ML033100456
| ML033100456 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/06/2003 |
| From: | Chandu Patel NRC/NRR/DLPM/LPD2 |
| To: | Moyer J Carolina Power & Light Co |
| Patel C P, NRR/DLPM, 415-3025 | |
| References | |
| TAC MB7932 | |
| Download: ML033100456 (4) | |
Text
November 6, 2003 Mr. J. W. Moyer, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 (TAC NO. MB7932)
Dear Mr. Moyer:
By letter dated February 11, 2003, Carolina Power & Light Company submitted Request for Relief No. 34 from the requirements of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code (the Code),Section XI, for H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). The request for relief is for the third 10-year inservice inspection interval, in which HBRSEP2 adopted the 1986 Edition of ASME Section XI as the Code of record, with the exception of Class 1, Examination Category B-J piping weld examinations, which are determined by the 1974 Edition through Summer 1975 Addenda of Section XI, as allowed by Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a.
Based on our review of the information provided by you, we have determined that additional information is required to complete our review. The details about the required information are provided in the enclosure. This information was discussed with your staff during a conference call on October 9, 2003. We request that you provide your response as soon as possible, but no later than December 30, 2003.
Sincerely,
/RA/
Chandu P. Patel, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
Request for Additional Information cc w/encl: See next page
November 6, 2003 Mr. J. W. Moyer, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 (TAC NO. MB7932)
Dear Mr. Moyer:
By letter dated February 11, 2003, Carolina Power & Light Company submitted Request for Relief No. 34 from the requirements of the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code (the Code),Section XI, for H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). The request for relief is for the third 10-year inservice inspection interval, in which HBRSEP2 adopted the 1986 Edition of ASME Section XI as the Code of record, with the exception of Class 1, Examination Category B-J piping weld examinations, which are determined by the 1974 Edition through Summer 1975 Addenda of Section XI, as allowed by Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a.
Based on our review of the information provided by you, we have determined that additional information is required to complete our review. The details about the required information are provided in the enclosure. This information was discussed with your staff during a conference call on October 9, 2003. We request that you provide your response as soon as possible, but no later than December 30, 2003.
Sincerely,
/RA/
Chandu P. Patel, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-261
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
PUBLIC AHowe EDunnington ACRS TChan PDII-2R/F CPatel OGC PFredrickson, RII TCoffin ADAMS: ML033100456 OFFICE PM:PDII/S2 LA:PDII/S2 SC:PDII/S2 NAME CPatel EDunnington AHowe DATE 11/6/02 11/5/02 11/ 6/02 COPY Yes/No Yes/No Yes/No OFFICIAL RECORD COPY
Enclosure REQUEST FOR ADDITIONAL INFORMATION ON THIRD 10-YEAR INSERVICE INSPECTION INTERVAL REQUEST FOR RELIEF FOR CAROLINA POWER & LIGHT COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NUMBER 50-261 1.0 SCOPE By letter dated February 11, 2003, Carolina Power & Light Company (the licensee, CP&L) submitted Request for Relief No. 34 from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (the Code),Section XI, for H. B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP2). The request for relief is for the third 10-year inservice inspection (ISI) interval, in which HBRSEP2 adopted the 1986 Edition of ASME Section XI as the Code of record, with the exception of Class 1, Examination Category B-J piping weld examinations, which are determined by the 1974 Edition through Summer 1975 Addenda of Section XI, as allowed by Title 10 of the Code of Federal Regulations (10 CFR)
Part 50, Section 50.55a.
In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee has submitted Relief Request 34 to address many components for which 100-percent coverage could not be obtained. The Code requires that essentially 100 percent of the examination volumes in IWB-2500-1 be completed.
Essentially 100%, as clarified by ASME Code Case N-460, is greater than 90-percent coverage of the examination volume, or surface area, as applicable. Code Case N-460 has been adopted by the licensee. 10 CFR 50.55a(g)(5)(iii) states that when licensees determine that conformance with Code requirements is impractical at their facility, they shall submit information to support this determination. The NRC will evaluate such requests based on impracticality, and may impose alternatives, giving due consideration to public safety and the burden imposed on the licensee.
Based on our review of the information provided by CP&L, we have determined that additional information is required to complete our review.
2.0 REQUEST FOR ADDITIONAL INFORMATION The licensee has requested relief in accordance with 10 CFR 50.55a(g)(5)(iii) based upon the argument that the Code examinations are impractical at their facility. However, the licensee must present adequate information to support a determination that the required examinations are impractical (not simply inconvenient) to perform to the extent required by the Code. This information should include drawings, or other physical descriptions, of the component examination areas, including examination coverage(s), weld cross-sections, etc., necessary to support the request. In addition, the licensee should submit argument(s) as to why the use of other methods would not reasonably increase the examination coverage(s).
In Attachment I for Relief Request 34 of the licensee's submittal (Table 1 on page 2 of 9), the limitation discussion for Reactor Vessel Upper Shell Welds states that the reduced volumetric coverage (90 percent) is due to Proximity of the inlet nozzle inner radius section. This discussion does not provide an adequate description of the physical limitation or indicate
whether other techniques such as different interrogation angles could have practically increased the coverage. Similar issues exist with the remainder of the components listed in Table 1. The drawings provided by the licensee are inadequate to determine the extent of actual scanning limitations.
The licensee should address the following issues in the revised relief request:
Provide a technical basis for each component listed in Table 1, describing in detail the examination limitation, and discuss whether other examinations may be used to increase or supplement the limited examinations. The technical basis should include a cross-sectional sketch of the weld, indicating ultrasonic coverage(s) and details of the weld and base metal materials. The technical basis should confirm, where applicable, that the examinations that were performed were also qualified under Appendix VIII of ASME Section XI.
Indicate what degradation mechanism(s) is most likely to occur in this weld and a technical basis for whether the achieved examination coverage could reasonably be expected to detect this degradation.
Mr. J. W. Moyer H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 cc:
Steven R. Carr Associate General Counsel - Legal Department Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, North Carolina 27602-1551 Ms. Margaret A. Force Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602 U. S. Nuclear Regulatory Commission Resident Inspectors Office H. B. Robinson Steam Electric Plant 2112 Old Camden Road Hartsville, South Carolina 29550 Mr. T. P. Cleary Plant General Manager Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. Chris L. Burton Director of Site Operations Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550 Public Service Commission State of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211 J. F. Lucas Manager - Support Services - Nuclear Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. C. T. Baucom Supervisor, Licensing/Regulatory Programs Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entrance Road Hartsville, South Carolina 29550 Ms. Beverly Hall, Section Chief N.C. Department of Environment and Natural Resources Division of Radiation Protection 3825 Barrett Dr.
Raleigh, North Carolina 27609-7721 Mr. Robert P. Gruber Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, North Carolina 27699-4326 Mr. Henry H. Porter, Assistant Director South Carolina Department of Health Bureau of Land & Waste Management 2600 Bull Street Columbia, South Carolina 29201 Mr. James W. Holt Manager Performance Evaluation and Regulatory Affairs PEB 7 Progress Energy Post Office Box 1551 Raleigh, North Carolina 27602-1551 Mr. John H. ONeill, Jr.
Shaw, Pittman, Potts, & Trowbridge 2300 N Street NW.
Washington, DC 20037-1128