ML092750130

Summary of Telephone Conference Call Held on September 16, 2009 Between the U.S. NRC and Arizona Public Service Company, Pertaining to the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, License Renewal Application

ML092750130
Person / Time
Site:	Palo Verde
Issue date:	11/03/2009
From:	Lisa Regner License Renewal Projects Branch 2
To:
Regner L M, NRR/DLR, 415-1906
References
Download: ML092750130 (8)

Text

November 3, 2009 LICENSEE: Arizona Public Service Company FACILITY: Palo Verde Nuclear Generating Station, Units 1, 2, and 3

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON SEPTEMBER 16, 2009, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, PERTAINING TO THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Arizona Public Service Company held a telephone conference call on September 16, 2009, to discuss a draft request for additional information (RAI) pertaining to the time-limited aging analyses for reactor coolant pump flywheel integrity and on the vessel surveillance aging management program associated with the safety review of the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application.

Enclosure 1 provides a listing of the participants and Enclosure 2 contains the draft RAI discussed with the applicant, including a brief description of the status.

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

ML092750130 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR PM:RPB2:DLR

NAME SFigueroa LRegner DWrona LRegner (Signature)

DATE 10/02/09 10/15/09 11/03/09 11/03/09 Memorandum to Arizona Public Service Company from Lisa M. Regner dated November 3, 2009

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON SEPTEMBER 16, 2009, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, PERTAINING TO THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION DISTRIBUTION

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L. Regner B. Mizuno R. Treadway, RIV G. Pick, RIV ENCLOSURE 1 TELEPHONE CONFERENCE CALL PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS SEPTEMBER 16, 2009 PARTICIPANTS AFFILIATIONS Lisa Regner U.S. Nuclear Regulatory Commission (NRC)

Simon Sheng NRC Nathaniel Ferrer NRC Angela Krainik Arizona Public Service Company (APS)

Glenn Michael APS Eugene Montgomery APS Chalmer Myer Strategic Teaming and Resource Sharing Alliance (STARS)

Eric Blocher STARS Neal Schneider STARS Donald Stevens STARS

ENCLOSURE 2 PALO VERDE NUCLEAR GENERATING STATION LICENSE RENEWAL APPLICATION DRAFT REQUEST FOR ADDITIONAL INFORMATION SEPTEMBER 16, 2009 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Arizona Public Service Company held a telephone conference call on September 16, 2009, to discuss and clarify the following draft request for additional information (RAI) concerning the Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3, license renewal application (LRA).

Part I. LRA Time-Limited Aging Analyses (TLAAs) 4.2, "Reactor Vessel Neutron Embrittlement Analysis," and 4.7.7, "Absence of a TLAA for a Reactor Coolant Pump Flywheel Fatigue Crack Growth Analysis."

RAI 4.2.1-1 LRA Tables 4.2-3 to 4.2-5 documented the 54 effective full power year (EFPY) upper-shelf energy (USE) values for Units 1, 2, and 3. LRA Tables 4.2-6 to 4.2-8 documented their corresponding 54 EFPY RT PTS values. The staff found mistakes in these tables and requests corrections:

1. In Table 4.2-3 for Unit 1, the 54 EFPY USE value for the intermediate shell plate M-6701-2 should be revised from 78.6 ft-lb to 75.4 ft-lb and the 54 EFPY USE value for the intermediate shell plate M-6701-3 should be revised from 75.4 ft-lb to 78.6 ft-lb.

2. In Table 4.2-4 for Unit 2, all unirradiated USE values are those associated with PVNGS, Unit 1. Please make corrections.

3. In Table 4.2-6 for Unit 1, the nickel content for the lower shell axial welds should be revised from 0.035 percent to 0.079 percent.

Discussion

The applicant indicated that the question is clear. This draft RAI will be sent as a formal RAI.

RAI 4.2.1-2 LRA Section 4.2.1, "Neutron Fluence, Upper Shelf Energy and Adjusted Reference Temperature (Fluence, USE, and ART)," Tables 4.2-3 to 4.2-5 listed 54 EPPY USE values for the beltline materials of PVNGS, Units 1, 2, and 3. They are all derived in accordance with Regulatory Guide (RG) 1.99, Revision (Rev.) 2, "Radiation Embrittlement of Reactor Vessel Materials," without using surveillance data. The applicant also stated, "[t]he most recent coupon examination results also show that the decline in USE and increase in RT NDT [reference temperature] in plate and weld materials are less than originally predicted by RG 1.99, Revision 2." One can conservatively estimate the ART and USE values for the beltline materials without using credible multiple surveillance data only when the estimates based on all measured surveillance data in accordance with RG 1.99, Rev. 2 are lower. Please provide your basis for not considering all surveillance data. Add references (i.e., surveillance reports) to support your clarification.

Discussion

The applicant indicated that the question is clear. This draft RAI will be sent as a formal RAI.

RAI 4.2.1-3 The staff found that the WCAP-15589 report (ML003764418), "Analysis of Capsule 38

° from the Arizona Public Service Company Palo Verde Unit 1 Reactor Vessel Radiation Surveillance Program," labeled two surveillance data from Capsule 38

° as intermediate shell plate M-6701-2 and used them in the chemistry factor calculation for this limiting plate. However, the WCAP-16374 report (ML051020500), "Analysis of Capsule 230

° from the Arizona Public Service Company Palo Verde Unit 1 Reactor Vessel Radiation Surveillance Program," dropped the two Capsule 38

° surveillance data from the chemistry factor calculation for intermediate shell plate M-6701-2. A statement on page D-3 of the WCAP-16374 report indicates a possible misidentification of specimens: "[t]he lower shell plate M4311-1 also has surveillance data but only one set up to this point (from Capsule 38

°), thus it will not be evaluated." Please confirm that you misidentified surveillance specimens for PVNGS, Unit 1 in the WCAP-15589 report and explain how it happened. Or, explain the basis of discarding surveillance data from Capsule 38

° in the WCAP-16374 report in calculating the chemistry factor for intermediate shell plate M-6701-2. Please confirm that Units 2 and 3, did not experience similar misidentifications as Unit 1. Discussion

The applicant indicated that the question is clear. This draft RAI will be sent as a formal RAI.

RAI 4.7.7-1

In LRA Section 4.7.7 the applicant stated, "[t]he current PVNGS licensing basis commits to the 10-year-interval inspections of Safety Guide 14 (Rev. 0) Position c.4.b." Your conclusion of not considering this issue as a TLAA suggests that you plan to continue to use the 10-year-interval inspections of RG 1.14, Rev. 0, "Reactor Coolant Pump Flywheel Integrity," Position c.4.b during the period of extended operation. Please use and reference RG 1.14, Rev. 1, as the licensing basis for reactor coolant pump flywheels during the period of extended operation because it supersedes RG 1.14, Rev. 0.

Discussion

Based on the discussion with the applicant, the staff agreed to revise this question as follows. The revised question will be sent as a formal RAI.

The title of LRA Section 4.7.7 is "Absence of a TLAA for a Reactor Coolant Pump Flywheel Fatigue Crack Growth Analysis." To demonstrate that this is true, please confirm that the underlying stress and fracture mechanics analysis for the flywheels is not a part of the current licensing basis for PVNGS, Units 1, 2, and 3, or the underlying stress and fracture mechanics analysis does not contain fatigue and fatigue crack evaluations.

RAI 4.7.7-2

The Updated Final Safety Analysis Report (UFSAR) Section 5.4.1.1, "Pump Flywheel Integrity," specified a minimum dynamic stress intensity factor for the flywheel material. Since it is very unlikely in any engineering practice to have a requirement on the minimum material resistance without addressing the driving force, a fracture mechanics analysis for the flywheels might exist.

Please explain the basis for the minimum dynamic stress intensity factor for the flywheel material in the UFSAR and how it is used to ensure structural integrity of the flywheels.

Discussion

Based on discussion with the applicant, the staff determined that this RAI will be addressed in the modified RAI 4.7.7-1. Draft RAI 4.7.7-2 will be deleted from the formal RAI.

RAI 4.7.7-3 Discuss the evaluation of past examination results from in-place ultrasonic volumetric examination of the areas of higher stress concentration at the bore and keyway approximately every three years and from a surface examination of all exposed surfaces and complete ultrasonic volumetric examination approximately every 10 years. If a fracture mechanics analysis was performed on any indications from the examinations, provide your TLAA evaluation or explain why it is not a TLAA. Discussion

Based on the discussion with the applicant, the staff agreed to revise this question as follows. The revised question will be sent as formal RAI 4.7.7-2.

Discuss the evaluation of past examination results. Discussion should include results from the surface examination of all exposed surfaces and complete ultrasonic volumetric examination approximately every 10 years. Please confirm that no flaw evaluation was performed on indications from the examinations.

Part II. Aging Management Program B2.1.15, "Reactor Vessel Surveillance" RAI B2.1.15-1

LRA Section B2.1.15 states under Program

Description:

PVNGS, Units 1, 2, and 3, determined neutron embrittlement effects, consistent with RG 1.99, Rev. 2, by option 1[b], "Neutron Embrittlement Using Surveillance Data." This is misleading. The staff found from its review of LRA Section 4.2 that, after having considered option 1b of Generic Aging Lessons Learned Report (GALL) Aging Management Program (AMP) XI.M31, you actually used the more conservative option 1a, "Neutron Embrittlement Using Chemistry Tables" to evaluate USE and pressure-temperature limits for 60 years. Both options are consistent with RG 1.99, Rev. 2. Please make the necessary clarification.

Discussion:

The applicant indicated that the question is clear. This draft RAI will be sent as a formal RAI.

RAI B2.1.15-2

LRA Section B2.1.15 states under Enhancements: "[t]he schedule will be revised to withdraw the next capsule at the equivalent clad-base metal exposure of approximately 54 EFPY expected for the 60-year period of extended operation, and to withdraw remaining standby capsules at equivalent clad-base metal exposures not exceeding the 72 EFPY expected for a possible 80-year second period of extended operation." Criterion 5 of GALL AMP XI.M31, "Reactor Vessel Surveillance," which applies to the PVNGS units, states, "at least one capsule is to remain in the reactor vessel and is tested during the period of extended operation. The applicant may either delay withdrawal of the last capsule or withdraw a standby capsule during the period of extended operation to monitor the effects of long-term exposure to neutron irradiation." Except for the applicant's provision of a quantitative meaning (72 EFPY) for "long-term exposure to neutron irradiation," the staff found that the applicant's enhancements do not exceed the quoted Criterion 5 requirements. Therefore, please remove your claim of having enhancements.

Discussion

The staff determined that the RAI was related only to the classification of the AMP, and not its adequacy. Therefore, this question is withdrawn and will not be sent as a formal RAI. RAI B2.1.15-3

LRA Section B2.1.15 stated under Operating Experience what the recent examination results of the reactor vessel surveillance data revealed regarding neutron fluence, USE, and RT NDT. Evaluation of operating experience of this PVNGS AMP should not be limited to "the recent examination results." Please expand your discussion to include all tested reactor vessel surveillance data.

Discussion: The applicant indicated that the question is clear. This draft RAI will be sent as a formal RAI B.2.1.15-2.

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. Scott Bauer, 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

Palo Verde Nuclear Generating Station, Units 1, 2, and 3 cc: Mr. Randall K. Edington Executive Vice President Nuclear/CNO Arizona Public Service Company P.O. Box 52034, Mail Station 7602 Phoenix, AZ 85072-2034