ML083010087
| ML083010087 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 10/21/2008 |
| From: | Morris J Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 06-CN-003, TAC MD3729, TAC MD3730 | |
| Download: ML083010087 (8) | |
Text
SDuke JAMES R. MORRIS, VICE PRESIDENT aEEnergy Duke Energy Carolinas, LLC Carolinas Catawba Nuclear Station 4800 Concord Road! CN01 VP York, SC 29745 803-701-4251 803-701-3221 fax October 21, 2008 U.S. Nuclear Regulatory Commission Attention:
Document Control.Desk Washington, D.C.
20555
Subject:
Duke Energy Carolinas, LLC (Duke)
Catawba Nuclear Station, Units 1 and 2 Docket Numbers 50-413 and 50-414 Request for Relief Number 06-CN-0.03 Use of Polyethylene Material in Nuclear Safety Related Piping Applications (TAC Numbers MD3729 and MD3730)
References:
- 1. Letters from Duke to NRC, same subject, dated October 26,
- 2006, June 21,
- 2007, March 13,
- 2008, and May 29, 2008
- 2. Letters from NRC to Duke, same subject, dated September 8, 2008 and September 12, 2008 The Reference 1 letters comprise Duke's original submittal and responses to NRC Requests for Additional Information (RAIs) to support a proposed alternative of utilizing polyethylene material in lieu of steel material in piping associated with the emergency diesel generator jacket water coolers.
The September 12, 2008 Reference 2 letter documented NRC's approval of this Request for Relief for the jacket water cooler supply lines for emergency diesel generators 1A and 2A.
The September 8, 2008 Reference 2 letter provided two additional RAI questions dealing with the remaining two supply lines and all four return lines.
The purpose of this letter is to formally respond to the first question of these RAIs.
Duke anticipates providing the response to the second question by November 15, 2008.
The attachment to this letter contains Duke's RAI response.
The format of the response is to restate each RAI question, followed by our response.
www.duke-energy.comr
Document Control Desk Page 2 October 21, 2008 In addition, this letter documents several issues associated with the September 12, 2008 Reference 2 Safety Evaluation.
Conversation with the NRC Project Manager indicated that these issues will be resolved when the NRC provides the approval for the remaining lines.
There are no NRC commitments contained in this letter or its attachment.
If you have any questions concerning this information, please call L.J. Rudy at (803) 701-3084.
Very truly yours, James R.
Morris LJR/s Attachment
Document Control Desk Page 3 October 21, 2008 xc (with attachment):
L.A. Reyes, Regional Administrator U.S. Nuclear Regulatory Commission, Region II Atlanta Federal Center 61 Forsyth St.,
SW, Suite 23T85 Atlanta, GA 30303 A.T. Sabisch, Senior Resident Inspector U.S. Nuclear Regulatory Commission Catawba Nuclear Station J.F. Stang, Jr., Senior Project Manager (addressee only)
U.S. Nuclear Regulatory Commission Mail Stop 8-G9A Washington, D.C. 20555-0001
Document Control Desk Page 4 October 21, 2008 bxc (with attachment):
R.D.
Hart L.J. Rudy D.L.
Ward E.W.
McElroy M.L.
- Arey, Jr.
S.S. Lefler, Jr.
M.A.
Pyne M.J.
Ferlisi K.
Douthit Document Control File 801.01 RGC File NCMPA-1 NCEMC PMPA ELL-EC050
Attachment Response to RAIs
OFFICE OF NUCLEAR REACTOR REGULATION MECHANICAL AND CIVIL ENGINEERING BRANCH REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF 06-CN-003, USE OF POLYETHYLENE MATERIAL IN NUCLEAR SAFETY-RELATED PIPING APPLICATIONS CATAWBA NUCLEAR STATION UNITS 1 AND 2 TAC NOS.
MD3729 AND MD3730 By letter dated October 26,
- 2006, as supplemented by letters dated June 21,
- 2007, March 13,
- 2008, and May 29,
- 2008, Duke Energy Carolinas,
- LLC, the licensee, submitted a request for relief RR-06-CN-003 from the American Society of Mechanical Engineers (ASME),
Boiler and Pressure Vessel Code (Code),
Section XI, 1998 Edition through 2000 Addenda requirement pertaining to using high-density polyethylene (HDPE) pipe in lieu of the ASME Code requirements for Class 3 carbon steel piping for the ASME Code Class 3, 12-inch nominal diameter supply and return buried piping to and from the diesel generator jacket water coolers for the third 10-year inservice inspection (ISI) interval at Catawba Nuclear Station, Units 1 and 2 (Catawba 1 and 2).
There are a total of 8 lines for which the licensee is seeking approval for the use of HDPE pipe, supply and return lines 1A, 1B, 2A and 2B.
The U.S.-Nuclear Regulatory Commission (NRC) staff has identified additional information needed to complete its review of this relief request.
The NRC staff is seeking information concerning supply lines lB, 2B and return lines 1A, lB, 2A, and 2B.
The NRC staff has concluded that the licensee has provided sufficient information for the NRC staff to accept the use of HDPE pipe for the 1A and 2A supply lines to the diesel generator jacket water coolers for the third 10-year ISI interval.
The NRC will document this in the near future.
For the NRC staff to make a determination regarding the acceptability of the entire proposed alternative, the licensee is requested to respond to the following items.
- 1. In the relief request 06-CN-003, dated October 26,
- 2006, the licensee stated that the request for relief is to support a proposed alternative of utilizing polyethylene material in lieu of steel material in piping associated with the emergency diesel generator jacket water coolers and other nuclear safety related piping applications.
The licensee is requested to clarify whether the relief request is limited to a total of eight (8) lines only, namely four (4) emergency diesel jacket-water intake or supply lines Attachment Page 1
(1A, 1B, 2A, 2B),
and four (4) emergency diesel jacket water discharge lines (lA, lB, 2A, 2B),
and that no other nuclear safety related piping applications are included in the relief request.
Duke Response:
Duke relief request 06-CN-003 is limited to a total of eight lines consisting of the four emergency diesel jacket water cooler supply lines and the four emergency diesel jacket water cooler return lines.
No other nuclear safety related piping applications are included in relief request 06-CN-003.
This limitation was stated in response to NRC RAI 5 which is described in the Duke March 13, 2008 letter to the NRC.
2* In Appendix A of the October 26, 2006 letter (Analysis for Catawba Piping),
of the relief request, the licensee included the detailed analytical calculations for 12 inch supply lines for Diesel Buildings 1A and 2A along with simple isometrics of the piping model.
The licensee is requested to supplement its request to confirm that the analysis for supply lines 1B, & 2B, and.discharge lines 1A, lB, 2A, and 2B will employ the same methodology, assumptions, parameters., and allowable limits reviewed 'and approved by the staff for intake lines 1A and 2A.
In addition to confirming the analysis methodology, the licensee is requested to provide (a) input parameters (pipe size, wall thickness, design pressure, and design temperature),
(b) simple isometrics of the piping model, and (c) a summary of results based on as-designed analysis for the remaining six (6) emergency diesel jacket water lines, namely two (2) intake.or supply lines (lB,
& 2B),
and four (4) discharge lines (1A, 1B, 2A, and 2B).
Duke Response:
Duke anticipates providing a response to this RAI by November 15, 2008.
Attachment Page 2
I I
Duke has reviewed the September 12, 2008 Reference 2 Safety Evaluation and notes the following issues that need to be resolved by the NRC:
- 1. Section 2.0, Background NRC should correct the reference to Sizewell B service experience in the last paragraph.
The sentence is correct except that this piping was not required to be seismically designed.
Duke suggests deleting the phrase "seismically qualified" to make this sentence read, "Sizewell B is the first plant in the world to install HDPE piping in nuclear safety-related systems."
- 2. Section 5.7, Test Program for HDPE Piping for Application in ASTM Class 1, 2 and 3 Piping
" Editorial correction -
" The first paragraph discusses five specific items related to EPRI testing.
These items were not included in Duke's May 29, 2008 commitment letter.
Rather, they were part of an earlier draft of this letter.
The discussion of these specific items should be deleted, as Duke cannot commit EPRI to future testing specifics.
" Item 1 states, "Prior to submitting Catawba 1 and 2 fourth 10-year ISI interval,.....
According to Duke's May 29, 2008 commitment letter, this should state, "Prior to submitting Catawba 1 and 2 fourth 10-year ISI interval plan,...
so as not to infer that Catawba will automatically need to submit a fourth 10-year ISI interval Request for Relief.
Attachment Page 3