ML20230A205

Relief Request RA-20-0031, Delay to Update the Code of Record for Inservice Inspection

ML20230A205
Person / Time
Site:	McGuire
Issue date:	08/21/2020
From:	Markley M Plant Licensing Branch II
To:	Teresa Ray Duke Energy Carolinas
Gregory Croon-NRR/DORL 301-415-0123
References
EPID L-2019-LLR-0119
Download: ML20230A205 (9)

Text

August 21, 2020 Mr. Thomas D. Ray Site Vice President Duke Energy Carolinas, LLC McGuire Nuclear Station 12700 Hagers Ferry Road Huntersville, NC 28078-8985

SUBJECT:

MCGUIRE NUCLEAR STATION, UNIT 1 - RELIEF REQUEST RA-20-0031, DELAY TO UPDATE THE CODE OF RECORD FOR INSERVICE INSPECTION (EPID L-2019-LLR-0119)

Dear Mr. Ray:

By letter dated December 19, 2019, as superseded by letter dated January 23, 2020, and supplemented by letter dated April 2, 2020, Duke Energy Carolinas, LLC (Duke Energy, the licensee) submitted relief request RA-20-0031 to the U.S. Nuclear Regulatory Commission (NRC) requesting use of an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, at McGuire Nuclear Station (McGuire), Unit 1.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1), the licensee requested to use the proposed alternative on the basis that the alternative provides an acceptable level of quality and safety. The licensee requested to continue to use the 2007 Edition with 2008 Addenda of the ASME Code,Section XI for Class 1, 2, and 3 components and associated supports during the first inspection period of the fifth 10-year inservice inspection (ISI) interval on the basis that the alternative provides an acceptable level of quality and safety.

The NRC staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that Duke Energy has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1). Therefore, the NRC staff authorizes the use of relief request RA-20-0031 for the Class 1, 2, and 3 components and associated supports at McGuire, Unit 1, for the first inspection period of the fifth 10-year ISI interval, which is scheduled to start on December 1, 2021.

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.

T. Ray If you have any questions, please contact the Project Manager, Ed Miller at 301-415-2481 or via e-mail at Ed.Miller@nrc.gov.

Sincerely, Digitally signed by Shawn A. Shawn A. Williams Date: 2020.08.21 Williams 11:23:48 -04'00' Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-369

Enclosure:

Safety Evaluation cc: ListServ

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST RA-20-0031 REGARDING DELAY TO UPDATE THE CODE OF RECORD FOR INSERVICE INSPECTION DUKE ENERGY CAROLINAS MCGUIRE NUCLEAR STATION, UNIT 1 DOCKET NO. 50-369

1.0 INTRODUCTION

By letter dated December 19, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession ML19353C619), as superseded by letter dated January 23, 2020 (ADAMS Accession No. ML20023A272), and supplemented by letter dated April 2, 2020 (ADAMS Accession No. ML20097A026), Duke Energy Carolinas (Duke Energy, the licensee) requested an alternative to certain requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI. In its letter dated January 23, 2020 (RA-20-0031), the licensee proposed to delay updating the inservice inspection (ISI) program code of record for the McGuire Nuclear Station (McGuire), Unit 1, to the latest edition and addenda of the ASME Code,Section XI, that is incorporated by reference into Title 10 of the Code of Federal Regulations (10 CFR) 50.55a until the end of the first inspection period of the fifth 10-year ISI interval.

Specifically, pursuant to 10 CFR 50.55a(z)(1), the licensee proposed to continue to use the 2007 Edition with 2008 Addenda of the ASME Code,Section XI, for Class 1, 2 and 3 components and associated component supports during the first inspection period of the fifth 10-year ISI interval on the basis that the alternative provides an acceptable level of quality and safety.

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.55a(g)(4)(ii), Applicable ISI Code: Successive 120-month interval, states, in part, that Inservice examination of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in paragraph (a) of this section 18 months before the start of the 120-month inspection interval (or the optional ASME Code Cases listed in NRC Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1 (ADAMS Accession No. ML19128A244), when Enclosure

using ASME Code,Section XI, or NRC Regulatory Guide 1.192, when using the ASME OM Code, as incorporated by reference in paragraphs (a)(3)(ii) and (iii) of this section), subject to the conditions listed in paragraph (b) of this section. However, a licensee whose ISI interval commences during the 12 through 18-month period after June 3, 2020, may delay the update of their Appendix VIII program by up to 18 months after June 3, 2020. Alternatively, licensees may, at any time in their 120-month ISI interval, elect to use the Appendix VIII in the latest edition and addenda of the ASME Code incorporated by reference in paragraph (a) of this section, subject to any applicable conditions listed in paragraph (b) of this section. Licensees using this option must also use the same edition and addenda of Appendix I, Subarticle I-3200, as Appendix VIII, including any applicable conditions listed in paragraph (b) of this section.

Pursuant to 10 CFR 50.55a(z), alternatives to the requirements of paragraph (b) through (h) of Section 50.55a or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be submitted and authorized prior to implementation. The licensee must demonstrate that: (1) the proposed alternative would provide an acceptable level of quality and safety; or (2) compliance with the specified requirements of Section 50.55a would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the NRC to authorize the alternative request by the licensee.

3.0 TECHNICAL EVALUATION

3.1 Background

By letter dated August 30, 2010 (ADAMS Accession No. ML102510186), the NRC approved a similar relief request, 10-MN-001, on March 30, 2011 (ADAMS Accession No. ML110550770),

for McGuire, Unit 1, authorizing the licensee to delay updating the Unit 1 ISI program code of record to the later edition and addenda of the ASME Code,Section XI, that is incorporated by reference into 10 CFR 50.55a until the end of the first inspection period of the fourth 10-year ISI interval. The fourth 10-year ISI interval started on December 1, 2011, and is scheduled to end on November 30, 2021.

3.2 Component Affected ASME Code Class 1, 2, and 3 components and associated component supports are affected.

3.3 Applicable Code Edition and Addenda The code of record for the fourth 10-year ISI interval of McGuire, Unit 1, is the 2007 Edition with 2008 Addenda of the ASME Code. The licensee requested to use the same code of record (i.e., 2007 Edition with 2008 Addenda) during the first inspection period of the fifth 10-year ISI interval.

3.4 Regulatory Requirement Pursuant to 10 CFR 50.55a(g)(4)(ii), the ISI program code of record shall be updated to the latest edition and addenda of the ASME Code,Section XI, incorporated by reference in 10CFR 50.55a 12 months before start of the 120-month ISI interval.

3.5 Duration of Relief Request

The licensee submitted Relief Request RA-20-0031 for the first inspection period of the fifth 10-year ISI interval at McGuire, Unit 1. The fifth 10-year ISI interval is scheduled to commence on December 1, 2021, and is scheduled to end on November 30, 2031.

3.6 Proposed Alternative The licensee proposed to continue to use the 2007 Edition with 2008 Addenda of the ASME Code,Section XI, during its first inspection period of the fifth 10-year ISI interval, and to meet all applicable requirements of 10 CFR 50.55a.

As part of relief request RA-20-0031, the licensee proposed to continue to use certain relief requests approved previously by the NRC for the fourth 10-year ISI interval of McGuire, Unit 1, during the first inspection period of the fifth 10-year ISI interval. The approved relief requests include:

NRC safety evaluation dated July 14, 2014 (ADAMS Accession No. ML14188C348), for Relief Request 13-MN-002 (request dated August 13, 2013, ADAMS Accession No. ML13234A069).

NRC safety evaluation dated December 26, 2017 (ADAMS Accession No. ML17331A086), for Relief Request 17-GO-001 (request dated March 29, 2017, ADAMS Accession No. ML17088A846).

NRC safety evaluation dated June 20, 2019 (ADAMS Accession No. ML19128A326), for Relief Request 18-GO-001 (request dated September 6, 2018, ADAMS Accession No. ML18249A008).

NRC safety evaluation dated September 17, 2019 (ADAMS Accession No. ML19254A620), for Relief Request 19-GO-001 (request dated May 20, 2019, ADAMS Accession No. ML19143A072).

3.7 Basis for Use of Alternative The licensee stated that Relief Request RA-20-0031 would facilitate updating the McGuire ISI program code of record to the latest edition and addenda of the ASME Code that is incorporated by reference in 10 CFR 50.55a at the same date. The ASME Code,Section XI, activities (e.g.,

ISI, repair/replacement, pressure testing, and nondestructive examination) for McGuire, Units 1 and 2, are standardized and administered by a centralized ISI organization at Duke Energy.

Use of a common ASME code of record at both units simplifies program administration, requires fewer programs and procedures than would otherwise be needed to implement requirements of different editions and addenda of the ASME Code. Standardizing these programs using a common code of record also minimizes the risk that errors will occur during program development and implementation.

The licensee stated that the continued use of the previous NRC-approved relief requests listed above during the first inspection period of the fifth 10-year ISI interval provide an acceptable level of quality and safety because:

ASME Code Case N-716-1, Alternative Piping Classification and Examination Requirements,Section XI, superseded ASME Code Case N-716, and has been

incorporated by reference into 10 CFR 50.55a via inclusion in RG 1.147, Revision 19, without conditions. The use of Relief Request 13-MN-002 during the first inspection period of the fifth 10-year ISI interval will continue to provide an acceptable level of quality and safety.

ASME Code Case N-831, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic Pipe Section XI, has been incorporated by reference into 10 CFR 50.55a via inclusion in RG 1.147, Revision 19, with a condition that its use is prohibited in new reactor construction. The use of Relief Request 19-GO-001 during the first inspection period of the fifth 10-year ISI interval will continue to provide an acceptable level of quality and safety.

The stress and flaw tolerance analyses documented in Electric Power Research Institute (EPRI) Technical Report 3002007626, Nondestructive Evaluation: Reactor Pressure Vessel Threads in Flange Examination Requirements, are demonstrated to be bounding for the McGuire, Unit 1, RPV flange, thus the inspection of threads in the flange could safely be eliminated. The use of Relief Request 17-GO-001 during the first inspection period of the fifth 10-year ISI interval will continue to provide an acceptable level of quality and safety.

ASME Code Cases N-695-1, Qualification Requirements for Dissimilar Metal Piping Welds,Section XI, and N-696-1, Qualification Requirements for Mandatory Appendix VIII Piping Examinations Conducted from the Inside Surface,Section XI, have been incorporated by reference into 10 CFR 50.55a via inclusion in RG 1.147, Revision 19, without conditions. The use of Relief Request 18-GO-001 during the first inspection period of the fifth 10-year ISI interval will continue to provide an acceptable level of quality and safety.

3.8 NRC Staff Evaluation The NRC staff evaluated Relief Request RA-20-0031 pursuant to 10 CFR 50.55a(z)(1). The NRC staffs evaluation focused on whether (1) there exists major difference between the licensees proposed edition/addenda and the latest editions/addenda of the ASME Code incorporated by reference in Section 50.55a(a); and (2) applicable conditions in Section 50.55a will be met. The NRC staff finds that if these two criteria are met, the proposed alternative provides an acceptable level of quality and safety.

In evaluating the licensees proposed alternative, the NRC staff confirmed that:

The 2017 Edition of the ASME Code,Section XI, has been incorporated by reference in 10 CFR 50.55a. Use of the 2007 Edition with 2008 Addenda as opposed to the 2017 Edition during the first inspection period of the fifth 10-year ISI interval does not affect the integrity of the components because there are no major differences.

The licensee has acknowledged that it will comply with all applicable provisions in 10 CFR 50.55a.

The licensee identified Relief Requests 13-MN-002, 17-GO-001, 18-GO-001, and 19-GO-001 that were initially approved by the NRC for the fourth 10-year ISI interval of McGuire, Unit 1, for use in the first inspection period of the fifth 10-year ISI interval. The

NRC staffs evaluation of each relief request for use in the proposed inspection period is as follows:

o The NRC staff finds that the continued use of Relief Request 13-MN-002 during the first inspection period of the fifth 10-year ISI interval is as safe as using ASME Code Case N-716-1 which is now incorporated by reference into 10 CFR 50.55a via inclusion in RG 1.147, Revision 19, without exceptions or conditions.

o The NRC staff finds that the continued use of Relief Request 17-GO-001 during the first inspection period of the fifth 10-year ISI interval will provide reasonable assurance of the structural integrity of the RPV flange because the stress and flaw tolerance analyses documented in EPRI TR 3002007626 bound the McGuire, Unit 1, RPV flange and are still valid for the duration of the first period of the fifth 10-year ISI interval.

o The NRC staff finds that the continued use of Relief Request 18-GO-001 during the first inspection period of the fifth 10-year ISI interval is as safe as using ASME Code Cases N-695-1 and N-696-1 directly, and these code cases are now incorporated by reference into 10 CFR 50.55a via inclusion in RG 1.147, Revision 19, without conditions.

o The NRC staff finds that the continued use of Relief Request 19-GO-001 during the first inspection period of the fifth 10-year ISI interval is as safe as using ASME Code Case N-831 directly because this code case is now incorporated by reference into 10 CFR 50.55a via inclusion in RG 1.147, Revision 19, with a condition that its use is prohibited in new reactor construction.

Based on the above, the NRC staff finds that extending the duration of the above four relief requests to the end of the first inspection period of the fifth 10-year ISI interval is acceptable and does not impact safety.

Based on the above, the NRC staff determined that the licensees proposed alternative (i.e., use of the 2007 Edition with 2008 Addenda of the ASME Code and the above four relief requests) in the first inspection period of the fifth 10-year ISI interval is acceptable, and provides reasonable assurance of structural integrity and safety.

4.0 CONCLUSION

As set forth above, the NRC staff concludes that the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed the regulatory requirements set forth in 10 CFR 50.55a(z)(1).

Therefore, the NRC staff authorizes the use of relief request RA-20-0031 for the Class 1, 2, 3 components and associated supports at McGuire, Unit 1, for the first inspection period of the fifth 10-year ISI interval, which is scheduled to start on December 1, 2021.

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: Michael Farnan, NRR Date: August 21, 2020

ML20230A205 *By Memorandum **By Email OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NAME GCroon EMiller*** KGoldstein**

DATE 8/18/2020 8/18/2020 08/18/2020 OFFICE NRR/DNRL/NPHP/BC NRR/DORL/LPL2-1/ABC NAME MMitchell* MMarkley (SWilliams for)*

DATE 7/21/2020 8/21/2020