RA-20-0262, Duke Energy - Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI

Duke Energy - Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI

ML20260H325
Person / Time
Site:	Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire
Issue date:	09/16/2020
From:	Snider S Duke Energy Carolinas, Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0262
Download: ML20260H325 (5)

Text

Steve Snider Vice President Nuclear Engineering 526 South Church Street, EC-07H Charloote, NC 28202 980-373-6195 Steve.Snider@duke-energy.com Serial: RA-20-0262 10 CFR 50.55a September 16, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2, DOCKET NOS. 50-325, 50-324 CATAWBA NUCLEAR STATION, UNITS 1 AND 2, DOCKET NOS. 50-413, 50-414 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, DOCKET NOS. 50-369, 50-370 OCONEE NUCLEAR STATION, UNITS 1, 2 AND 3, DOCKET NOS. 50-269, 50-270, 50-287 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2, DOCKET NO. 50-261 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1, DOCKET NO. 50-400

Subject:

Request to Use a Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI

Reference:

NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section Xl," dated July 28, 2004.

In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv), and the guidance provided in the referenced document, Duke Energy Carolinas, LLC and Duke Energy Progress, LLC (hereafter referred to collectively as Duke Energy) request NRC approval to use a specific provision of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, for the units identified above. Specifically, Duke Energy requests approval to use IWA-4540(b) of the 2017 Edition of the ASME B&PV Code. The request is provided as the Attachment to this submittal.

Based upon the approval date of the precedent listed in the Attachment, Duke Energy requests approval of this request by November 30, 2020. There are no regulatory commitments in this letter.

U.S. Nuclear Regulatory Commission Request to Use a Provision of a Later Addenda of the ASME B&PV Code,Section XI Page 2 If you have any questions concerning this letter, please contact Art Zaremba, Manager -

Fleet Licensing at (980) 373-2062.

Respectfully, Steve Snider Vice President - Nuclear Engineering

Attachment:

Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI cc: L. Dudes, Regional Administrator USNRC Region II G. Smith, USNRC Senior Resident Inspector - BNP J. D. Austin, USNRC Senior Resident Inspector - CNS J. Zeiler, USNRC Senior Resident Inspector - HNP G. A. Hutto, USNRC Senior Resident Inspector - MNS J. Nadel, USNRC Senior Resident Inspector - ONS M. Fannon, USNRC Senior Resident Inspector - RNP A. Hon, NRR Project Manager

Attachment Request to Use a Portion of a Later Edition of the ASME B&PV Code,Section XI

Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)

Page 1 In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv) and the guidance provided in Reference 1, Duke Energy requests NRC approval to use specific provisions of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, for Brunswick Steam Electric Plant, Catawba Nuclear Station, McGuire Nuclear Station, Oconee Nuclear Station, H.B. Robinson Steam Electric Plant and Shearon Harris Nuclear Power Plant all units. Specifically, Duke Energy requests approval to use IWA-4540(b) of the 2017 Edition of the ASME B&PV Code.

ASME Code Component(s) Affected:

All Class 1, 2, and 3 items located in the ASME Section XI boundaries.

Requested Date for Approval:

Approval requested by , 2020

Applicable Code Edition and Addenda

ISI ASME Section XI Code Plant/Unit(s) Interval Start Date Interval End Date1 Interval Edition/Addenda Brunswick Steam Electric 2007 Edition, Through Fifth 05/11/2018 05/10/2028 Plant, Units 1 and 2 2008 Addendum Catawba Nuclear Station, 2007 Edition, Through 12/06/2024 (Unit 1)

Fourth 08/19/2015 Units 1 and 2 2008 Addendum 02/24/2026 (Unit 2)

H.B. Robinson Steam 2007 Edition, Through Fifth 07/21/2012 02/19/2023 Electric Plant, Unit 2 2008 Addendum McGuire Nuclear Station, 2007 Edition, Through 12/01/2011 (Unit 1) 11/30/2021 (Unit 1)

Fourth Units 1 and 2 2008 Addendum 07/15/2014 (Unit 2) 02/29/2024 (Unit 2)

Oconee Nuclear Station, 2007 Edition, Through Fifth 07/15/2014 07/15/2024 Units 1, 2, and 3 2008 Addendum Shearon Harris Nuclear 2007 Edition, Through Fourth 09/09/2017 09/08/2027 Power Plant, Unit 1 2008 Addendum Note 1: Date listed is the currently planned interval end date. In accordance with IWA-2430(c)(1), this end date may be extended or shortened as necessary.

4. Proposed Subsequent Code Edition and Addenda (or Portion):

All Duke Energy nuclear plants perform Repair/Replacement activities in accordance with a standardized fleet program. This standardized program is based on an Edition of ASME Section XI which, at present, is the 2007 Edition through the 2008 Addenda.

Pursuant to 10 CFR 50.55a(g)(4)(iv), Duke Energy requests permission to utilize IWA-4540(b) from the 2017 Edition. This subparagraph outlines items that are exempt from pressure testing after repair/replacement activities.

Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)

Page 2

5. Related Requirements:

10 CFR 50.55a(g)(4)(iv) states:

Inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (a) of this section, subject to the conditions listed in paragraph (b) of this section, and subject to Commission approval. Portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met.

10 CFR 50.55a(b)(2) incorporates by reference Section XI, Division 1, of the ASME B&PV Code 2017 Edition as approved in Reference 3. Duke Energy is requesting to use of IWA-4540(b) of the 2017 Edition of ASME Section XI to utilize the exemptions listed. There are no related requirements or applicable conditions associated with this subparagraph, IWA-4540(b).

Duration of Proposed Request:

The duration of this will continue for the remainder of the sites current Inservice Inspection interval.

References:

NRC Regulatory Issue Summary 2004-12, Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section Xl, dated July 28, 2004.

U.S. Nuclear Regulatory Commission Memorandum from D. Rudland (Senior Level Advisor, Division of New and Renewed Licenses) to Anna H. Bradford (Director, Division of New and Renewed Licenses), Summary of the June 25, 2020, Public Meeting with the Nuclear Industry to Discuss Title 10 of the Code of Federal Regulations Section 50.55a(b)(2)(xxvi) Condition on the Pressure Testing of Class 1, 2, and 3 Mechanical Joints, dated July 8, 2020 (ML20189A286)

Federal Register, 85 FR 26540, dated May 4, 2020 Precedents