ML100360296

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)

ML100360296
Person / Time
Site:	Palo Verde
Issue date:	03/02/2010
From:	Regner L M License Renewal Projects Branch 2
To:	Edington R K Arizona Public Service Co
Regner L M, NRR/DLR, 415-1906
References
TAC ME0254, TAC ME0255, TAC ME0256
Download: ML100360296 (9)

Text

March 2, 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 enclosures areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

A telephone conference call was held on February 24, 2010, with APS staff, to clarify the intent of the questions in Enclosure 1. A mutually agreeable date for your response, as discussed with your staff, was determined to be 30 calendar days from the date 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

Enclosures:

As stated cc w/encls: See next page

ML100360296 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR PM:RPB2:DLR

NAME SFigueroa LRegner DWrona LRegner DATE 02/22/10 03/01/10 03/01/10 03/02/10 Letter to Randall K. Edington from Lisa M. Regner dated March 2, 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

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

ENCLOSURE 1 PALO VERDE NUCLEAR GENERATING STATION (PVNGS) LICENSE RENEWAL APPLICATION (LRA) REQUEST FOR ADDITIONAL INFORMATION RAI 4.5-1

Background

Section 4.5 stated that the 25-year containment prestressed tendons surveillance of Unit 1 was not completed in time to be included in the LRA; therefore, a tendon regression analysis "was performed on Unit 1 and 3 horizontal and vertical tendon data including the 15-year surveillances for Units 1 and 3, and on the 20-year surveillance data for Unit 2."

Issue: Section 4.5 of the LRA, pages 4.5-5 through 4.5-16, does not include the results of the 25-year containment prestressed tendons surveillance of Unit 1 that was completed in 2008. Section 4.5 should incorporate the data and results from the 25-year tendon surveillance of the Unit 1 containment, so that the staff can confirm that the loss of prestress is expected to remain within acceptable values for the period of extended operation, in accordance with 10 CFR 54.21(c)(1)(ii).

Request: Provide the data and results from the 25-year tendon surveillance of the Unit 1 containment.

RAI 4.5-2

Background:

Section 4.5 of the LRA stated that Nuclear Regulatory Commission (NRC) staff approved a revised schedule for the containment prestressed tendons surveillance in Relief Request RR-L4. The Relief Request RR-L4 permits a 10-year interval between tendon prestress surveillance for the three units.

Issue: RR-L4 is valid for the 40 years of operation during the current licensing basis. The LRA did not address the period of extended operation.

Request: Provide information on how the aging of the containment tendons will be managed during the period of extended operation. RAI 4.6-1 Background

Section 4.6.1 of the LRA states that the Updated Final Safety Analysis Report (UFSAR) contains no description of cyclic loads or design cycles for the entire containment building.

Section 3.8.1.5.4.B of the UFSAR described design cycles that are to be included in the design of the liner plate and penetrations. The applicant further states in the LRA that review of the design specifications, design report, and design calculations found time dependent aspects of some penetration designs, but none for liner plate design. The applicant concludes in the LRA that the liner plate design is not supported by a time limited aging analysis (TLAA). As a result, the applicant did not evaluate fatigue of the liner plate for cyclic loading during the period of extended operation.

Issue The UFSAR, Section 3.8.1.5.4, "Liner Plate System," item B, "Loads," states that the following loads are considered in liner design:

1. Thermal cycling due to annual outdoor temperature variations where: a. Daily temperature variations do not penetrate a significant distance into the concrete shell to appreciably change the average temperature of the shell relative to the liner plate b. The number of cycles for this loading is 40 cycles for plant life of 40 years

2. Thermal cycling due to variation in the interior temperature of the containment during the heatup and cooldown of the reactor system in which the number of cycles is assumed to be 500 cycles for plant life of 40 years

3. Thermal cycling due to the loss of coolant accident is assumed to be one cycle.

Request Evaluate the liner plate system for cyclic loading during period of extended operation consistent with UFSAR, section 3.8.1.5.4.B, requirements or provide additional technical basis to demonstrate this evaluation is not required.

RAI 4.7.8-1

Background

Section 4.7.8 of the LRA provided details of a TLAA performed for building absolute or differential heave or settlement , including possible effects of changes in a perched groundwater lens. The purpose of this TLAA is to demonstrate that the assumptions for the building settlements used in the original design will remain valid for the period of extended operation. Issue: The first paragraph under "Current Settlement Monitoring Activities" on page 4.7-14, states that the Structures Monitoring Program monitors foundation responses and ground movement of the "major structures" on five-year intervals. A review of the applicant's Structures Monitoring Program, B2.1.32, showed that similar wording is included in the program description on page B-92. The applicant did not specify which structures would be monitored during the period of extended operation and how the inspection frequency will be adjusted as described in the UFSAR, Section 2.5.4.13, in the event post-construction settlement reaches 90 percent of the design criteria values.

Request: Provide the following information:

a) List the structures included in the scope of 10 CFR 54.4 that will be monitored for the effects of settlement during the period of extended operation. In addition, provide a technical basis for excluding any structure that performs an intended function pursuant to 10 CFR 54.4 (a)(1),

(a)(2), or (a)(3).

b) List the structures included in the scope of 10 CFR 54.4, that will be monitored on a different frequency or using different instrumentation than specified in the UFSAR, Section 2.5.4.13 and Table 2.5-19.

RAI 4.7.8-2

Background

The results of settlement monitoring program performed for PVNGS are summarized in Table 4.7-2 of the LRA.

Issue:

The post-construction differential settlement measured in 2003 between the Unit 2 auxiliary and the radwaste buildings exceeds the maximum allowable value of 0.5 inches by nearly 75 percent. In addition, post construction differential settlement in Units 1 and 3 between the auxiliary and the radwaste buildings is about 90 percent of the maximum estimated value.

Request: a) Provide post-construction settlement and post-construction differential settlement data for the 1998 and 2008 inspections for the same locations for which the values are tabulated in Table 4.7-2. Include data for the marker between the radwaste and control buildings where the differential settlement was measured in 2003 as 0.4332 inches.

b) Provide post-2003 settlement data for marker SM-31, including the data recorded with increased frequency.

c) Provide the corrective actions taken to address the impact of exceeding the maximum allowable post-construction differential settlement on Unit 2 structures and critical piping.

ENCLOSURE 2 PALO VERDE NUCLEAR GENERATING STATION (PVNGS) LICENSE RENEWAL APPLICATION (LRA) REQUEST FOR ADDITIONAL INFORMATION RAI B2.1.33-1

Background

Element 4 of the Generic Aging Lessons Learned (GALL) Report, AMP XI.S7, discusses performing inspections immediately following the occurrence of significant natural phenomena such as large floods, earthquakes, hurricanes, tornadoes, intense local rainfalls, etc.

Issue: "Aging Management Program Evaluation Report - Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants," states that PVNGS has no earthen dams or other water control structures in-scope for license renewal that would require inspections after the occurrence of significant natural phenomena.

Request: Explain why it is unnecessary for the spray pond structures to be inspected after unusual natural events.

RAI B2.1.33-2

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Background===

PVNGS includes two safety-related spray ponds for each unit.

Issue: During the operating experience review, the applicant provided several condition reports which discussed degradation of the spray pond concrete walls. During walkdowns, the staff observed cracking and spalling near the top of the spray pond walls.

Request:

a) Explain how AMP B2.1.33 addresses degradation of the spray pond walls and how structural stability of the spray ponds will be maintained during the period of extended operation.

b) Discuss any plans to repair the current degradation prior to, or during, the period of extended operation.

ENCLOSURE 3 PALO VERDE NUCLEAR GENERATING STATION (PVNGS) LICENSE RENEWAL APPLICATION (LRA) REQUEST FOR ADDITIONAL INFORMATION RAI 3.1.1-1

Background

Table 3.1.1 of the LRA, item 3.1.1-80, states that this line item is not applicable because PVNGS does not have cast austenitic stainless steel (CASS) reactor vessel internals. The UFSAR, Section 4.5.2.1, "Reactor Internals Materials," Subsection B on page 4.5-9, states that the upper guide structure assembly contains "ASTM A-351, Grade CF8" which is a CASS material.

Issue: There is a discrepancy between the information from the LRA Table 3.1.1 and the applicant's UFSAR. It is not clear whether the reactor vessel internals contain CASS components.

Request: Please resolve the discrepancy between the UFSAR, Section 4.5.2.1, which states the upper guide structure assembly contains CASS components, and Table 3.1.1, which states the reactor vessel internals do not contain CASS components. If the reactor vessel internals contain CASS components, provide the necessary revisions to the LRA.