ML21029A335
| ML21029A335 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire  |
| Issue date: | 02/16/2021 |
| From: | Undine Shoop Plant Licensing Branch II |
| To: | Snider S Duke Energy Corp |
| Hon A | |
| References | |
| EPID L-2020-LLR-0126 | |
| Download: ML21029A335 (8) | |
Text
February 16, 2021 Mr. Steve Snider Vice President Nuclear Engineering Duke Energy 526 South Church Street, EC-07H Charlotte, NC 28202
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2; CATAWBA NUCLEAR STATION, UNITS 1 AND 2; H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2; MCGUIRE NUCLEAR STATION, UNITS 1 AND 2; OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3; AND SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 - REQUEST TO USE A PROVISION OF A LATER EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI (EPID L-2020-LLR-0126)
Dear Mr. Snider:
The U.S. Nuclear Regulatory Commission (NRC) has approved your request to use a provision of a later edition of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, for Brunswick Steam Electric Plant, Units 1 and 2; Catawba Nuclear Station, Units 1 and 2; H. B. Robinson Steam Electric Plant, Unit 2; McGuire Nuclear Station, Units 1 and 2; Oconee Nuclear Station, Units 1, 2, and 3; and Shearon Harris Nuclear Power Plant, Unit 1. This action is in response to your request RA-20-0191, dated September 21, 2020 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML20265A028).
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv),
Duke Energy Carolinas, LLC and Duke Energy Progress, LLC (hereafter referred to collectively as Duke Energy), proposed to use paragraphs IWA-5120, IWA-5213, IWA-5241, IWA-5242, and IWA-5250 of the 2017 Edition of the ASME B&PV Code,Section XI, for pressure testing of Class 1, Class 2, and Class 3 systems.
The NRC staff approves the use of paragraphs IWA-5120, IWA-5213, IWA-5241, IWA-5242, and IWA-5250 of the 2017 Edition of ASME B&PV Code,Section XI, for pressure testing of Class 1, Class 2, and Class 3 systems for the Fourth 10-Year Inservice Inspection (ISI) interval for Catawba Nuclear Station, Units 1 and 2, that started on August 19, 2015, and ends on December 6, 2024 (Unit 1) and February 24, 2026 (Unit 2); McGuire Nuclear Station, Units 1 and 2, that started on December 1, 2011 (Unit 1) and July 15, 2014 (Unit 2) and ends on November 30, 2021 (Unit 1) and February 29, 2024 (Unit 2); and Shearon Harris Nuclear Power Plant, Unit 1, that started on September 9, 2017, and ends on September 8, 2027; and the Fifth 10-year ISI interval for Brunswick Steam Electric Plant, Units 1 and 2, that started on May 11, 2018, and ends on May 10, 2028; H. B. Robinson Steam Electric Plant, Unit 2, that started on July 21, 2012, and ends on February 19, 2023; and Oconee Nuclear Station, Units 1, 2, and 3, that started on July 15, 2014, and ends on July 15, 2024.
All other ASME B&PV Code,Section XI, requirements which are not modified by the NRC staffs approval of the licensees request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact the Duke Fleet Project Manager, Andrew Hon at 301-415-8480 or via e-mail at Andrew.Hon@nrc.gov or Michael Mahoney at 301-415-3867 or via email at Michael.Mahoney@nrc.gov.
Sincerely, Undine S. Shoop, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-261, 50-269, 50-270, 50-287, 50-324, 50-325, 50-369, 50-370, 50-400, 50-413, and 50-414
Enclosure:
Safety Evaluation cc:
Mr. J. Ed Burchfield, Jr.
Site Vice President Oconee Nuclear Station Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672-0752 Mr. Ernest J. Kapopoulos, Jr.
Site Vice President H. B. Robinson Steam Electric Plant Duke Energy Progress, LLC 3581 West Entrance Road, RNPA01 Hartsville, SC 29550 Mr. John A. Krakuszeski Site Vice President Brunswick Steam Electric Plant Duke Energy Progress, LLC 8470 River Rd. SE (M/C BNP001)
Southport, NC 28461 Ms. Kim Maza Site Vice President Shearon Harris Nuclear Power Plant Duke Energy Progress, LLC 5413 Shearon Harris Road Mail Code NHP01 New Hill, NC 27562-9300 Mr. Tom Ray Site Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078 Mr. Robert T. Simril Site Vice President Catawba Nuclear Station Duke Energy Carolinas, LLC Catawba Nuclear Station 4800 Concord Road York, SC 29745 Additional Distribution via Listserv Undine S.
Shoop Digitally signed by Undine S. Shoop Date: 2021.02.16 08:58:20 -05'00'
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST RA-20-0191 - REQUEST TO USE A PROVISION OF A LATER EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE DUKE ENERGY CAROLINAS, LLC CATAWBA NUCLEAR STATION, UNITS 1 AND 2 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 DUKE ENERGY PROGRESS, LLC BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 DOCKET NOS. 50-413, 50-414, 50-369, 50-370, 50-269, 50-270, 50-287, 50-324, 50-325, 50-261, and 50-400
1.0 INTRODUCTION
By letter RA-20-191, dated September 21, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20265A028), Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC (Duke Energy or the licensee) requested U.S. Nuclear Regulatory Commission (NRC) approval to use specific provisions of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (B&PV Code) for Brunswick Steam Electric Plant, Units 1 and 2, Catawba Nuclear Station, Units 1 and 2, McGuire Nuclear Station, Units 1 and 2, Oconee Nuclear Station, Units 1, 2, and 3, H. B. Robinson Steam Electric Plant, Unit 2, and Shearon Harris Nuclear Power Plant, Unit 1.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv),
and guidance provided in NRC Regulatory Issue Summary (RIS) 2004-12, Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI, dated July 28, 2004 (ADAMS Accession No. ML042090436), the licensee proposed to use paragraphs IWA-5120, IWA-5213, IWA-5241, IWA-5242, and IWA-5250 of the 2017 Edition of the ASME B&PV Code,Section XI, for pressure testing of Class 1, Class 2, and Class 3 systems.
2.0 REGULATORY EVALUATION
Regulatory Requirements The licensee is proposing to use a section of a later edition and addenda of the ASME B&PV Code,Section XI, in accordance with 10 CFR 50.55a(g)(4)(iv), Applicable ISI [inservice inspection] Code: Use of subsequent Code editions and addenda, which 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.
Given that 10 CFR 50.55(g)(4)(iv) permits the NRC to approve the use of subsequent ASME B&PV Code edition and addenda, the NRC staff finds that subject to the following technical evaluation, the licensee may propose to use a section of a later edition and addenda of the ASME B&PV Code,Section XI, and the NRC staff has the regulatory authority to approve the later edition and addenda of the ASME B&PV Code,Section XI.
Guidance NRC RIS 2004-12, Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI clarifies the requirements for ISI when using later editions and addenda of the ASME B&PV Code,Section XI, as required by 10 CFR 50.55a(g)(4)(iv).
3.0 NRC TECHNICAL EVALUATION 3.1 Proposed Use of Subsequent Code Edition Duke Energy proposes to utilize portions of the ASME B&PV Code Section XI, 2017 Edition in lieu of the 2007 Edition up to and including the 2008 Addenda. Until the 2017 Edition was published, the ASME B&PV Code,Section XI code did not contain requirements for pressure testing pneumatic safety-related systems. Additionally, the 2017 Edition provides exemptions for periodic system pressure tests, clarifications for test condition hold times, and incorporates clarification for systems borated for the purpose of controlling reactivity.
3.2 Component(s) for Which the Subsequent Code Edition is Requested Duke Energy stated the affected components are all pressure-retaining components subject to pressure testing requirements of Examination Category B-P for Class 1, Category C-H for Class 2, and Category D-B for Class 3.
3.3 Current Code Edition and Addenda of Record The Code of Record for the current 10-year ISI interval at the subject plants is ASME Code,Section XI, 2007 Edition with the 2008 Addenda.
3.4 Proposed Subsequent Code Edition and Addenda:
Duke Energy proposes to utilize portions of the ASME B&PV Code Section XI, 2017 Edition in lieu of the ASME B&PV Code Section XI, 2007 Edition up to and including the 2008 Addenda.
Specifically, Duke Energy requests approval to use Articles IWA-5120, IWA-5213, IWA-5241, IWA-5242, and IWA-5250 for pressure testing of Class 1, 2, and 3 systems. The licensee stated that until the 2017 Edition of the Code was published, ASME B&PV Code,Section XI did not contain requirements for pressure testing pneumatic safety-related systems. Additionally, the 2017 Edition of the ASME B&PV Code provides exemptions for periodic system pressure tests, clarification for test condition hold times, and incorporates clarification for systems borated for the purpose of controlling reactivity. The affected ASME B&PV,Section XI, Examination Categories are B-P for Class 1, C-H for Class 2, and D-B for Class 3.
3.5 Duration of the Use of the Later Code Edition and Addenda The licensee is requesting approval of this proposed alternative for the remainder of the 10-year ISI intervals, as shown in Table 1 below.
Table 1 Plant/Unit(s)
ISI Interval Interval Start Date Current Planned Interval End Date Brunswick Steam Electric Plant, Units 1 and 2 Fifth 05/11/2018 05/10/2028 Catawba Nuclear Station, Units 1 and 2 Fourth 08/19/2015 12/06/2024 (Unit 1) 02/24/2026 (Unit 2)
H. B. Robinson Steam Electric Plant, Unit 2 Fifth 07/21/2012 02/19/2023 McGuire Nuclear Station, Units 1 and 2 Fourth 12/01/2011 (Unit 1) 07/15/2014 (Unit 2) 11/30/2021 (Unit 1) 02/29/2024 (Unit 2)
Oconee Nuclear Station, Units 1, 2, and 3 Fifth 07/15/2014 07/15/2024 Shearon Harris Nuclear Power Plant, Unit 1 Fourth 09/09/2017 09/08/2027 3.6
NRC Staff Evaluation
The 2017 edition of the ASME B&PV Code,Section XI, paragraph IWA-5120, Periodic System Pressure Test Exemptions, provides systems and components, which are exemption from the periodic pressure test requirement.
The 2017 edition of the ASME B&PV Code,Section XI, paragraph IWA-5213, Test Condition Holding Times, describes the holding time after pressurization to test conditions, before the visual examinations commence.
The 2017 edition of the ASME B&PV Code,Section XI, paragraph IWA-5241, Insulated and Noninsulated Components specifies visual examination requirements for insulated and non-insulated components.
The 2017 edition of the ASME B&PV Code,Section XI, paragraph IWA-5242, Pneumatic Components provides the requirements for leakage tests in lieu of VT-2 visual examinations.
The 2017 edition of the ASME B&PV Code,Section XI, paragraph IWA-5250, Corrective Action provides the steps required for corrective action of leaks in components.
As previously stated in Section 2.0 of this safety evaluation, prior to approving the use of a subsequent edition and addenda of the ASME B&PV Code under 10 CFR 50.55a(g)(4)(iv), the NRC staff must find that (1) the proposed subsequent edition and addenda are incorporated by reference in 10 CFR 50.55a(a); (2) the licensee has identified any conditions listed in 10 CFR 50.55a(b) appropriate to the request and will comply with those conditions; (3) the licensee has requested approval to use the subsequent edition and addenda; and (4) if only portions of edition or addenda are to be used, all related requirements of the respective edition or addenda are met. If these criteria are met, the NRC staff finds the use of the subsequent edition and addenda of the ASME B&PV Code,Section XI, to be acceptable.
3.6.1 Incorporation by Reference The first criterion is that the edition and addenda of the ASME B&PV Code,Section XI, that will be used by the licensee in the proposed request is incorporated by reference in 10 CFR 50.55a(b). Currently, the latest edition and addenda incorporated by reference in 10 CFR 50.55a(b)(2) is the 2017 Edition, which is the edition that the licensee proposed to use in their request. Therefore, the NRC staff finds that the proposed request satisfies the first criterion.
3.6.2 Subject to Conditions Listed in 10 CFR 50.55a(b)
The second criterion is that the licensee has identified any conditions listed in 10 CFR 50.55a(b) appropriate to the request and will comply with those conditions. The licensee stated in their request that Duke Energy will adhere to any conditions that apply to pressure testing as it relates to 10 CFR 50.55a(b). Therefore, the NRC staff finds that the proposed request satisfies the second criterion 3.6.3 Requesting Commission Approval The third criterion is that the licensee needs to request approval to use the subsequent edition and addenda of the ASME B&PV Code,Section XI. The NRC staff has determined that the licensees request dated September 21, 2020, constitutes a request to the Commission for approval to use a subsequent edition/addendum of the ASME B&PV Code,Section XI.
Therefore, the NRC staff finds that the proposed request satisfies the third criterion.
3.6.4 All Related Requirements The fourth criterion is if only portions of edition or addenda are to be used, all related requirements of the respective edition or addenda are met. The NRC staff has reviewed article IWA-5000of the 2017 Edition of the ASME B&PV Code,Section XI to determine whether other relevant provisions in article IWA-5000 of the 2017 Edition of the ASME B&PV Code,Section XI would affect the proposed use of paragraphs IWA-5120, IWA-5213, IWA-5241, IWA-5242, and IWA-5250. The NRC staff has determined that no other related changes, which were introduced when IWA-5120, IWA-5213, IWA-5241, IWA-5242, and IWA-5250 were adopted in the 2017 Edition of the ASME B&PV Code, that the licensee would need to implement as a result of their request. Therefore, the NRC staff finds that the proposed request satisfies the fourth criterion.
3.6.5 NRC Staff Evaluation Summary The NRC staff determines that the licensee has identified the affected components, the ASME code of records for each unit, the appropriate regulation, and the duration of the request.
Based on the review above, the NRC staff finds that the licensee has adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv).
5.0 CONCLUSION
As set forth above, NRC staff finds that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv). Therefore, the NRC staff concludes that the use of paragraphs IWA-5120, IWA-5213, IWA-5241, IWA-5242, and IWA-5250 of the 2017 Edition of the ASME B&PV Code,Section XI, is acceptable. The NRC staff, therefore, approves the use of paragraphs IWA-5120, IWA-5213, IWA-5241, IWA-5242, and IWA-5250 of the 2017 Edition of the ASME B&PV Code,Section XI for the remainder of the Fourth 10-Year ISI interval for Catawba Nuclear Station, Units 1 and 2, that started on August 19, 2015, and ends on December 6, 2024 (Unit 1) and February 24, 2026 (Unit 2); McGuire Nuclear Station, Units 1 and 2, that started on December 1, 2011 (Unit 1) and July 15, 2014 (Unit 2) and ends on November 30, 2021 (Unit 1) and February 29, 2024 (Unit 2); and Shearon Harris Nuclear Power Plant, Unit 1, that started on September 9, 2017, and ends on September 8, 2027; and the remainder of the Fifth 10-year ISI interval for Brunswick Steam Electric Plant, Units 1 and 2, that started on May 11, 2018, and ends on May 10, 2028; H. B. Robinson Steam Electric Plant, Unit 2, that started on July 21, 2012, and ends on February 19, 2023; and Oconee Nuclear Station, Units 1, 2, and 3, that started on July 15, 2014, and ends on July 15, 2024.
All other ASME B&PV Code,Section XI, requirements which are not modified by the NRC staffs approval of the licensees request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributors: E. Reichelt, NRR Date: February 16, 2021
- Via Memo* via email OFFICE NRR/DORL/LPL2-2/PM*
NRR/DORL/LPL2-2/LA*
NRR/DNRL/NPHP/BC**
NAME MMahoney BAbeywickrama MMitchell DATE 02/08/2021 02/05/2021 01/27/2021 OFFICE DORL/LPL2-2/BC*
NAME UShoop DATE 02/16/2021