ML092590613
| ML092590613 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/30/2009 |
| From: | Lisa Regner License Renewal Projects Branch 2 |
| To: | Edington R Arizona Public Service Co |
| Regner L M, NRR/DLR, 415-1906 | |
| References | |
| TAC ME0254, TAC ME0256 | |
| Download: ML092590613 (11) | |
Text
September 30, 2009 Mr. Randall K. Edington Executive Vice President, Nuclear Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072
SUBJECT:
PLAN FOR THE SCOPING AND SCREENING METHODOLOGY REGULATORY AUDIT REGARDING THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION REVIEW (TAC NOS. ME0254 - ME0256)
Dear Mr. Edington:
By letter dated December 11, 2008, Arizona Public Service Company submitted an application for renewal of operating licenses NPF-41, NPF-51, and NPF-74 for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde). The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants.
The staff plans to conduct its scoping and screening methodology regulatory audit at Palo Verde during the week of October 19, 2009, in accordance with the enclosed regulatory audit plan. If you have any questions, please contact me by telephone at 301-415-1906 or by e-mail at Lisa.Regner@nrc.gov.
Sincerely,
/RA/
Lisa Regner, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-528, 50-529, 50-530
Enclosures:
As stated cc w/encls: See next page
September 30, 2009 Mr. Randall K. Edington Executive Vice President, Nuclear Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072
SUBJECT:
PLAN FOR THE SCOPING AND SCREENING METHODOLOGY REGULATORY AUDIT REGARDING THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION REVIEW (TAC NOS. ME0254 - ME0256)
Dear Mr. Edington:
By letter dated December 11, 2008, Arizona Public Service Company submitted an application for renewal of operating licenses NPF-41, NPF-51, and NPF-74 for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde). The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants.
The staff plans to conduct its scoping and screening methodology regulatory audit at Palo Verde during the week of October 19, 2009, in accordance with the enclosed regulatory audit plan. If you have any questions, please contact me by telephone at 301-415-1906 or by e-mail at Lisa.Regner@nrc.gov.
Sincerely,
/RA/
Lisa Regner, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-528, 50-529, 50-530
Enclosures:
As stated cc w/encls: See next page DISTRIBUTION: See next page ADAMS Accession Number: ML092590613 OFFICE LA:DLR PM:RPB2:DLR BC:RER2:DLR BC:RPB2:DLR PM:RPB2:DLR NAME SFigueroa LRegner RAuluck DWrona LRegner DATE 09/21/09 09/21/09 09/23/09 09/30/09 09/30/09 OFFICIAL RECORD COPY
Letter to R. Edington from L. Regner dated September 30, 2009 DISTRIBUTION:
SUBJECT:
PLAN FOR THE SCOPING AND SCREENING METHODOLOGY REGULATORY AUDIT AND ENVIRONMENTAL SITE VISIT REGARDING THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION REVIEW (TAC NOS. ME0261 - ME0266)
HARD COPY:
DLR RF E-MAIL:
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Palo Verde Nuclear Generating Station, Units 1, 2, and 3 cc:
Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ 85007 Mr. Douglas Kent Porter Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 40 Buckeye, AZ 85326 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ 85003 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 S. 40th Street Phoenix, AZ 85040 Mr. Scott Bauer, Director Regulatory Affairs Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box 52034 Phoenix, AZ 85072-2034 Mr. Dwight C. Mims, Vice President Regulatory Affairs and Plant Improvement Palo Verde Nuclear Generating Station Mail Station 7605 P.O. Box 52034 Phoenix, AZ 85072-2034 Mr. John C. Taylor Director, Nuclear Generation El Paso Electric Company 340 E. Palm Lane, Suite 310 Phoenix, AZ 85004 Mr. James Ray Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM 87107-4224 Mr. Geoffrey M. Cook Southern California Edison Company 5000 Pacific Coast Hwy., Bldg. D21 San Clemente, CA 92672 Mr. Robert Henry Salt River Project 6504 E. Thomas Road Scottsdale, AZ 85251 Mr. Jeffrey T. Weikert Assistant General Counsel El Paso Electric Company Mail Location 167 123 W. Mills El Paso, TX 79901 Mr. Eric Tharp Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA 90051-0100 Mr. Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 N. Congress Avenue Austin, TX 78701-3326 Ms. Karen O'Regan Environmental Program Manager City of Phoenix Office of Environmental Programs 200 W. Washington Street Phoenix, AZ 85003
ENCLOSURE 1 Audit Plan Scoping and Screening Methodology Review for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3 License Renewal Application Audit Date: October 19, 2009 Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
License Renewal Scoping and Screening Methodology Audit Plan Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde)
- 1.
Background
By letter dated, December 11, 2008, Arizona Public Service Company (APS) submitted an application for renewal of operating licenses NPF-41, NPF-51, and NPF-74, for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (Palo Verde). APS requested renewal of the operating licenses for an additional 20 years beyond the 40-year current license terms, which expire on June 1, 2025 (Unit 1), April 24, 2026 (Unit 2), and November 25, 2027 (Unit 3). The staff from the Division of License Renewal will lead a regulatory audit to gain a better understanding of the scoping and screening methodology that was used to prepare Palo Verdes integrated plant assessment (IPA). The IPA is to describe and justify methods used to identify systems, structures, and components (SSCs) subject to an aging management review (AMR).
- 2.
Regulatory Audit Bases License renewal requirements are specified in Title 10 of the Code of Federal Regulations (CFR), Part 54 (10 CFR Part 54), Requirements for Renewal of Operating Licenses for Nuclear Power Plants, and the guidance is provided in NUREG-1800, Rev. 1, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), dated September 2005, and NUREG-1801, Rev. 1, Generic Aging Lessons Learned (GALL) Report, dated September 2005.
- 3.
Regulatory Audit Scope The scope of this regulatory audit for Palo Verde is the methodology used by the applicant to implement the scoping requirements of 10 CFR 54.4, Scope. The methodology used by the applicant to implement the screening requirements of 10 CFR 54.21(a)(1) is also reviewed.
- 4.
Site Documentation List Engineering reports and procedures which contain requirements or guidelines for the implementation of scoping and screening methodology.
10 CFR 54.4(a)(1) plant evaluations and implementing procedures.
10 CFR 54.4(a)(2) plant evaluations and implementing procedures.
10 CFR 54.4(a)(3) plant evaluations, implementing procedures and any specific analyses performed.
License renewal drawings.
System design basis documents and system and component level scoping and screening reports for selected systems and structures: safety injection and shutdown cooling system, diesel generator fuel oil storage and transfer system, auxiliary feedwater system, and the turbine building.
Description of the design basis events included in the Updated Final Safety Analysis Report, and all other additional events (e.g., high energy line break, fire, high wind, earthquakes, flooding, tornadoes), which were evaluated during the scoping process.
Plant equipment database and administrative control procedure.
Plant and industry operating experience used to determine the scope of 10 CFR 54.4(a)(2) systems, structures and components.
Documentation of quality assurance activities associated with license renewal application development.
Documentation of training activities associated with license renewal application development.
- 5.
Team Assignments Area of Review Assigned Auditor Team Lead Billy Rogers Project Manager Lisa Regner Electrical TBD Mechanical and Materials TBD Structural TBD
- 6.
Logistics The audit will be conducted at Palo Verde from October 19, 2009 until October 23, 2009.
Entrance and exit briefings will be held at the beginning and end of this audit, respectively.
- 7.
Special Requests The staff requests the applicant to make available their condition report database for independent searches by the regulatory audit team.
- 8.
Deliverables An audit report should be issued to the applicant within 90 days from the end of the audit.
ENCLOSURE 2 Palo Verde Nuclear Generating Station License Renewal Scoping and Screening Methodology Audit Schedule 10/19/09 - 10/23/09 Monday 10/19 A.M.
! 8:30 a.m. entrance meeting - introductions, audit activities and goals, and audit logistics.
! Applicant presentation to NRC team - consisting of a general overview of the following topics:
Technical references used for scoping and screening (UFSAR, equipment database, Maintenance Rule information).
Program tools used for LRA development (database).
Implementing procedures, guidance, and reports.
Overview of scoping and screening methodology developed and applied to meet the requirements of 10 CFR 54.4(a)(1), (a)(2), (a)(3),
and 10 CFR 54.21(a)(2).
! NRC team breakout - staff review of implementing procedures, basis documents and reports related to 10 CFR 54.4(a)(1) and (a)(3) scoping.
P.M.
! Discussion with the applicant on scoping and screening methodology (a)(1) and (a)(3) for mechanical systems and components - detailed review of scoping and screening methodology, applicable to the mechanical discipline, using the auxiliary feedwater system as an example. Includes the following topics: implementing procedures; source information; electronic databases; definition of safety-related; design bases events consideration; identification of SSCs within scope; identification of intended functions; scoping boundaries and license renewal drawings; identification of SCs subject to AMR; and documentation of the results in scoping and screening reports.
! NRC team breakout - staff follow-up review of implementing procedures, basis documents and reports related to 10 CFR 54.4(a)(1) and (a)(3) scoping (mechanical).
! Daily review of audit activities.
Palo Verde Nuclear Generating Station License Renewal Scoping and Screening Methodology Audit Schedule 10/19/09 - 10/23/09 (cont.)
Tuesday 10/20 A.M.
! NRC team breakout - staff follow-up review of implementing procedures, basis documents and reports related to 10 CFR 54.4(a)(1) and (a)(3) scoping (mechanical) [continued].
! NRC team breakout - staff review of implementing procedures, basis documents and reports related to 10 CFR 54.4(a)(2) scoping.
P.M.
! Discussion with the applicant on scoping and screening methodology (a)(2) for mechanical systems and components -
detailed review of scoping and screening methodology, applicable to the mechanical discipline using the auxiliary feedwater system as an example. Includes the following topics: implementing procedures; source information; electronic databases; identification of SSCs within scope; scoping boundaries and license renewal drawings; identification of SCs subject to AMR; exceptions taken to NEI 95-10, Appendix F; and documentation of the results in scoping and screening reports.
! NRC team breakout - staff follow-up review of implementing procedures, basis documents and reports related to 10 CFR 54.4(a)(2).
! NRC team breakout - staff review of implementing procedures, basis documents and reports related to 10 CFR 54.4(a)(1), (a)(2) and (a)(3) scoping (structural).
! NRC team breakout - staff review of implementing procedures, basis documents and reports related to 10 CFR 54.4(a)(1), (a)(2) and (a)(3) scoping (electrical).
! Daily review of audit activities.
Palo Verde Nuclear Generating Station License Renewal Scoping and Screening Methodology Audit Schedule 10/19/09 - 10/23/09 (cont.)
Wednesday 10/21 A.M.
! Discussion with the applicant on scoping and screening methodology (a)(1), (a)(2) and (a)(3) for structural systems and components - focusing on the differences from the previous discussion on mechanical systems and components, as applicable to the structural discipline, using the turbine building as an example.
! Discussion with the applicant on scoping and screening methodology (a)(1), (a)(2), and (a)(3) for electrical and I&C systems and components.
! Discussion with the applicant on the evaluation of various plant-wide topics: (1) commodities, (2) consumables, (3) plant insulation, (4) overhead handling systems, (5) abandoned equipment, and (6) staged equipment/replacement parts, as applicable.
! Plant equipment database sample review - a staff sampling of the plant equipment database to verify that the selected components were correctly scoped (to be accomplished by the NRC staff, with assistance from the applicant as required).
! Sample system reviews - a staff sample review of safety injection and shutdown cooling system, diesel generator fuel oil storage and transfer system, auxiliary feedwater system, and the turbine building (to be accomplished by the NRC staff, with assistance from the applicant as required).
P.M.
! Plant equipment database sample review [continued].
! Sample system reviews - [continued].
! Plant walkdowns - safety injection and shutdown cooling system, diesel generator fuel oil storage and transfer system, auxiliary feedwater system, and the turbine building (as reasonably accessible and in accordance with ALARA).
! Daily review of audit activities.
Palo Verde Nuclear Generating Station License Renewal Scoping and Screening Methodology Audit Schedule 10/19/09 - 10/23/09 (cont.)
Thursday 10/22 A.M.
! Plant equipment database sample review [continued].
! Sample system reviews [continued].
! Discussion with the applicant on training activities - as applicable to LRA development.
! Discussion with the applicant on quality assurance activities - as applicable to LRA development.
P.M.
! Plant equipment database sample review [continued].
! Sample system reviews [continued].
! Discussion with the applicant on aging management program quality assurance elements - corrective actions, confirmation process, and administrative controls.
UFSAR supplement.
Review of individual aging management programs quality assurance elements - corrective actions, confirmation process, and administrative controls
! Daily review of audit activities.
Friday 10/23 A.M.
! Continuation of previous days activities as required.
! 10:00 a.m. final briefing of audit activities and status (tentative).