ML15023A047

Response to Request for Additional Information (RAI) for Unit 3 Bottom Mounted Instrument Relief Request 52

ML15023A047
Person / Time
Site:	Palo Verde
Issue date:	01/16/2015
From:	Cadogan J Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15023A075	List: ML15023A047
References
102-06991-JJC/DCE
Download: ML15023A047 (3)

Text

The Attachment to the Enclosure contains PROPRIETARY information to be withheld 10 CFR 50.55a under 10 CFR 2.390 John J. Cadogan 0,)aps Vice President, Nuclear Engineering Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7602 Tel 623 393 5553 102-06991-JJC/DCE January 16, 2015 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

References:

1. Arizona Public Service Company (APS) letter number 102-06879, Palo Verde Nuclear Generating Station Unit 3, Docket No. STN 50-530, American Society of Mechanical Engineers (ASME) Code,Section XI, Request for Approval of an Alternative to Flaw Removal, Flaw Characterizationand Successive Examinations - Relief Request 52, dated May 16, 2014 [Agencywide Documents Access And Management System (ADAMS) Accession No. ML14142A029]

2. APS letter number 102-06880, Palo Verde Nuclear Generating Station Unit 3, Docket No. STN 50-530, Transmittal of ProprietaryDocuments for Relief Request 52, dated May 16, 2014 (ADAMS Accession No. ML14141A545)

3. Nuclear Regulatory Commission (NRC) letter Palo Verde Nuclear Generating Station, Unit 3 - Request for Relief from ASME Code,Section XI Requirements Regarding Half-Nozzle Repair and Flaw Evaluation as an Alternative to Flaw Removal and Flaw Characterizationfor Flaw in Bottom Mounted Instrument Nozzle PenetrationNo.3, dated April 10, 2014 (ADAMS Accession Number ML14093A407)

4. NRC letter Palo Verde Nuclear GeneratingStation, Unit 3 - Request for Additional Information Re: Relief Request 52, Alternative to ASME Code,Section XI Requirements for Flaw Evaluation, Flaw Characterization,and Successive Examinations, dated December 4, 2014 (ADAMS Accession No. ML14330A510)

5. APS letter number 102-06992, Palo Verde Nuclear Generating Station Unit 3, Docket No. STN 50-530, Response to Request for Additional Information (RAI) for Unit 3 Bottom Mounted Instrument Relief Request 52 (Non-Proprietary Version)

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Unit 3 Docket No. 50-530 Response to Request for Additional Information (RAI) for Unit 3 Bottom Mounted Instrument Relief Request 52 (Proprietary Version)

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

102-06991-JJC/DCE ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to Request for Additional Information (RAI) for Unit 3 Bottom Mounted Instrument Relief Request 52 (Proprietary Version)

Page 2 On May 16, 2014, pursuant to 10 CFR 50.55a(a)(3)(i), Arizona Public Service Company (APS) requested the Nuclear Regulatory Commission (NRC) approve Relief Request 52 (References 1 and 2).

Relief Request 52 was submitted to obtain NRC approval for operation of Unit 3 beyond the current operating cycle based on analyses that justify continued operation for the remainder of licensed operating life. The request was in response to the identification of leakage in Unit 3. Specifically, on October 6, 2013, APS identified evidence of leakage in the annulus of the Palo Verde Nuclear Generating Station (PVNGS) Unit 3 reactor vessel (RV) bottom mounted instrument (BMI) nozzle penetration 3.

Previously, APS submitted Relief Request 51 on November 8, 2013, which was verbally approved by the NRC staff on November 21, 2013, and formally approved on April 10, 2014 (Reference 3). NRC approval of Relief Request 51 permitted operation of Unit 3 through the end of the current operating cycle based on ASME code-compliant repairs and the one cycle analyses completed by APS prior to restart of Unit 3.

On December 4, 2014, NRC staff requested additional information (RAI) from APS to clarify information provided in the Relief Request 52 (Reference 4).

This letter transmits the complete set of responses, including proprietary information, to the RAIs. A non-proprietary version of the responses is being sent by separate correspondence (Reference 5).

The attachment to the enclosure of this letter contains proprietary information. An affidavit provided by AREVA NP, Incorporated, the owner of the information, to support the proprietary nature of the information is included in the attachment. The affidavit, signed by AREVA, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information which is proprietary to AREVA be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the proprietary documents or the supporting AREVA affidavit should be addressed to Philip Opsal, Manager, Product Licensing, AREVA NP Inc., 3315 Old Forest Road, Lynchburg, VA 24501.

Should you need further information regarding this submittal, please contact Thomas N. Weber, Nuclear Regulatory Affairs Department Leader, at (623) 393-5764.

102-06991-JJC/DCE ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Response to Request for Additional Information (RAI) for Unit 3 Bottom Mounted Instrument Relief Request 52 (Proprietary Version)

Page 3 No commitments are being made to the NRC by this letter.

Sincerely, JJC/DCE Enclosure - Response to Relief Request 52 Request for Additional Information (Proprietary Version) cc: M. L. Dapas NRC Region IV Regional Administrator B. K. Singal NRC NRR Project Manager for PVNGS M. M. Watford NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS