ML13135A184

Request for Additional Information Related to the Pressurized Water Reactors Internals Program Plan for Aging Management of Reactor Internals

ML13135A184
Person / Time
Site:	Robinson
Issue date:	05/29/2013
From:	Billoch-Colon A Plant Licensing Branch II
To:	William Gideon Carolina Power & Light Co
Billoch-Colon A NRR/DORL/LPL2-2
References
TAC ME9633
Download: ML13135A184 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 29, 2013 Mr. William R. Gideon, Vice President Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit 2 3581 West Entrance Road Hartsville, South Carolina 29550

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO.2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PRESSURIZED WATER REACTOR INTERNALS PROGRAM PLAN FOR AGING MANAGEMENT OF REACTOR INTERNALS (TAC NO. ME9633)

Dear Mr. Gideon:

By letter to the U.S. Nuclear Regulatory Commission (NRC) dated September 26,2012 (Agencywide Documents Access and Management System Accession No. ML12278A398),

Carolina Power & Light Company, submitted an aging management program (AMP) for the reactor vessel internals (RVI) for H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).

The Materials Reliability Program-227-A report, "Pressurized Water Reactor Internals Inspection and Evaluation Guidelines," and its supporting reports were used as technical bases for developing HBRSEP's AMP. The NRC staff reviewed this report and issued a final safety evaluation on December 16, 2011. Based on the review of HBRSEP's AMP conducted thus far, the NRC staff developed a request for additional information (RAI) that was provided to the licensee on March 27,2013. The licensee provided its response to the first RAI on May 23, 2013.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The enclosure to this letter contains a second set of RAls that address, in part, the American Society of Mechanical Engineers Code,Section XI inspection requirements for the RVI components. The staff may however, issue additional RAls based on the resolution of Action Items 1 and 2 addressed in the staffs safety evaluation for the MRP-227 -A report. During a discussion with your staff on May 23, 2013, it was agreed that you would provide a response 60 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources.

W. Gideon - 2 Please contact me at (301) 415-3302 if you have any questions.

Sincerely, Araceli Billoch Col6n, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosure:

Request for Additional Information cc w/encl: Distribution via ListServ

REQUEST FOR ADDITIONAL INFORMATION REGARDING H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 PRESSURIZED WATER REACTORS INTERNALS PROGRAM PLAN FOR AGING MANAGEMENT OF REACTOR INTERNALS DOCKET NO. 50-261 By letter to the U.S. Nuclear Regulatory Commission (NRC) dated September 26,2012 (Agencywide Documents Access and Management System Accession No. ML12278A398 and ML12278A399), Carolina Power & Light Company (the licensee), submitted an aging management program (AMP) for the reactor vessel internals (RVI) for H. B. Robinson Steam Electric Plant, Unit No.2 (HBRSEP).

The Materials Reliability Program (MRP)-227-A report, "Pressurized Water Reactor (PWR)

Internals Inspection and Evaluation Guidelines," and its supporting reports were used as technical bases for developing HBRSEP's AMP. The NRC staff reviewed this report and issued a final safety evaluation on December 16, 2011. Based on the review of HBRSEP's AMP conducted thus far, the NRC staff developed a first request for additional information (RAI) that was provided to the licensee on March 27, 2013. The licensee provided its response to the first RAI on May 23, 2013.

This enclosure contains a second set of RAls that address, in part, the American Society of Mechanical Engineers (ASME) Code,Section XI inspection requirements for the RVI components.

RAI2-1: RVI Components a) Identify all RVI components in the HBRSEP plant design that are defined in the current licensing basis (CLB) as ASME Section XI, Examination Category B-N-3 core support structure components. For these components, identify which of the four inspection categories in MRP-227 -A is applicable to the component.

b) If a component identified in the reply to Part (a) is defined as either a "Primary Category" or "Expansion Category" component, identify any differences between the inspections that would be performed on the components under MRP-227-A versus the plant's ASME Section XI inservice inspection program.

c) For the components identified in Part (b), clarify how the differences in inspection bases for these components will be reconciled consistent with the CLB for the facility.

RAI2-2: Control Rod Guide Tube (CRGT) a) Clarify whether the CRGT spilt pins are defined as ASME Section XI, Examination Category B-N-3 components for the HBRSEP CLB. If the CRGT split pins are defined in the CLB as ASME Section XI, Examination Category B-N-3 core support structure Enclosure

-2 components, justify why the CRGT split pins would not need to be inspected as a part of the "Existing Program" or in accordance with an augmentation of the PWR Vessel Internals Program.

b) Justify why the response to Applicant/Licensee Action Item No.3 did not specifically address whether the ASME Section XI "Existing Program" bases in the CLB for the CRGT split pins is sufficient for ensuring adequate aging management of the split pins during the period of extended operation. Otherwise, provide a response to the Applicant/Licensee Action Item No. 3 that specifically addresses the adequacy of ASME-Section XI "Existing Program" bases for the CRGT split pins and whether these bases are sufficient to manage aging in the components during the period of extended operation.

RAI 2-3: RVI Hold-Down Spring a) Provide the basis for not identifying the alternative replacement basis for the RVI hold-down spring as a deviation from the MPR-227-A recommended physical measurement basis, thus requiring the deviation to be reported and dispositioned by the Electric Power Research Institute (EPRI) MRP RVI Technical Committee. If a replacement is planned for the hold-down spring, identify the limit on when the replacement activity would need to be implemented and justify the timeframe selected for replacement of the component.

b) Describe plans to manage aging of the replaced RVI hold-down spring. If loss of preload due to stress relaxation or irradiation-assisted creep is still an aging effect that is applicable to the replacement hold-down spring, provide the basis for not needing to implement the physical measurements in MRP-227 -A to the replaced hold-down spring as well. If physical measurements will be performed on the replaced hold-down spring, provide and justify the acceptance criteria that will be applied to the physical measurement results, as recommended in Applicant/Licensee Action Item No.5.

RAI 2-4: Operating Experience a) Describe the programmatic activities that will be used to continually identify plant-specific and industry-aging issues, evaluate them, and, as necessary, enhance the PWR Vessel Internals Program. Identify whether these activities are consistent with the intent outlined in the NRC staff's latest guidance described in the Final License Renewal Interim Staff Guidance LR-ISG-2011-05 "Ongoing review of Operating Experience."

Otherwise, provide a basis for the conclusion that the current operating experience review activities for the AMP will be sufficient to ensure an adequate evaluation of operating experience on an ongoing basis and that the program will be appropriately adjusted, as necessary, to address age-related degradation in the plant's RVI components during the period of extended operation.

b) Provide your basis why the "Operating Experience" program element does not provide a more comprehensive list of sources of relevant operating experience that will be reviewed by the licensee, including operating experience that is discussed in the following sources: (i) Appendix A of the MRP-227-A report (or in periodic updates issued by the EPRI MRP); (ii) NRC issued generic communications, such as NUREG reports,

-3 information notices, generic letters, bulletins, or regulatory information summaries; (iii) applicable vendor reports, such as Westinghouse Commercial Atomic Power reports or vendor-issued degradation summaries; and (iv) PWR Owners Group reports or EPRI MRP reports.

c) Provide the basis for not including in the "Operating Experience" program element, nor evaluating the impact on the PWR Vessel Internals Program, the relevant operating experience associated with Westinghouse-designed flux thimble tubes, thermal shield/core barrel bolting, baffle-to-former bolts, clevis insert bolts/screws, and hold-down springs.

W. Gideon - 2 Please contact me at (301) 415-3302 if you have any questions.

Sincerely.

IRA!

Araceli Billoch Col6n, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket No. 50-261

Enclosure:

Request for Additional Information cc w/encl: Distribution via ListServ DISTRIBUTION:

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