ML093380051

Request for Additional Information, License Renewal Application

ML093380051
Person / Time
Site:	Palo Verde
Issue date:	12/23/2009
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 ME0255, TAC ME0256
Download: ML093380051 (8)

Text

December 23, 2009 Mr. Randall K. Edington Executive Vice President, Nuclear Mail Station 7602 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION (TAC NOS. ME0254, ME0255, AND ME0256)

Dear Mr. Edington:

By letter dated December 11, 2008, as supplemented by letter dated April 14, 2009, Arizona Public Service Company (APS) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 to renew Operating License Nos. NPF-41, NPF-51, and NPF-74 for the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, respectively. The staff is reviewing the information contained in the license renewal application and has identified in the enclosure areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

A mutually agreeable date for your response, as discussed with Angela Krainik of APS staff, was determined to be 45 calendar days from the date of this letter. If you have any questions, please contact me at 301-415-1906 or by e-mail at Lisa.Regner@nrc.gov.

Sincerely,

/RA David J. Wrona for/

Lisa M. Regner, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-528, 50-529, and 50-530

Enclosure:

As stated cc w/encl: See next page

ML093380051 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR PM:RPB2:DLR NAME SFigueroa LRegner DWrona LRegner (DWrona for)

DATE 12/07/09 12/22/09 12/23/09 12/23/09

Letter to R. Edington from L. Regner dated December 23, 2009 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION (TAC NOS. ME0254, ME0255 AND ME0256)

HARD COPY:

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L. Regner B. Mizuno R. Treadway, RIV G. Pick, RIV

Palo Verde Nuclear Generating Station, Units 1, 2 and 3 cc:

Mr. Steve Olea Mr. John C. Taylor Arizona Corporation Commission Director, Nuclear Generation 1200 W. Washington Street El Paso Electric Company Phoenix, AZ 85007 340 E. Palm Lane, Suite 310 Phoenix, AZ 85004 Mr. Douglas Kent Porter Senior Counsel Mr. James Ray Southern California Edison Company Public Service Company of New Mexico Law Department, Generation Resources 2401 Aztec NE, MS Z110 P.O. Box 800 Albuquerque, NM 87107-4224 Rosemead, CA 91770 Mr. Geoffrey M. Cook Senior Resident Inspector Southern California Edison Company U.S. Nuclear Regulatory Commission 5000 Pacific Coast Hwy., Bldg. D21 P.O. Box 40 San Clemente, CA 92672 Buckeye, AZ 85326 Mr. Robert Henry Regional Administrator, Region IV Salt River Project U.S. Nuclear Regulatory Commission 6504 E. Thomas Road 612 E. Lamar Blvd., Suite 400 Scottsdale, AZ 85251 Arlington, TX 76011-4125 Mr. Jeffrey T. Weikert Chairman Assistant General Counsel Maricopa County Board of Supervisors El Paso Electric Company 301 W. Jefferson, 10th Floor Mail Location 167 Phoenix, AZ 85003 123 W. Mills El Paso, TX 79901 Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency Mr. Eric Tharp 4814 S. 40th Street Los Angeles Department of Water & Power Phoenix, AZ 85040 Southern California Public Power Authority P.O. Box 51111, Room 1255-C Mr. Scott Bauer, Director Los Angeles, CA 90051-0100 Regulatory Affairs Palo Verde Nuclear Generating Station Mr. Brian Almon Mail Station 7636 Public Utility Commission P.O. Box 52034 William B. Travis Building Phoenix, AZ 85072-2034 P.O. Box 13326 1701 N. Congress Avenue Mr. Dwight C. Mims, Vice President Austin, TX 78701-3326 Regulatory Affairs and Plant Improvement Palo Verde Nuclear Generating Station Mail Station 7605 P.O. Box 52034 Phoenix, AZ 85072-2034

PALO VERDE NUCLEAR GENERATING STATION LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION RAI 2.1-1

Background:

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 54.4(a), the applicant must consider the following plant systems, structures, and components (SSCs) within the scope of license renewal:

(1) SSCs which are those relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49(b)(1)) to ensure the following functions:

(i) The integrity of the reactor coolant pressure boundary; (ii) The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11, as applicable.

(2) All nonsafety-related SSCs whose failure could prevent satisfactory accomplishment of any of the functions identified above.

(3) All SSCs relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station blackout (10 CFR 50.63).

License Renewal Application (LRA), Section 1.5, Application Structure, states:

PVNGS Unit 1, Unit 2, and Unit 3 [Palo Verde Nuclear Generating Station, Unit Nos. 1, 2, and 3] are constructed of similar materials with similar environments. Unless otherwise noted throughout this application, plant systems and structures discussed in this application apply to PVNGS Units 1, 2 and 3.

LRA Section 2.1.3.1, Mechanical System Scoping Methodology, states:

Unit 1 P&IDs [piping and instrumentation drawings] or combined unit P&ID(s) were marked-up to show the license renewal boundary. PVNGS uses combined unit P&IDs to depict all three units on a single P&ID. When Unit 1 P&IDs were used, Unit 2 and Unit 3 P&IDs were reviewed to confirm the similarity of the boundaries/interfaces and the absence of unit specific differences. Component level scoping results from the plant equipment database also confirmed P&ID information for each units boundaries/interfaces and components within the license renewal boundary.

ENCLOSURE

Issue:

During review of the LRA and the performance of the scoping and screening methodology audit, performed on-site October 19 - 22, 2009, the staff determined that although differences exist between the three units, the applicant had provided a single set of license renewal drawings to assist the staff in performing its review. The staffs review of license renewal drawing LR-PVNGS-CT-01-M-CTP-001 identified a vent and drain valve, which is present only in Unit 2, but which is not identified or described in the LRA.

Request:

The staff requests that the applicant:

(1) Provide a description of the process used to identify and document the differences in SSC configurations between the three units.

(2) Provide a list of any differences of SSCs included within the scope of license renewal and any structures or component subject to aging management review, between the three units.

(3) Provide a description of the process used to identify and document the difference in material and environments between similar structures or components between the three units.

The staff requests that the applicant perform a review of the issue and indicate if the review concludes that use of the scoping methodology precluded the identification of SSCs which should have included within the scope of license renewal in accordance with 10 CFR 54.4(a).

Describe any additional scoping evaluations to be performed to address the 10 CFR 54.4(a) criteria. As part of your response, list any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted or any additional information related to material and environment combinations.

For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.

RAI 2.1-2

Background:

Pursuant to 10 CFR 54.4(a)(2), the applicant must consider all nonsafety-related SSCs, within the scope of license renewal, whose failure could prevent the satisfactory accomplishment of safety-related functions, as described in 10 CFR 54.4(a)(1).

Issue:

During the scoping and screening methodology audit, performed on-site October 19 - 22, 2009, the staff determined, through a review of the 10 CFR 54.4(a)(2) implementing document, that the applicant had not included certain fluid-filled, nonsafety-related SSCs, adjacent to safety-related SSCs, within the scope of license renewal. The applicants basis for not including the

nonsafety-related SSCs was information contained in the applicants Moderate Energy Crack Evaluation, document.

Request:

The staff requests that the applicant perform a review of the issue and provide the following:

(1) The basis for the applicants determination that the Moderate Energy Crack Evaluation is part of the current licensing basis (CLB).

(2) A description and analysis of the pertinent information contained in the Moderate Energy Crack Evaluation which provides the basis for the conclusion that failure of the nonsafety-related, fluid filled SSCs could not prevent the satisfactory accomplishment of safety-related functions for SSCs relied on to remain functional during and following a design basis event.

(3) The nonsafety-related SSCs which were not included within the scope of license renewal on the basis of information contained in the Moderate Energy Crack Evaluation.

Indicate if the review concludes that use of the scoping methodology precluded the identification of nonsafety-related SSCs that could interact with safety-related SSCs, and which were not specifically exempted by the CLB, and therefore should have been considered within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations to be performed to address the (a)(2) criteria. As part of your response, list any additional SSCs included within the scope as a result of your efforts, and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects RAI 2.1-3

Background:

Pursuant to 10 CFR 54.4(a)(2), the applicant must consider all nonsafety-related SSCs, within the scope of license renewal, whose failure could prevent the satisfactory accomplishment of safety-related functions, as described in 10 CFR 54.4(a)(1).

Issue:

During the scoping and screening methodology audit, performed on-site October 19 - 22, 2009, the staff determined that the following nonsafety-related SSCs had not been included within the scope of license renewal:

(1) Nonsafety-related pipe, attached to the safety-related penetration of the condensate tank.

(2) Nonsafety-related, abandoned containment spray chemical addition tanks, located in containment along with safety-related SSCs, for which the associated piping had been cut and capped but the tanks had not been verified to be dry. This applies to Units 1 and 3.

(3) Nonsafety-related, fluid-filled SSCs located within the turbine building and adjacent to a penetration into the safety-related main steam support structure.

(4) Nonsafety-related, fluid-filled SSCs located on the auxiliary building roof and adjacent to opening in the safety-related main steam support structure.

Request:

The staff requests that the applicant perform a review of these issues and provide the basis for not including nonsafety-related SSCs, attached or adjacent to safety-related SSCs, within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Indicate if the review concludes that use of the scoping methodology precluded the identification of nonsafety-related SSCs that could interact with safety-related SSCs, and which were not specifically exempted by your CLB, and therefore should have been considered within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Describe any additional scoping evaluations to be performed to address the (a)(2) criteria. As part of your response, list any additional SSCs included within the scope as a result of your efforts and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.