ML24276A098
| ML24276A098 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/02/2024 |
| From: | Vaughn Thomas NRC/NRR/DNRL/NLRP |
| To: | Vistra Operations Company |
| References | |
| Download: ML24276A098 (1) | |
Text
1 REQUEST FOR COMFIRMATORY INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PERRY UNIT 1 LICENSE RENEWAL APPLICATION REVIEW (SAFETY)
ENERGY HARBOR NUCLEAR GENERATION LLC PERRY, UNIT 1 DOCKET NO. 05000440 ISSUE DATE: 10/02/2024 ESEB RCI-10331-R1 Regulatory Basis Part 54 of Title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants, is designed to elicit application information that will enable the NRC staff to perform an adequate safety review and the Commission to make the necessary findings. Reliability of application information is important and advanced by requirements that license applications be submitted in writing under oath or affirmation and that information provided to the NRC by a license renewal applicant or required to be maintained by NRC regulations be complete and accurate in all material respects. Information that must be submitted in writing under oath or affirmation includes the technical information required under 10 CFR 54.21(a) related to assessment of the aging effects on structures, systems, and components subject to an aging management review. Thus, both the general submission requirements for license renewal applications and the specific technical application information requirements require that submission of information material to NRCs safety findings (see 10 CFR 54.29 standards for issuance of a renewed license) be submitted by an applicant as part of the application.
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Background===
LRA Section B.2.43, as modified by LRA Supplement 3 (ML24206A150), provides new enhancement to the scope of program program element to inspect accessible areas of concrete for the signs of alkali silica reaction (ASR), etc. which belongs to the parameters monitored or inspected program element.
LRA Section B.2.43, as modified by LRA Supplement 3 (ML24206A150), provides an enhancement to the parameters monitored or inspected, program element to require (a) evaluation of the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to such inaccessible areas and (b) examination of representative samples of the exposed portions of the below grade concrete, when excavated for any reason. If normally inaccessible areas become accessible due to planned activities, an inspection of these areas shall be conducted. GALL-LR XI.S6 AMP categorizes this as the detection of aging effects, program element.
Question 1 Confirm that the program element for this enhancement related to ASR can be changed to the parameters monitored or inspected, program element.
2 Question 2 Confirm that the program element in the enhancement, including items (a) and (b), can be changed to the detection of aging effects, program element.
NCSG RCI-10338-R1 Regulatory Basis Part 54 of Title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants, is designed to elicit application information that will enable the NRC staff to perform an adequate safety review and the Commission to make the necessary findings. Reliability of application information is important and advanced by requirements that license applications be submitted in writing under oath or affirmation and that information provided to the NRC by a license renewal applicant or required to be maintained by NRC regulations be complete and accurate in all material respects. Information that must be submitted in writing under oath or affirmation includes the technical information required under 10 CFR 54.21(a) related to assessment of the aging effects on structures, systems, and components subject to an aging management review. Thus, both the general submission requirements for license renewal applications and the specific technical application information requirements require that submission of information material to NRCs safety findings (see 10 CFR 54.29 standards for issuance of a renewed license) be submitted by an applicant as part of the application.
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Background===
As supplemented by letter dated July 24, 2024 (License Renewal Application (LRA) Supplement 3, ML24206A150), LRA Tables 3.5.2-1 and 3.5.2-4 include several component types with intended functions (i.e., support for regulated events Criterion (a)(3) equipment, enclosure, flood barrier, structural pressure boundary, and support for non-safety affecting safety Criterion (a)(2) equipment), in addition to the fire barrier intended function, where only the Fire Protection program is credited to manage the effects of aging. The component types include unimpregnated fiberglass fabric; fiberglass fabric impregnated with elastomer drywell mechanical penetration (fiberglass fabric), fiberglass/alumina silicate/calcium silicate/mineral fiber drywell mechanical penetration (fiberglass), pyrocrete fire proofing, 3M Interam fire wrap and radiant energy shield, fiberglass/alumina silicate/calcium silicate/mineral fiber fire wrap, fiberglass/alumina silicate/calcium silicate/mineral fiber penetration sealant (fire), unimpregnated fiberglass fabric; fiberglass fabric impregnated with elastomer penetration sealant (fire), and unimpregnated fiberglass fabric; fiberglass fabric impregnated with elastomer safety relief valve (SRV) tailpipe penetration boot seals.
Issue During the audit of the Fire Protection AMP, it was discussed whether the Structures Monitoring program should be cited to manage the effects of aging of elastomer fire stops and elastomer penetration sealant (fire) with intended functions, in addition to the fire barrier intended function.
The applicant stated that either the Fire Protection or Structures Monitoring program is sufficient to manage the effects of aging for all intended functions for the elastomer fire stops and elastomer penetration sealant (fire).
3 Question 1 To ensure the effects of aging associated with all intended functions are appropriately managed during the period of extended operation, please confirm that the Fire Protection program is sufficient to manage the effects of aging for all the component types noted in this request. That is, the inspections, inspection frequency, acceptance criteria, and corrective actions of the Fire Protection program are sufficient to manage the effects of aging associated with all cited intended functions.