June 25, FACILITY: Palo Verde Nuclear Generating Station, Units 1, 2, and 3

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1 June 25, 2010 LICENSEE: Arizona Public Service Company FACILITY: Palo Verde Nuclear Generating Station, Units 1, 2, and 3 SUBJECT: SUMMARY OF TELEPHONE CONFERENCE CALLS HELD BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH AGING MANAGEMENT OF BURIED PIPING 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 telephone conference calls on May 20 and June 9, 2010, to discuss and clarify the staff s draft requests for additional information (RAIs) concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application. The telephone conference calls were useful in clarifying the intent of the staff s draft RAI. Enclosure 1 provides a listing of the participants and Enclosure 2 contains a listing of the draft RAIs discussed with the applicant, including a brief description on the status of the items. 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 , , and Enclosures: As stated cc w/encls: See next page

2 June 25, 2010 LICENSEE: Arizona Public Service Company FACILITY: Palo Verde Nuclear Generating Station, Units 1, 2, and 3 SUBJECT: SUMMARY OF TELEPHONE CONFERENCE CALLS HELD BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH AGING MANAGEMENT OF BURIED PIPING 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 telephone conference calls on May 20 and June 9, 2010, to discuss and clarify the staff s draft requests for additional information (RAIs) concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application. The telephone conference calls were useful in clarifying the intent of the staff s draft RAI. Enclosure 1 provides a listing of the participants and Enclosure 2 contains a listing of the draft RAIs discussed with the applicant, including a brief description on the status of the items. 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 , , and Enclosures: As stated cc w/encls: See next page DISTRIBUTION: See next page ADAMS Accession No.: ML OFFICE LA:RPOB:DLR PM:RPB2:DLR BC:RPB2:DLR PM:RPB2:DLR NAME IKing LRegner DWrona LRegner (Signature) DATE 6/14/2010 6/15/2010 6/16/2010 6/25/2010 OFFICIAL RECORD COPY

3 Memorandum to Arizona Public Service Company from Lisa M. Regner dated June 25, 2010 SUBJECT: SUMMARY OF TELEPHONE CONFERENCE CALLS HELD BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ARIZONA PUBLIC SERVICE COMPANY, CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION ASSOCIATED WITH AGING MANAGEMENT OF BURIED PIPING PERTAINING TO THE PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3, LICENSE RENEWAL APPLICATION DISTRIBUTION: HARD COPY: DLR RF PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRer1 Resource RidsNrrDlrRer2 Resource RidsNrrDlrRerb 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 L. Regner B. Mizuno R. Treadway, RIV G. Pick, RIV

4 TELEPHONE CONFERENCE CALL PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS May 20, 2010 June 9, 2010 PARTICIPANTS Lisa Regner* Bill Holston* Dave Alley Angela Krainik* Glenn Michael* Shabbir Pittalwala Daniel Wittas Jennifer Dent Chris Bird Eric Blocher* AFFILIATIONS U.S. Nuclear Regulatory Commission (NRC) NRC NRC Arizona Public Service Company () Strategic Teaming and Resource Sharing (STARS) Alliance * Participants on the June call ENCLOSURE 1

5 DRAFT REQUESTS FOR ADDITIONAL INFORMATION PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 LICENSE RENEWAL APPLICATION May 20, 2010 June 9, 2010 DRAFT RAI B The U.S. Nuclear Regulatory Commission (the staff) and representatives of Arizona Public Service Company (the applicant) held a telephone conference call on May 20, 2010, to discuss and clarify the following draft follow-up request for additional information (RAI) concerning the Palo Verde Nuclear Generating Station, Units 1, 2, and 3, license renewal application (LRA). 1. Provide a list and brief summary of any leaks or adverse conditions discovered during inspections (e.g., coating damage that directly exposes the piping or tank to the environment, presence of any coarse material in backfill within 6 inches of the pipe or tank, unexpected corrosion or damage to piping walls or component pressure boundaries) which have occurred in buried or underground piping or tanks at the station in the past five years that were entered in your corrective action program but are not included in your LRA. 2. Provide a list and commit to any inspections that will be conducted where the buried pipe is excavated and visually inspected all around the circumference of the pipe between now and the PEO. 3. What percentage of your total underground linear feet of in scope piping will have been exposed and visually inspected during the inspections in 1 and 2 above? 4. Although not discussed in the RAI, to what extent has in scope buried piping been protected by the existing cathodic protection system over the past five years? Discussion: Following discussion with the applicant, the NRC will modify draft request 2 and 3 to read as follows: 2. Discuss the number of planned inspections that will be conducted in the ten year period prior to extended operation where the in-scope buried pipe is excavated and visually inspected around the circumference of the pipe. 3. For in-scope buried piping that is not protected by a cathodic protection system, what percentage of this piping will have been or will be exposed and visually inspected during the inspections in 1 and 2 above? The applicant stated that the questions are clear and agreed to supplement its response to RAI B dated February 19, ENCLOSURE 2

6 - 2 - DRAFT RAI B Background: The GALL Report Buried Piping and Tanks Inspection AMP recommends that buried pipe be coated during installation with a protective coating system to protect the piping from contacting the aggressive soil environment in the preventive actions program element. In the detection of aging effects program element, the GALL Report further states that inspections are performed to confirm that coatings are intact and an effective method to ensure corrosion of external surfaces has not occurred. In LRA Section B , the applicant has taken an exception to the preventive actions program element to allow portions of buried stainless steel piping not be coated or wrapped. The applicant stated that inspections of buried piping that is not wrapped will inspect for loss of material due to general pitting, crevice and MIC. During the audit the applicant stated that there was approximately fifty feet of buried stainless steel piping in scope. The LRA states that the stainless steel buried piping is present in the chemical volume control and fire protection systems, AMR line item Issue: During the audit, the applicant stated that soil quality had been examined during the review of the fire protection system and the results of soil chemistry analysis indicate that the soil is corrosive with chloride concentration greater than 250 ppm and resistivity less than 2500 ohmcm. Given these soil conditions, the uncoated buried stainless steel piping is susceptible to pitting corrosion. In addition, depending on the water table level where the pipe is buried, it may also be susceptible to MIC. Request: Provide a justification for why the proposed Buried Piping and Tanks Inspection Program will be adequate to manage the aging of uncoated buried stainless steel piping given the aggressive soil conditions discussed above. Discussion: The applicant stated that the question is clear and agreed to supplement its response to RAI B dated February 19,

7 Palo Verde Nuclear Generating Station, Units 1, 2, and 3 cc: Mr. Steve Olea Arizona Corporation Commission 1200 W. Washington Street Phoenix, AZ Mr. Douglas Kent Porter, Senior Counsel Southern California Edison Company Law Department, Generation Resources P.O. Box 800 Rosemead, CA Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 40 Buckeye, AZ Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX Chairman Maricopa County Board of Supervisors 301 W. Jefferson, 10th Floor Phoenix, AZ Mr. Aubrey V. Godwin, Director Arizona Radiation Regulatory Agency 4814 S. 40th Street Phoenix, AZ Mr. Ron Barnes, Director Regulatory Affairs Palo Verde Nuclear Generating Station Mail Station 7636 P.O. Box Phoenix, AZ Mr. Dwight C. Mims, Vice President Regulatory Affairs and Plant Improvement Palo Verde Nuclear Generating Station Mail Station 7605 P.O. Box Phoenix, AZ Mr. John C. Taylor, Director, Nuclear Generation El Paso Electric Company 340 E. Palm Lane, Suite 310 Phoenix, AZ Mr. James Ray Public Service Company of New Mexico 2401 Aztec NE, MS Z110 Albuquerque, NM Mr. Geoffrey M. Cook Southern California Edison Company 5000 Pacific Coast Highway, Bldg. D21 San Clemente, CA Mr. Robert Henry Salt River Project 6504 E. Thomas Road Scottsdale, AZ Mr. Jeffrey T. Weikert Assistant General Counsel El Paso Electric Company Mail Location W. Mills El Paso, TX Mr. Eric Tharp Los Angeles Department of Water & Power Southern California Public Power Authority P.O. Box 51111, Room 1255-C Los Angeles, CA Mr. Brian Almon Public Utility Commission William B. Travis Building P.O. Box N. Congress Avenue Austin, TX Mr. Randall K. Edington Executive Vice President Nuclear/CNO Arizona Public Service Company P.O. Box 52034, Mail Station 7602 Phoenix, AZ