ML110550770

Relief 10-MN-001 for a Proposed Alternative to to Delay the Update to the Code of Record During the Fourth 10-Year Inservice Inspection (ISI) Interval

ML110550770
Person / Time
Site:	McGuire
Issue date:	03/03/2011
From:	Kulesa G Plant Licensing Branch II
To:	Repko R Duke Energy Carolinas
Thompson Jon, NRR/DORL/LPL 2-1, 415-1119
References
TAC ME4676
Download: ML110550770 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 3, 2011 Mr. Regis T. Repko Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078

SUBJECT:

MCGUIRE NUCLEAR STATION, UNIT 1 - RELIEF 10-MN-001 FOR A PROPOSED ALTERNATIVE TO DELAY THE UPDATE TO THE CODE OF RECORD DURING THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NO. ME4676)

Dear Mr. Repko:

By letter dated August 30, 2010, Duke Energy Carolinas, LLC (the licensee), submitted relief request 10-MN-001 for McGuire Nuclear Station, Unit 1 (McGuire 1), related to delaying the update to the Code of Record for the fourth 1O-year inservice inspection (lSI) interval. The third 10-year lSI interval for McGuire 1 ends on December 1, 2011. The licensee requested approval of a proposed alternative to the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (the Code) requirements for lSI. The proposed alternative would delay the required update of the McGuire 1 Code of Record for the fourth lSI interval until the time of the required update to the McGuire 2 Code of Record, scheduled for July 15, 2014.

The Nuclear Regulatory Commission (NRC) staff has reviewed the licensee's submittal and, based on the information provided in the licensee's request for relief, the NRC staff has determined that the proposed alternative provides an acceptable level of quality and safety.

Therefore, pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 50.55a(a)(3)(i), the NRC staff authorizes the use of the proposed alternative to delay the required update of the McGuire 1 Code of Record for the fourth lSI interval until the time of the required update to the McGuire 2 Code of Record.

R. Repko - 2 All other requirements of ASME Code.Section XI for which relief has not been specifically requested remain applicable. including third-party review by the Authorized Nuclear Inservice Inspector.

Sincerely.

0r (C--.____

Gloria Kulesa. Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear ReactorRegulation Docket No. 50-369

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF FOURTH 10-YEAR INTERVAL INSERVICE INSPECTION RELIEF NO. 10-MN-001 DUKE ENERGY CAROLINAS, LLC MCGUIRE NUCLEAR STATION, UNIT 1 DOCKET NO. 50-369

1.0 INTRODUCTION

By letter dated August 30. 2010 (Agencywide Documents Access and Management System (ADAMS), Accession No. ML102510186), Duke Energy Carolinas, LLC (the licensee),

submitted Request for Relief 10-MN-001 for the McGuire Nuclear Station. Unit 1, (McGuire 1) requesting approval of a proposed alternative to delay updating the Code of Record for the fourth Inservice Inspection (lSI) interval until the time of the required update to the Code of Record for the fourth lSI interval for McGuire 2.

2.0 REGULATORY EVALUATION

Pursuant to Title 10 of the Code of Federal Regulations (10 CFR). Part 50. Section 50.55a, paragraph 50.55a(g)(4), American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (the Code) Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the pre-service examination requirements. set forth in ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year inspection interval and subsequent 10-year inspection intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein.

Paragraph 50.55a(a)(3) of 10 CFR Part 50 states that alternatives to the requirements of 10 CFR 50.55a(g) may be used, when authorized by the Nuclear Regulatory Commission (NRC), if (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The NRC staff reviewed and evaluated the licensee's request pursuant to 10 CFR 50.55a(a)(3)(i).

Enclosure

-2

3.0 TECHNICAL EVALUATION

3.1 ASME Code Components Affected

ASME Class 1, 2, and 3 components and component supports.

Note: This relief request specifically excludes ASME Class MC components at McGuire 1.

3.2 Code Requirement Pursuant to 10 CFR 50.55a(g)(4)(ii), McGuire 1 is required to update its lSI program to the requirements of the latest Code edition and addenda incorporated by reference in 10 CFR 50.55a(b)(2) twelve months prior to the start of its subsequent 120-month lSI interval.

In the case of McGuire 1, the fourth 10-year lSI program Code of Record should reflect the ASME Code,Section XI, 2004 Edition, no Addenda. The third 10-year lSI program Code of Record is the 1998 Edition through the 2000 Addenda.

3.3 Licensee's Proposed Alternative and Basis The licensee requests authorization to delay the update of the McGuire 1 Code of Record for the fourth lSI interval until the time of the required update for McGuire 2. The McGuire 1 fourth lSI interval starts on December 1, 2011. McGuire 2 is scheduled to adopt the latest ASME Code edition and addenda incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of its fourth lSI interval, which is scheduled to begin on July 15, 2014.

The McGuire 'I lSI program will continue with a revised 10-year program plan for the fourth interval that references the same Code of Record used for the third lSI interval, that is, the 1998 Edition through the 2000 Addenda of ASME Code,Section XI. This edition and addenda of the Code is the same as that currently being used for the third lSI interval program at McGuire 2. The licensee states that having two separate ASME Code editions implemented on a two-unit site can create procedural and programmatic differences that could potentially result in implementation errors, and that having both units on the same Code of Record provides many implementation benefits which will maintain the existing level of quality and safety and provide cohesive programs for lSI, repairs, replacements and pressure testing.

At the time of the required McGuire 2 Code update, the McGuire 1 lSI interval program will be revised to implement the updated Code of Record for the remainder of the McGuire 1 fourth lSI interval, which is expected to include the second and third inspection periods in their entirety (approximately 7 years).

3.4 Staff Evaluation The licensee requests authorization to have the lSI programs for McGuire 1 and McGuire 2 based on the same Code of Record. The licensee proposes that McGuire 1 will continue lSI inspections for the first inspection period of the fourth lSI interval in accordance with the 1998 Code Edition through the 2000 Addenda, with provisions and restrictions, until the time of the required McGuire 2 update. At the time of the McGuire 2 update, both units will be updated to the applicable Code Edition required by 10 CFR 50.55a(g)(4)(ii) for McGuire 2. The NRC staff

- 3 concurs with the licensee that having two different lSI programs based on separate editions and addenda of the ASME Code implemented for the two McGuire units can possibly create procedural and programmatic differences that could potentially result in implementation errors, and that having the lSI programs for both units based on the same Code edition and addenda can eliminate such differences and should provide for more cohesive programs for lSI, repairs, replacements, and pressure testing. Therefore, the NRC staff finds that delaying the Code of Record update will maintain the existing level of quality and safety and, thus, is acceptable.

The licensee states that the following limitations and modifications of 10 CFR SO.SSa(b)(2) shall apply when using the 1998 Edition through the 2000 Addenda:

Code Cases, if used, shall comply with the requirements specified in Regulatory Guide 1.147.

Use of the provisions of IWA-4340, "Mitigation of Defects by Modification," of Section XI of the ASME Code is prohibited except when specifically authorized by the NRC staff in accordance with 10 CFR SO.SSa(a)(3).

Repair and replacement activity provisions in IWA-4S40(c) of the 1998 Edition of ASME Code,Section XI, for pressure testing Class 1, 2, and 3 mechanical joints must be applied.

The NRC staff finds that the licensee's provisions, limitations and modifications for the use of the 1998 Edition through the 2000 Addenda of ASME Code,Section XI, meet the provisions, limitations and modifications specified in 10 CFR SO.SSa(b)(2) and, thus, are acceptable.

The licensee proposes to transition to the implementation of the McGuire 1 fourth lSI interval Code of Record by including the second and third inspection periods in their entirety. The NRC staff finds that this plan clearly defines an acceptable transition between the two Code editions, and finds that the licensee's proposed alternative will provide an acceptable level of quality and safety. The NRC staff also notes that it has previously authorized delay of the Code of Record for Comanche Peak Nuclear Power Plant, Unit 1, for the third 1O-year lSI interval by letter dated April 28. 2010 (ADAMS Accession No. ML100850122).

The NRC staff notes that for Class 1 and Class 2 piping, Examination Category B-F, B-J, C-F-1 and C-F-2 piping welds are inspected under a risk-informed lSI (RI-ISI) program through the end of the third interval by letter dated June 12,2002 (ADAMS Accession No. ML021480421).

and that 100% of the required RI-ISI inspections will be completed in the third lSI interval. At the end of the third interval, the RI-ISI program will need to be authorized if it is to be used in the fourth lSI interval.

4.0 CONCLUSION

As set forth above, the NRC staff determines that the proposed alternative, to delay updating the fourth lSI interval Code of Record for McGuire 1 until the time of the fourth lSI interval McGuire 2 Code of Record update provides an acceptable level of quality and safety.

Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the

- 4 regulatory requirements set forth in 10 CFR SO.SSa(3)(i). Therefore, the NRC staff authorizes the proposed alternative at McGuire 1, until the time of the McGuire 2, Code of Record update, currently scheduled for July 1S, 2014.

All other ASME Code,Section XI requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: Jay Wallace, NRR/DCI Date: March 3, 2011

R. Repko -2 All other requirements of ASME Code,Section XI for which relief has not been specifically requested remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Sincerely, IRA!

Gloria Kulesa, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-369

Enclosure:

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