ML21228A104

RR-67, Request for Alternative Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (EPID L-2021-LLR-0050) (Email)

ML21228A104
Person / Time
Site:	Palo Verde
Issue date:	08/12/2021
From:	Cox M Arizona Public Service Co
To:	Siva Lingam NRC/NRR/DORL/LPL4
Lingam S, 301-415-1564
References
EPID L-2021-LLR-1050
Download: ML21228A104 (2)

Text

From: Matthew.Cox@aps.com To: Lingam, Siva Cc: Carl.Stephenson@aps.com; Thomas.N.Weber@aps.com; Sarah.Kane@aps.com; Nawaporn.AaronsCooke@aps.com

Subject:

[External_Sender] RE: Palo Verde 1, 2, and 3 - RR-67, Request for Alternative Frequency to Containment Unbonded Post-Tensioning System lnservice Inspection (EPID L-2021-LLR-0050)

Date: Thursday, August 12, 2021 11:14:11 AM Attachments: image001.png

Siva, APS is providing the requested clarification below:

As described in Section 5.1, Alternative Proposed for Units 1 and 3, of the submittal, page 4 of the Enclosure, APS is requesting relief for Units 1 and 3 from the requirement of IWL-2421(b) and proposed an alternative. Unit 2 is not included in this element of the relief request. The information regarding future Unit 2 testing, described in the submittal and quoted in the NRC clarification request, was provided for completeness; however, APS is not requesting NRC approval for Unit 2 regarding the requirements of IWL-2421(b). The NRC staff is requested to limit review to Units 1 and 3 regarding this element of the relief request at this time. The necessary information for NRC review for Units 1 and 3 for this element of the relief request are included in the original submittal, APS letter number 102-08286, dated July 29, 2021. APS expects to make available test results from Unit 2 following the scheduled testing, but do not intend to complicate NRC acceptance review for Units 1 and 3 for this element of the relief request.

The proposed duration for this element of the relief request is:

The proposed alternatives are requested for use during the PVNGS Units 1 and 3 third 10-year containment Inservice Inspection Interval and during the fourth 10-year containment Inservice Inspection Interval, provided the edition of the ASME BPV Code,Section XI required to be used during the fourth Inservice Inspection Interval does not impose requirements that are more stringent than those of the alternatives approved by the NRC in this relief request.

As described in Section 5.2, Additional Alternatives Proposed for Units 1, 2 and 3, of the submittal, page 5 of the Enclosure, APS is requesting relief for Units 1, 2 and 3 to limit the scope of tendons required to be detensioned for wire removal and examination, elongation measurement, and to eliminate the requirement of IWL-2523.2(b) to perform tendon wire tension testing. The proposed duration for this element of the relief request is:

The proposed alternatives are requested for use during the PVNGS Units 1, 2 and 3 third 10-year containment Inservice Inspection Interval and during the fourth 10-year containment Inservice Inspection Interval, provided the edition of the ASME BPV Code,Section XI required to be used during the fourth Inservice Inspection Interval does not impose requirements that are more stringent than those of the alternatives approved by the NRC in this relief request.

Matthew S. Cox Section Leader, Licensing 5801 South Wintersburg Road, Tonopah, AZ 85354-7529, M.S. 7636 Office 623.393.5753 Cell 865.300.1903 From: Lingam, Siva <Siva.Lingam@nrc.gov>

Sent: Monday, August 9, 2021 2:48 PM To: Cox, Matthew S <Matthew.Cox@aps.com>; Stephenson, Carl J <Carl.Stephenson@aps.com>

Cc: Dixon-Herrity, Jennifer <Jennifer.Dixon-Herrity@nrc.gov>; Colaccino, Joseph <Joseph.Colaccino@nrc.gov>; Ma, John <John.Ma@nrc.gov>;

Hernandez, Raul <Raul.Hernandez@nrc.gov>

Subject:

Palo Verde 1, 2, and 3 - RR-67, Request for Alternative Frequency to Containment Unbonded Post-Tensioning System lnservice Inspection (EPID L-2021-LLR-0050)

• • • CAUTION*** ***CAUTION*** ***CAUTION***

This e-mail is from an EXTERNAL address (prvs=8485c6d0f=Siva.Lingam@nrc.gov). DO NOT click on links or open attachments unless you trust the sender and know the content is safe. If you suspect this message to be phishing, please report it to the APS Cyber Defense Center at ACDC@aps.com.

Before we complete our acceptance review of the subject relief request, we need the clarification as noted below:

The application states, APS proposes to extend the post-tensioning system examination and testing interval from 10 years to 20 years for Units 1 and 3. For Unit 2, the NRC approved a delay in performing the Unit 2 test for one year due to COVID-19 in Relief Request 66. The due date was extended from February 8, 2021, to February 8, 2022. As a result, the potential for an alternative examination schedule for the Unit 2 post-tensioning system examinations and tests will be evaluated after this data has been collected. [in the letter of the application]

Prior to the 20th year surveillance, only visual examinations were performed on Unit 2. As a result, sufficient data has not yet been

obtained to support seeking an alternative to the tendon examination frequency for Unit 2. [page 10 of the enclosure of the application]

DURATION OF PROPOSED ALTERNATIVES:

The proposed alternatives are requested for use during the PVNGS Units 1, 2, and 3 third 10-year containment Inservice Inspection Interval and during the fourth 10-year containment Inservice Inspection Interval, provided the edition of the ASME BPV Code,Section XI required to be used during the fourth Inservice Inspection Interval does not impose requirements that are more stringent than those of the alternatives approved by the NRC in this relief request. [page 11 of the enclosure of the application]

The above first statement from the application in item 1 above clearly stated that the proposed extension is for Unit 1 and Unit 3, but for Unit 2 the potential for extension will be evaluated after February 8, 2022. However, item 3 above states that the proposed alternatives are requested for Units 1,2, and 3. Regarding Unit 2, do you have plans to provide the test results through supplementary letter by February 8, 2022, or mutually acceptable date? Otherwise, we cannot accept the review for Unit 2, and will limit our review for Units 1 and 3.

Please let me know the proposed dates and timings for the clarification call to discuss further. You are also welcome to respond to this email providing the details for our concern. Thank you.

Siva P. Lingam U.S. Nuclear Regulatory Commission Project Manager Palo Verde Nuclear Generating Station, Units 1, 2, and 3 Grand Gulf Nuclear Station Entergy Fleet Location: O-9E22; Mail Stop: O-9E03 Telephone: 301-415-1564 E-mail address: Siva.Lingam@nrc.gov