ML101160357

Request for Additional Information - Palo Verde License Renewal Review

ML101160357
Person / Time
Site:	Palo Verde
Issue date:	04/28/2010
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: ML101160357 (8)

Text

April 28, 2010 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 within 30 days of the issuance 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/

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

ML101160357 OFFICE PM:RPB2:DLR LA:DLR BC:RPB2:DLR PM:RPB2:DLR NAME LRegner SFigueroa DWrona LRegner DATE 04/27/2010 04/27/2010 04/27/2010 04/28/2010

Letter to R. Edington from L. Regner dated April 28, 2010

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)

DISTRIBUTION:

HARD COPY:

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

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

PALO VERDE NUCLEAR GENERATING STATION (PVNGS)

LICENSE RENEWAL APPLICATION (LRA)

REQUEST FOR ADDITIONAL INFORMATION (RAI)

RAI 3.3.2.2.3-1

Background

The staff reviewed Section 3.3.2.2.3.2 of the LRA against the criteria in the Standard Review Plan-License Renewal (SRP-LR), Section 3.3.2.2.3.2, which states that stress corrosion cracking (SCC) could occur in stainless steel and stainless clad steel heat exchanger components exposed to treated water greater than 60 °C (140 °F). The SRP-LR recommends further evaluation of a plant-specific aging management program to ensure this aging effect is adequately managed and notes that acceptance criteria are described in Appendix A.1 of the SRP-LR.

Issue The staff noted that, contrary to the applicants statement, the related item applies to both boiling water reactors and pressurized water reactors. Furthermore, in reviewing LRA Table 3.3.2-30, the staff noted that the sample cooler heat exchanger is listed with an aging mechanism of cracking for stainless steel exposed to secondary water. According to LRA Table 3.0-1, Mechanical Environments, secondary water is described as treated water; however, the item description in Table 3.3.2-30 did not indicate the temperature. As such, it was unclear to the staff that this item is not applicable to PVNGS, as stated by the applicant.

Request Provide justification as to why SRP-LR Section 3.3.2.2.3.2 is not applicable or, if it is applicable, explain how aging will be managed.

RAI 4.5-3

Background

In Section 4.5 of the LRA, the applicant provided Table 4.5-1, Tendon Regression Analysis Input Data. The table contains lift-off forces of individual tendons used in the regression analysis. The review of the table identified the following anomalies:

a) Only the shop end force is provided for tendons H21-04 (3rd year surveillance), V07, and V015.

b) The lift-off force for tendon H21-04 was measured in the 3rd year surveillance and again in the 5th year.

c) The Unit 3 dome horizontal tendon lift-off average forces are greater than the wall horizontal lift-off average forces. In some cases they are greater by nearly 100 kilo-pounds-force (i.e., H13-45, H32-42, and H21-43).

ENCLOSURE

Issue The anomalies in items (a) and (c) could influence the slope of regression analysis conducted to demonstrate that the predicted prestress forces remain above their respective minimum required values (MRVs) through the period of extended operation. In particular, the staff is concerned with the influence of the higher Unit 3 dome horizontal tendon forces on the combined wall and dome trend line (Figure 4.5-3), which shows the least margin. Item (b) may not satisfy IWL-2521, which requires that tendons examined during an inspection be selected on a random basis from a sample of tendons that have not been examined in earlier examinations.

Request The applicant is requested to explain the anomalies and confirm that they have no impact on its conclusion that regression analysis trend lines indicate that tendon prestress will remain above the MRV through the period of extended operation.

RAI B2.1.28-3

Background

In response to RAI B2.1.28-2, dated February 19, 2010, the applicant stated that the frequency of inspection for the ASME Section XI, Subsection IWL Aging Management Program (AMP) is consistent with ASME Section XI Subsection IWL, paragraph IWL-2421, Sites with Multiple Plants. This paragraph allows inspection intervals of every ten years, staggered, so that at least one unit is inspected every five years. Therefore, the applicant concluded that the existing program is consistent with ASME Section XI Subsection IWL and the Generic Aging Lessons Learned (GALL) Report, and no exception is required.

Issue ASME Section III, Subsection IWL, Subarticle IWL-2421 allows the inspection frequency to increase to ten years for examinations required by IWL-2524 and IWL-2525. However, IWL-2524 and IWL-2525 requirements are for examination of tendon anchorage areas, and corrosion protection medium and free water in the post-tensioning system, respectively.

IWL-2410(a) Inservice Inspection Schedule of Concrete provides the inspection periodicity of concrete surface exams and states, Concrete shall be examined in accordance with IWL-2510 at 1, 3, and 5 years following the completion of the containment Structural Integrity Test CC-6000 and every 5 years thereafter. IWL-2510 Surface Examination Requirements provides the requirements for concrete surface examinations.

Request Provide the basis for containment concrete surface visual examination inspection frequency of ten years.

RAI 3.5.2.3-4

Background

For the component type, supports ASME 2 and 3, LRA Table 3.5.2-14 credits the ASME Section XI, Subsection IWF Program (B2.1.29) to manage loss of material for carbon and stainless steel components in 1) a raw water environment, and 2) a fuel oil environment.

The LRA states that these environments are not in NUREG-1801 for carbon and stainless steel components.

Issue The components in the environments identified above may have limited accessibility. It is not clear to the staff how the ASME Section XI Subsection IWF Program will inspect the components to ensure the aging effect is being managed.

Request Explain how the ASME Section XI Subsection IWF Program will manage the effect of aging on carbon and stainless steel components in 1) a raw water environment, and 2) a fuel oil environment that have limited accessibility.

RAI 3.3.2-2

Background

In the LRA, Tables 3.3.2.2 Spent Fuel Pool Cooling and Cleanup System, 3.3.2.7 Essential Spray Pond System, and 3.3.2.20 Diesel Fuel Oil Storage and Transfer System, there are aging management review (AMR) result lines for stainless steel or carbon steel closure bolting in environments of treated borated water, raw water, and fuel oil, respectively. The AMR results credit the Bolting Integrity Aging Management Program (AMP) with managing the aging effect-loss of preload for bolts in these wet environments.

Issue The LRA does not provide sufficient information for the staff to understand how the Bolting Integrity AMP can effectively manage loss of preload for bolts in wet environments where simple visual techniques during normal system walk downs could detect signs of closure bolting loosening, such as indications of leakage around a flange or gasket which would otherwise be noticed in a dry environment.

Request a) Explain what features or activities of the Bolting Integrity AMP will manage the aging effect of loss of preload for closure bolting that is in a wet environment and why the credited features or activities are adequate to ensure that loss of the subject bolts intended function(s) does not occur during the period of extended operation.

b) Clarify whether there are any indirect indicators that might be indicative of loss of bolting preload for closure bolting in each of these wet environments and their associated systems.