ML24164A005

NRR E-mail Capture - Request for Additional Information Regarding Dukes February 15, 2024, Relief Request RA-23-0300 for Robinson

ML24164A005
Person / Time
Site:	Robinson
Issue date:	06/11/2024
From:	Luke Haeg Plant Licensing Branch II
To:	Duc J Duke Energy Progress
References
L-2024-LLR-0017
Download: ML24164A005 (5)

Text

From: Luke Haeg Sent: Tuesday, June 11, 2024 5:24 PM To: Duc, Joshua Brian

Subject:

Request for Additional Information Regarding Duke's February 15, 2024, Relief Request RA-23-0300 for Robinson (EPID L-2024-LLR-0017)

Attachments: Final RAI for Robinson RA-23-0300 EPID L-2024-LLR-0017.pdf

Dear Mr. Duc,

By letter dated February 15, 2024 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML24050A006), Duke Energy Progress, LLC (Duke Energy, the licensee) submitted a request for relief (RA-23-0300) from certain requirements of the ASME Boiler and Pressure Vessel Code (BPVC),Section XI, for H. B. Robinson Steam Electric Plant, Unit No. 2 (Robinson). The request for relief applied to the fifth 10-year inservice inspection (ISI) interval, in which the licensee adopted the 2007 Edition through the 2008 Addenda of ASME BPVC Section XI as the code of record.

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has identified areas where additional information is needed to complete its review.

A request for additional information (RAI) is attached. A draft RAI was sent to you to ensure that it was understandable, the regulatory basis for the question was clear, and to determine whether the information was previously docketed.

Based on a discussion with you, a response from Duke Energy to the attached RAI is requested within 45 days from the date of this email (i.e., by July 26, 2024).

The NRC staff considers timely responses to RAIs help to ensure sufficient time is available for staff review and contribute to the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-0272 or Lucas.Haeg@nrc.gov. Thank you.

Luke Haeg Project Manager NRR/DORL/LPL2-2 301-415-0272

Hearing Identifier: NRR_DRMA Email Number: 2518

Mail Envelope Properties (DM8PR09MB64074B3DB6646D599FDC75E498C72)

Subject:

Request for Additional Information Regarding Duke's February 15, 2024, Relief Request RA-23-0300 for Robinson (EPID L-2024-LLR-0017)

Sent Date: 6/11/2024 5:23:34 PM Received Date: 6/11/2024 5:23:00 PM From: Luke Haeg

Created By: Lucas.Haeg@nrc.gov

Recipients:

"Duc, Joshua Brian" <Joshua.Duc@duke-energy.com>

Tracking Status: None

Post Office: DM8PR09MB6407.namprd09.prod.outlook.com

Files Size Date & Time MESSAGE 1620 6/11/2024 5:23:00 PM Final RAI for Robinson RA-23-0300 EPID L-2024-LLR-0017.pdf 122929

Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION

REGARDING RELIEF REQUEST RA-23-0300

FOR THE FIFTH 10-YEAR INSERVICE INSPECTION INTERVAL

EPID L-202 4-LLR-0 017

DUKE ENERGY PROGRESS, LLC

H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2

DOCKET NO. 50-261

INTRODUCTION

By letter dated February 15, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24050A006), Duke Energy Progress, LLC (Duke Energy, the licensee), submitted relief request RA-23-0300 from the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC),Section XI, Rules for lnservice Inspection of Nuclear Power Plant Components for H. B. Robinson Steam Electric Plant, Unit No. 2 (Robinson). The request for relief applies to the fifth 10-year inservice inspection (ISI) interval, in which the licensee adopted the 2007 Edition through the 2008 Addenda of ASME BPVC Section XI as the code of record.

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the request and has identified areas where it needs additional information to support its review. In order for the NRC staff to determine if the relief request may be authorized pursuant to 10 CFR 50.55a( g)(6)(i), the staff requests the following additional information.

INFORMATION REQUESTED

Background

Table 1 of Enclosure 1 (Page 10 of 12) to the submittal shows that weld 116B/18 in Examination Category B-J could not receive essentially 100% ultrasonic examination coverage due to the proximity of an adjacent weld. Under the Component Description column of Table 1, the weld joint is described as an elbow to pipe weld.

Issues

1. Report No. UT-15-020 on Page 56 of 90 of Enclosure 2 to the submittal shows a photo that appears to be the pressurizer spray nozzle with the filename of the photo given as 63300 63400 PZR Spray\\166B-18.jpg.

2. The Specific Technical Brief Sheet of Report No. UT-15-020 on Page 58 of 90 of Enclosure 2 to the submittal contains a partially legible handwritten note under Post-Job Comments stating,

in part, Previous PT [dye penetrant testing] Inspection on these components identified []

issue.

Request

A. Clarify whether the correct photo is attached or if the photo is mislabeled, and if weld 116B/18 is one of the pressurizer spray nozzle welds.

B. Confirm that the hand-written note is not reporting a PT indication and that the Remarks for weld 116B/18 on Page 10 of Enclosure 1 to the submittal: The surface examination achieved 100% coverage with no relevant indications noted, is still valid.

Background

Section 3.2 of Enclosure 1 to the submittal states that Examination Category C -C welded attachments require surface examination. The rationale provided by the licensee under Section 6.3 of Enclosure 1 to the submittal includes discussion regarding the coverage obtained by magnetic particle testing (MT) examination. However, the Exam Requirements Figure No.

and (Method) column on Page 11 of Enclosure 1 to the submittal, along with the nondestructive testing (NDT) Report No. PT-13-001 provided as Pages 59-60 of Enclosure 2 to the submittal, indicate that weld joint 204/AWS-1-ATT received a PT examination.

Issue

The technical rationale provided in Section 6.3 of Enclosure 1 to the submittal only discusses MT coverage but one of the subject weld joints received a PT examination.

Request

Discuss if the statement regarding MT in Section 6.3 of Enclosure 1 to the submittal is accurate or whether discussion of PT examination coverage results should be provided.

Background

Section 3.2 of Enclosure 1 to the submittal states that Examination Category C -C welded attachments require surface examination.

Issue

Neither the rationale in Section 6.3 of Enclosure 1 to the submittal nor the Remarks column on Page 11 of Enclosure 1 to the submittal discuss whether the surface examinations found any indications. The PT and MT reports on Pages 59, 61, and 64 of Enclosure 2 to the submittal do not report indications but the C omments for Report No. PT-13-001 on Page 59 notes, in part, Observed tool marks, weld overlap, undercut.

Request

Discuss how the issues identified on Report No. PT-13-001 were dispositioned.

Background

Section 6.4 of Enclosure 1 to the submittal states that Examination Category F-A supports require visual examination.

Issue

The comments on Pages 68, 76, and 84 of Enclosure 2 to the submittal indicate that boron was identified throughout. The sub-section Historic Findings on Pa ge 68 states, in part:

Reference RNP RO-32 historic documents EC 418725: Attachments A through C, "Structural Engineering Review and Comparison of RX Vessel Support Material Condition" for background information pertaining to history of identified cavity leakage within the Reactor Vessel Support areas.

EC 418725 concluded that the condition of the Reactor Vessel supports are acceptable for continued service based on structural review of past inspection images, engineering change packages, condition reports, examination of critical structural parameters.

Request

Discuss why the presence of boron is not a concern to the structural integrity of the reactor vessel supports.