ML25220A285

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NRC Staff Talking Points Used in the Pre-Submittal Meeting with Palo Verde Relief Requests 74 and 75 August 7, 2025
ML25220A285
Person / Time
Site: Palo Verde  
Issue date: 08/08/2025
From: William Orders
Office of Nuclear Reactor Regulation
To: Dilorenzo M
Arizona Public Service Co
Orders, William
References
RR 74, RR 75
Download: ML25220A285 (1)


Text

From:

William Orders To:

Dilorenzo, Michael D Cc:

Tony Nakanishi; Angie Buford Bcc:

William Orders

Subject:

NRC Staff Talking Points used in the Pre-Submittal Meeting with Palo Verde Relief Requests 74 and 75 August 7, 2025.

Date:

Friday, August 8, 2025 4:40:00 PM Mr. DiLorenzo, please find attached the NRC Staff Talking Points used in the Pre-Submittal Meeting with Palo Verde Relief Requests 74 and 75 August 7, 2025.

V/r, William Orders Senior Project Manager Division of Operating Reactors Office of Nuclear Reactor Regulation Nuclear Regulatory Commission

NRC Staff Talking Points For the Pre-Submittal Meeting with Palo Verde Relief Requests 74 and 75 August 7, 2025

Below are staff talking points for the pre-submittal meeting with Arizona Public Service Company personnel to discuss the upcoming Relief Requests 74 and 75 for Palo Verde Units 1, 2 and 3.

Staff Comments on Pre-Submittal Meeting on Relief Request (RR)-74

1. Licensees presentation slide #12 states that For the 5th and 6th Intervals, the plant specific proposal is to perform inspections on one Pressurizer and one Steam Generator, with a PM percentage of 33%...

The staff initially interpreted this statement as inspecting one pressurizer and one SG in either the 5th or 6th interval. This raised concerns about the adequacy of performance monitoring of pressurizers if only one pressurizer is inspected during either 5th interval or the 6th interval. The licensee clarified that one pressurizer will be inspected in the 5th interval and one pressurizer in the 6th interval. The licensee further clarified that one SG will be inspected in the 5th interval and one SG in the 6th interval. With this clarification, the staff had no additional comments on the inspections of the pressurizers and SGs.

The staff suggested that RR-74 provide clarity on this point.

2. The staff suggested that RR-74 discuss previous inspection results (e.g., weld

examination coverage) of steam generator welds and nozzles and pressurizer welds, including (a) any indications detected and associated disposition, if any, and (b) any indications that remain in service, if any.

3. The staff suggested that RR-74 provide information on future inspections. If indications are detected in a steam generator or a pressurizer as part of the performance monitoring examination in a unit, RR-74 may address (a) whether the SG and pressurizer at other Palo Verde units will be examined as part of the extent of condition/scope expansion, and (b) the timeline when the scope expansion examination will be conducted.

Comments on Pre-submittal meeting for Relief Request (RR)-75

1. Licensees presentation slide #7 for RR-75 states that the methodology used for the analysis is based on Topical Report WCAP-16186-NP-A, Revision 3, Risk-Informed Extension of the Reactor Vessel In-Service Inspection Interval (ML11306A084).

The staff suggested that RR-75 address the three conditions noted in the staffs SE approving WCAP-16168, Revision 3.

In addition, the staff noted that Condition #3 states that Licensees seeking to extend additional intervals after the first extended interval shall provide the information and analyses requested in Section (e) of 10 CFR 50.61a The staff noted that the licensee had requested an extended interval for the reactor vessel weld examination in 2010. Relief Request 75 would be the additional interval extension. As such, Condition # 3 applies to Relief Request 75. The staff suggested that RR-75 address Condition #3.

2. The staff suggested that RR-75 provide previous inspection results.