ML040650140

RAI, Relief Request No. 34 from the Requirements of ASME and Pressure Vessel Code Section XI

ML040650140
Person / Time
Site:	Robinson
Issue date:	03/05/2004
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: ML040650140 (7)

Text

March 5, 2004 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, as supplemented by letter dated December 30, 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, 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 February 24, 2004. We request that you provide your response as soon as possible but no later than April 19, 2004.

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

March 5, 2004 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, as supplemented by letter dated December 30, 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, 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 February 24, 2004. We request that you provide your response as soon as possible but no later than April 19, 2004.

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-2 R/F CPatel OGC PFredrickson, RII SCoffin Adams Accession No. ML040650140 OFFICE PM:PDII/S2 LA:PDII/S2 SC:PDII/S2 NAME CPatel EDunnington MLMarshall for:

WBurton (A)

DATE 3/4/04 3/4/04 3/4/04 COPY Yes/No Yes/No Yes/No OFFICIAL RECORD COPY

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 (CP&L, the licensee) submitted Request for Relief No. 34 from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components. The request for relief is for the third 10-year inservice inspection (ISI) interval, in which H.B. Robinson adopted the 1986 Edition of ASME Section XI as the Code of record.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 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. For Class 1 and 2 welds, the Code requires that 100 percent of the examination volumes described in IWB-2500-1 be completed.

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.

In response to an NRC Request for Additional Information (RAI), the licensee revised the request and provided further information in a letter dated December 30, 2003. During review of the licensees RAI response, it was discovered that several welds had been omitted, and other relevant information was incomplete. The NRC staff, with assistance from its contractor, Pacific Northwest National Laboratory, has determined that the following information is required to complete the evaluation.

2.0 REQUEST FOR ADDITIONAL INFORMATION 2.1 Omitted Welds Several welds included in original Relief Request 34 were omitted in the revision. In one case, it was stated that, upon further review of examination reports, the licensee determined that greater than 90-percent coverage had been obtained for certain welds; therefore, relief was not required. These welds are listed in Table 1 below. Please clarify that greater than 90-percent volumetric and surface, as applicable, examination coverage was obtained for the welds in Table 1 and how the decision to list these welds in the original request was reached.

Other welds appear to have been omitted in revised Relief Request 34 with no explanation.

Please provide clarifying information as to why these welds listed in Table 2 were omitted.

Table 1 Welds Removed Based on Greater Than 90% Coverage in Revised Request Drawing/ ASME Description Item Exam Limitation/Comment Weld Category Coverage 101/14 B-A Reactor Vessel Upper B1.12 90% Proximity of the inlet Shell Longitudinal Weld nozzle inner radius section at 70° 101/15 B-A Reactor Vessel Upper B1.12 90% Proximity of the inlet Shell Longitudinal Weld nozzle inner radius section at 190° 101/16 B-A Reactor Vessel Upper B1.12 90% Proximity of the inlet Shell Longitudinal Weld nozzle inner radius section at 310° 101A/30 B-D Reactor Vessel Cold Leg B3.90 90% Proximity of the inlet Loop A Nozzle Weld at nozzle inner radius section 80° 101A/32 B-D Reactor Vessel Cold Leg B3.90 90% Proximity of the inlet Loop C Nozzle Weld at nozzle inner radius section 200° Table 2 Welds Missing in Revised Request With no Explanation Drawing/ ASME Description Item Exam Limitation/Comment Weld Category Coverage 202/01 C-A Boron Injection Tank C1.20 83% Vessel weld/component Shell to Upper Head configuration Weld 202/01 C-A Boron Injection Tank C1.20 83% Vessel weld/component Shell to Lower Head configuration Weld 204/A02 C-A Residual Heat C1.20 68% Inlet and outlet nozzles Exchanger A Shell to and vessel supports Lower Head Weld 231/30 C-F-1 Safety Injection System C5.21 50% Weld crown configuration Pipe to Elbow 239/12 C-F-1 Safety Injection System C5.21 52% Weld crown configuration Pipe to Elbow 239/13 C-F-1 Safety Injection System C5.21 42% Weld crown configuration Pipe to Elbow 239/14 C-F-1 Safety Injection System C5.21 41% Weld crown/component Pipe to Elbow configuration 240/13 C-F-1 Safety Injection Pipe to C5.21 86% Weld crown configuration Elbow

Finally, the welds listed in Table 3 below were omitted from the revised relief request with the following explanation:

During the review process performed on the subject welds, it was identified that the ISI Program description included steam generator nozzle safe end welds. After further review, it appears that the steam generators were provided with a stainless steel build-up on the hot leg and cold leg nozzles and that there is no weld in this location. Therefore, these welds are not included in this RAI response and have been deleted from the ISI Program description.

Please provide clarifying information on the weld configuration as the result of steam generator replacement and provide the dates for when the steam generators were replaced pertaining to these nozzle-to-piping welds. Please clarify that no new welds have been included in the ISI Program Plan. Also, provide any information related to limitations for examining these Category B-J welds or B-F welds.

Table 3 Welds in Original Relief Request That do not Exist Drawing/ Code Description Item Exam Limitation/Comment Weld Category Coverage 107/04 B-J Hot Leg Loop A Elbow B9.11 75% Weld/component to Safe End configuration 107/05 B-J Crossover Leg-Loop A B9.11 75% Weld/component Safe End to Elbow configuration 107A/04 B-J Hot Leg Loop B Elbow B9.11 75% Weld/component to Safe End configuration 107A/05 B-J Crossover Leg-Loop B B9.11 75% Weld/component Safe End to Elbow configuration 107B/04 B-J Hot Leg Loop C Elbow B9.11 75% Weld/component to Safe End configuration 107B/05 B-J Crossover Leg-Loop C B9.11 75% Weld/component Safe End to Elbow configuration 2.2 Request for Relief 34, Revision 1, Category B-D Examinations of Full-Penetration Welded Nozzles in Vessels Based upon the drawings and descriptions provided by the licensee for welds 101A/29, 101A/31, and 101A/33, it is not clear why only 10 percent of the subject nozzle weld can be examined when scanning transverse to the weld. In addition, the licensee does not state whether the subject weld was examined from the nozzle bore during the first period of the third inspection interval. Clearly explain why only 10 percent of the weld can be examined in the transverse direction and provide additional information to support a determination of reasonable assurance for continued structural integrity.

2.3 Request for Relief 34, Revision 1, Category B-G-1 Examinations of Pressure-Retaining Bolting The licensee has requested relief from the 100-percent Code-required examination volume for reactor coolant pump stud No. 7. The licensee states that the lower 8 inches of the stud cannot be examined due to a taper in the stud design. Further, the licensee states that the limitation equates to only 0.36 percent of the overall examination volume for all studs in aggregate. We understand that this relief is no longer required. Please clarify your position.

2.4 Confirm the end date for the H.B. Robinson third 10-year inspection interval was February 18, 2002.

2.5 Request for Relief 34, Revision 1, Examination Categories B-F, B-J, C-F-1, and C-F-2 Pressure-Retaining Welds in Piping Clarify that 100 percent, with the exception noted for socket Weld 133/10, of the Code-required surface examinations were completed for all Class 1 and 2 dissimilar metal, austenitic, and ferritic piping welds included in Request for Relief 34. Briefly discuss any relevant indication, if observed, during the volumetric and surface examinations.

2.6 Request for Relief 34, Revision 1, Examination Category C-C, Integral Attachments for Vessels, Piping, Pumps, and Valves Briefly discuss whether relevant indications have been detected on the subject integrally welded attachments, and describe other attachment welds that have received full Code examinations.

Mr. J. W. Moyer H. B. Robinson Steam Electric Plant, Carolina Power & Light Company Unit No. 2 cc:

Steven R. Carr Supervisor, Licensing/Regulatory Programs Associate General Counsel - Legal H. B. Robinson Steam Electric Plant, Department Unit No. 2 Progress Energy Service Company, LLC Carolina Power & Light Company Post Office Box 1551 3581 West Entrance Road Raleigh, North Carolina 27602-1551 Hartsville, South Carolina 29550 Ms. Margaret A. Force Ms. Beverly Hall, Section Chief Assistant Attorney General N.C. Department of Environment State of North Carolina and Natural Resources Post Office Box 629 Division of Radiation Protection Raleigh, North Carolina 27602 3825 Barrett Dr.

Raleigh, North Carolina 27609-7721 U. S. Nuclear Regulatory Commission Resident Inspectors Office Mr. Robert P. Gruber H. B. Robinson Steam Electric Plant Executive Director 2112 Old Camden Road Public Staff - NCUC Hartsville, South Carolina 29550 4326 Mail Service Center Raleigh, North Carolina 27699-4326 Mr. T. P. Cleary Plant General Manager Mr. Henry H. Porter, Assistant Director H. B. Robinson Steam Electric Plant, South Carolina Department of Health Unit No. 2 Bureau of Land & Waste Management Carolina Power & Light Company 2600 Bull Street 3581 West Entrance Road Columbia, South Carolina 29201 Hartsville, South Carolina 29550 Mr. James W. Holt Mr. Chris L. Burton Manager Director of Site Operations Performance Evaluation and H. B. Robinson Steam Electric Plant, Regulatory Affairs PEB 7 Unit No. 2 Progress Energy Carolina Power & Light Company Post Office Box 1551 3581 West Entrance Road Raleigh, North Carolina 27602-1551 Hartsville, South Carolina 29550 Mr. John H. ONeill, Jr.

Public Service Commission Shaw, Pittman, Potts, & Trowbridge State of South Carolina 2300 N Street NW.

Post Office Drawer 11649 Washington, DC 20037-1128 Columbia, South Carolina 29211 J. F. Lucas Manager - Support Services - Nuclear H. B. Robinson Steam Electric Plant, Unit No. 2 Carolina Power & Light Company 3581 West Entrance Road Hartsville, South Carolina 29550 Mr. C. T. Baucom