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MONTHYEARML16202A4872016-07-21021 July 2016 07/21/2016 Talking Points, Supplemental Information for South Texas Project and NRC Public Meeting Project stage: Request ML16172A0192016-07-25025 July 2016 STP Aluminum Bronze Selective Leaching Public Meeting - June 21, 2016 Project stage: Meeting ML16218A3672016-08-30030 August 2016 07/21/2016 Summary of Public Teleconference Meeting with STP Nuclear Operating Company Discussing Revisions to License Renewal Application Aluminum Bronze Selective Leaching Aging Management Program and Background Document Project stage: Meeting ML17017A1482017-01-24024 January 2017 Plan for the 2017 Selective Leaching of Aluminum Bronze Aging Management Program Regulatory Audit Regarding the South Texas Project, Units 1 and 2, License Renewal Application Review(Cac Nos. ME4936 and ME4937) Project stage: Other NOC-AE-17003441, Revised Response Request for Additional Information for the Review of the South Texas Project License Renewal Application2017-02-0909 February 2017 Revised Response Request for Additional Information for the Review of the South Texas Project License Renewal Application Project stage: Request ML17068A2532017-03-23023 March 2017 Extend Timeframe for the 2017 Selective Leaching of Aluminum Bronze AMP Regulatory Audit Regarding the South Texas Project, Units 1 and 2, License Renewal Application Review (CAC Nos. ME4936 and ME4937) Project stage: Other NOC-AE-17003454, Supplement to the License Renewal Application2017-03-30030 March 2017 Supplement to the License Renewal Application Project stage: Supplement NOC-AE-17003459, Supplement to the License Renewal Application Re Aging Management Programs2017-04-19019 April 2017 Supplement to the License Renewal Application Re Aging Management Programs Project stage: Supplement NOC-AE-17003475, Supplement to the License Renewal Application2017-05-0202 May 2017 Supplement to the License Renewal Application Project stage: Supplement ML17172A0142017-05-0404 May 2017 STP Response to ACRS Questions Project stage: Other ML17107A3192017-05-16016 May 2017 Aluminum Bronze Selective Leaching Aging Management Program Audit Report Regarding the South Texas Project, Units 1 and 2, License Renewal Application (CAC Nos. ME4936 and ME4937) Project stage: Other 2017-03-23
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Category:Audit Report
MONTHYEARML21236A3082021-09-10010 September 2021 Regulatory Audit Summary Regarding License Amendment Request to Revise Moderator Temperature Coefficient Surveillance Requirements ML20142A2792020-05-27027 May 2020 Regulatory Audit Summary Regarding Exigent License Amendment Request to Revise the Safety Injection Accumulators Pressures ML17107A3192017-05-16016 May 2017 Aluminum Bronze Selective Leaching Aging Management Program Audit Report Regarding the South Texas Project, Units 1 and 2, License Renewal Application (CAC Nos. ME4936 and ME4937) ML16218A2562016-08-30030 August 2016 Aluminum Bronze Selective Leaching Aging Management Program and PWR Reactor Internals Program Inspection Plan Audit Report Regarding the South Texas Project, Units 1 and 2 ML16214A2912016-08-26026 August 2016 Summary of June 28-30, 2016, Regulatory Audit at Westinghouse in Rockville, MD, License Amendment Request to Revise Technical Specification 5.3.2 to Allow Operation with 56 Full-Length Control Rod Assemblies ML16141B0812016-05-31031 May 2016 Audit Summary, Risk Audit on April 12-13, 2016, at Alumni Center at the University of Texas, Austin, Tx; Pilot Generic Safety Issue 191 Submittal and Exemption Request, and Draft Request for Additional Information ML16127A4002016-05-11011 May 2016 Audit Summary, Thermal-Hydraulic Review on February 23-25, 2016 at Texas A&M University; Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue 191 (CAC MF2400-MF2409) ML16103A3442016-04-26026 April 2016 Summary of February 24-26, 2016 Audit, Debris Transport Review at Alion Science and Technology Corporation, Albuquerque, Nm; Pilot Submittal and Exemption Request, Risk-Informed Approach to Resolve GSI 191 ML16095A0102016-04-13013 April 2016 Summary of November 17-19, 2015 Thermal-Hydraulic Review at Texas A&M University; Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 (CAC MF2400-MF2409) ML16096A0652016-04-13013 April 2016 Summary of February 4 and 16, 2016, Regulatory Audit at Westinghouse in Rockville, MD, Boric Acid Precipitation, Exemption and License Amendment Request, Risk-Informed Approach to Resolve Generic Safety Issue 191 ML16029A2722016-03-15015 March 2016 12/7-8/2015 Audit Summary, Audit Conducted to Support License Amendment Request to Revise TS 5.3.2 to Allow Operation with 56 Full-Length Control Rod Assemblies for Unit 1 Cycle 20 (Emergency Circumstances) ML15175A0242015-07-29029 July 2015 Audit Summary for May 12-14, 2015 Audit of Roverd Methodology Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 (TAC Nos. MF2400 Through MF2409) ML15183A0072015-07-15015 July 2015 Audit Summary, 3/31 to 4/2/15 Audit of Systems, Structures and Equipment at STP Facility; Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 ML15131A1452015-06-0404 June 2015 Audit Report for the 2015 Supplemental Audit STP License Renewal ML15111A4652015-05-0606 May 2015 Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 ML15183A0092015-04-0202 April 2015 Photos, Audit Summary, 3/31 to 4/2/15 Audit of Systems, Structures and Equipment at STP Facility; Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 ML14321A6772015-01-15015 January 2015 Audit Report for 9/16-17/2014 Audit at University of New Mexico Pilot Submittal and Request for Exemptions for a Risk-Informed Approach to Resolve Generic Safety Issue (GSI)-191 (TAC MF2400 Through and MF2409) ML13339A7362014-01-29029 January 2014 Interim Staff Evaluation and Audit Report Relating to Overall Integrated Plan in Response to Order EA-12-049 - Mitigation Strategies ML12165A2392012-06-15015 June 2012 Report Regarding the Follow-up Audit of the Selective Leaching of Aluminum Bronze Aging Management Program for the South Texas Project, Units 1 and 2, License Renewal Application (TAC ME4936 and ME4937) ML11224A2652011-09-22022 September 2011 Aging Management Programs Audit Report Regarding the South Texas Project, Units 1 and 2, Station License Renewal Application (TAC Nos. ME4936 and ME4937) ML1122106582011-09-0707 September 2011 Audit of the Licensee Regulatory Commitment Management Program, Audit Performed July 19-20, 2011 ML11230A0032011-09-0606 September 2011 Scoping and Screening Audit Report Regarding the South Texas Project, Units 1 and 2 (TAC Nos. ME4936 and ME4937) ML11173A3042011-07-18018 July 2011 Audit Report Regarding South Texas Project License Renewal Application - Cultural Resource ML11145A0642011-06-21021 June 2011 Plan for the Environmental Related Regulatory Audit Regarding the South Texas Project, Units 1 and 2, License Renewal Application Review (TAC Nos. ME4938 and ME4939) ML0834501622008-12-24024 December 2008 Audit Report of Licensee Regulatory Commitment Management Program for Audit Performed August 19, 2008 ML0721101192007-08-16016 August 2007 Us NRC Audit Report for South Texas Project Combined License Application Review ML0426702502004-09-22022 September 2004 Audit of the Licensees Management of Regulatory Commitments NOC-AE-04001712, Appendix a Cameco Corporation 2003 Consolidated Audited Financial Statements2004-02-27027 February 2004 Appendix a Cameco Corporation 2003 Consolidated Audited Financial Statements 2021-09-10
[Table view] Category:Letter
MONTHYEARML24029A2752024-01-29029 January 2024 Request to Reschedule Evaluated Force-on-Force Drill IR 05000498/20230042024-01-29029 January 2024 Integrated Inspection Report 05000498/2023004 and 05000499/2023004 ML24024A1162024-01-24024 January 2024 STP Unit 2 Request for Information IR 05000498/20244042024-01-18018 January 2024 Information Request for the Cyber-Security Baseline Inspection, Notification to Perform Inspection 05000498/2024404; 05000499/2024404 IR 05000498/20230032023-12-28028 December 2023 Acknowledgment of Reply to a Notice of Violation (NRC Inspection Report 05000498/2023003 and 05000499/2023003) ML23360A1692023-12-26026 December 2023 FEMA, Submittal of Radiological Emergency Preparedness Final Report for the South Texas Project Medical Services Drill Evaluated on August 31, 2023 NOC-AE-230040, Supplement to Proposed Alternate Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (Relief Request RR-ENG-4-06)2023-12-14014 December 2023 Supplement to Proposed Alternate Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (Relief Request RR-ENG-4-06) NOC-AE-230039, Docket Nos. Stn 50-498, Stn 50-499 - Reply to a Notice of Violation, NRC Inspection Report 05000498/2023003 and 05000499/20230032023-12-12012 December 2023 Docket Nos. Stn 50-498, Stn 50-499 - Reply to a Notice of Violation, NRC Inspection Report 05000498/2023003 and 05000499/2023003 ML23326A2592023-12-0505 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report ML23339A1902023-12-0505 December 2023 Update Foreign Ownership, Control, or Influence (FOCI) IR 05000498/20234012023-12-0404 December 2023 Security Baseline Inspection Report 05000498/2023401 and 05000499/2023401 ML23324A0102023-11-16016 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23310A2282023-11-13013 November 2023 Integrated Inspection Report 05000498/2023003 and 05000499/2023003, and Notice of Violation ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23298A0002023-11-0101 November 2023 the Associated Independent Spent Fuel Storage Installation - Issuance of Amendment Nos. 226 and 211 Related to Order Approving Indirect Transfer of Licenses and Conforming License Amendments ML23303A0782023-10-30030 October 2023 Submittal of Supplemental Information in Response to Order Consenting to License Transfers and Approval of Draft Conforming License Amendments ML23279A0342023-10-30030 October 2023 Associated Independent Spent Fuel Storage Installation - Order Approving Indirect Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0004) (Letter) IR 05000498/20234032023-10-26026 October 2023 Material Control and Accounting Program Inspection Report 05000498/2023403 and 05000499/2023403 (Cover Letter) ML23317A1262023-10-12012 October 2023 South. Texas Project Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program Revision 26 ML23279A1382023-10-0505 October 2023 Responses to Requests for Additional Information Related to Application for Order Approving Indirect Transfer of Control of Licenses ML23271A1942023-10-0303 October 2023 Notification of Commercial Grade Dedication Inspection (05000498/2024013 and 05000499/2024013) and Request for Information ML23270B2592023-09-27027 September 2023 Update Foreign Ownership, Control, or Influence ML23263B1132023-09-20020 September 2023 Operator Licensing Examination Schedule Revision 1 IR 05000498/20243012023-09-0707 September 2023 Notification of NRC Initial Operator Licensing Examination 05000498/2024301; 05000499/2024301 IR 05000498/20233012023-09-0101 September 2023 NRC Examination Report 05000498/2023301 and 05000499/2023301 ML23243B0562023-08-31031 August 2023 Supplemental Information to Application for Order Approving Indirect Transfer of Control of Licenses ML23236A6042023-08-24024 August 2023 Annual Dose Report for 2022 IR 05000498/20230052023-08-22022 August 2023 Updated Inspection Plan for South Texas Project Electric Generating Station, Units 1 and 2 (Report 05000498/2023005 and 05000499/2023005) - Mid Cycle Letter ML23229A5262023-08-17017 August 2023 Inservice Inspection Summary Report - 1 RE24, ML23229A5892023-08-17017 August 2023 Voluntary Response to Regulatory Issue Summary (RIS) 2023-02, Scheduling Information for the Licensing of Accident Tolerant, Increased Enrichment, and Higher Burnup Fuels ML23229A4992023-08-17017 August 2023 Supplement to Proposed Alternate Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (Relief Request RR-ENG-4-06) ML23228A2102023-08-15015 August 2023 Closure of Investigation (OI 4-22-19) ML23222A0322023-08-10010 August 2023 Report of Changes Made to Quality Assurance Program for Radioactive Material Packages ML23221A3002023-08-0909 August 2023 RE22 Inspection Summary Report for Steam Generator Tubinq, Rev. 1 (Epld L-2023-LRO-0029) ML23222A2792023-08-0909 August 2023 Submittal of Update Foreign Ownership, Control, or Influence (FOCI) IR 05000498/20230022023-07-28028 July 2023 Integrated Inspection Report 05000498/2023002 and 05000499/2023002 ML23198A0532023-07-24024 July 2023 Request for Withholding Information from Public Disclosure ML23188A1612023-07-14014 July 2023 the Associated ISFSI - Notice of Consideration of Approval of Indirect Transfer of Licenses and Conforming Amendments and Opportunity to Request a Hearing (EPID L-2023-LLM-0004) - Letter ML23193A9932023-07-11011 July 2023 Submittal of Update Foreign Ownership, Control or Influence (FOCI) ML23192A0482023-07-11011 July 2023 NRC Initial Operator Licensing Examination Approval 05000498/2023301; 05000499/2023301 NOC-AE-230039, Submittal of Update Foreign Ownership, Control or Influence (FOCI)2023-07-11011 July 2023 Submittal of Update Foreign Ownership, Control or Influence (FOCI) ML23180A2822023-06-29029 June 2023 Operator Licensing Examination Schedule ML23177A2522023-06-26026 June 2023 Units 1, 2 & Independent Spent Fuel Storage Installation - Biennial Submittal of Technical Specification Bases Changes, Commitment Changes, 10 CFR 50.59 Evaluation Summary, and 10 CFR 72.48 Evaluation Summary ML23166B0802023-06-14014 June 2023 Update Foreign Ownership, Control, or Influence (FOCI) ML23163A1762023-06-12012 June 2023 Application for Order Approving Indirect Transfer of Control of Licenses 2024-01-29
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 16, 2017 Mr. G.T. Powell Site Vice President STP Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483
SUBJECT:
SELECTIVE LEACHING OF ALUMINUM BRONZE AGING MANAGEMENT PROGRAM AUDIT REPORT REGARDING THE SOUTH TEXAS PROJECT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (CAC NOS. ME4936 AND ME4937)
Dear Mr. Powell:
By letter dated October 25, 2010, STP Nuclear Operating Company (or the applicant) submitted an application for renewal of operating licenses NPF-76 and NPF-80 for the South Texas Project (STP), Units 1 and 2. By letter dated January 24, 2017, the staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) issued an audit plan (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17017A148) to inform you of our intent to conduct an in-office follow-up regulatory audit of your Selective Leaching of Aluminum Bronze Aging Management Program (AMP) and associated issues. By letter dated March 23, 2017, the staff amended the audit plan to extend the audit closure date from March 3, 2017, to April 28, 2017 to permit continued review of the Selective Leaching of Aluminum Bronze AMP (ADAMS Accession No. ML17068A253).
During the audit period, a question arose concerning STPs bolting integrity AMP, specifically regarding closure bolting located in air-filled, gas-filled, or air-filled systems that are not normally pressurized. The staff is also documenting its review of documents relevant to the bolting integrity AMP.
The NRC staff has completed its audit activities and documented the results in the enclosed audit report.
G.T. Powell If you have any questions, please contact me by telephone at 301-415-3306 or by e-mail at Lois.James@nrc.gov.
Sincerely,
/RA/
Lois M. James, Senior Project Manager Project Management and Guidance Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499
Enclosure:
As stated cc: Listserv
ML17107A319 OFFICE LA:RPGB:DLR PM: RPGB:DLR BC:RARB:DLR BC:RPGB:DLR NAME YEdmonds LJames DMorey SBloom DATE 5/11/2017 5/15/2017 4/25/2017 5/16/2017 OFFICE PM:RPB1:DLR NAME LJames DATE 5/16/2017
AUDIT REPORT FOR SOUTH TEXAS PROJECT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REVIEW SELECTIVE LEACHING OF ALUMINUM BRONZE AGING MANAGEMENT PROGAM (CAC NOS. ME4936 AND ME4937)
Docket Nos: 50-498 and 50-499 License Nos: NPF-76 and NPF-80 Licensee: STP Nuclear Operating Company Facility: South Texas Project, Units 1 and 2 Location: P.O. Box 289 Wadsworth, TX 77483 Dates: January 20 - April 18, 2017 Reviewers: Stephen Cumblidge, Materials Engineer Component Performance, NDE, and Testing Branch Division of Engineering Office of Nuclear Reactor Regulations William Holston, Senior Mechanical Engineer Aging Management of Reactor and Mechanical System Branch Division of License Renewal Office of Nuclear Reactor Regulations Lois James, Senior Project Manager Project Management and Guidance Branch Division of License Renewal Office of Nuclear Reactor Regulations Carol Nove, Senior Materials Engineer Component Integrity Branch Division of Engineering Office of Nuclear Regulatory Research Approved By: Dennis Morey, Chief Aging Management of Reactor and Mechanical System Branch Division of License Renewal Office of Nuclear Regulatory Research ENCLOSURE
1.0 INTRODUCTION
By letter dated October 25, 2010, STP Nuclear Operating Company (STPNOC or applicant) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating license NPF-76 and NPF-80 for South Texas Project (STP), Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff).
Between January 20 and April 18, 2017, the NRC staff conducted an in-office audit to examine STPNOC Selective Leaching of Aluminum Bronze aging management program (AMP) and related documents.
The purpose of the audit was to gain an understanding of the applicants AMP for aluminum bronze welds that are susceptible to loss of material due to selective leaching such that the NRC staff has confidence that Open Item 3.0.3.3.3-2 in the 2016 Safety Evaluation Report with Open Items (Agencywide Documents and Access Management System (ADAMS) Package Accession No. ML16271A011) has a closure path. This audit focused on the "corrective actions" program element of the Aluminum Bronze Selective Leaching AMP, specifically the Time-of-Flight Diffraction (TOFD) ultrasonic testing (UT) technique for examining aluminum bronze welds.
During the audit period, a question arose concerning STPs bolting integrity AMP. The NRC staff examined plant-specific documents related to managing the aging effects for closure bolting located in air-filled or gas-filled systems, or air-filled systems that are not normally pressurized.
In performing the audit, the NRC staff examined the applicants license renewal application (LRA), supplements to the LRA, program-bases documents and related references, and interviewed various applicant representatives.
Results of this audit will be ultimately documented in the NRC staffs safety evaluation report (SER). The table below lists the documents that were reviewed by the NRC staff and found relevant to the audit.
Relevant Documents Reviewed Document Title Revision/Date LRA Section A1.37 Selective Leaching of Aluminum Bronze NA UFSAR Supplement LRA Section B2.1.37 Selective Leaching of Aluminum Bronze NA AMP UTI-TOFD-AB-002 Ultrasonic Technical Instruction: Revision 1 Ultrasonic Examination of Aluminum Bronze Piping Butt Welds for Selective Leaching Using the Time-of-Flight Diffraction (TOFD) Technique NDE-PQ-2017-002 Ultrasonic Examination of Aluminum Revision 1 UTI-TOFD-AB-002 Bronze Pipe to Pipe Butt Welds for Selective Leaching Using the Time-of-Flight Diffraction (TOFD)
Technique
Relevant Documents Reviewed Document Title Revision/Date SEG-0001 System Engineer Administrative Revision 15 Guidance 0PGP03-ZA-0133 Fluid Leak Management Program Revision 4 2.0 PLANT-SPECIFIC PROGRAMS 2.1 Selective Leaching of Aluminum Bronze Aging Management Program During the audit of the Selective Leaching of Aluminum Bronze Aging Management Program, the staff interviewed the applicants staff and reviewed documentation provided by the applicant.
The staff reviewed LRA changes associated with dealloying of aluminum-bronze welds along with a Technical Justification Report and a plant-specific nondestructive examination (NDE) procedure associated with TOFD UT examinations. The staff made the following observations based on the content of the reports.
- The staff reviewed changes to LRA Sections A1.37 and B2.1.37 and conducted breakout sessions with the applicant. During these breakout sessions, the staff discussed degraded but operable criteria for welds that did not meet structural integrity requirements, the extent of TOFD UT examinations, and evaluation criteria for potential follow-on inspections of buried pipe welds. Near the end of the audit, the applicant submitted changes to the LRA by letter dated March 30, 2017. The staffs evaluation of the final version of the AMP and Updated Final Safety Analysis Report (UFSAR)
Supplement is documented in the SER.
- The staff reviewed the Technical Justification for the TOFD UT examination technique and the plant-specific procedure for implementing the TOFD UT examination technique.
During breakout sessions with the applicant, the staff discussed specific concerns with the documents encompassed within the following six areas: (a) qualifications; (b) scanning; (c) calibration; (d) detection; (e) sizing; and (f) noise. Subsequent to review of the final documents, the staff noted that:
o Personnel are qualified in accordance with the plant-specific NDE written practices document and will have: (a) completed 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of TOFD class; (b) demonstrated detection and sizing capability; and (c) met all aspects of a Practical Examination 10 Point Checklist.
o The procedure requires the weld crown preparation to be conditioned to a smooth flat (in-service inspection finish) and scanning is conducted in a direction parallel to the weld.
o The encoder is calibrated such that the display of measured distance is within one percent of actual distance moved.
o The procedure states that when dealloying approaches the outside diameter surface, the lateral wave may break or have a localized reduction in its strength coupled with changes in the back wall thickness.
o The procedure states that the depth of dealloying is determined by selection of the deepest TOFD arc reflector, and dealloying length is derived from the overall presence of the TOFD arcs and measured down to the noise level.
o The procedure addresses determining the source of excessive noise by signal averaging.
In addition to identifying the above concerns that were resolved by the applicant with revisions to the documents prior to completion of the audit, the staff noted:
- The use of the method was validated by conducting TOFD UT examinations followed by destructive examination to confirm that the extent of degradation had been sufficiently detected by the examination technique.
- The applicants plant-specific procedures include: (a) qualification requirements for examiners that collect the data and examiners that interpret the data; (b) the equipment to be used for the inspections; (c) essential variables for the inspections; (d) details on how to conduct the inspections; and (e) requirements for data analysis and recording.
- A technical justification was provided, which meets a Low Rigor level of qualification conducted in accordance with the 2004 Edition of ASME Code Section V, Nondestructive Examination, Article 14, Examination System Qualification.
2.2 Managing Aging Effects for Closure Bolting Located in Air-Filled, Gas-Filled, or Air-Filled Systems that are not Normally Pressurized During this audit the NRC staff interviewed the applicants staff and reviewed documentation provided by the applicant.
The staff reviewed procedures SEG-001 and 0PGP03-ZA-0133 to determine whether the plant-specific procedures included adequate controls to manage loss of material due to general (where applicable), pitting. or crevice corrosion, cracking due to stress corrosion cracking, or loss of preload due to thermal effects, gasket creep, and self-loosening for air-filled or gas-filled systems, or air-filled systems that are not normally pressurized. The staff noted that:
- SEG-001 states that for valves, inspections for leakage are conducted at connections, and particularly for air-operated values leaks at hoses and regulators. The Appendix also states that for instrument/electrical connections inspections occur for air or fluid leaks. The procedure cites 0PGP03-ZA-0133.
- 0PGP03-ZA-0133 cites criteria for leaks evidenced by the use of leak detection fluid; however, it does not state that every air-filled or gas-filled bolted connection is subject to leak detection fluid testing. Addendum 1 Leakage Classification Severity, states, Gas leakage stream detectable by motion of a tell-tale as a severity level C; however, again there is no requirement to use a tell-tale at all air-filled or gas-filled bolted connections.
- The definition for a fluid, as cited in SEG-001, includes compressed gas systems, but not those at atmospheric pressure. It is possible that there are in-scope air-filled systems that are not normally pressurized.
Based on the available information, the staff concluded that the applicants plant-specific procedures do not include adequate guidance to detect loss of preload or loss of material for closure bolting associated with air-filled or gas-filled systems, or air-filled systems that are not normally pressurized. The staff will review future submittals in regard to this topic and document its evaluation in SER Section 3.0.3.2.5.
3.0 EXIT MEETING At the conclusion of the audit, an exit meeting was held on April 18, 2017, to summarize the review completed. No follow-up requests for additional information will be issued.
4.0 LIST LICENSEE STAFF THAT PARTICIPATED IN THE AUDIT Name Title Affiliation Mike Murray Manager of Regulatory Affairs STP Lance Sterling Supervisor of Regulatory Affairs STP Arden Aldridge Supervisor of Engineering Projects STP Rob Engen Manager of Engineering Projects STP Craig Younger Testing and Programs Supervisor STP Lyle Spiess Testing and Programs Supervisor STP Rafael Gonzales Licensing Staff Engineer STP Gary Warner License Renewal Support Worley Parsons Mike Garner Testing and Programs - STP Consulting Engineer