ML23115A070
| ML23115A070 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/24/2023 |
| From: | Dennis Galvin NRC/NRR/DORL/LPL4 |
| To: | Brost W South Texas |
| References | |
| L-2023-LLR-0004 | |
| Download: ML23115A070 (5) | |
Text
From:
Dennis Galvin Sent:
Monday, April 24, 2023 6:07 PM To:
Wendy Brost (webrost@stpegs.com)
Cc:
Dibbern, Zachary
Subject:
South Texas Project Units 1 and 2 - Audit Plan - Proposed Alternative to ASME Code,Section XI Requirements for Containment Building Inspections (EPID L-2023-LLR-0004)
Attachments:
STP RR-ENG-4-06 Tendon Inspection Audit Plan Issued 2023-04-24.pdf
Dear Ms. Brost,
By letter dated February 1, 2023 (ADAMS Accession No. ML23032A484), as supplemented by letter dated March 9, 2023 (ML23068A364), STP Nuclear Operating Company (STPNOC, the licensee) submitted a proposed alternative to the Subsection IWL of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components, regarding the frequency of certain Containment Unbonded Post-Tensioning System Inservice Inspection at South Texas Project (STP) Units 1 and 2.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined that a regulatory audit would support its review of the proposed alternative. The audit will be conducted via online access to non-docketed information set up by the licensee and via webinar as described in the attached audit plan. The licensee is requested to provide online access to specific NRC staff and to be read-only (i.e., to establish measures to prevent the downloading, copying, printing, or otherwise storing of any documents). The audit information the NRC staff determines to be necessary to support the development of the NRC staffs safety evaluation will be requested to be submitted on the docket following the audit.
If you have any questions, please contact me at (301) 415-6256.
Respectfully, Dennis Galvin Project Manager U.S Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Operating Reactor Licensing Licensing Project Branch 4 301-415-6256 Docket No. 50-498, 50-499
Hearing Identifier:
NRR_DRMA Email Number:
2048 Mail Envelope Properties (SA1PR09MB8111331B1EF159FD0AC5FA50FB679)
Subject:
South Texas Project Units 1 and 2 - Audit Plan - Proposed Alternative to ASME Code,Section XI Requirements for Containment Building Inspections (EPID L-2023-LLR-0004)
Sent Date:
4/24/2023 6:06:30 PM Received Date:
4/24/2023 6:06:00 PM From:
Dennis Galvin Created By:
Dennis.Galvin@nrc.gov Recipients:
"Dibbern, Zachary" <zedibbern@STPEGS.COM>
Tracking Status: None "Wendy Brost (webrost@stpegs.com)" <webrost@stpegs.com>
Tracking Status: None Post Office:
SA1PR09MB8111.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1597 4/24/2023 6:06:00 PM STP RR-ENG-4-06 Tendon Inspection Audit Plan Issued 2023-04-24.pdf 318219 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Enclosure AUDIT PLAN PROPOSED ALTERNATIVE TO ASME CODE, SECTION XI REQUIREMENTS FOR CONTAINMENT BUILDING INSPECTIONS STP NUCLEAR OPERATING COMPANY SOUTH TEXAS PROJECT, UNITS 1 AND 2 DOCKET NOS. 50498 AND 50499
1.0 BACKGROUND
By letter dated February 1, 2023 (ADAMS Accession No. ML23032A484), as supplemented by letter dated March 9, 2023 (ML23068A364), STP Nuclear Operating Company (STPNOC, the licensee) submitted a proposed alternative to the Subsection IWL of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components, regarding the frequency of certain Containment Unbonded Post-Tensioning System Inservice Inspection at South Texas Project (STP) Units 1 and 2.
The U.S. Nuclear Regulatory Commission (NRC) staff has determined the need for a regulatory audit to be conducted in accordance with the Office of Nuclear Reactor Regulation Office Instruction LIC-111, Revision 1, Regulatory Audits (ADAMS Accession No. ML19226A274), for the NRC staff to examine the licensees non-docketed information.
2.0 REGULATORY AUDIT BASES The NRC staff (i.e., audit team) will perform the audit to support its evaluation of whether the licensees request provides plant-specific examination results on STP, Units 1 and 2, as a basis for the proposed deviations from the ASME Section XI, Subsection IWL requirements.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The audit team will review the licensees tendon surveillance reports, calculations, and analyses supporting the proposed alternative. The audit team will use this review to gain a better understanding of the alternative request, to verify information, and to determine if the licensee needs to submit any additional information on the docket in support of the requested changes in order to support conclusions for the NRC staffs safety evaluation.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff requests that the licensee has the following information readily available and accessible for the NRC staffs review via an internet-based portal:
- 1.
10th, 15th, 20th, 25th, and 30th year detailed inspection reports for the general visual examinations of containment concrete components, and the detailed visual examinations of suspect areas, as required by Table IWL25001(LA)
Examination Category L-A, Concrete, at STP Units 1 and 2.
- 2.
10th, 15th, 20th, 25th, and 30th year detailed reports for the Containment building tendon surveillance, as required by Table IWL25001(LB) Examination Category L-B, Unbounded Post-Tensioning System, at STP Units 1 and 2, including but not limited to the following:
- a. Tendon force trends & forecasts, elongation measurements, and the minimum required tendon forces;
- b. Tendon wire sampling and testing results, and their evaluations against the acceptance criteria;
- c. Visual examination results on the anchorage hardware and surrounding concrete, and their evaluations, and conclusions;
- d. Corrosion protection medium testing results, their evaluations, and conclusions;
- e. Free water testing results, their evaluations, and conclusions.
- 3.
Applicable calculations for supporting the Containment building tendon surveillance and for the acceptability of tendon/wires by the responsible engineer.
Based on the review of the above documents, the NRC staff will determine whether it needs to request any additional documents to be made available on the portal or whether additional information needs to be submitted on the docket for the staff to complete the review of the requested changes.
5.0 AUDIT TEAM The members of the audit team are:
Dennis Galvin, Project Manager, NRC (Dennis.Galvin@nrc.gov)
George Wang, Structural Engineer, NRC (George.Wang@nrc.gov) 6.0 LOGISTICS The audit will be conducted from May 1 through July 31, 2023, through an online portal (also known as electronic portal, ePortal, or electronic reading room) established by STPNOC.
If requested, the audit team will conduct a webinar with the licensee for the purposes of introducing the team, discussing the scope of the audit, and describing the information to be made available on the internet portal. The audit team expects to request that the licensee answer audit team questions during the audit related to information provided online at a mutually agreeable day and time by webinar. An exit discussion will be held at the conclusion of the audit.
7.0 SPECIAL REQUESTS The NRC staff would like online access to the documents listed above in Section 4.0 that allows the NRC staff to access documents remotely. Additional documents may be identified as the review progresses.
Online access to documents is to be limited to specific NRC staff (e.g., based on NRC staff email addresses or the use of passwords which will only be assigned to NRC staff directly involved in the audit on a need-toknow basis), and to be read-only (i.e., establish measures to prevent the downloading, copying, printing, or otherwise storing of any documents). The conditions associated with the online access of documents must be maintained throughout the review process. The NRC staff who should be granted access to the portal are those listed in the Audit Team section. All other communications should be coordinated with the NRC project manager.
8.0 DELIVERABLES An audit summary will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue requests for additional information to the licensee after the completion of the audit.