ML17318A472

Relief Request 56 - Unit 2 Third 10-Year Inservice Inspection (ISI) Interval Extension and Request to Adopt 2013 Edition of Section XI of the American Society of Mechanical Engineers (Asme)Code for the Fourth 10-Year..

ML17318A472
Person / Time
Site:	Palo Verde
Issue date:	11/10/2017
From:	Lacal M Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
102-07604-MLL/TNW
Download: ML17318A472 (6)

Text

10 CFR 50.55a Oaps MARIA L. LACAL Senior Vice President, Nuclear Regulatory & Oversight 102-07604-MLL/TNW November 10, 2017 Palo Verde Nuclear Generating Station P.O. Box 52034 U. S. Nuclear Regulatory Commission Phoenix, AZ 85072 ATTN: Document Control Desk Mail Station 7605 Washington, DC 20555-0001 Tel 623.393.6491

Dear Sirs:

Subject; Palo Verde Nuclear Generating Station Units 1, 2, and 3 Docket Nos. STN 50-528/529/530 Relief Request 56 - Unit 2 Third 10-Year Inservice Inspection (ISI)

Interval Extension and Request to Adopt 2013 Edition of Section XI of the American Society of Mechanical Engineers (ASME) Code for the Fourth 10-Year Interval for Units 1, 2 and 3 Pursuant to 10 CFR 50.55a(z)(l), Arizona Public Service Company (APS) is submitting the enclosed Relief Request 56, which seeks an extension to the third 10-year Inservice Inspection (ISI) interval for Palo Verde Nuclear Generating Station (PVNGS) Unit 2, as an alternative that provides an acceptable level of quality and safety. The extension would be beyond the one year extension permitted in American Society of Mechanical Engineers (ASME) Code,Section XI, IWA-2430.

The planned third 10-year ISI interval examinations have been completed for Unit 2 and the interval closeout is in progress. Relief Request 56 will not extend Unit 2 third interval required inspections. Additionally, Unit 2 third interval relief requests for impractical inspections are still planned for submittal (March 2018) within 12 months of the scheduled end of the third interval, as required by 10 CFR 50.55a(g)(5)(iii), and are not within the scope of this relief request.

The basis for the relief request is to better align the fourth 10-year ISI intervals and the Code required repair/replacement process with scheduled outages. This alignment also coordinates each of the PVNGS ISI programs to a common edition of the ASME Code and supports APS utilizing the latest available 10 CFR 50.55a requirements for the ISI programs and repair/replacement activities.

As a separate item, APS is requesting authorization to use a later edition of Section XI of the ASME Code to update the PVNGS ISI programs for the fourth 10-year ISI interval. In light of the final rulemaking for 10 CFR 50.55a (82 FR 32934) dated July 18, 2017, APS is requesting authorization to adopt the 2013 Edition of Section XI of the ASME Code. If authorized, APS will use the recently approved 2013 Edition of Section XI of the ASME Code to develop and implement the ISI programs for the fourth 10-year ISI interval for each of the three PVNGS units to maintain consistency across the plant site.

A pre-submittal conference call was held with the NRC staff on October 5, 2017. APS requests approval of Relief Request 56 and authorization to adopt the 2013 Edition of Section XI of the ASME Code prior to June 1, 2018, to support initiation of the proposed fourth 10-year ISI interval Inspections for Unit 3 and the implementation of a common repair and replacement plan for the three PVNGS Units.

A member of the STARS Alliance LLC Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

102-07604-MLL/TNW ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Extension of Unit 2 Third 10-Year ISI Interval - Adoption of 2013 Section XI of ASME Code Page 2 At PVNGS, each unit has a separate ISI program which will be updated prior to the first required examinations of the fourth 10-year ISI interval. These ISI programs will be submitted to the NRC in accordance with Section XI, IWA-1400(c) of the ASME Code.

The ISI relief requests needed for the fourth 10-year ISI intervais are expected to be submitted for NRC staff review in advance of the proposed fourth ISI interval inspections.

No new commitments are being made in this submittal.

If you have any questions about this request, please contact Matthew Cox, Licensing Section Leader, at (623) 393-5753.

Sincerely, Lacal, Maria DN: cn=Lacal, Maria UZ06149)

L(Z06149) Date: 2017.11,1016:19:47

-07'00 MLL/TNW/MDD/sma

Enclosure:

Relief Request 56 - Extension of Unit 2 Third 10-Year ISI Interval cc: K. M. Kennedy NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS M. M. Watford O'Banion NRC NRR Project Manager C. A. Peabody NRC Senior Resident Inspector for PVNGS

Enclosure Relief Request 56 Extension of Unit 2 Third 10-Year ISI Interval

Enclosure Relief Request 56 - Extension of Unit 2 Third 10-Year ISI Interval Arizona Public Service Company (APS)

Palo Verde Nuclear Generating Station (PVNGS) - Unit 2 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(l)

Third 10-Year Inservice Inspection (ISI) Interval Extension

1.0 DESCRIPTION

APS is submitting Relief Request 56 which seeks an extension to the third 10-year ISI interval for PVNGS Unit 2 pursuant to 10 CFR 50.55a(z)(l), as an alternative that provides an acceptable level of quality and safety. The relief request will permit better coordination of the ISI programs at the PVNGS site. This relief request will also permit the Code required repair/replacement program for the fourth 10-year ISI interval to begin on a common date coincident with the proposed first implementation of the fourth 10-year ISI interval, currently targeted for June 1, 2018, for PVNGS Unit 3.

2.0 ASSESSMENT Technical Evaluation of the Proposed Alternative to the ASME Section XI Code APS is requesting relief to extend the PVNGS Unit 2 third 10-year ISI interval approximately 8 months beyond the ASME Code one year extension permitted in IWA-2430. It is intended that this relief request re-set the Unit 2 10-year ISI intervals, such that the Code allowable one year extension would remain available for future contingencies.

The planned third 10-year ISI interval examinations have been completed for Unit 2 and the interval closeout is in progress. APS is planning to submit a separate relief request, similar to previous 10-year intervals, to use ASME Code Case N-798, Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Vent, Drain, and Test Isolation Devices, and ASME Code Case N-800, Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Injection Valves, in lieu of pressure testing in accordance with ASME Section XI, paragraph IWB-5222(b). The need for such a relief request, however, would be obviated if 10 CFR 50.55a rulemaking to adopt Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 18, that recognizes these Code Cases, is completed in the near term.

Relief Request 56 will not extend third interval required inspections.

In addition, third interval relief requests for impractical inspections for Unit 2 are still planned for submittal (March 2018) within 12 months of the end of the current third interval, as required by 10 CFR 50.55a(g)(5)(iii), and are not within the scope of this relief request.

The various PVNGS Unit ISI 10-year intervals are shown in the following table.

interval 1

• Interval 2

• Interval 3 Interval 4 Start End Start End Start End Start End Uniti 1/28/1986 7/17/1998 7/18/1998 7/17/2008 7/18/2008 7/17/2018 7/18/2018 7/17/2028 Unit 2 9/19/1986 3/17/1997 3/18/1997 3/17/2007 3/18/2007 3/17/2017 3/18/2017 3/17/2027 Units 1/8/1988 1/10/1998 1/11/1998 1/10/2008 1/11/2008 1/10/2018 1/11/2018 1/10/2028 None of tile intervals date changes were based on the Code allowable one-year extension provision pWA-2430<d)].

The interval changes were based upon extended plant outages, pursuant to IWA-2430(e)

Enclosure Relief Request 56 - Extension of Unit 2 Third 10-Year ISI Interval r ASME Code Components Affected ASME Item Number: All

Description:

This Relief Request is applicable to all ASME Section XI Code items in PVNGS Unit 2 for the proposed extended third ISI interval.

Code Class: All

Applicable Code Edition and Addenda

The third 10-year ISI interval Code for PVNGS is the 2001 Edition through and including the 2003 Addenda of ASME Code,Section XI.

APS is requesting that the PVNGS Units 1, 2, and 3 be permitted to use the recently approved 2013 Edition of Section XI of the ASME Code, which went into effect on August 17, 2017, for the fourth 10-year ISI intervals. Absent such requested authorization, the PVNGS units would be required by 10 CFR 50.55a(g)(4)(ii) to use the 2008 Edition of Section XI of the ASME Code, which was in effect 12 months prior to the scheduled start of the respective fourth 10-year ISI intervals for each unit.

Installation Code for PVNGS: ASME Code,Section III, 1974 Edition, 1975 Winter Addenda.

Applicable Code Requirement

The current PVNGS third 10-year ISI interval programs for each of the three units utilize the 2001 Edition through the 2003 Addenda of the ASME Section XI Code. All intervals at PVNGS utilized Inspection Program B that specifies the use of 10-year intervals. Paragraph IWA-2430, Inspection Intervals, allows each of these intervals to be extended by as much as one year, but these adjustments cannot alter the original pattern of intervals by more than one year.

APS has utilized the year extension within past intervals to perform specific examinations, but has not changed the overall interval dates by use of the provisions of IWA-2430.

Reason for Request

The basis for the relief request is to better align the fourth 10-year ISI intervals and the Code required repair/replacement process with scheduled outages. This alignment also coordinates each of the PVNGS ISI programs to a common edition of the ASME Code and supports APS utilizing the latest available 10 CFR 50.55a requirements for the ISI programs and repair/replacement procedures.

Aligning the ISI programs to be implemented in the requested sequence allows cost effective and efficient use of resources for development and implementation.

This relief request will not extend third interval required inspections. The proposed alternative provides an acceptable level of quality and safety.

Proposed Alternative and Basis for Use The current 10 CFR 50.55a, Codes and standards, effective August 17, 2017, documents that the 2013 Edition of the ASME Code,Section XI, is approved for use. This becomes the mandatory code when updating ISI programs after August 17, 2018. APS would like to utilize this Edition of Section XI of the ASME Code for all three PVNGS Units for the fourth 10-year ISI interval programs.

Enclosure Relief Request 56 - Extension of Unit 2 Third 10-Year ISI Interval To support the use of the 2013 Edition and to align the fourth 10-year ISI interval programs and the repair/replacement process with the scheduled outages, APS is requesting that the third 10-year ISI interval for Unit 2 be extended approximately 8 months past the Code allowed one year extension (approximately 20 months total extension). The other units will remain within the Code permitted one year extension. Figure 1 provides an overall view of the requested dates.

Units 1 and 3 will begin their fourth interval within their respective one year allowed extension intervals just after refueling outages 1R21 (Spring 2019) and 3R20 (Spring 2018), respectively.

The corresponding Unit 1 and 3 fourth 10-year ISI interval end dates will not change from the original pattern. The proposed change will reset the end of the Unit 2 third 10-year ISI interval such that the Unit 2 fourth 10-year ISI interval start and end dates will better coordinate with Units 1 and 3. This relief request will set up the station for a consistent 10-year interval pattern for the remaining life of the facility.

GMiraM (3rd) MIVMI ASMCn 1 Dons 2017 201<< 20>> 4th Interval Start Dates 4th Interval Dates S)a*q Fai Spring Fal UNITl 07-U<<etB07-17-U 7/17/2019 R19 no > 6-1-19 (ilrealy after U1R21) 06411-19 to 07-17-28 UNIT 2 V17/2018 R20 -> 11-1-18 (directly after U2R21) U-Ol-U to 10-31-28 UNrT3 oi-ii-oetooi-io-ia 1/10/2019 R19 6-1-18 (directly after U3R20) 08-01-18 to 01-10-28

^ Repair & Replacement 2013 date for aH 3 units 6-1-18 Figure 1 Duration of Proposed Alternative The proposed alternative is requested to extend the Unit 2 third 10-year ISI interval through October 31, 2018.