ML23118A076
| ML23118A076 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire  |
| Issue date: | 05/01/2023 |
| From: | David Wrona Plant Licensing Branch II |
| To: | Ellis K Duke Energy Corp |
| Jordan, N | |
| References | |
| EPID L 2023-LLR-0018 | |
| Download: ML23118A076 (1) | |
Text
May 1, 2023 Kevin Ellis GM Nuclear Regulatory Affairs, Policy, & Emergency Preparedness Duke Energy Corporation 3581 W. Entrance Rd.
Hartsville, SC 29550
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2; CATAWBA NUCLEAR STATION, UNITS 1 AND 2; SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1; MCGUIRE NUCLEAR STATION, UNITS 1 AND 2; OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3; AND H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 - APPROVAL FOR USE OF SPECIFIC PROVISION OF A LATER EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI (EPID L-2023-LLR-0018)
Dear Mr. Ellis:
By letter dated February 2, 2023 (Agencywide Documents Access and Management System Accession No. ML23033A037), Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC (Duke Energy or the licensee) submitted a request to use a provision of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI at Brunswick Steam Electric Plant (Brunswick), Units 1 and 2; Catawba Nuclear Station (Catawba), Units 1 and 2; Shearon Harris Nuclear Power Plant (Harris), Unit 1; McGuire Nuclear Station (McGuire), Units 1 and 2; Oconee Nuclear Station (Oconee), Units 1, 2, and 3; and H.B. Robinson Steam Electric Plant (Robinson), Unit 2. Specifically, the licensee requested approval to use subarticle IWA-6230(b) of the 2019 Edition of the ASME Code,Section XI, which permits plant owners to submit inservice inspection (ISI) summary reports to the U.S.
Nuclear Regulatory Commission (NRC) within 120 calendar days of the completion of each refueling outage.
The NRC staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that Duke Energy has adequately addressed the requirements in Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(1)(ii). Therefore, the NRC staff approves the use of subarticle IWA-6230(b) of the 2019 Edition of the ASME Code,Section XI at Brunswick Units 1 and 2; Catawba Units 1 and 2; Harris Unit 1; McGuire Units 1 and 2; Oconee Units 1, 2, and 3; and Robinson Unit2for the remainder of the current 10-year ISI interval.
All other requirements of the ASME Code,Section XI, as incorporated by reference in 10 CFR 50.55a, for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact Natreon (Nate) Jordan at 301-415-7410 or via e-mail at Natreon.Jordan@nrc.gov.
Sincerely, David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-324, 50-325, 50-369, 50-370, 50-400, 50-413, 50-269, 50-270, 50-287, 50-261, and 50-414
Enclosure:
Safety Evaluation cc:
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 Mr. Thomas Haaf 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. Edward Pigott Site Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078 Mr. Tom Simril Site Vice President Catawba Nuclear Station Duke Energy Carolinas, LLC Catawba Nuclear Station 4800 Concord Road York, SC 29745 Steven M. Snider Laura Basta Site Vice President, Oconee Nuclear Station Site Vice President Duke Energy Carolinas, LLC H. B. Robinson Steam Electric Plant Oconee Nuclear Station Duke Energy Progress, LLC 7800 Rochester Highway 3581 West Entrance Road, RNPA11 Seneca, SC 29672-0752 Hartsville, SC 29550 Additional Distribution via Listserv David J.
Wrona Digitally signed by David J. Wrona Date: 2023.05.01 13:30:59 -04'00'
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST TO USE A PORTION OF A LATER EDITION OF THE ASME CODE REGARDING REPORTING REQUIREMENTS CATAWBA NUCLEAR STATION, UNITS 1 AND 2 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 DOCKET NOS. 50-413, 50-414, 50-369, 50-370, 50-324, 50-325, 50-269, 50-270, 50-287, 50-261, and 50-400
1.0 INTRODUCTION
By letter dated February 2, 2023, (Agencywide Documents and Access Management System (ADAMS) Accession No. ML23033A037), pursuant to Title 10 of Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv), Duke Energy (the licensee) requested U.S. Nuclear Regulatory Commission (NRC) approval to use a specific provision of a later edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, for the units identified above. Specifically, the licensee requested approval to use subarticle IWA-6230(b) of the 2019 Edition of the ASME Code,Section XI, which permits plant owners to submit inservice inspection (ISI) summary reports to the NRC within 120 calendar days of the completion of each refueling outage.
2.0 REGULATORY EVALUATION
Specific editions and addenda, or portions thereof, of the ASME Code,Section XI, have been incorporated by reference into 10 CFR 50.55a(a)(1)(ii). The editions and addenda of the ASME Code,Section XI, are subject to the limitations in 10 CFR 50.55a(b)(2).
The regulations in 10 CFR 50.55a(g)(4) state, in part, that ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in Section XI of the applicable editions and addenda of the ASME Code to the extent practical within the limitations of design, geometry, and materials of construction of the components. Paragraph 50.55a(g)(4)(iv) of 10 CFR states:
lnservice 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 [10 CFR 50.55a], 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.
Paragraph 50.55a(b)(2)(xxxii) of 10 CFR 50.55a states:
Section XI condition: Summary report submittal. When using ASME BPV Code,Section XI, 2010 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, Summary Reports and Owners Activity Reports described in IWA-6230 must be submitted to the NRC. Preservice inspection reports for examinations prior to commercial service must be submitted prior to the date of placement of the unit into commercial service. For preservice and inservice examinations performed following placement of the unit into commercial service, reports must be submitted within 120 calendar days of the completion of each refueling outage.
NRC Regulatory Issue Summary (RIS) 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section Xl," reinforces that licensees must request approval to use later Code editions and addenda via a letter to the NRC. The licensees may not simply update their IST or ISI program without NRCs prior regulatory approval.
3.0 TECHNICAL EVALUATION
3.1 Licensees Request 3.1.1 ASME Code Components Affected All pressure-retaining components described in the ASME Code,Section XI, 2019 Edition, Article IWA-6230, Owners Activity Report, paragraph (b).
3.1.2 Applicable Code Edition and Addenda The applicable Edition and Addenda of the ASME Code,Section XI is identified in Table 1.
Table 1: Current ASME Code,Section XI, Code of Record PLANT ISI INTERVAL ASME CODE, SECTION XI START END Brunswick Steam Electric Plant Units 1 and 2 5th 2007 Edition, Through 2008 Addendum 05/11/2018 05/10/2028 Catawba Nuclear Station Units 1 and 2 4th 2007 Edition, Through 2008 Addendum 08/19/2015 12/06/2024 (Unit 1) 02/24/2026 (Unit 2)
PLANT ISI INTERVAL ASME CODE, SECTION XI START END H.B. Robinson Steam Electric Plant Unit 2 6th 2017 Edition 02/20/2023 02/19/2033 McGuire Nuclear Unit 1 5th 2007 Edition, Through 2008 Addendum 12/01/2021 11/30/2031 McGuire Nuclear Unit 2 4th 2007 Edition, Through 2008 Addendum 07/15/2014 02/29/2024 Oconee Nuclear Station Units 1, 2, and 3 5th 2007 Edition, Through 2008 Addendum 07/15/2014 07/15/2024 Shearon Harris Nuclear Power Plant Unit 1 4th 2007 Edition, Through 2008 Addendum 09/09/2017 09/08/2027 The licensee noted that the end date listed above is the planned interval end date. In accordance with IWA-2430(c)(1) of the ASME Code,Section XI, the end date may be extended or shortened, as necessary.
3.1.3 Proposed Subsequent Code Edition The licensee proposed to use portions of the ASME Section XI, 2019 Edition in lieu of the 2007 Edition up to and including the 2008 Addenda and 2017 Edition. Specifically, the licensee proposed to use IWA-6230(b) of the 2019 Edition of the ASME Code,Section XI which provides an extension of the 90-calendar day submittal requirement of the Owners Activity Report to 120 calendar-days following completion of a refueling outage.
3.1.4 Basis for Use The licensee cited 10 CFR 50.55a(g)(4)(iv) as the basis for its request to use a portion of a later ASME Code, subject to any related requirements and conditions. The licensee stated that 10 CFR 50.55a(b)(2) incorporates by reference the 2019 Edition of the ASME Code,Section XI as shown in Federal Register, 87 FR 65128, dated October 27, 2022. The licensee requested use of IWA-6230(b) of the 2019 Edition of the ASME Code,Section XI to apply an extension of the 90 calendar-day submittal requirement of the Owners Activity Report to 120 calendar-days.
According to the licensee, there are no related requirements or applicable conditions associated with the subarticle IWA-6230(b).
3.1.5 Duration of Proposed Alternative The licensee proposed the alternative for the remainder of the current inservice inspection intervals listed in Table 1 of its submittal.
3.2
NRC Staff Evaluation
Based on the requirements in 10 CFR 50.55a(g)(4)(iv), the NRC staff considered the following criteria in its review of the subject submittal:
- 1. The proposed edition or addenda of the ASME Code are incorporated by reference in 10 CFR 50.55a(a).
- 2. The proposed edition or addenda of the ASME Code are subject to the conditions listed in 10 CFR 50.55a(b).
- 3. The licensee requested NRC approval to use the subsequent edition or addenda of the ASME Code.
- 4. If only portions of editions or addenda are to be used, all related requirements of the respective editions or addenda are met.
Criterion 1 -- The licensee requested to use subarticle IWA-6230(b) in the 2019 Edition of the ASME Code,Section XI, which has been incorporated by reference in 10 CFR 50.55a(a) as shown in 87 FR 65128. Therefore, the first criterion above has been satisfied.
Criterion 2 -- Paragraph 50.55a(b)(2)(xxxii) of 10 CFR states, in part: Summary Reports and Owners Activity Reports described in IWA-6230 must be submitted to the NRC... For preservice and inservice examinations performed following placement of the unit into commercial service, reports must be submitted within 120 calendar days of the completion of each refueling outage.
The NRC staff determined that this condition on subarticle IWA-6230 of the 2019 Edition of the ASME Code,Section XI, listed in 10 CFR 50.55a(b), is consistent with the licensees proposal.
That is, the licensees proposal is subject to the condition in Paragraph 50.55a(b)(2)(xxxii).
Therefore, the second criterion above has been satisfied.
Criterion 3 -- The NRC staff determined that the licensees submittal dated February 2, 2023, constitutes a request to the Commission for approval to use a later, subsequent edition or addendum of the ASME Code,Section XI. Therefore, the third criterion above has been satisfied.
Criterion 4 -- Subarticle IWA-6230(b) of the 2019 Edition of the ASME Code,Section XI states that, For preservice and inservice examinations performed following placement of the unit into commercial service, Form OAR-1 [Owners Activity Report], as shown in Mandatory Appendix II [Owners Record and Report], shall be processed as specified below within 120 calendar days of the completion of each refueling outage.
The NRC staff compared the 2019 Edition with the prior Editions cited in Table 1 of the submittal to determine whether other relevant provisions would affect the proposed use of subarticle IWA-6230 and Mandatory Appendix II at the licensees facilities. The 2019 Edition of the ASME Code,Section XI, incorporates the alternate repair/replacement activity documentation and Inservice Inspection summary report preparation and submission requirements of ASME Code Case N-532-5. As such, the 2019 Edition extends the submittal time of the Owners Activity Report, Form OAR-1, outage summary report from 90 days to 120 days. The NRC staff determined that no other related changes were added to the 2019 Edition of the ASME Code,Section XI, Article IWA-6230(b), that would need to be implemented as part of the licensees request. The NRC noted that the licensee did not ask to use any other provisions of the 2019 Edition of the ASME Code,Section XI. The licensee only requested the use of IWA-6230(b).
Therefore, the fourth criterion above has been satisfied.
The NRC staff finds that the licensee has adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv) because the four criteria above have been satisfied.
4.0 CONCLUSION
As set forth above, the NRC staff finds that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(a)(1)(ii). Therefore, the NRC staff concludes that the use of subarticle IWA-6230(b) of the 2019 Edition of the ASME Code,Section XI, is acceptable. The NRC staff approves the use of subarticle IWA-6230(b) of the 2019 Edition of the ASME Code,Section XI, at Brunswick Units 1 and 2, Catawba Units 1 and 2, Shearon Harris Unit 1, McGuire Units 1 and 2, Oconee Units 1, 2, and 3, and H. B. Robinson Unit2for the remainder of the current 10-year ISI interval, as listed in Table 1 above.
The NRC staff notes that this approval does not apply to the use of provisions other than IWA-6230(b) of the 2019 Edition of the ASME Code,Section XI.
All other requirements of the ASME Code,Section XI, as incorporated by reference in 10 CFR 50.55a, for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: John Tsao, NRR/DNRL/NVIB Carol Moyer, NRR/DNRL/NVIB Date: May 1, 2023
- Via Memo OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DNRL/NVIB/BC*
NAME NJordan RButler ABuford DATE 04/27/2023 4/28/2023 04/25/2023 OFFICE DORL/LPL2-2/BC NAME DWrona DATE 5/1/2023