ML21032A049

NRR E-mail Capture - Request for Additional Information - Duke Fleet RA-20-0263 - Use of Later ASME B&Pv, XI for Repair - Replacement (L-2020-LLR-0124)

ML21032A049
Person / Time
Site:	Harris
Issue date:	02/01/2021
From:	Michael Mahoney NRC/NRR/DORL/LPL2-2
To:	Sigmon C Duke Energy Progress
References
L-2020-LLR-0124
Download: ML21032A049 (4)

Text

From: Mahoney, Michael Sent: Monday, February 1, 2021 9:01 AM To: Sigmon, Chet Austin Cc: Art Zaremba

Subject:

Request for Additional Information - Duke Fleet RA-20-0263 - Use of Later ASME B&PV, XI for Repair-Replacement (L-2020-LLR-0124)

Attachments: RAIs - Duke Fleet - Use of Later ASME B&PV, XI for Repair-Replacement ( L-2020-LLR-0124).docx

Chet, Attached are RAIs for the subject Duke Fleet request RA-20-0263 dated September 16, 2020, for use of a provision of a later edition and addenda of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code),Section XI. Specifically, the licensee requested the use of paragraph IWA-4340, "Mitigation of Defects by Modification" of ASME Code,Section XI, 2017 Edition with no Addenda, subject to modifications and limitations imposed by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(b)(2) for repair and replace activities.

Please provide your response to the attached RAIs within 30 days of the date of this electronic correspondence.

Thanks Mike Mahoney Project Manager, LPL2-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Desk: (301)-415-3867 Mobile: (301)-250-0450 Email: Michael.Mahoney@nrc.gov

Hearing Identifier: NRR_DRMA Email Number: 992 Mail Envelope Properties (MN2PR09MB553115466AE4F09D2A94493BE5B69)

Subject:

Request for Additional Information - Duke Fleet RA-20-0263 - Use of Later ASME B&PV, XI for Repair-Replacement (L-2020-LLR-0124)

Sent Date: 2/1/2021 9:00:59 AM Received Date: 2/1/2021 9:01:01 AM From: Mahoney, Michael Created By: Michael.Mahoney@nrc.gov Recipients:

"Art Zaremba" <Arthur.Zaremba@duke-energy.com>

Tracking Status: None "Sigmon, Chet Austin" <Chet.Sigmon@duke-energy.com>

Tracking Status: None Post Office: MN2PR09MB5531.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 930 2/1/2021 9:01:01 AM RAIs - Duke Fleet - Use of Later ASME B&PV, XI for Repair-Replacement ( L-2020-LLR-0124).docx 31399 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION REQUEST TO USE A PROVISION OF A LATER EDITION AND ADDENDA OF THE ASME BOILER AND PRESSURE VESSEL CODE, SECTION XI FOR REPAIR/REPLACEMENT ACTIVITIES IN ACCORDANCE WITH 10 CFR 50.55A(G)(4)(IV)

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 DOCKET NOS. 50-413, 50-414, 50-369, 50-370, 50-269, 50-270, AND 50-287 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. 50-325, 50-324, 50-261, AND 50-400 EPID L-2020-LLR-0124 By letter RA-20-0263, dated September 16, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20260H326), Duke Energy Carolinas, LLC and Duke Energy Progress, LLC (referred to collectively as Duke Energy or licensee) requests NRC approval to use a provision of a later edition and addenda of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code),Section XI. Specifically, the licensee requested the use of paragraph IWA-4340, "Mitigation of Defects by Modification" of ASME Code,Section XI, 2017 Edition with no Addenda, subject to modifications and limitations imposed by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(b)(2) for repair and replace activities on Class 1, 2, and 3 components.

During the Nuclear Regulatory Commission (NRC) staffs review of the license amendment request, the NRC staff determined that additional information was needed to complete the review.

Request for Additional Information (RAI) - 1 In the cover letter of the request, the licensee states, in part:

requests NRC approval to use paragraph IWA-4340, "Mitigation of

Defects by Modification" of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV),Section XI, 2017 Edition no Addenda, subject to modifications and limitations imposed by 10CFR50.55a(b)(2) for Repair/Replacement Activities on Class 1, 2, and 3 components.

Paragraph IWA-4340 of ASME Code,Section XI, 2017 Edition does not include Class 1 components in its scope.

Please clarify whether the scope of the request includes repair and replacement activities for Class 1 components.

If the scope of the request includes repair and replacement activities for Class 1 components, provide justification for the inconsistency between the licensee's request and the scope of IWA-4340.

RAI - 2 Paragraph (g)(4)(iv) of 10 CFR 50.55a, "Codes and standards" states, in part, Portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are me.

Please confirm that the licensee's use of paragraph IWA-4340 will meet all related requirements of ASME Code,Section XI, 2017 Edition.

If not, provide justification for why all related requirements are not met.