ML13249A000

NRR E-mail Capture - Robinson, Unit 2 PWR Vessel Internal Program Plan for Aging Management - Requests for Additional Information (Rais) (TAC No. ME9633) - Correction to RAI-3-3

ML13249A000
Person / Time
Site:	Robinson
Issue date:	09/05/2013
From:	Siva Lingam Plant Licensing Branch II
To:	Hightower R Progress Energy Co
References
ME9633
Download: ML13249A000 (3)

Text

NRR-PMDAPEm Resource From: Lingam, Siva Sent: Thursday, September 05, 2013 2:16 PM To: richard.hightower@pgnmail.com Cc: Broaddus, Doug; Rosenberg, Stacey; Cheruvenki, Ganesh; Alexander, Donna (Donna.Alexander@duke-energy.com); Poehler, Jeffrey; Jenkins, Joel

Subject:

Robinson, Unit 2 PWR Vessel Internal Program Plan for Aging Management - Requests for Additional Information (RAIs) (TAC No. ME9633) - Correction to RAI-3-3 As a result of the conference call yesterday, please note the correction in red for RAI-3-3.

From: Lingam, Siva Sent: Tuesday, August 27, 2013 10:36 AM To: richard.hightower@pgnmail.com Cc: Broaddus, Doug; Rosenberg, Stacey; Cheruvenki, Ganesh; Alexander, Donna (Donna.Alexander@duke-energy.com)

Subject:

Robinson, Unit 2 PWR Vessel Internal Program Plan for Aging Management - Requests for Additional Information (RAIs) (TAC No. ME9633)

Please note the following official RAIs for the subject matter. Please provide your responses as early as possible.

REQUEST FOR ADDITIONAL INFORMATION ON AGING MANAGEMENT PROGRAM FOR THE REACTOR VESSEL INTERNALS AT H. R. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 PROGRESS ENERGY INC.

DOCKET NUMBER 50-261 By letter dated September 26, 2012 (Agencywide Documents Access and Management (ADAMS) Accession No. ML12278A398), as supplemented by letters dated May 23, 2013 (ADAMS Accession No. ML13156A144) and July 25, 2013 (ADAMS Accession No. ML13219A252), Carolina Power and light Company (currently known as Duke Energy Progress, inc.) (the licensee), submitted an aging management program (AMP) for the reactor vessel internals (RVI) at H.B. Robinson Steam Electric Plant, also known as Robinson Nuclear plant (RNP). The Materials Reliability Program (MRP)-227-A report, Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, (ADAMS Accession No. ML120170453) and its supporting reports were used as technical bases for developing Robinsons AMP. The Nuclear Regulatory Commission (NRC) staff reviewed this report and issued a final safety evaluation (SE) on December 16, 2011 (ADAMS Accession No. ML11334A009). The NRC staff has developed a third set of RAIs as addressed below, and it includes issues related to Action Item 1 of the staffs SE for the MRP-227-A.

RAI-3-1 (Action Item 1 of the NRC staffs SE for MRP-227-A):

The NRC staff and EPRI met on November 28, 2012 (ADAMS Accession No. ML13014A672), January 22-23, 2013 (ADAMS Accession No. ML13042A048), and February 25, 2013 (ADAMS Accession No. ML13067A262) to facilitate development of a generic approach for resolution of Applicant/Licensee Action Item 1. As discussed in References 1 and 2, the NRC staff requests the licensee to provide the following information related to verification of the applicability of MRP-227-A to RNP. This is the initial RAI for Action Item 1.

1. Do the RNP RVI have non-weld or bolting austenitic stainless steel components with 20% cold work or greater, and if so do the affected components have operating stresses greater than 30 ksi? If so, perform a plant-specific evaluation to determine the aging management requirements for the affected components.

1

2. Have RNP ever utilized atypical fuel design or fuel management that could make the assumptions of MRP-227-A regarding core loading/core design non-representative for that plant, including power changes/uprates? If so, describe how the differences were reconciled with the assumptions of MRP-227-A or provide a plant-specific aging management program for affected components as appropriate.

RAI-3-2: In response to staffs RAI-5 (a) dated March 27, 2013 (ADAMS Accession No. ML13079A293), the licensee, by a letter dated May 23, 2013, provided a response which addresses the issue related to neutron embrittlement and irradiation induced stress corrosion cracking in cast austenitic stainless steel (CASS) lower support column bodies at RNP. The licensee stated that plant-specific acceptance criteria, WCAP-17254-P, were developed by Westinghouse and the acceptance criteria will demonstrate functionality of the CASS lower support column bodies at RNP. MRP-227-A, Section 4.2.7, requires the plant-specific analysis for Licensee Action Item 7 demonstrating that the lower support column bodies will maintain their functionality during the period of extended operation (PEO) to be submitted along with a licensees submittal to apply the approved version of MRP-227. This analysis was not provided with the licensees submittal of the RVI Inspection Plan for RNP. Therefore, the NRC staff requests that the licensee submit WCAP-17254-P as part of the RVI AMP, for review and approval. Without an approved analysis, the NRC staff would not have reasonable assurance of the functionality of the lower support columns for the PEO. Therefore, the NRC staff requests the licensee to inspect the lower support column bodies during the initial inspections if WCAP-17254-P showed that these lower support column bodies (expansion components) could not maintain their intended function during PEO, or if the staff could not review and approve the analysis prior to the initial inspections of the relevant primary components.

RAI-3-3: In its response to the NRC staffs RAI-3, dated March 27, 2013, the licensee by a letter dated May 23, 2013, stated that Alloy X-750 material that is used for clevis insert bolts did not receive high temperature heat treatment (HTH) and, therefore, this material might be susceptible to primary water stress corrosion cracking (PWSCC). Appendix A to MRP-227-A indicates that failures of Alloy X-750 clevis insert bolts were reported by one Westinghouse-designed plant in 2010. Appendix A to MRP-227-A also stated that the most likely cause for failure was PWSCC. A recent metallurgical analysis of bolts removed from this plant confirmed that the bolts cracked due to PWSCC. The only aging mechanism requiring management by MRP-227-A for the clevis insert bolts is wear. The clevis insert bolts are categorized as an Existing Programs component under MRP-227-A, with the ASME Code,Section XI Inservice Inspection Program credited for managing aging due to wear only. The ASME Code,Section XI specifies a VT-3 visual inspection for the clevis insert bolts which may not be adequate to detect cracking before it results in bolt failure. Therefore, the licensee is requested to discuss if it will modify the MRP-227-A inspection requirement for clevis insert bolts to require an inspection that will detect cracking. If the inspection requirement is not modified, provide a technical justification for the adequacy of the existing VT-3 visual inspection requirement to detect cracking before it results in clevis insert bolt failure.

References:

1. Meeting Summary EPRI-Westinghouse January 22-23, 2013, February 21, 2013 (ADAMS Accession No. ML13042A048).

2. 2/25/2013 Summary of Telecon with EPRI and Westinghouse Electric Company, March 15, 2013 (ADAMS Accession No. ML13067A262).

Siva P. Lingam U.S. Nuclear Regulatory Commission Project Manager (NRR/DORL/LPL2-2)

Sequoyah Nuclear Plant St. Lucie Plant Robinson Steam Electric Plant Location: O8-D5; Mail Stop: O8-G9a Telephone: 301-415-1564; Fax: 301-415-1222 E-mail address: siva.lingam@nrc.gov 2

Hearing Identifier: NRR_PMDA Email Number: 827 Mail Envelope Properties (Siva.Lingam@nrc.gov20130905141500)

Subject:

Robinson, Unit 2 PWR Vessel Internal Program Plan for Aging Management -

Requests for Additional Information (RAIs) (TAC No. ME9633) - Correction to RAI-3-3 Sent Date: 9/5/2013 2:15:41 PM Received Date: 9/5/2013 2:15:00 PM From: Lingam, Siva Created By: Siva.Lingam@nrc.gov Recipients:

"Broaddus, Doug" <Doug.Broaddus@nrc.gov>

Tracking Status: None "Rosenberg, Stacey" <Stacey.Rosenberg@nrc.gov>

Tracking Status: None "Cheruvenki, Ganesh" <Ganesh.Cheruvenki@nrc.gov>

Tracking Status: None "Alexander, Donna (Donna.Alexander@duke-energy.com)" <Donna.Alexander@duke-energy.com>

Tracking Status: None "Poehler, Jeffrey" <Jeffrey.Poehler@nrc.gov>

Tracking Status: None "Jenkins, Joel" <Joel.Jenkins@nrc.gov>

Tracking Status: None "richard.hightower@pgnmail.com" <richard.hightower@pgnmail.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 6996 9/5/2013 2:15:00 PM Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: