ML12025A232

Request for Additional Information Regarding License Renewal Nickel-Alloy Nozzles and Penetrations Program Inspection Plan Commitment

ML12025A232
Person / Time
Site:	Robinson
Issue date:	03/01/2012
From:	Heather Jones NRC/NRR/DLR/RPOB
To:	Gideon R Carolina Power & Light Co
Jones H
References
TAC ME7124
Download: ML12025A232 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 1, 2012 Mr. Randy S. Gideon, Vice President Carolina Power & light Company H. B. Robinson Steam Electric Plant Unit No.2 3581 West Entrance Road Hartsville, SC 29550

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT: REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE RENEWAL NICKEL-ALLOY NOZZLES AND PENETRATIONS PROGRAM INSPECTION PLAN COMMITMENT (TAC NO. ME7124)

Dear Mr. Gideon:

By letter dated March 29, 2009 (Agencywide Document Access and Management Systems (ADAMS) Accession No. ML092170065), as supplemented by letter dated April 13, 2010, (ADAMS Accession No. ML101090153), Carolina Power and light Company (the licensee) submitted the "Nickel-Alloy Nozzles and Penetrations Program Inspection Plan" to satisfy commitment item no. 31 of the licensee's "Response to Open and Confirmatory Items," letter dated September 16, 2003 (ADAMS Accession No. ML032650884), for the H. B. Robinson Steam Electric Plant.

To complete its review of the subject aging management program inspection plan, the staff requests the additional information shown in the enclosure. The request for additional information was discussed with Richard Hightower, and a mutually agreeable date for the response is within 45 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-4054 or bye-mail at Heather.Jones@nrc.gov.

Sincerely,

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Heather M.I ones, Project Manager Program Operations Branch Division of license Renewal Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosure:

As stated cc w/encl: Listserv

REQUEST FOR ADDITIONAL INFORMATION NICKEL-ALLOY NOZZLES AND PENETRATIONS PROGRAM INSPECTION PLAN H. B. ROBINSON STEAM ELECTRIC PLANT DOCKET NO. 50-261 By letter dated March 29, 2009 (Agencywide Document Access and Management Systems (ADAMS) Accession No. ML092170065), as revised by letter dated April 13, 2010 (ADAMS Accession No. ML101090153), Carolina Power and Light Company (the licensee) submitted for review and approval the "Nickel-Alloy Nozzles and Penetrations Program Inspection Plan" to satisfy commitment item no. 31 of the licensee's "Response to Open and Confirmatory Items,"

letter dated September 16,2003 (ADAMS Accession No. ML032650884). The subject commitment item states:

"The Nickel-Alloy Nozzles and Penetrations Program is a new program that will incorporate the following:

(1) evaluations of indications will be performed under the American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code,Section XI program, (2) corrective actions for augmented inspections will be performed in accordance with repair and replacement procedures equivalent to those requirements in ASME Boiler & Pressure Vessel Code,Section XI, (3) RNP will maintain its involvement in industry initiatives and will systematically assess for implementation applicable programmatic enhancements, that are agreed upon between the NRC and the nuclear power industry to monitor for, detect, evaluate, and correct cracking in the vessel head penetration (VHP) nozzles, specifically as the actions relate to ensuring the Integrity of VHP nozzles in the RNP upper reactor vessel head during the extended period of operation, and (4) RNP will submit, for review and approval, its Inspection plan for the Nickel-Alloy Nozzles and Penetrations Program, as it will be implemented from the applicant's participation in industry initiatives, prior to July 31, 2009."

The staff notes that revisions to guidance concerning augmented inspection of pressure retaining nickel-alloy welds are now codified in Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(6)(ii)(D) through (F). The staff additionally notes that the requirements in 10 CFR 50.55a(g)(6)(ii)(D) through (F) bound the recommendations contained in Revision 0 of the Generic Aging Lessons Learned (GALL) Report and all subsequent revisions. Based on these changes, the staff finds that meeting the elements of the commitment, as stated, are not sufficient to provide reasonable assurance that the aging of the components under consideration will be adequately managed.

Alternatively, the staff finds that compliance with 10 CFR 50.55a(g)(6)(ii)(D) through (F) is sufficient to provide such assurance. Finally, that staff notes that there is insufficient information contained in the submission to demonstrate compliance with all aspects of 10 CFR 50.55a(g)(6)(ii)(D) through (F).

-2 To complete its review of the inspection plan, the staff requests the following additional information:

1. Please confirm compliance with the regulatory requirements found in 10 CFR 50.55a(g)(6)(ii)(D) through (F).

2. Please provide the rationale for the proposed Flux Thimble Tube inspection frequency, including any trending analysis of inspection results which would support this inspection frequency.

3. Discuss whether, on the basis of industry and regulatory relevant guidance, new components should be added to, or the inspection type or frequency changed in, the "Nickel-Alloy Nozzles and Penetrations Program Inspection Plan."

4. Submit a revised "Nickel-Alloy Nozzles and Penetrations Program Inspection Plan" which reflects industry and regulatory guidance.

ML101090153), Carolina Power and Ught Company (the licensee) submitted the "Nickel-Alloy Nozzles and Penetrations Program Inspection Plan" to satisfy commitment item no. 31 of the licensee's "Response to Open and Confirmatory Items," letter dated September 16.2003 (ADAMS Accession No. ML032650884), for the H. B. Robinson Steam Electric Plant.

To complete its review of the subject aging management program inspection plan. the staff requests the additional information shown in the enclosure. The request for additional information was discussed with Richard Hightower, and a mutually agreeable date for the response is within 45 days from the date of this letter. If you have any questions. please contact me by telephone at 301-415-4054 or bye-mail at Heather.Jones@nrc.gov.

Sincerely.

IRA!

Heather M. Jones, Project Manager Program Operations Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosure:

As stated cc w/encl: Listserv DISTRIBUTION:

See next page ADAMS Accession No.: ML12025A232 OFFICE LA:RPB2/DLR PM:RPOB/DLR BC: RPOB/DLR PM:RPOB/DLR NAME IKing HJones YDiaz-Sanabria HJones DATE 01/27/2012 02/2912012 03/01/2012 03/01/2012

Letter to R. Gideon from H. Jones dated March 1, 2012

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT: REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE RENEWAL NICKEL-ALLOY NOZZLES AND PENETRATIONS PROGRAM INSPECTION PLAN COMMITMENT (TAC NO. ME7124)

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