ML25211A281
| ML25211A281 | |
| Person / Time | |
|---|---|
| Site: | Electric Power Research Institute |
| Issue date: | 12/08/2025 |
| From: | Lois James Licensing Processes Branch |
| To: | |
| Shared Package | |
| ML25211A269 | List: |
| References | |
| EPRI Report 3002032184, EPID L-2025-LRM-0030 pre-app, EPID L-2025-TOP-0024 pre-fee, NDE Optimization Topical Report | |
| Download: ML25211A281 (0) | |
Text
Enclosure f
REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION IN SUPPORT OF THE REVIEW OF EPRI REPORT 3002032184, U.S. INDUSTRY PERFORMANCE MONITORING INSPECTION PLAN FOR SELECT ASME CODE EXAMINATION ITEMS OF PWR STEAM GENERATORS AND PRESSURIZERS DECEMBER 2025 - JANUARY 2026 ELECTRIC POWER RESEARCH DOCKET NO. 99902021
1.0 BACKGROUND
By letter dated June 19, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25171A128), Electric Power Research Institute (EPRI) submitted Non-Destructive Examination (NDE) Technical Report titled U.S. Industry Performance Monitoring [(PM)] Inspection Plan for Select ASME [American Society of Mechanical Engineers]
Code Examination Items of PWR [Pressurized Water Reactor] Steam Generators [SGs] and Pressurizers [PZRs] (TR or the NDE Optimization TR) to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. The PM Inspection Plan presents a comprehensive U.S. PWR fleet-wide inspection plan for the SG and PZR components to address the NRCs requirement for PM. By email dated July18, 2025 (ML25174A097), the NRC staff accepted the NDE Optimization TR for review.
The NRC staff has determined that a regulatory audit of EPRI NDE Optimization TR should be conducted in accordance with the Office of Nuclear Regulatory Reactor (NRR) Office Instruction (OI) LIC-111, Regulatory Audits, Revision 2, effective October 1, 2024 (ML24309A281), for the staff to gain a better understanding of EPRIs U.S. PWR-fleet-wide inspection plan for SGs and PZRs components to address the NRCs requirement for PM during the extended relief period.
A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The audit is conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the NRC staff in efficiently conducting its review and gaining insights to the vendors processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.
2.0 REGULATORY AUDIT BASES The NRC regulations in Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4),
Codes and standards, state, in part, components that are classified as ASME Code Class 1, 2, and 3 must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The NRC regulations in 10 CFR 50.55a(z) state, in part, that alternatives to the requirements of paragraph (f) of 10 CFR 50.55a may be used, when authorized by the NRC, if the licensee demonstrates (1) the proposed alternatives would provide an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
3.0 REGULATORY AUDIT SCOPE The NRC staff will conduct a virtual audit which will include technical discussion pertaining to potential requests for additional information questions as well as comprehension questions on the TR itself.
4.0 INFORMATION NEEDS The area of focus for the regulatory audit is the information contained in the Topical Report (TR), Reference 4 of the TR (Technical Bases for Inspection Requirements for PWR Steam Generator Auxiliary Feedwater Nozzle-to-Shell Welds. EPRI, Palo Alto, CA: 2022.
3002023713), and the enclosed audit information needs.
The NRC staff needs to understand the applicable industry practices by which unexpected degradation, that is degradation other than the analyzed corrosion, mechanical, and thermal fatigue, will:
Be analyzed for broader impacts (e.g., potential for occurrence at other facilities than which was initially identified)
Be communicated to the wider stakeholder community (e.g., PWR/Boiling Water Reactor owners groups, etc.)
Be used, and by whom, to identify and act on follow-on actions The NRC staff also seeks clarification regarding the operation of TR Section 5.3 for future replacement SGs and PZRs. This section appears to suggest that new replacement components with no operating history should be sampled consistent with components with much longer operating histories prior to completing even one full interval of inservice inspections.
This information is important in reaching and documenting findings regarding the TR due to the generic nature of the report. Previously follow-on-actions were fully under the control of individual licensees within their fleet request. It is expected, because this TR is meant to be used communally and individually, that the same approaches proposed by licensees and approved by the NRC in plant/fleet specific applications will not be suitable or practicable for a TR approach.
5.0 TEAM AND R EVIEW ASSIGNMENTS The audit team will consist of the following NRC staff:
NAME ASSIGNMENT BRANCH DIVISION Lois James Senior Project Manager Licensing Projects Branch Division of Operating Reactor Licensing Dan Widrevitz Materials Engineer Vessels and Internals Branch (NVIB)
Division of New and Renewed Licenses (DNRL)
Steven Levitus Materials Engineer NVIB DNRL Stephen Cumblidge Materials Engineer Piping and Head Penetration Branch DNRL 6.0 LOGISTICS The audit will be conducted from December 8, 2025, through January 16, 2026, through an online portal (also known as electronic portal, ePortal, or electronic reading room) established by EPRI.
The audit team will conduct a TEAMS-based entrance meeting with the vendor on December 8, 2025, for the purposes of introducing the team, discussing the scope of the audit, and describing the information to be made available on the portal. Through the audit period between December 8, 2025 through January 16, 2026, the NRC staff will hold breakout sessions with representatives of EPRI to answer audit team questions and to have technical discussions. An exit meeting/call will be held at the conclusion of the audit on January 16, 2025.
The NRC staff does not foresee the need for an onsite visit or in-person discussions between the NRC and vendor staff to discuss information to be provided on the portal at this time.
However, if the need for such a meeting is identified in the future, the audit plan will be revised, and the schedule for the audit will be adjusted accordingly. The NRC project manager will coordinate any changes to the audit schedule and location with the vendor.
7.0 SPECIAL REQUESTS Should review of documents prove necessary, the NRC staff requests that they be provided via online portal that allows the audit team to access documents via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the audit team has access to the online portal:
The online portal will be password-protected, and separate passwords will be assigned to the NRC staff who are participating in the audit.
The online portal will be sufficiently secure to prevent the NRC staff from printing, saving, downloading, or collecting any information on the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.
Username and password information should be provided directly to the NRC staff. The NRC PM will provided to EPRI the names and contact information of the NRC staff who will be participating in the audit. All other communications should be coordinated through the NRC PM.
8.0 DELIVERABLES An audit summary report will be prepared at the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the NRC staff will issue requests for additional information to the vendor.