ML22025A001
| ML22025A001 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde |
| Issue date: | 01/25/2022 |
| From: | Arizona Public Service Co |
| To: | Division of Operating Reactor Licensing |
| Lingam S, 301-415-1564 | |
| References | |
| EPID L-2022-LRM-0008 | |
| Download: ML22025A001 (8) | |
Text
Palo Verde Nuclear Generating Station Containment Post-Tensioning System Inspection Unit 2 Relief Request 69 Pre-Submittal Call with NRC January 25, 2022
2
- Introduction
- Code Required Tendon Surveillance
- Proposed Relief Request 69
- Relief Request Summary
- Schedule
- Questions/Comments Agenda
4 ASME BPVC Section XI Subsection IWL-2420 requires containment post-tensioning systems to be examined visually every 5 years (10 years for physical exams) 35th surveillance year was February 2020 PVNGS deadline for inspection was 2/8/21 Extended to 2/8/22 by Relief Request (RR) 66 The surveillance was previously performed in 2015 and 2011 (30th and 25th year surveillances)
Both surveillances concluded the post-tensioned tendons met the applicable Code requirements with no abnormal degradation of the post-tensioning system identified The 35th year surveillance is currently in progress The final test report will not be complete by 2/8/22 Code Required Tendon Surveillance
5 Requesting relief from the requirements of IWL-2420 regarding the interval between containment tendon inspections for Unit 2 Pursuant to 10 CFR 50.55a(z)(2)
Representing a hardship or unusual difficulty without a compensating increase in the level of quality and safety Applies to ASME Code Class CC Concrete Component of Light-Water Cooled Plants - Containment Post-Tensioning System Inspections Requesting approximately 3-month extension of the current 12-month extension provided by RR 66 to permit time to finalize the inspection report and complete the surveillance Proposed Relief Request 69 Purpose and Basis
6 Good faith efforts made to complete by 2/8/22 date Examinations originally scheduled to start in November 2021 Delays in vendor completion of work at other sites Inspections initiated at PVNGS January 2022 Majority of inspection work complete by 2/8/22 Continuing to experience COVID-19 impacts Final vendor report targeted for March 2022 Final APS acceptance targeted for April 2022 Past Unit 2 examinations support technical adequacy of Unit 2 containment tendons as described in RR 66 RR 67 provides a description of Units 1 and 3 similar design and basis for a further extension of certain examinations to 20-years (APS letter 102-08286 dated July 29, 2021, ML21210A300)
Data from these examinations will be used to form the basis for a similar Unit 2 RR at a later date Proposed Relief Request 69 Purpose and Basis
RR 66 was submitted as a hardship per 10 CFR 50.55a(z)(2) due to the COVID-19 pandemic Provided a one-time extension of the 35th year inspections to 2/8/2022 Verbal approval received 11/19/2020 (ML20325A039)
Written approval received 4/2/21 (ML21089A010)
Proposed RR 69 requests an approximately 3-month extension of current 12-month extension provided by RR 66 to permit completion of final test report and surveillance Relief Request Summary 7
8
- Planning to submit January 28, 2022
- NRC approval requested by February 8, 2022 Schedule
Questions/Comments