ML24295A036
| ML24295A036 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/23/2024 |
| From: | William Orders Plant Licensing Branch IV |
| To: | Heflin A Arizona Public Service Co |
| Orders, William | |
| References | |
| EPID L-2024-LLR-0050 | |
| Download: ML24295A036 (1) | |
Text
Enclosure October 23, 2024 Adam Heflin Executive Vice President/
Chief Nuclear Officer Mail Station 7605 Arizona Public Service Company P.O. Box 52034 Phoenix, AZ 85072-2034
SUBJECT:
PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 -
REGULATORY AUDIT PLAN IN SUPPORT OF RELIEF REQUEST NO. 71:
RESUBMITTAL OF RELIEF REQUEST-30 (EPID L-2024-LLR-0050)
Dear Adam Heflin:
By letter dated July 31, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24213A323), Arizona Public Service Company (the licensee) requested U.S. Nuclear Regulatory Commission (NRC) approval of a proposed alternative to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(c), Reactor coolant pressure boundary, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code),Section III, Code Case parameter. Specifically, the licensee requested approval of an alternative to ASME Section III, Sub-Section NB-3356, Code Case 1361-2, Socket Welds,Section III, to allow a diametral clearance (cMAX) of 0.062 inches between the replacement pressurizer heater sleeves and the heater sheaths, instead of 0.045 inches inch as specified in the Code Case. This reactor coolant pressure boundary relief request resubmittal is being tracked by the licensee as Inservice Inspection Program Relief Request (RR)-71 and is to renew existing RR-30.
The NRC staff will conduct a virtual regulatory audit to support its review of the request. The audit will be conducted to increase the NRC staffs understanding of the relief request and identify information that may require docketing to support the NRC staffs regulatory findings.
In accordance with the enclosed audit plan, the audit team will review documentation and calculations that support the efficient review of the relief request. The team requests the licensee to establish a secure, online portal for remote access to this material. The team may also interview the licensees subject matter experts using video and teleconferencing if necessary.
If you have any questions, please contact me at 301-415-3329 or by email to William.Orders@nrc.gov.
Sincerely,
/RA/
William Orders, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-528, STN 50-529, and STN-530
Enclosure:
Audit Plan cc: Listserv
Enclosure REGULATORY AUDIT PLAN IN SUPPORT OF RELIEF REQUEST NO. 71 PROPOSED ALTERNATIVE TO 10 CFR 50.55a(c),
ARIZONA PUBLIC SERVICE COMPANY PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2 AND 3 -
DOCKET NOS. STN 50-528, STN 50-529, AND STN 50-530
1.0 BACKGROUND
By letter dated July 31, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24213A323), Arizona Public Service Company (the licensee) requested U.S. Nuclear Regulatory Commission (NRC) approval of a proposed alternative to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(c), Reactor coolant pressure boundary, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code),Section III, Code Case parameter. Specifically, the licensee requested approval of an alternative to ASME Section III, Sub-Section NB-3356, Code Case 1361-2, Socket Welds,Section III, to allow a diametral clearance (cMAX) of 0.062 inches between the replacement pressurizer heater sleeves and the heater sheaths, instead of 0.045 inches as specified in the Code Case. This reactor coolant pressure boundary relief request resubmittal is being tracked by the licensee as Inservice Inspection Program Relief Request (RR)-71 and is to renew existing RR-30.
2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned activity to examine and evaluate information that provides the technical basis for actions related to a license or regulation. An audit allows the NRC staff to gain insights to the licensees processes and procedures. In the case of a relief request, the NRC staff can clarify its understanding of the request, verify the information submitted, and identify additional information that the staff needs to make a licensing or regulatory decision.
Information that the NRC staff relies upon to make a safety determination or decision must be submitted on the docket.
The NRC staff will perform this audit to support its evaluation of whether the licensees proposed alternative to 10 CFR 50.55a(c) can be approved pursuant to 10 CFR 50.55a(z)(1),
Acceptable level of quality and safety; and 10 CFR 50.55a(z)(2), Hardship without a compensating increase in quality and safety. The audit will be conducted in accordance with the Office of Nuclear Reactor Regulation (NRR) LIC-111, Regulatory Audits, dated October 31, 2019 (ML19226A274).
3.0 REGULATORY AUDIT SCOPE The audit team will view the documentation and calculations that provide the technical support for the relief request.
The scope of the NRC staffs audit will focus on the following subjects:
Confirm the NRC staffs understanding of the relief request and gain a better understanding of the detailed calculations, analyses, and bases on which it is based.
Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Information needed to support a licensing decision may already be docketed, which can be determined during the audit. Otherwise, it must be submitted under oath or affirmation. The licensee may supplement the relief request with this information. Alternatively, the licensee may respond to a formal request for additional information (RAI). If needed, RAIs will be developed and transmitted separately in accordance with NRR Office Instruction LIC-115, Revision 1, Processing Requests for Additional Information, dated August 5, 2021 (ML21141A238).
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC staff may request information and interviews throughout the audit period. The NRC staff will use an audit items list to identify the information to be audited (e.g., methodology, process information, and calculations) and the subjects of requested interviews and meetings.
The NRC staff requests that the licensee have the information referenced in the attachment of this audit plan available and accessible for the NRC staffs review via a web portal within 2 weeks of the date of this audit plan. If additional or supplemental information is requested, it should be available and accessible within 1 week of the date of the NRC staffs notification to the licensee of the new requests. The NRC staff requests that the licensee notify the review team when an audit item is added to its portal by sending an email to the NRC licensing project manager.
The NRC staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit. The NRC staff will not remove non-docketed information from the audit site or web portal.
5.0 AUDIT TEAM The following table identifies the NRC audit team members and their respective organization:
Name Email Organization Kaihwa Hsu Kaihwa.Hsu@nrc.gov NRR Mechanical Engineering & Inservice Testing Branch William Orders William.Orders@nrc.gov NRR Plant Licensing Branch 4 6.0 LOGISTICS The audit will be conducted remotely via a secure, online portal, established by the licensee to present supporting documentation and calculations. In addition to the review of documents made available on the portal, the NRC staff may interview the licensees subject matter experts, virtually (by telephone and videoconference) and, if necessary, in person. The audit will begin within 2 weeks of the date of this audit plan and last through November 2024. The NRC staff will establish a schedule of audit meetings as appropriate on mutually agreeable dates and times.
At the meetings, the licensee is to discuss information needs and questions arising from the NRCs review of the relief request application. The NRC project manager will inform the licensee of audit meeting dates when they are established.
7.0 SPECIAL REQUESTS The following conditions associated with the online portal should be maintained while the NRC staff on the audit team have access to the online portal:
The online portal will be password-protected, and separate passwords will be assigned to each member of the audit team.
The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.
The licensee should provide username and password information directly to the NRC staff on the audit team members listed above. All communications should be coordinated with the NRC project manager. The NRC project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal.
No data accessed by the audit team members will be retained by the NRC following the conclusion of the audit.
8.0 DELIVERABLES The NRC staff will develop any RAIs, if needed, in accordance with NRR LIC-115 and issue such RAIs independent of audit-related correspondence. At the end of the audit, the NRC staff will conduct an exit meeting to inform the licensee of the outcome of the audit. The NRC staff will issue an audit summary report within 90 days of the audit exit.
Attachment:
Audit Item List
Attachment AUDIT ITEM LIST ITEM AUDIT REQUEST 1
Relief Request (RR)-71 addresses environmentally assisted fatigue that applies to wetted reactor coolant system pressure boundary components that are monitored for fatigue as part of license extension obligation. Subsequent analysis by Structural Integrity Associates (SIA) was performed using an environmentally assisted fatigue (EAF) screening (References 1 and 2).
References:
- 1.
Letter Report JDC24-001, dated April 5, 2024, RR-71 Support-EAF Monitoring with SIA:FatiguePro4
- 2.
SIA Calculation No. 1301095.302, Revision 1, Additional Analysis of Screened-in Locations, Palo Verde Units 1, 2, and 3, November 2016.
Audit team will review references in portal.
- concurrence via email OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA*
NRR/DEX/EMIB/BC*
NAME WOrders PBlechman SBailey DATE 10/18/2024 10/21/2024 10/23/2024 OFFICE NRR/DORL/LPL4/BC*
NRR/DORL/LPL4/PM*
NAME JRankin WOrders DATE 10/23/2024 10/23/2024