ML22025A001

1/25/22 Pre-submittal Meeting Presentation Slides for RR-69 to Extend Containment Tendon Inspection by Three Months Beyond 2/8/22

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

Agenda

• Introduction

• Code Required Tendon Surveillance

• Proposed Relief Request 69

• Relief Request Summary

• Schedule

• Questions/Comments 2

Code Required Tendon Surveillance

• 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 4

Proposed Relief Request 69 Purpose and Basis

• 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 5

Proposed Relief Request 69 Purpose and Basis

• 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 6

Relief Request Summary

• 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 7

Schedule

• Planning to submit January 28, 2022

• NRC approval requested by February 8, 2022 8

Questions/Comments