ML23277A277

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Regulatory Audit Summary Concerning Review of Request Number CI3R-01 for Proposed Alternative Inspection Frequency for Containment Unbonded Post Tensioning System Components
ML23277A277
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 10/11/2023
From: Samson Lee
Plant Licensing Branch IV
To: Reasoner C
Wolf Creek
Lee S, 301-415-3168
References
EPID L-2023-LLR-0026
Download: ML23277A277 (1)


Text

October 11, 2023 Mr. Cleveland Reasoner Chief Executive Officer and Chief Nuclear Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION, UNIT 1 - REGULATORY AUDIT

SUMMARY

CONCERNING REVIEW OF REQUEST NUMBER CI3R-01 FOR PROPOSED ALTERNATIVE INSPECTION FREQUENCY FOR CONTAINMENT UNBONDED POST-TENSIONING SYSTEM COMPONENTS (EPID L-2023-LLR-0026)

Dear Mr. Reasoner:

By letter dated May 17, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23137A328), Wolf Creek Nuclear Operating Corporation (the licensee) submitted a relief request for the third 10-year interval of the Containment Inservice Inspection Program at Wolf Creek Generating Station, Unit 1. The proposed alternative is to change inspection frequency from 5 to 10 years for the concrete containment unbonded post-tensioning system from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, subsection IWL-2420(a).

To support its review of the alternative request, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a regulatory audit via the use of an online reference portal set up by the licensee. The NRC staff reviewed surveillance reports and analyses supporting the licensees alternative request. The audit summary is enclosed.

C. Reasoner If you have any questions, please contact me at (301) 415-3168 or by email to Samson.Lee@nrc.gov.

Sincerely,

/RA/

Samson S. Lee, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-482

Enclosure:

Audit Summary cc: Listserv

REGULATORY AUDIT

SUMMARY

CONCERNING REVIEW OF REQUEST FOR ALTERNATIVE CI3R-01 REGARDING CONTAINMENT INSERVICE INSPECTION FREQUENCY WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION, UNIT 1 DOCKET NO. 50-482

1.0 BACKGROUND

By letter dated May 17, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23137A328), Wolf Creek Nuclear Operating Corporation (WCNOC, the licensee) submitted a relief request for the third 10-year interval of the Containment Inservice Inspection Program at Wolf Creek Generating Station, Unit 1 (Wolf Creek). The proposed alternative is to change the inspection frequency from 5 to 10 years for the concrete containment unbonded post-tensioning system from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code),Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, subsection IWL-2420(a).

Per the ASME Code, the periodic visual examination and physical testing of containment building concrete are required in accordance with table IWL-2500-1 L-A, as well as physical testing of unbonded post-tensioning systems in accordance with table IWL-2500-1 L-B.

The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the licensees alternative request and determined that a regulatory audit would assist in the timely completion of the licensing review process. The audit was conducted in accordance with the audit plan dated June 26, 2023 (ML23167A004).

2.0 AUDIT DATES AND LOCATION The regulatory audit was conducted via an internet portal established by the licensee from June 26, 2023, through August 28, 2023.

3.0 AUDIT ACTIVITIES The purpose of the audit was for the NRC staff to examine the licensees non-docketed information with the intent to gain a better understanding of the alternative request, to verify information, and to identify information that may require docketing to support the basis of the NRC staffs licensing decision. The audit activities conducted by the NRC staff included a review of surveillance and evaluation reports supporting the licensees proposed alternative request.

The audit team had clarification calls on August 9, 2023, and August 17, 2023, with the licensee during the audit period.

Enclosure

The licensee provided the following supporting calculations and evaluations for the NRC staff review via the online reference portal:

Document No. REP-1167-510, Final Report for the 35th Year Tendon Surveillance at Wolf Creek Generating Station, Revision 0, November 18, 2020 Document No. REP-1119-510, Final Report for the 30th Year Tendon Surveillance at Wolf Creek Generating Station, Revision 0, December 9, 2015 Wolf Creek Generating Station 7th Period - 25th Year Building Tendon Surveillance, Revision 2, August 16, 2010 Twentieth Year Surveillance Report of the of the Post-Tensioning System at the Wolf Creek Generating Station, Revision 0, November 30, 2005 Engineering Disposition: 20th year Post Tensioning Surveillance, Rev 0, July 20, 2005

[Change Package #: 011852]

Fifteenth Year Physical Tendon Surveillance of the Containment Building at the Wolf Creek Nuclear Plant, Revision 0, May 8, 2001 Tenth Year Physical Surveillance of the Wolf Creek Unit 1 Containment Building Post-Tensioning Surveillance Report, Revision 0, February 6, 1995 WR No. 3663-94, Work Request for Tendon No. V39 System Z2, July 01, 1994 Fifth Year Physical Surveillance of the Wolf Creek Unit 1 Containment Building Post-Tensioning Surveillance Report, Revision 0, May 14, 1993 Grease Leakage Examination Results, July 2002 to December 2021 Summary of Surveillance Results Containment Inservice Inspection (CISI) Program Plan - Wolf Creek Generating Station, Interval 3, Revision 5, March 6, 2023 RAI (licensees tracking notation for NRC staffs audit questions) 1.1 Response (Response to corrosion and spalling near anchor plates)

RAI 2 Writeup (Response to corrosion protection medium (CPM) test results not meeting criteria) o Lab Analysis Data (CPM test results summary for year 5 to year 35 surveillance)

RAI 3 Response (Response to non-conformance report (NCR) requests for multiple broken or missing wires) o NCR FN1054-001 o NCR FN 1054-002 o CCP 15006 Evaluation for 40AB - Visual Inspection Nonconformance for Reactor Building Tendon 40AB

o CCP 13427 Evaluation for V7 and V65 - Engineering Disposition: Broken Wires in Containment Tendons V7 and V65 RAI 4 Response (CPM volume installed vs removed not within criteria) o CCP 11852 - Engineering Disposition: 20th Year Post Tensioning Surveillance o CCP 05222 - Change Package & Engineering Disposition: 10th Year o WR 0489 Work Request Evaluation for 3rd Year o WR 05163 Work Request Evaluation for 3rd Year RAI 5 Response (Level 3 Corrosion and cracks greater than 0.01 inch) o 05-274942-001 - Level 3 Corrosion Evaluation o NCR N919F-003 - Level 3 Corrosion o RAI 5 Write Up 4.0 RESULTS OF THE AUDIT During the audit, the NRC staff did not make any regulatory decisions regarding the alternative request under the NRC staff review. At the conclusion of the audit, the NRC staff informed the licensee that it would not be issuing a request for additional information following the completion of its review of the audit portal information. The NRC staff noted that the audit facilitated the NRC staffs timely review of the request.

5.0 AUDIT PARTICIPANTS NRC Participants from the Office of Nuclear Reactor Regulation George Wang, Division of Engineering and External Hazards (DEX), Structural, Civil, and Geotechnical Branch (ESEB)

Shaohua Lai, DEX, ESEB Samson Lee, Division of Operating Reactor Licensing, Plant Licensing Branch IV Licensee Participants Robert Kelley, ASME Section XI/IWL Responsible Engineer Jeffrey Wilson, Engineering Programs Manager Nathan Lee, Licensing Engineer Dustin Hamman, Director of Nuclear and Regulatory Affairs 6.0 EXIT BRIEFING On August 28, 2023, Samson Lee of the NRC staff informed Nathan Lee of WCNOC, via telephone, that the NRC staff did not need to review any additional calculations or evaluations and, accordingly, the audit was concluded.

ML23277A277 *by email OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DEX/ESEB/BC*

NAME SLee PBlechman ITseng DATE 10/4/2023 10/5/2023 10/3/2023 OFFICE NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*

NAME JDixon-Herrity SLee DATE 10/11/2023 10/11/2023