ML091280219
| ML091280219 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 05/12/2009 |
| From: | Hall J Plant Licensing Branch IV |
| To: | Markley M Plant Licensing Branch IV |
| Hall, J R, NRR/DORL/LPL4, 301-415-4032 | |
| References | |
| TAC ME0664, TAC ME0665, TAC ME0666 | |
| Download: ML091280219 (4) | |
Text
May 12, 2009 MEMORANDUM TO: Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
James R. Hall, Senior Project Manager /RA/
Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE MAY 6, 2009, CONFERENCE CALL WITH ARIZONA PUBLIC SERVICE COMPANY AND VERBAL NRC AUTHORIZATION GRANTING RELIEF REQUEST NO. 41 FOR THE PALO VERDE NUCLEAR GENERATING STATION UNITS 1, 2, AND 3 (TAC NOS. ME0664, ME0665, AND ME0666)
By letter dated February 17, 2009 (Agencywide Documents Access Management System (ADAMS) Accession No. ML090580199), Arizona Public Service Company (APS), the licensee for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, submitted Relief Request No. 41 (RR 41) for approval of an alternative from certain requirements of the 2001 Edition through 2003 Addenda of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) under the provisions of Title 10 of the Code of Federal Regulations 50.55a(a)(3)(i). Specifically, the licensee requested approval from the U.S. Nuclear Regulatory Commission (NRC) to use the methodology of Appendix I of Code Case N-729-1 to define an alternative examination area or volume definition for reactor head penetrations. The requested relief would apply for each of the three PVNGS units, through the end of that units third inspection interval, or until that units reactor vessel head is replaced, whichever occurs first.
A conference call was held on May 6, 2009, to discuss the results of the NRC staffs review of the relief request with APS. The NRC Project Manager (PM) noted that APS had requested approval of RR 41 by May 7, 2009, in order to support the start-up of the Unit 3 reactor upon completion of the current refueling outage. The PM also noted that NRC procedures allow for granting temporary verbal authorizations under 10 CFR 50.55a(a)(3), in certain limited circumstances, as described in LIC-102, Revision 1, Relief Request Reviews, dated January 26, 2005 (ADAMS Accession No. ML042780148). APS submitted the application in February 2009, as the result of a new rule for reactor vessel head inspections, 10 CFR 50.55a(g)(6)(ii)(D), which the licensee implemented on December 31, 2008. Representatives of the NRC staff from the Piping and NDE Branch in the Office of Nuclear Reactor Regulation stated that the staff has completed its technical review of RR 41. However, due to the limited time between the submittal date and the requested approval date, the staff has not yet completed its written safety evaluation; therefore, the staff considered this relief request as a candidate for a verbal authorization.
The NRC staff summarized the results of its review. The staff did not find a sufficient basis to support the licensee's original request under 10 CFR 50.55a(a)(3)(i) to use the methodology of Appendix I of ASME Code Case N-729-1 to provide an equivalent inspection to demonstrate the adequacy of the proposed examination volume or surface for each nozzle as required by Figure 2 of ASME Code Case N-729-1. However, the analysis submitted in support of, and referenced by RR 41, was sufficient to provide reasonable assurance of the structural integrity of the reactor coolant pressure boundary. Furthermore, the licensee's analysis demonstrated that additional examination beyond the proposed alternative, to meet the original requirement for all penetration nozzles, would present a significant hardship due to radiological dose, without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the staff verbally authorized the implementation of the proposed alternative of RR 41 at PVNGS Units 1, 2, and 3, for the third 10-year inservice inspection interval for each unit, or until that units reactor vessel head is replaced, whichever occurs first.
The NRC staff stated that it intends to issue a written safety evaluation (SE) in support of its authorization for APS to use the alternative of RR 41. The staffs goal is to issue that written SE within 30 days. A list of the participants on the call is enclosed.
Docket Nos.: STN 50-528 STN 50-529 STN 50-530
Enclosure:
List of Participants
The NRC staff summarized the results of its review. The staff did not find a sufficient basis to support the licensee's original request under 10 CFR 50.55a(a)(3)(i) to use the methodology of Appendix I of ASME Code Case N-729-1 to provide an equivalent inspection to demonstrate the adequacy of the proposed examination volume or surface for each nozzle as required by Figure 2 of ASME Code Case N-729-1. However, the analysis submitted in support of, and referenced by RR 41, was sufficient to provide reasonable assurance of the structural integrity of the reactor coolant pressure boundary. Furthermore, the licensee's analysis demonstrated that additional examination beyond the proposed alternative, to meet the original requirement for all penetration nozzles, would present a significant hardship due to radiological dose, without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the staff verbally authorized the implementation of the proposed alternative of RR 41 at PVNGS Units 1, 2, and 3, for the third 10-year inservice inspection interval for each unit, or until that units reactor vessel head is replaced, whichever occurs first.
The NRC staff stated that it intends to issue a written safety evaluation (SE) in support of its authorization for APS to use the alternative of RR 41. The staffs goal is to issue that written SE within 30 days. A list of the participants on the call is enclosed.
Docket Nos.: STN 50-528 STN 50-529 STN 50-530
Enclosure:
List of Participants DISTRIBUTION:
PUBLIC LPLIV Reading RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsOgcRp Resource RidsRgn4MailCenter Resource JWallace, NRR/DCI/CPNB JCollins, NRR/DCI/CPNB ADAMS Accession No: ML091280219
- see previous concurrence OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/CPNB/BC NRR/LPL4/BC NRR/LPL4/PM NAME JRHall JBurkhardt TChan* (JTsao for)
MMarkley JRHall DATE 5/11/09 5/11/09 5/12/09 5/12/09 5/12/09 OFFICIAL AGENCY RECORD
Enclosure LIST OF PARTICIPANTS MAY 6, 2009, CONFERENCE CALL REGARDING RELIEF REQUEST NO. 41 FOR THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 ARIZONA PUBLIC SERVICE COMPANY Russell Stroud, Licensing Section Leader Rich Rogalski, Sr. Engineer, Licensing Edison Fernandez U.S. NUCLEAR REGULATORY COMMISSION Terence Chan, Chief, Piping and NDE Branch (CPNB), NRR James R. Hall, Sr. Project Manager and Acting Chief, Plant Licensing Branch IV, DORL/NRR Jay Collins, CPNB/NRR Jay Wallace, CPNB/NRR Michele Catts, Resident Inspector, Region IV