ML23219A140
| ML23219A140 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 10/10/2023 |
| From: | Shawn Williams Plant Licensing Branch II |
| To: | Snider S Duke Energy Carolinas |
| Williams S | |
| References | |
| EPID L-2022-LLR-0060 | |
| Download: ML23219A140 (1) | |
Text
October 10, 2023 Mr. Steven M. Snider Site Vice President, Oconee Nuclear Station Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672-0752
SUBJECT:
OCONEE NUCLEAR STATION, UNITS 1, 2 AND 3 - AUDIT REPORT RE: PROPOSED ALTERNATIVE TO USE ASME CODE CASE N-752 (EPID L-2022-LLR-0060)
Dear Mr. Snider:
By letter dated July 27, 2022, as supplemented by letter dated March 9, 2023, Duke Energy Carolinas, LLC (Duke Energy, the licensee) submitted a request to the U.S. Nuclear Regulatory Commission (NRC) to authorize a proposed alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components. Specifically, the licensee requested to use the alternative requirements of ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in Class 2 and 3 SystemsSection XI, Division 1, for determining the risk-informed categorization and implementing alternative treatment for repair/replacement activities on moderate-and high-energy Class 2 and 3 items in lieu of ASME Code Section XI, paragraphs IWA-1000, IWA-4000, and IWA 6000 requirements.
A clarification call was held on June 12, 2023, to ensure mutual understanding of a draft request for additional information contained in the Enclosure to this Audit Plan. As a result of the clarification call, Duke Energy suggested and the NRC agreed to conduct a regulatory audit to gain a better understanding of the issues identified in the Enclosure and to identify information that may require submittal on the docket for the NRC to complete its review of the proposed alternative.
From August 1 to October 10, 2023, NRC staff conducted a virtual audit. Audit teleconference calls were held on August 1, 8, 16 and September 20, 2023. An internet-based portal (Certrec),
provided by the licensee was used to review documents. The enclosure to this letter provides a report of the NRC staffs audit.
If you have any questions, please contact me by telephone at (301) 415-1009 or by e-mail at Shawn.Williams@nrc.gov.
Sincerely,
/RA/
Shawn A. Williams, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-269, 50-270, and 50-287
Enclosure:
Audit Report cc: Listserv
Enclosure REGULATORY AUDIT REPORT DUKE ENERGY CAROLINAS, LLC.
OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 ALTERNATIVE TO UTILIZE CODE CASE N-752 DOCKET NOS. 50-267, 50-270, AND 50-287
1.0 BACKGROUND
By letter dated July 27, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22208A031), as supplemented by letter dated March 9, 2023 (ML23068A015), Duke Energy Carolinas, LLC (Duke Energy, the licensee) submitted a licensing action request to authorize a proposed alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components. Specifically, the licensing action proposes to use the alternative requirements of ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 SystemsSection XI, Division 1, for determining the risk-informed categorization and implementing alternative treatment for repair/replacement activities on moderate-and high-energy Class 2 and 3 items in lieu of ASME Code Section XI, paragraphs IWA-1000, IWA-4000, and IWA-6000 requirements.
The NRC staff conducted the regulatory audit in accordance with the Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, Regulatory Audits (ML082900195).
2.0 SCOPE AND PURPOSE From August 1 to October 10, 2023, NRC staff conducted a virtual audit. The audit plan was issued on July 3, 2023 (ML23178A068). The purpose of the audit was to gain a better mutual understanding of the issues noted in the Enclosure (draft request for additional information (RAI))
to the Audit Plan and to identify information that may require docketing to support the basis of the NRC staffs licensing decision.
3.0 AUDIT TEAM The following NRC staff members participated in the audit:
Shawn Williams, NRR, Division of Operating Reactor Licensing (DORL)
Jigar Patel, NRR, Division of Risk Assessment (DRA)
Ching Ng, NRR, Division of Risk Assessment (DRA)
Jeff Circle, NRR, Division of Risk Assessment (DRA)
Jay Collins, NRR, Division of New and Renewed Licenses (DNRL)
John Honcharik, NRR, DNRL Thomas Scarbrough, NRR, Division of Engineering and External Hazards (DEX),
Mechanical Engineering and Inservice Testing Branch (EMIB) 4.0 AUDIT
SUMMARY
From August 1 to October 10, 2023, the NRC staff reviewed the documents that were placed on the Certrec Portal for the purpose of determining information needed to be submitted on the docket in a formal response for additional information.
4.1 Audit Call, August 1, 2023 Duke Energy presented the history of risk-informed inservice inspection and overview of the passive categorization methodology in Code Case N-752. In the afternoon session, Duke discussed how it proposes to address the issues in the NRCs draft RAI.
The presentation and draft RAI response discussed was provided to NRC staff via the Certrec Portal.
4.2 Audit Call, August 8, 2023 The NRC staff and licensee discussed the consequence evaluation process.
The licensee provided the following docketed references that include examples of the consequence evaluation process.
March 31, 1998, D. C. Mims (Entergy Operations, Inc.) to Document Control Desk (NRC),
requesting approval of a risk-informed alternative for examination of piping systems, letter submitting service water system evaluation dated March 31, 1998. (Package ML20217N838)
Request for Alternative ANO2-R&R-004, Revision 1 Response to NRC Request for Additional Information, dated August 6, 2007 (ML072220160).
4.3 Audit Call, August 16, 2023 NRC staff and Duke discussed information related to the Oconee specific submittal. The same presentations slides (ML23227A219) were used at the industry public meeting (ML23228A021) also on August 16, 2023.
4.4 Follow-up Audit Communication, August 22, 2023 Based on the audit call on August 16, and subsequent meeting with the industry later the same day, the licensee provided clarifying information in an August 22 e-mail regarding an example of a valve with an active high safety significant (HSS) function and passive LSS (low safety significant) function including aspects of quality and design processes (ML23269A041).
4.5 Audit Call, September 20, 2023 The NRC staff requested the following additional audit discussion:
In its submittal dated July 27, 2022, as supplemented by March 9, 2023, the licensee states that the use of ASME Code Case N-752 is requested with no exceptions or deviations. The NRC has not approved ASME Code Case N-752 generically. As discussed during the NRC audit and related discussions concerning possible information needs to make a regulatory decision, the NRC staff requests the licensee to clarify:
- 1. Whether its implementation of N-752 will be in accordance with the QA requirements of 10 CFR Part 50, Appendix B. As written, Footnote 1 of N-752-1 appears ambiguous and could be read to mean that a licensee may be exempt from Appendix B, which could require a separate regulatory action separate from 10 CFR 50.55a. If the NRC understanding is correct in that 10 CFR Part 50, Appendix B still applies, the NRC may issue a request for confirmation rather than a request for additional information.
- 2. What code/standard would apply for alternative treatment when implementing ASME Code Case N-752 for repair/replacement of passive components? The current provision in N-752 allows for broad application of "Owner's Requirements" in addressing repair/replacement and non-destructive examination activities in accordance with Section 5.2.E Paragraphs 4 through 9, and 16 of the licensees submittal. Some confirmation or clarification is needed regarding the applicable code/standard to evaluate uncertainty in the change in safety margins. For NRC to reach a finding of acceptable quality and safety, additional confirmation is needed regarding the applicable code/standard. An example of such codes/standards include the ASME Boiler and Pressure Vessel [BPV] Code, ASME B31.1, Power Piping Standard and/or ASME Post Construction Committee 2 (PCC-2) Repair of Pressure Equipment and Piping), which the NRC staff have found to be acceptable in similar application for repair/replacement and NDE [non-destructive examination] for passive components. The NRC recognizes that specifying the code/standard may be an exception/deviation from N-752, nevertheless, the staff may issue a request for confirmation that the code/standard in the analysis of record still applies or request for additional information to clarify if another code/standard is proposed.
The licensee provided a draft response on the Certec Portal. The NRC staff and licensee discussed the written response during the audit call on September 20, 2023.
4.6 Follow-up Audit Communication, September 26, 2023 Based the audit call on September 20, 2023, the licensee provided additional information in an e-mail dated September 26, 2023 (ML23270B836), concerning the use of Owner's Requirements and engineering judgment in lieu of Code and Standards. The licensees draft response was placed on the Certrec Portal.
5.0 DOCUMENTS AVAILABLE ON CERTREC PORTAL The following documents were available on the licensees Certrec on-line Portal:
5.1 Presentation Slides, August 1, 2023.
5.2 Draft Responses to the draft Request for Additional Information included as an enclosure to the July 3, 2023, Audit Plan(ML23178A068).
5.3 U.S. Nuclear Regulatory Commission, Arkansas Nuclear One, Units 1 and 2 - Approval of Request for Alternative from Certain Requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (EPID L-2020-LLR-0076),
dated May 19, 2021 (ML21118B039).
5.4 Letter from U.S. Nuclear Regulatory Commission to Vermont Yankee Nuclear Power Corporation, Request to Use Code Case N560 as an Alternative to the Requirements of ASME Code,Section XI, Table IWB-2500-1 at Vermont Yankee Nuclear Power Station (TAC No. M99389), dated November 9, 1998 (ML20195C403; enclosed Safety Evaluation at ML20195C416).
5.5 U.S. Nuclear Regulatory Commission Letter to Entergy Operations, Inc., Request to Use a Risk-Informed Alternative to the Requirements of ASME Code Section XI, Table IWX-2500 at Arkansas Nuclear One, Unit No. 2 (TAC No. M99756), dated December 29, 1998 (ML20198M762; enclosed Safety Evaluation at ML20198M784).
5.6 Letter from Dana A. Powers (Chairman, Advisory Committee on Reactor Safeguards) to Dr. William D. Travers (Executive Director for Operations, U.S. Nuclear Regulatory Commission), Safety Evaluation Report Related to Electric Power Research Institute Risk-Informed Methods to Inservice Inspection of Piping (EPRI TR-112657, Revision B, July 1999), dated September 15, 1999 (ML992650028).
5.7 Electric Power Research Institute (EPRI) TR-112657, Rev B-A Revised Risk-Informed Inservice Inspection Evaluation Procedure (PWRMRP-05), dated December 1999 (ML013470102).
o Including the NRC Safety Evaluation dated October 28, 1999. ML993190474 5.8 Letter from U.S. Nuclear Regulatory Commission to Southern Nuclear Operating Company, Inc., Vogtle Generating Electric Plant, Units 1 and 2 - Issuance of Amendments RE: Use of 10 CFR 50.69 (TAC Nos. ME9472 and ME9473), dated December 17, 2014 (ML14237A034).
5.9 U.S. Nuclear Regulatory Commission Letter to Tennessee Valley Authority, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Issuance of Amendment Nos. 317, 340, and 300 Regarding Adoption of Title 10 of the Code of Federal Regulations Section 50.69, Risk informed categorization and treatment of structures, systems, and components for nuclear power plants, dated July 27, 2021 (ML21173A177).
5.10 Federal Register, American Society of Mechanical Engineers 2019-2020 Code Editions, 87 FR 65128 (October 27, 2022) (Codified at 10 CFR 50.55a) 5.11 Southern Nuclear Operating Company Inc. Letter to U.S. Nuclear Regulatory Commission, Vogtle Electric Generating Plant - Unit 1 and Unit 2 Pilot 10 CFR 50.69 License Amendment Request Response to Request for Additional Information, dated May 2, 2014 (ML14122A364).
5.12 Westinghouse Non-Proprietary Class 3 Report WCAP-14572, Revision 1-NP-A, Westinghouse Owners Group Application of Risk-Informed Methods to Piping Inservice Inspection Topical Report, dated February 1999 (ML042610469).
5.13 European Commission Report prepared by The Nuclear Regulators Working Group Task Force on Risk-Informed Inservice Inspection, Report on the Regulatory Experience of Risk-Informed Inservice Inspection of Nuclear Power Plant Components, dated August 2004.
5.14 Report by Nuclear Energy Agency Committee on the Safety of Nuclear Installations (CSNI) Integrity and Ageing Working Group (IAGE), EC-JRC/OECD-NEA Benchmark Study on Risk Informed In Service Inspection Methodologies (RISMET), dated November 2010.
5.15 Tennessee Valley Authority Letter to the U.S. Nuclear Regulatory Commission, Browns Ferry Nuclear Plant (BFN) - Unit 3 - Request for Approval of the BFN American Society of Mechanical Engineers (ASME)Section XI Alternate Inservice Inspection Program -
Risk Informed Inservice Inspection (RI-ISI) and Cost Beneficial Licensing Action (CBLA) 99-01, dated April 23, 1999 (ML18039A754; enclosed ISI Program is at ML18039A756).
5.16 FirstEnergy Nuclear Operating Company Letter to the U.S. Nuclear Regulatory Commission, Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Risk-Informed Inservice Inspection Program Plans ISI (Inservice Inspection) Program Relief Request, dated July 24, 2002 (ML022060549).
5.17 U.S. Nuclear Regulatory Commission Letter to Energy Northwest, Columbia Generating Station - Issuance of Amendment No. 269 RE: License Amendment to Adopt 10 CFR 50.69, Risk-informed categorization and treatment of structures, systems, and components for nuclear power reactors (EPID L-2021-LLA-0207), dated December 15, 2022 (ML22308A096).
5.18 Dukes response to Additional Audit Questions that was discussed on September 20, 2023.
5.19 Title 10 of the Code of Federal Regulations (10 CFR) 50.69 - Statements of Considerations (69 FR 68008, dated November 22, 2004) 5.20 September 26, 2023, Dukes response to NRCs concern that was discussed on September 20, 2023, regarding the use of Owner's Requirements and engineering judgment in lieu of Code and Standards. Also, provided in a September 26, 2023, e-mail (ML23270B836).
6.0 CONCLUSION
The audit was closed on October 10, 2023. There were no regulatory decisions made during the audit. The NRC staff will identify information that may require docketing to support the basis of the NRC staffs licensing decision and issue a request for additional information, as needed.
Date: October 10, 2023
Table 1 NRC Audit - Attendees August 1 to October 10, 2023 Attendee Name Affiliation Shawn Williams NRC-NRR-DORL Michael Markley NRC-NRR-DORL Ed Miller NRC-NRR-DORL Bob Pascarelli NRC-NRR-DRA Jigar Patel NRC-NRR-DRA Ching Ng NRC-NRR-DRA Stephen Cumblidge NRC-NRR-DNRL Jay Collins NRC-NRR-DNRL John Honcharik NRC-NRR-DNRL Tom Scarbrough NRC-NRR-DEX Ryan Treadway Duke Energy Christopher Whitener Duke Energy Jordan Vaughn Duke Energy Jennifer Varnedoe Duke Energy Andrew Lipetzky Duke Energy Mark Pyne Duke Energy Josh Riley Duke Energy Robert Rishel Duke Energy Kaitlyn Sullivan Duke Energy Heather Szews Duke Energy Robert Isbell Duke Energy Joseph Renner Duke Energy Contractor (Jensen Hughes)
David Bidwell Duke Energy Contractor (Jensen Hughes)
Pat ORegan Electric Power Research Institute (EPRI)
ML23219A140 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DRA/APLA/BC NRR/
DNRL/NPHP/BC NAME SWilliams KGoldstein BPascarelli SCumblidge DATE 9/26/2023 09/26/2023 10/03/2023 10/05/2023 OFFICE DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME EdMiller for MMarkley SWilliams DATE 10/10/2023 10/10/2023