ML19288A294

NRR E-mail Capture - RAIs for Robinson Revision to RPV Surveillance Program Withdrawal Schedule

ML19288A294
Person / Time
Site:	Robinson
Issue date:	10/15/2019
From:	Natreon Jordan NRC/NRR/DORL/LPL2-2
To:	Zaremba A Duke Energy Carolinas
References
Download: ML19288A294 (3)

Text

NRR-DRMAPEm Resource From: Jordan, Natreon Sent: Tuesday, October 15, 2019 2:01 PM To: Zaremba, Arthur H.

Cc: Barillas, Martha; Gonzalez, Hipolito

Subject:

Draft Requests for Additional Information for H.B. Robinson LAR Regarding the Revision to the Reactor Pressure Vessel (RPV) Material Surveillance Program Withdrawal Schedule - RPV Surveillance Capsule Removal Attachments: EPID L-2019-LLL-0021 - RAI - Robinson Capsule U Request - Staff RAIs 10-15-2019 DA.docx Mr. Zaremba, By letter dated May 2, 2019 (Agencywide Documents Access and Management System Accession No. ML19122A012), Duke Energy (the licensee) submitted a request for NRC approval of a proposed revision to the reactor pressure vessel (RPV) surveillance capsule removal schedule for the H.B. Robinson Steam Electric Plant, Unit 2 Facility (Robinson). Specifically, the licensee proposes to allow the following regulatory commitment:

RPV Capsule U will be withdrawn at 41.3 effective full-power years (EFPY) or during the scheduled outage after the 80-year peak vessel fluence is reached, but prior to 57.1 EFPY.

to replace the existing commitment to allow the capsule to be withdrawn at 38.0 EFPY or during the scheduled outage after the 80-year peak vessel fluence is reached. To complete its review, the U.S. Nuclear Regulatory Commission (NRC) staff has prepared the attached requests for additional information (RAIs) in DRAFT form.

If a clarification call is needed by the licensee to discuss the attached draft RAIs and the due date for the RAI responses, please contact either Martha Barillas by email or at 301-415-2760, or myself at 301-415-7410. The NRC request response to the RAIs within 30 days of this email in order to support your license amendment request. If you do not believe you can meet the response date, please provide an acceptable alternate date and justification for extending the response date.

Thanks,

-Nate Natreon (Nate) Jordan Nuclear Engineer (Project Manager)

Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8B1A Washington, DC 20555 301-415-7410 natreon.jordan@nrc.gov 1

Hearing Identifier: NRR_DRMA Email Number: 266 Mail Envelope Properties (BN6PR09MB1236F367DA919754F2B4130D8A930)

Subject:

Draft Requests for Additional Information for H.B. Robinson LAR Regarding the Revision to the Reactor Pressure Vessel (RPV) Material Surveillance Program Withdrawal Schedule -

RPV Surveillance Capsule Removal Sent Date: 10/15/2019 2:00:43 PM Received Date: 10/15/2019 2:00:00 PM From: Jordan, Natreon Created By: Natreon.Jordan@nrc.gov Recipients:

"Barillas, Martha" <Martha.Barillas@nrc.gov>

Tracking Status: None "Gonzalez, Hipolito" <Hipolito.Gonzalez@nrc.gov>

Tracking Status: None "Zaremba, Arthur H." <Arthur.Zaremba@duke-energy.com>

Tracking Status: None Post Office: BN6PR09MB1236.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1796 10/15/2019 2:00:00 PM EPID L-2019-LLL-0021 - RAI - Robinson Capsule U Request - Staff RAIs 10-15-2019 DA.docx 41737 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 10 CFR PART 50, APPENDIX H WITHDRAWAL SCHEDULE CHANGE REQUEST DUKE ENERGY COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 DOCKET NUMBER 50-261 EPID: L-2019-LLL-0021 By letter dated May 2, 2019 (Agencywide Document Access and Management System (ADAMS) Accession No. ML19122A012), Duke Energy Company (the licensee) submitted a reactor pressure vessel (RPV) material surveillance program withdrawal schedule change for the H. B Robinson Steam Electric Plant, Unit 2. The licensee submitted its request in accordance with the reporting requirements specified in the 10 CFR Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements (Appendix H).

Specifically, the licensee proposes to amend the time for withdrawing RPV Capsule U from the reactor from 38 effective full power years (EPFY), when the capsule is projected to achieve an approximate neutron fluence exposure (at the time of removal) of 7.84 x 1019 n/cm2 (E > 1.0 MeV), to 41.3 EFPY, when the capsule is projected to achieve an approximate neutron fluence exposure of 8.09 x 1019 n/cm2 (E > 1.0 MeV). The licensees submittal includes the following regulatory commitment (Commitment #1 in the submittal) in relation to the proposed capsule withdrawal schedule change:

Capsule U will be withdrawn at 41.3 effective full-power years (EFPY) or during the scheduled outage after the 80-year peak vessel fluence is reached, but prior to 57.1 EFPY.

Based on its review of the incoming submittal and the stated commitment, it is not clear when Capsule U will be withdrawn in accordance with the proposed withdrawal schedule for the capsule. For example, according to Section 4.0 of the licensees submittal, Capsule U will be withdrawn at either 41.3 EFPY (at a capsule fluence exposure of 8.09 x 1019 n/cm2 (E > 1.0 MeV)) or during the scheduled outage after the capsule has achieved a neutron fluence exposure equivalent to the peak neutron fluence projected in the RPV at 80 years of operation.

However, per Note 1 on the proposed capsule withdrawal schedule and the commitment statement, the withdrawal of Capsule U could be deferred out to 57.1 EFPY. Given the uncertainty in the proposed withdrawal time for Capsule U, it is not evident how the proposed schedule meets the withdrawal schedule criteria of Appendix H.

RAI-1

Please provide clarification as to how the proposed withdrawal schedule for Capsule U meets the requirements of Appendix H or modify the proposal to provide clarity concerning the proposed schedule.