ML23284A332

Request for Additional Information Alternative Request (RA-22-0174) (L-2022-LLR-0060)

ML23284A332
Person / Time
Site:	Oconee
Issue date:	10/11/2023
From:	Shawn Williams Plant Licensing Branch II
To:	Treadway R Duke Energy Carolinas
Williams S
References
EPID L-2022-LLR-0060
Download: ML23284A332 (4)

Text

From: Shawn Williams To: Treadway, Ryan I Cc: Vaughan, Jordan L

Subject:

Oconee Nuclear Station, Units 1, 2, and 3 - Second Round Request for Additional Information RE: Alternative Request (RA-22-0174) (L-2022-LLR-0060)

Date: Wednesday, October 11, 2023 7:39:14 AM Attachments: Oconee CC N-752 RAIs.docx

Dear Mr. Treadway,

By letter dated July 27, 2022, as supplemented by letter dated March 9, 2023, Duke Energy Carolinas, LLC, (Duke Energy) submitted an alternative request for Oconee Nuclear Station, Units 1, 2, and 3. Duke Energy is requesting to use the alternative requirements of American Society of Mechanical Engineers (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 for implementing alternative treatment for repair/replacement activities on moderate and high energy Class 2 and 3 items in lieu of certain ASME Code Section XI, paragraph IWA-1000, IWA-4000, and IWA-6000 requirements.

Duke Energy submitted the request pursuant to Section 50.55a(z) (1) of Title 10 of the Code of Federal Regulations, which requires the applicant to demonstrate that the proposed alternative would provide an acceptable level of quality and safety.

From August 1 to October 10, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a virtual audit to support its review of the alternative. The audit plan was issued on July 3, 2023 (ML23178A068). The purpose of the audit was for NRC staff to gain a better understanding of the issues identified in the draft request for additional information (RAI) in the Enclosure to the Audit Plan and to identify information that may require docketing to support the basis of the NRC staffs licensing decision.

Based on the audit, the NRC staff has determined that additional information is needed as discussed in the enclosure.

Please respond within 30 days of the date of this e-mail.

If you have any questions, please contact me at 301-415-1009 or via e-mail at Shawn.Williams@nrc.gov.

Sincerely, 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:

Request for Additional Information

cc w/encl: Listserv REQUEST FOR ADDITIONAL INFORMATION ALTERNATIVE REQUEST (RA-22-0174)

OCONEE NUCLEAR STATION UNITS 1, 2 AND 3 DUKE ENERGY CAROLINAS, LLC DOCKET NOS. 50-269, 50-270 AND 50-287

Dear Mr. Snider:

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, (Code Case N-752) for determining the risk-informed categorization and implementing alternative treatment for repair/replacement activities on moderate- and high-energy Class 2 and 3 items instead of ASME Code Section XI, paragraphs IWA-1000, IWA-4000, and IWA-6000 requirements.

From August 1 to October 10, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a virtual audit to support its review of the alternative. The audit plan was issued on July 3, 2023 (ML23178A068). The purpose of the audit was for NRC staff to gain a better understanding of the issues identified in the draft request for additional information (RAI) in the Enclosure to the Audit Plan and to identify information that may require docketing to support the basis of the NRC staffs licensing decision. Duke Energy established a Web-based portal (portal) to add documents needed to support audit discussions.

Based on the audit, the NRC staff has determined that additional information is needed.

RAI No. 1 Please provide the information presented during the audit that addressed the draft RAI No. 1 included as an Enclosure to the audit plan. The information related to this RAI was discussed during an audit call on August 1, 2023, and provided on the portal.

RAI No. 2 Please provide the information presented during the audit about the example of the possible interaction effects if a valve with an active high safety-significant function and passive low safety significant function were to have the bonnet replaced using the allowances of Code Case N-752. Please address aspects of quality and design processes. The information related to this RAI was discussed during the August 16, 2023, audit call, and provided via e-mail dated August 22, 2023 (ML23269A041).

Enclosure

RAI No. 3 Code Case N-752 allows for broad application of codes and standards, as well as Owner's Requirements in addressing repair/replacement and non-destructive examination activities in accordance with Section 5.2.E of the licensees proposed alternative.

Please provide the information presented during the audit as it relates to the use of Owners Requirements to meet an acceptable level of quality and safety under 10 CFR 50.55a(z)(1) for the proposed alternative. The information related to this RAI was discussed during the September 20, 2023, audit call, and provided in an e-mail dated September 26, 2023 (ML23270B836).