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EPID:L-2022-LLR-0060, Proposed Alternative to Use American Society of Mechanical Engineers (ASME) Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems. (Open) |
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MONTHYEARML22139A2302022-05-19019 May 2022 NRR E-mail Capture - Acceptance Review for Summer TS 4.6.2.1.d LAR (L-2022-LLR-0060) Project stage: Acceptance Review RA-22-0174, Proposed Alternative to Use American Society of Mechanical Engineers (ASME) Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems.2022-07-27027 July 2022 Proposed Alternative to Use American Society of Mechanical Engineers (ASME) Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems. Project stage: Request ML22235A6552022-08-23023 August 2022 Acceptance of Requested Licensing Action Proposed Alternative to Use ASME Code Case N-752 Project stage: Acceptance Review ML23038A1832023-02-0707 February 2023 Request for Additional Information Alternative Request (RA-22-0174) to Use ASME Code Case N-752 Project stage: RAI RA-23-0051, Response to Request for Additional Information (RAI) Regarding Proposed Alternative to Use American Society of Mechanical Engineers Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities2023-03-0909 March 2023 Response to Request for Additional Information (RAI) Regarding Proposed Alternative to Use American Society of Mechanical Engineers Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities Project stage: Response to RAI ML23125A1452023-05-0505 May 2023 Change in Estimated Review Schedule and Level of Effort for Proposed Alternative to Use Code Case N-752 Project stage: Other ML23178A0682023-07-0303 July 2023 Audit Plan Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 & 3 Systems Section XI, Division 1 Project stage: Other ML23269A0412023-08-22022 August 2023 Code Case N-752 Audit; August 22, 2023, E-mail Providing Additional Information Regarding Design and Quality Program Requirements Project stage: Other ML23270B8362023-09-26026 September 2023 Code Case N-752 Audit September 26, 2023, E-mail Providing Additional Information Regarding the Use of Owner'S Requirements and Engineering Judgment in Lieu of Code and Standards Project stage: Other ML23219A1402023-10-10010 October 2023 Audit Report Proposed Alternative to Use ASME Code Case N-752, Risk Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems XI, Division 1 Project stage: Other ML23284A3322023-10-11011 October 2023 Request for Additional Information Alternative Request (RA-22-0174) (L-2022-LLR-0060) Project stage: RAI ML23331A9212023-11-16016 November 2023 Public - Non-Concurrence of SE for Proposed Alternative RR-22-0174 for Oconee Nuclear Station, Units 1, 2, and 3 Duke Energy Carolinas, LLC Project stage: Request ML23262A9672023-12-13013 December 2023 Alternative to Use RR-22-0174, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems Section XI, Division 1 Project stage: Other 2023-12-13
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Category:Audit Plan
MONTHYEARML23269A0412023-08-22022 August 2023 Code Case N-752 Audit; August 22, 2023, E-mail Providing Additional Information Regarding Design and Quality Program Requirements ML23178A0682023-07-0303 July 2023 Audit Plan Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 & 3 Systems Section XI, Division 1 ML23075A0732023-04-0505 April 2023 License Renewal Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application Supplement (EPID Number L-2021-SLE-0002) ML22111A3142022-05-0202 May 2022 Limited Aging Management Audit Plan Regarding the Subsequent License Renewal Application Review ML21362A7532022-01-0606 January 2022 Regulatory Audit in Support of the License Amendment Request for One-Time Note to Technical Specification 3.7.7, Low Pressure Service Water (LPSW) System ML21263A0312021-09-21021 September 2021 License Renewal Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application ML21196A0762021-07-23023 July 2021 Aging Management Audit Plan Regarding the Subsequent License Renewal Application Review ML20036E3902020-02-11011 February 2020 Regulatory Audit in Support of Review of License Amendment Request to Revise the Licensing Basis for High Energy Line Breaks Outside of the Containment Building ML19037A0052019-02-0808 February 2019 Regulatory Audit in Support of Review of License Amendment Request No. 2018-02 ML18032A4612018-03-0505 March 2018 Regulatory Audit in Support of Review of License Amendment Request No. 2017-03 ML18004A0122018-01-0404 January 2018 Regulatory Audit in Support of Review of Proposed Alternative (CAC Nos. MF7365, MF7366 and MF7367; EPID No. L-2016-LLR-001) ML17202U7312017-07-25025 July 2017 Regulatory Audit in Support of License Amendment Request No. 2015-03 ML17177A4462017-07-0606 July 2017 Audit Plan for Licensee Responses Concerning Seismic Hazard Reevaluations Related to Request for Information -(50.54(F) Letter) Regarding Recommendation 2.1 of the Near-Term Task Force ML16259A1892016-12-0505 December 2016 Nuclear Regulatory Commission Plan for the Audit of Mitigation Strategies Assessment Submittals Related to Order EA-12-049, Order to Modify Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events ML15281A2932015-10-22022 October 2015 Plan for the Regulatory Audit Regarding License Amendment Request for Alternate Fission Gas Gap Release Fractions ML15226A1852015-09-0808 September 2015 Nuclear Regulatory Commission Plan for the Audit of Duke Energy Carolinas, LLC Interim Evaluations Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1 - Seismic ML15160A6642015-06-10010 June 2015 Plan for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Instrumentation Related to Orders EA-12-049 and EA-12-051 ML15118A4602015-05-0808 May 2015 Audit Plan for the Flood Hazard Reevaluation Report Submittal Relating to the Near-Term Task Force Recommendation 2.1 - Flooding ML14356A0032015-02-10010 February 2015 Audit of Licensee Responses to the Expedited Seismic Evaluation Process to Support Implementation of Near-Term Task Force Recommendation 2.1, Seismic ML14083A6202014-03-26026 March 2014 Nuclear Regulatory Commission Audits of Licensee Responses to Reliable Spent Fuel Pool Instrumentation Order EA-12-051 2023-08-22
[Table view] Category:E-Mail
MONTHYEARML23349A0272023-12-15015 December 2023 Acceptance of Requested Licensing Action License Amendment Request to Revise Technical Specification 5.5.2 ML23284A3322023-10-11011 October 2023 Request for Additional Information Alternative Request (RA-22-0174) (L-2022-LLR-0060) ML23270B8362023-09-26026 September 2023 Code Case N-752 Audit September 26, 2023, E-mail Providing Additional Information Regarding the Use of Owner'S Requirements and Engineering Judgment in Lieu of Code and Standards ML23267A0032023-09-21021 September 2023 RP Inspection Document Request ML23269A0412023-08-22022 August 2023 Code Case N-752 Audit; August 22, 2023, E-mail Providing Additional Information Regarding Design and Quality Program Requirements ML23172A0132023-06-20020 June 2023 Duke Fleet - Correction to June 2, 2023, Request for Additional Information Proposed License Amendment Request to Revise Restrictive Surveillance Requirement Frequencies ML23153A1892023-06-0202 June 2023 Duke Fleet - Request for Additional Information Proposed License Amendment Request to Revise Restrictive Surveillance Requirement Frequencies ML23151A3482023-05-30030 May 2023 Duke Fleet - Request for Additional Information Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) ML23144A0862023-05-24024 May 2023 Acceptance of Requested Licensing Action Proposed Relief Request (RA-23-0018) to Use ASME Code Case 853 ML23142A2732023-05-22022 May 2023 Duke Fleet - Request for Additional Information Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) ML23125A1452023-05-0505 May 2023 Change in Estimated Review Schedule and Level of Effort for Proposed Alternative to Use Code Case N-752 ML23124A1212023-05-0404 May 2023 Acceptance of Requested Licensing Action Duke Fleet Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) ML23095A0052023-04-0404 April 2023 002 Radiation Safety Baseline Inspection Information Request ML23086C0362023-03-27027 March 2023 Request for Additional Information Steam Generator Tube Inspection Report (03R31) ML23073A2282023-03-13013 March 2023 Duke Fleet- Adoption of TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements - Acceptance Review ML23058A0562023-02-27027 February 2023 Acceptance of Amendment to Revise Surveillance Frequencies for RCS Pressure Isolation Valve Operational Leakage Testing and Reactor Trip System Instrumentation ML23048A1512023-02-16016 February 2023 Acceptance Review - Proposed Alternative for Steam Generator Welds (L-2023-LLR-0003) ML23038A1832023-02-0707 February 2023 Request for Additional Information Alternative Request (RA-22-0174) to Use ASME Code Case N-752 ML23031A1552023-01-17017 January 2023 1/17/2023 Email from John Moses, Deputy Director, Division of Rulemaking, Environmental, and Financial Support, to Diane Curran, Counsel to Beyond Nuclear and the Sierra Club, Request for Extension of Scoping Comment Period for Oconee EIS ML22294A0812022-10-21021 October 2022 Nrc/Duke Steam Generator Inspection Call for November 8, 2022 NRC-2100-2022, EN 55999 Valcor Coil Shell Assemblies Final Notification (004)2022-09-12012 September 2022 EN 55999 Valcor Coil Shell Assemblies Final Notification (004) ML22251A2902022-09-0808 September 2022 Request for Additional Information Additional Mode Change Limitations Applicable to the Adoption of Technical Specifications Tasks Force Traveler (TSTF) No. 359, Revision 9 ML22235A6552022-08-23023 August 2022 Acceptance of Requested Licensing Action Proposed Alternative to Use ASME Code Case N-752 NRC 2110-2022, EN 55999 - Valcor Engineering Corporation (009)2022-07-18018 July 2022 EN 55999 - Valcor Engineering Corporation (009) ML22234A1262022-07-0808 July 2022 Email from NRC to Duke - Feedback on Trp 76 RAI Responses - July 8, 2022 ML22234A1272022-06-14014 June 2022 Email from NRC to Duke - Feedback on Trp 76 RAI Responses - June 14, 2022 ML22154A2142022-06-0101 June 2022 Email from NRC (Angela Wu) to Duke (Paul Guill) - Oconee SLRA - 2nd Round RAI B2.1.7-4b ML22157A0012022-06-0101 June 2022 Email from NRC (Angela Wu) to Duke (Paul Guill) - Oconee SLRA - Additional NRC Comments on RAI 4.6.1-1a ML22124A2052022-05-0404 May 2022 Summary of May 4, 2022, Clarification Call with Duke Energy Carolinas, LLC, Application to Revise TS 3.7.7, Low Pressure Service Water (LPSW) System ML22124A1612022-05-0303 May 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - 2nd Round RAI B2.1.7-4a ML22122A0192022-04-28028 April 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - 2nd Round RAI B2.1.9-2a ML22122A1322022-04-27027 April 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - 2nd Round Requests for Additional Information (FE 3.5.2.2.2.6 - Irradiation Structural) ML22115A1412022-04-25025 April 2022 NRR E-mail Capture - Duke Common EOF Relocation - Request for Addition Information ML22130A0112022-04-25025 April 2022 Email: Oconee SLRA - RAI 4.6.1-1a - NRC Staff Comments ML22112A1892022-04-22022 April 2022 Acceptance Review for Additional Mode Change Limitations Applicable to the Adoption of TSTF- 359, Revision 9 ML22112A0072022-04-20020 April 2022 Email from Marieliz Johnson (NRC) to Steve Snider (Duke) - Oconee SLRA - Request for Confirmation of Information 3.5.2.2.2.6-L ML22113A0082022-04-20020 April 2022 Email from Marieliz Johnson (NRC) to Steve Snider (Duke) - Oconee SLRA - Request for Additional Information 3.1.2-1 ML22088A0452022-03-28028 March 2022 Radiation Safety Baseline Inspection Initial Information Request Inspection Report 2022002 ML22081A0052022-03-21021 March 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - 2nd Round RAI B4.1-3 ML22080A0792022-03-16016 March 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - Requests for Additional Information - Set 4 (2nd Round Rais) ML22075A2032022-03-11011 March 2022 Email from Duke to NRC - Follow-Up Items from March 7, 2022 Public Meeting ML22074A0022022-03-11011 March 2022 Email from Duke to NRC - Follow-up Item from March 7, 2022 Public Meeting - SSW Tendon AMP ML22069A0022022-03-0808 March 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - Requests for Confirmation of Information - Set 4 ML22063A4502022-03-0404 March 2022 Request for Additional Information Application to Revise TS 3.7.7, Low Pressure Service Water (LPSW) System, to Extend the Completion Time for One Required Inoperable LPSW Pump ML22063A1152022-02-23023 February 2022 Email from Duke to NRC - Follow Up Item from February 17, 2022 Public Meeting ML22038A1572022-02-0707 February 2022 NRR E-mail Capture - Duke Energy Fleet - Acceptance of License Amendment Request Regarding Adoption of TSTF-541, Revision 2 ML22035A1892022-01-31031 January 2022 Email from NRC (Angela Wu) to Duke (Paul Guill) - Oconee SLRA - Request for Public Meeting ML22018A0272022-01-18018 January 2022 2022 All RFI Responses - Exercise and Program Inspections - Revl ML22019A1032022-01-18018 January 2022 Email from Angela Wu (NRC) to Steve Snider (Duke) - Oconee SLRA - Requests for Additional Information - Set 3 ML22012A0432022-01-11011 January 2022 SLRA - Requests for Additional Information - Set 2 2023-09-26
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From: Vaughan, Jordan L To: Shawn Williams Cc: Treadway, Ryan I
Subject:
[External_Sender] N-752 Additional Information Date: Tuesday, August 22, 2023 5:09:22 PM Attachments: Material Change Example.docx
- Shawn, Could you please pass the attached document along to the NRC staff reviewing the Oconee N-752 proposed alternative. Based on some of the discussion in last weeks audit and public meeting, we wanted to provide a bit more information focused on the valve bonnet example and highlighting other aspects of quality and design processes that may help the staff in their ongoing discussions.
Please let me know if the staff would like additional information or discussion on anything in the attachment.
Also, if possible, Duke would greatly appreciate this attachment also going to NRR leadership involved with the decision-making on Oconee N-752.
- Thanks, Jordan
During our audit and public meeting discussions, the staff repeatedly expressed concerns about the possible interaction effects if a valve with an active HSS function and passive LSS function were to have the bonnet replaced using the allowances of ASME Code Case N-752. An example as suggested by NRC staff of these potential interaction effects, would be if the valve bonnet were made of a different or lower quality material and had different thermal expansion properties such that the bonnet would interact with the moving parts of the valve (HSS function).
The code case specifically states:
Section 1420, item c: Changes in configuration, design, materials, fabrication, examination, and pressure-testing requirements used in the repair/replacement activity shall be evaluated, as applicable, to ensure the structural integrity and leak tightness of the system are sufficient to support the design bases functional requirements of the system.
This requirement from the case is saying, for the example above (different bonnet material) that the licensee would evaluate the change in material to ensure the pressure boundary function would continue to support the design basis functional requirements of the system - aka the bonnet would retain the fluid and not allow the bonnet to impede the active function of the valve.
While the Relief Request implementation relaxes ASME Section XI and Quality Program Requirements, it does not alleviate Design Control process requirements. The Design Control program at Duke Energy requires various levels of engineering evaluation based on the change implemented and whether that change is within the Bounding Technical Requirements, including evaluation of the changes per 10 CFR 50.59. For example, the 10CFR50.59 change control process does not allow changes if they:
(v) Create a possibility for an accident of a different type than any previously evaluated in the final safety analysis report; (vi) Create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the final safety analysis report; Changes, such as changing the bonnet material, would be evaluated in the Duke Energy Design Control Process. The Duke Energy procurement process also requires Engineering to specify treatment (design, fabrication, testing, documentation, receipt, etc.) of the LSS SSCs to ensure reasonable confidence is maintained.
Further, as noted in ASME Code Case N-752 Section 1420 the licensee has numerous requirements to fulfill to ensure the alternate treatment is appropriate. These additional controls ensure continued capability and reliability of the design-basis function. Further, any conditions that may prevent an LSS SSC from performing its safety-related function under design-basis conditions will be identified and addressed in accordance with the licensees corrective action program (as discussed in Oconee Round 1 RAIs). In the example above, the valve bonnet must perform the pressure boundary function and must allow the active items of the valve to perform their function. Controls are established to ensure both of these functions are addressed for changes to the plant (via design control) and identification/resolution of undesirable conditions (via the corrective action program).
The licensee must continue to implement all special treatments applied to active components (e.g. In-Service Testing) and other special treatments to the pressure boundary components that are not
affected by this code case (e.g. In-Service Inspection, License Renewal Aging Management, Flow Accelerated Corrosion, Erosion, Raw Water Program, Buried Pipe Program). For a valve there are extensive tests and design calculations that would explicitly test for degradation via robust testing and the design calculations also would explicitly look for such material property changes.
This relief request does not change the Oconee Technical Specifications and all Surveillance Requirements will continue to be performed with the specified Frequencies. Oconee SR 3.0.1 governs and provides usage rules for all Surveillance Requirements.
As noted in Oconees Relief Request and Round 1 RAIs, Duke Energy intends to implement the QA Program exemption applicable to IWA-1400(n) and IWA-4000 when performing repair/replacement activities on LSS items. In accordance with 10 CFR 50.54(a), licensees may make changes to a previously accepted quality assurance program description provided the bases of the approval are applicable to the licensees facility. Duke Energy does not intend to deviate from the QAPD wording in the NRC Safety Evaluation for ANOs QAPD Reduction in Commitment utilized to implement ASME Code Case N-752.
The NRCs review of the ANO QAPD changes to implement ASME N-752 states [bolding added for emphasis]:
The NRC staff reviewed the licensees application, as supplemented, for the proposed change to the QAPM to allow the use of ASME Code Case N-752. The NRC staff has reasonable assurance that the licensees implementation of ASME Code Case N-752 will ensure that Class 2 and 3 LSS SSCs will perform their intended safety-related functions under design-basis conditions. This reasonable assurance is based on the licensees plans to continue using current processes and procedures, as supplemented, for the treatment of Class 2 and 3 LSS SSCs. In addition, when procuring Class 2 and 3 LSS SSC items, the licensee will specify supplemental procurement requirements and implement additional controls to ensure continued capability and reliability of the design-basis function. Therefore, the NRC staff concludes that the proposed Entergy QAPM change continues to provide an acceptable level of quality and safety.
In order to implement the same change to the Oconee QAPD without prior NRC approval, via the process outlined in 10 CFR 50.54a, Duke Energy must demonstrate the bases for the NRCs QAPD approval at ANO is applicable to Duke Energy. Meaning - the same QAPD changes the NRC found to provide an acceptable level of quality and safety for ANO will also be implemented at Duke Energy (Oconee specifically).