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| number = ML101340788
| number = ML101340788
| issue date = 06/02/2010
| issue date = 06/02/2010
| title = Summary of Tele Conf Call Held on 4/14/10, Btw Usnrc and APS, Concerning D-RAI Pertaining to the PVNGS, Units 1,2  and 3, License Renewal Application
| title = Summary of Tele Conf Call Held on 4/14/10, Btw USNRC and APS, Concerning D-RAI Pertaining to the PVNGS, Units 1,2  and 3, License Renewal Application
| author name = Regner L M
| author name = Regner L
| author affiliation = NRC/NRR/DLR/RPB2
| author affiliation = NRC/NRR/DLR/RPB2
| addressee name =  
| addressee name =  
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:June 2, 2010 LICENSEE: Arizona Public Service Company  
{{#Wiki_filter:June 2, 2010 LICENSEE:       Arizona Public Service Company FACILITY:       Palo Verde Nuclear Generating Station, Units 1, 2, and 3
 
FACILITY: Palo Verde Nuclear Generating Station, Units 1, 2, and 3  


==SUBJECT:==
==SUBJECT:==


==SUMMARY==
==SUMMARY==
OF TELEPHONE CONFERENCE CALL HELD ON APRIL 14, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION The U.S. Nuclear Regulatory Commission (the staff) and representatives of Arizona Public Service Company (the applicant) held a telephone conference call on April 14, 2010, to discuss and clarify the staff's draft request for additional information (RAI) concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application. The telephone conference call was useful in clarifying the intent of the staff's draft RAI.
OF TELEPHONE CONFERENCE CALL HELD ON APRIL 14, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION The U.S. Nuclear Regulatory Commission (the staff) and representatives of Arizona Public Service Company (the applicant) held a telephone conference call on April 14, 2010, to discuss and clarify the staffs draft request for additional information (RAI) concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application. The telephone conference call was useful in clarifying the intent of the staffs draft RAI. provides a listing of the participants and Enclosure 2 contains a listing of the draft RAI discussed with the applicant, including a brief description on the status of the item.
Enclosure 1 provides a listing of the participants and Enclosure 2 contains a listing of the draft RAI discussed with the applicant, including a brief description on the status of the item.  
The applicant had an opportunity to comment on this summary.
 
                                                /RA/
The applicant had an opportunity to comment on this summary.  
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
      /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  


==Enclosures:==
==Enclosures:==


As stated cc w/encls: See next page  
As stated cc w/encls: See next page
 
ML101340788 OFFICE  LA:DLR  PM:RPB2:DLR BC:RPB2:DLR PM:RPB2:DLR


NAME IKing LRegner DWrona LRegner  
ML101340788 OFFICE      LA:DLR              PM:RPB2:DLR            BC:RPB2:DLR          PM:RPB2:DLR NAME         IKing               LRegner               DWrona               LRegner DATE        05/24/10            05/24/10              05/26/10            06/02/10


DATE 05/24/10 05/24/10 05/26/10 06/02/10 Memorandum to Arizona Public Service Company from L. Regner dated June 2, 2010  
Memorandum to Arizona Public Service Company from L. Regner dated June 2, 2010


==SUBJECT:==
==SUBJECT:==


==SUMMARY==
==SUMMARY==
OF TELEPHONE CONFERENCE CALL HELD ON APRIL 14, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION DISTRIBUTION
OF TELEPHONE CONFERENCE CALL HELD ON APRIL 14, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION DISTRIBUTION:
HARD COPY: DLR RF E-MAIL: PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDciCsgb Resource RidsNrrDraAfpb Resource RidsNrrDraApla Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource RidsOpaMail Resource -------------
HARD COPY:
L. Regner D. Drucker R. Hall B. Mizuno, OGC R. Treadway, RIV G. Pick, RIV  
DLR RF E-MAIL:
 
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDciCsgb Resource RidsNrrDraAfpb Resource RidsNrrDraApla Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource RidsOpaMail Resource
ENCLOSURE 1 TELEPHONE CONFERENCE CALL PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS APRIL 14, 2010 PARTICIPANTS AFFILIATIONSLisa Re gner U.S. Nuclear Re gulator y Commission (NRC) James Gavula NRC
-------------
 
L. Regner D. Drucker R. Hall B. Mizuno, OGC R. Treadway, RIV G. Pick, RIV
An gela Krainik  Arizona Public Service Com p an y (APS) Glenn Michael APS Eric Blocher Strate gic Teamin g and Resource Sharin g (STARS) Alliance     


ENCLOSURE 2 DRAFT REQUESTS FOR ADDITIONAL INFORMATION PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 (PVNGS) LICENSE RENEWAL APPLICATION APRIL 14, 2010  
TELEPHONE CONFERENCE CALL PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS APRIL 14, 2010 PARTICIPANTS              AFFILIATIONS Lisa Regner                U.S. Nuclear Regulatory Commission (NRC)
James Gavula              NRC Angela Krainik            Arizona Public Service Company (APS)
Glenn Michael              APS Eric Blocher              Strategic Teaming and Resource Sharing (STARS) Alliance ENCLOSURE 1


The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Arizona Public Service Company (the applicant) held a telephone conference call on April 14, 2010, to discuss and clarify the following draft request for additional information (RAI) concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application (LRA).
DRAFT REQUESTS FOR ADDITIONAL INFORMATION PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 (PVNGS)
DRAFT RAI B2.1.6-1 Flow-Accelerated Corrosion  
LICENSE RENEWAL APPLICATION APRIL 14, 2010 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Arizona Public Service Company (the applicant) held a telephone conference call on April 14, 2010, to discuss and clarify the following draft request for additional information (RAI) concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application (LRA).
DRAFT RAI B2.1.6-1 Flow-Accelerated Corrosion


===Background===
===Background===
In its discussion of aging effects for cavitation erosion for treated water, EPRI 1010639, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4,"
In its discussion of aging effects for cavitation erosion for treated water, EPRI 1010639, Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, Appendix A, Section 3.1.6, Erosion and Flow Accelerated Corrosion, states, in part, that cavitation erosion is considered a design deficiency, which will be detected and corrected during current operation, and therefore, is not an applicable aging effect for the period of extended operation. However, in the same appendix, Section 4.1, Assumptions, No. 9 states, in part, that the above statement is an assumption, and notes an exception when the cavitation occurs in infrequently operated systems, and states in these cases, plant specific consideration may need to be addressed in the aging management review.
Appendix A, Section 3.1.6, "Erosion and Flow Accelerated Corrosion," states, in part, that cavitation erosion is considered a design deficiency, which will be detected and corrected during current operation, and therefore, is not an applicable aging effect for the period of extended operation. However, in the same appendix, Section 4.1, "Assumptions," No. 9 states, in part, that the above statement is an assumption, and notes an exception when the cavitation occurs in infrequently operated systems, and states in these cases, plant specific consideration may need to be addressed in the aging management review.
In addition, the Generic Aging Lessons Learned (GALL) Report, Table IX.E, Aging Effects notes that loss of material may be due to several causes and erosion is specifically included. The GALL Report, Table IX.F, Significant Aging Mechanisms, defines both cavitation, and erosion; however, the GALL Report does not include any specific items that address loss of material due to cavitation erosion. Since the GALL Report also does not include an aging management program to manage this specific aging effect, a plant-specific program would be needed to manage loss of material due to cavitation erosion.
In addition, the Generic Aging Lessons Learned (GALL) Report, Table IX.E, Aging Effects notes that "loss of material" may be due to several causes and erosion is specifically included. The GALL Report, Table IX.F, Significant Aging Mechanisms, defines both cavitation, and erosion; however, the GALL Report does not include any specific items that address loss of material due to cavitation erosion. Since the GALL Report also does not include an aging management program to manage this specific aging effect, a plant-specific program would be needed to manage loss of material due to cavitation erosion.  
Issue During a review of operating experience at PVNGS, the NRC identified CRDR 2932507, which documents a through-wall leak in piping immediately downstream of a valve in the high pressure safety injection recirculation line due to erosion by damaging cavitation. Within this document, CRAI 2964170 indicated that the Flow-Accelerated Corrosion (FAC) Program was to inspect, using UT, those components potentially susceptible to cavitation erosion as identified in the apparent cause evaluation. In addition, the FAC program was to be revised to include examination of portions of all three units HPSI train B recirculation piping every 18 months in order to assess cavitation erosion. Based on PVNGS operating experience, the exception noted above in EPRI 1010639, regarding infrequently operated systems, appears to apply. As such, the EPRI document indicates that a plant-specific consideration needs to be addressed in the aging management review. As described in CRDR 2932507, a monitoring program has been implemented to manage the identified aging effect.
 
ENCLOSURE 2
Issue During a review of operating experience at PVNGS, the NRC identified CRDR 2932507, which documents a through-wall leak in piping immediately downstream of a valve in the high pressure safety injection recirculation line "due to erosion by damaging cavitation.Within this document, CRAI 2964170 indicated that the Flow-Accelerated Corrosion (FAC) Program was to inspect, using UT, those components potentially susceptible to cavitation erosion as identified in the apparent cause evaluation. In addition, the FAC program was to be revised to include examination of portions of all three unit's HPSI train "B" recirculation piping every 18 months in order to assess cavitation erosion. Based on PVNGS' operating experience, the exception noted above in EPRI 1010639, regarding infrequently operated systems, appears to apply. As such, the EPRI document indicates that a plant-specific consideration needs to be addressed in the aging management review. As described in CRDR 2932507, a monitoring program has been implemented to manage the identified aging effect.     Request  1) Provide the aging effect evaluation, as described in NEI 95-10, Industry Guidelines for License Renewal Rule, Figure 4.2-1, which considered the operating experience documented in CRDR 2932507.
: 2) Provide the aging management review performed for any components determined to be susceptible to the aging effect caused by cavitation erosion as identified in CRDR 2932507. Provide the technical evaluation that was performed, which included or excluded components for further consideration.
: 3) Provide a description of the aging management program, that will be used to manage the effects of aging associated with cause(s) identified in CRDR 2932507, and address the ten elements of the program as indicated in the SRP-LR, Appendix A.1, Aging Management Review. 
 
Discussion
:  Following discussion with the applicant, the staff determined that the cavitation erosion identified in the draft RAI was a design issue and not an aging effect requiring aging management for this system. The applicant is monitoring the condition under the existing FAC program. The question is out of the scope of license renewal and will not be issued formally.
 
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. Ron Barnes, 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 Highway, 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
Request
: 1) Provide the aging effect evaluation, as described in NEI 95-10, Industry Guidelines for License Renewal Rule, Figure 4.2-1, which considered the operating experience documented in CRDR 2932507.
: 2) Provide the aging management review performed for any components determined to be susceptible to the aging effect caused by cavitation erosion as identified in CRDR 2932507.
Provide the technical evaluation that was performed, which included or excluded components for further consideration.
: 3) Provide a description of the aging management program, that will be used to manage the effects of aging associated with cause(s) identified in CRDR 2932507, and address the ten elements of the program as indicated in the SRP-LR, Appendix A.1, Aging Management Review.
Discussion: Following discussion with the applicant, the staff determined that the cavitation erosion identified in the draft RAI was a design issue and not an aging effect requiring aging management for this system. The applicant is monitoring the condition under the existing FAC program. The question is out of the scope of license renewal and will not be issued formally.


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

Latest revision as of 18:11, 13 November 2019

Summary of Tele Conf Call Held on 4/14/10, Btw USNRC and APS, Concerning D-RAI Pertaining to the PVNGS, Units 1,2 and 3, License Renewal Application
ML101340788
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 06/02/2010
From: Lisa Regner
License Renewal Projects Branch 2
To:
Arizona Public Service Co
Ferrer, N B, NRR/DLR, 415-1045
References
Download: ML101340788 (7)


Text

June 2, 2010 LICENSEE: Arizona Public Service Company FACILITY: Palo Verde Nuclear Generating Station, Units 1, 2, and 3

SUBJECT:

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON APRIL 14, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION The U.S. Nuclear Regulatory Commission (the staff) and representatives of Arizona Public Service Company (the applicant) held a telephone conference call on April 14, 2010, to discuss and clarify the staffs draft request for additional information (RAI) concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application. The telephone conference call was useful in clarifying the intent of the staffs draft RAI. provides a listing of the participants and Enclosure 2 contains a listing of the draft RAI discussed with the applicant, including a brief description on the status of the item.

The applicant had an opportunity to comment on this summary.

/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

Enclosures:

As stated cc w/encls: See next page

ML101340788 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR PM:RPB2:DLR NAME IKing LRegner DWrona LRegner DATE 05/24/10 05/24/10 05/26/10 06/02/10

Memorandum to Arizona Public Service Company from L. Regner dated June 2, 2010

SUBJECT:

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON APRIL 14, 2010, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION DISTRIBUTION:

HARD COPY:

DLR RF E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDciCsgb Resource RidsNrrDraAfpb Resource RidsNrrDraApla Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource RidsOpaMail Resource


L. Regner D. Drucker R. Hall B. Mizuno, OGC R. Treadway, RIV G. Pick, RIV

TELEPHONE CONFERENCE CALL PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS APRIL 14, 2010 PARTICIPANTS AFFILIATIONS Lisa Regner U.S. Nuclear Regulatory Commission (NRC)

James Gavula NRC Angela Krainik Arizona Public Service Company (APS)

Glenn Michael APS Eric Blocher Strategic Teaming and Resource Sharing (STARS) Alliance ENCLOSURE 1

DRAFT REQUESTS FOR ADDITIONAL INFORMATION PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 (PVNGS)

LICENSE RENEWAL APPLICATION APRIL 14, 2010 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Arizona Public Service Company (the applicant) held a telephone conference call on April 14, 2010, to discuss and clarify the following draft request for additional information (RAI) concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application (LRA).

DRAFT RAI B2.1.6-1 Flow-Accelerated Corrosion

Background

In its discussion of aging effects for cavitation erosion for treated water, EPRI 1010639, Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools, Revision 4, Appendix A, Section 3.1.6, Erosion and Flow Accelerated Corrosion, states, in part, that cavitation erosion is considered a design deficiency, which will be detected and corrected during current operation, and therefore, is not an applicable aging effect for the period of extended operation. However, in the same appendix, Section 4.1, Assumptions, No. 9 states, in part, that the above statement is an assumption, and notes an exception when the cavitation occurs in infrequently operated systems, and states in these cases, plant specific consideration may need to be addressed in the aging management review.

In addition, the Generic Aging Lessons Learned (GALL) Report, Table IX.E, Aging Effects notes that loss of material may be due to several causes and erosion is specifically included. The GALL Report, Table IX.F, Significant Aging Mechanisms, defines both cavitation, and erosion; however, the GALL Report does not include any specific items that address loss of material due to cavitation erosion. Since the GALL Report also does not include an aging management program to manage this specific aging effect, a plant-specific program would be needed to manage loss of material due to cavitation erosion.

Issue During a review of operating experience at PVNGS, the NRC identified CRDR 2932507, which documents a through-wall leak in piping immediately downstream of a valve in the high pressure safety injection recirculation line due to erosion by damaging cavitation. Within this document, CRAI 2964170 indicated that the Flow-Accelerated Corrosion (FAC) Program was to inspect, using UT, those components potentially susceptible to cavitation erosion as identified in the apparent cause evaluation. In addition, the FAC program was to be revised to include examination of portions of all three units HPSI train B recirculation piping every 18 months in order to assess cavitation erosion. Based on PVNGS operating experience, the exception noted above in EPRI 1010639, regarding infrequently operated systems, appears to apply. As such, the EPRI document indicates that a plant-specific consideration needs to be addressed in the aging management review. As described in CRDR 2932507, a monitoring program has been implemented to manage the identified aging effect.

ENCLOSURE 2

Request

1) Provide the aging effect evaluation, as described in NEI 95-10, Industry Guidelines for License Renewal Rule, Figure 4.2-1, which considered the operating experience documented in CRDR 2932507.
2) Provide the aging management review performed for any components determined to be susceptible to the aging effect caused by cavitation erosion as identified in CRDR 2932507.

Provide the technical evaluation that was performed, which included or excluded components for further consideration.

3) Provide a description of the aging management program, that will be used to manage the effects of aging associated with cause(s) identified in CRDR 2932507, and address the ten elements of the program as indicated in the SRP-LR, Appendix A.1, Aging Management Review.

Discussion: Following discussion with the applicant, the staff determined that the cavitation erosion identified in the draft RAI was a design issue and not an aging effect requiring aging management for this system. The applicant is monitoring the condition under the existing FAC program. The question is out of the scope of license renewal and will not be issued formally.

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