich was Granite's subtier contractor on the hypalon liner.
The inspection of the Evaporation Pond dam intergrity is not part of the subcontract specification but may be considered in the inspection -proceedures to be prepared.
State agencies did perform inspections during
Pond construction and received reports from the Owner.
Signs have been posted to limit access to pond bottoms and slopes, they should be maintained.
,9&.y t!
r4ivrg
98

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