ML24092A108

3R22 RFO ISI Owners Activity Report Extension - NRC Staff Acknowledgement Email (4/1/2024)

ML24092A108
Person / Time
Site:	Millstone
Issue date:	04/01/2024
From:	Richard Guzman NRC/NRR/DORL/LPL1
To:	Sinha S Dominion Energy Nuclear Connecticut
References
Download: ML24092A108 (1)

Text

From: Richard Guzman To: Shayan Sinha

Subject:

Millstone Unit 3 3R22 RFO ISI Owner"s Activity Report Extension - NRC acknowledgement of receipt Date: Monday, April 1, 2024 9:02:15 AM

Mr. Sinha,

By letter dated March 28, 2024 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML24088A294), Dominion Energy Nuclear Connecticut, Inc. (the licensee)proposed to extend the submittal of the 3R22 Refueling Outage Inservice Inspection Owners Activity report (OAR) for Millstone Power Station, Unit 3.

The Nuclear Regulatory Commission (NRC) staff notes that the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, IWA-6230(b) requires licensees to process the OAR (Form OAR-1) within specific calendar days after the completion of each refueling outage. Subarticle IWA-6230(b)(5) requires that the OAR be submitted to the regulatory authority having jurisdiction at the plant site. The 2017 and earlier editions of the ASME Code,Section XI, require the OAR be submitted to the NRC within 90 calendar days after the completion of the refueling outage. Starting from the 2019 edition of the Code, the OAR may be submitted within 120 calendar days. In addition, ASME Code Case N-892, Alternative Requirement for Form OAR-1, Owners Activity Report, Completion Time,Section XI, Division 1, allows the submittal of the OAR within 120 calendar days after the refueling outage. The NRC staff has approved the generic use of Code Case N-892 in Regulatory Guide 1.147, Revision 20. Regardless of the edition of the ASME Code,Section XI as the licensees code of record for the 10-year inservice inspection interval, a licensee can use Code Case-892 to submit its OAR within 120 calendar days.

In its letter dated March 28, 2024, the licensee stated that the 3R22 refueling outage was completed on December 1, 2023. Based on the 120 calendar days per ASME Code Case N-892, the licensee recognized that it is required to submit the OAR by April 1, 2024. The licensee stated that it was not able to meet the 120-day requirement due to several repair/replacement work orders and associated forms needing additional time to process during the refueling outage. The licensee stated that it expects to submit the OAR by May 9, 2024.

The NRC staff notes that the OAR documents the results of the inservice inspection and repair/replacement activities that have been performed during a refueling outage. If plant safety issues arise during the refueling outage, the licensee is required to expeditiously notify the NRC via other regulatory processes. As such, the NRC staff determined that the proposed extension for the OAR submittal does not affect the structural integrity of the plant components. The NRC staff also notes that the licensee has prepared a Condition report and entered the proposed extension into the stations corrective action program.

Based on the information provided, the NRC staff considers the extension of submitting the OAR for the 3R22 refueling outage at Millstone Unit 3 from April 1, 2024, to May 9, 2024, is acceptable because (1) the proposed extension has minimal safety significance, (2) the risk to the plant safety and public health is low, and (3) the licensee has documented the proposed extension into its corrective action program.

Please contact me if you have any questions. A copy of this email communication will be made publicly available in ADAMS.

Richard V. Guzman Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Office: O-10H17 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov