RA-20-0031, Revision to Request for Alternative in Accordance with 10 CFR 50.55a (z)(1) to Delay the Update of the ASME Code of Record for the First Inspection Period

Revision to Request for Alternative in Accordance with 10 CFR 50.55a (z)(1) to Delay the Update of the ASME Code of Record for the First Inspection Period

ML20023A272
Person / Time
Site:	McGuire
Issue date:	01/23/2020
From:	Teresa Ray Duke Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0031
Download: ML20023A272 (7)

Text

Tom Ray Vice President McGuire Nuclear Station Duke Energy MG01VP l 12700 Hagers Ferry Rd.

Huntersville, NC 28078 704.946.2305 Tom.Ray@duke-energy.com Serial: RA-20-0031 10 CFR 50.55a January 23, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 MCGUIRE NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-369

SUBJECT:

Revision to Request for Alternative in Accordance with 10 CFR 50.55a (z)(1) to Delay the Update of the ASME Code of Record for the First Inspection Period

REFERENCES:

1. RA-19-0341, Request for Alternative in Accordance with 10 CFR 50.55a (z)(1) to Delay the Update of the ASME Code of Record for the First Inspection Period [ML19353C619]

On December 19, 2019 Duke Energy Carolinas, LLC (Duke Energy) submitted RA-19-0341, Request for Alternative in Accordance with 10 CFR 50.55a (z)(1) to delay the update of the ASME code of record for the first inspection period of the fifth interval for McGuire Nuclear Station Unit 1 (Reference 1). Duke Energy is submitting this letter as a revision to RA-19-0341, in which Duke Energy is requesting the proposed alternative for only the fifth 10-year Inservice Inspection Interval (ISI).

Pursuant to 10 CFR 50.55a(z)(1), Duke Energy requests an alternative from the requirements of 10 CFR 50.55a(g)(4)(ii) pertaining to the 10-year ISI Interval update for McGuire Nuclear Station Unit 1 to the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code,Section XI (ASME Section XI). The requested alternative will permit the use of the ASME Code,Section XI, 2007 Edition through the 2008 Addenda during the first period of the Unit 1 Fifth ISI interval. Relief is being sought on the basis that the alternative provides an acceptable level of quality and safety.

Duke Energy requests that this Relief Request receive review and approval by December 31, 2020.

NRC FORM 366 (04-2017)

U.S. Nuclear Regulatory Commission RA-20-0031 Page 2 Relief Request RA-20-0031 is provided as an enclosure to this letter. This submittal supersedes RA-19-0341. If you have questions concerning this request, please contact Art Zaremba, Manager - Fleet Licensing, at (980) 373-2062.

Tom Ray Vice President McGuire Nuclear Station

Enclosure:

1. Relief Request RA-20-0031, Request for Alternative in Accordance with 10 CFR 50.55a (z)(1) to Delay the Update of the ASME Code of Record for the First Inspection Period cc : (all with Enclosure)

L. Dudes, Regional Administrator USNRC Region II Andy Hutto, USNRC Senior Resident Inspector - MNS M. Mahoney, NRR Project Manager - MNS

Enclosure Duke Energy Carolinas, LLC McGuire Nuclear Station, Unit 1 Relief Request RA-20-0031 Request for Alternative in Accordance with 10 CFR 50.55a (z)(1) to Delay the Update of the ASME Code of Record for the First Inspection Period

Relief Request RA-20-0031 Enclosure 1 Page 2 of 5 1.0 American Society of Mechanical Engineers (ASME) Code Components Affected:

ASME Class 1, 2, and 3 components and component supports.

Note: This request specifically excludes ASME Class MC components at McGuire Unit 1.

A separate inservice inspection (ISI) program has been established for Class MC components that uses the ASME Code, Section Xl, 2007 Edition with the 2008 Addenda, and the Code of Record for this program will be updated to a later Code Edition and Addenda when the Class MC interval expires in 2024.

2.0 Applicable Requirements:

2.1. 10 CFR 50.55a(g)(4)(ii) states that "Inservice examination of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in paragraph (a) of this section 12 months before the start of the 120-month inspection interval (or the optional ASME Code Cases listed in NRC Regulatory Guide 1.147, when using ASME BPV Code,Section XI, or NRC Regulatory Guide 1.192, when using the ASME OM Code, as incorporated by reference in paragraphs (a)(3)(ii) and (iii) of this section), subject to the conditions listed in paragraph (b) of this section. However, a licensee whose inservice inspection interval commences during the 12 through 18-month period after August 17, 2017, may delay the update of their Appendix VIII program by up to 18 months after August 17, 2017. Alternatively, licensees may, at any time in their 120-month ISI interval, elect to use the Appendix VIII in the latest edition and addenda of the ASME BPV Code incorporated by reference in paragraph (a) of this section, subject to any applicable conditions listed in paragraph (b) of this section. Licensees using this option must also use the same Edition and Addenda of Appendix I as Appendix VIII, including any applicable conditions listed in paragraph (b) of this section."

In accordance with 10 CFR 50.55a(a)(1)(ii)(C)(53), the 2013 Edition of ASME Section XI is the latest NRC approved version with the exception that IWB-3112(a)(3) and IWC-3112(a)(3) are not approved for use and may not be used.

2.2. 10 CFR 50.55a(b)(2) states that "As used in this section, references to Section XI refer to Section XI, Division 1, of the ASME BPV Code, and include the 1970 Edition through the 1976 Winter Addenda and the 1977 Edition through the 2013 Edition, subject to the following conditions:"

Note: Unless 10 CFR 50.55a(b)(2) is amended to incorporate by reference a later Edition and Addenda of Section Xl prior to December 1, 2020 (12 months before the start date of the McGuire Unit 1 fifth ISI interval), the ISI program for the fifth interval must be updated to comply with the 2013 Edition.

Relief Request RA-20-0031 Enclosure 1 Page 3 of 5 3.0 Proposed Alternative Pursuant to 10 CFR 50.55a(z)(1), Duke Energy proposes the following alternative to the requirements cited in Section 2.0 of this Enclosure.

3.1. Duke Energy proposes to use the Edition and Addenda of ASME Section XI which is the Code of Record applicable to the fourth 10-year Interval, 2nd and 3rd Periods, during the 1st Period of the fifth 10-year Interval.

3.2. The ASME Section XI Code of Record for McGuire Unit 1 shall be updated by the end of the 1st Period of the fifth 10-year Interval, to the same Edition and Addenda required for the McGuire Unit 2 fifth 10-year Interval. The updated Code of Record shall be used during the 2nd and 3rd Periods of the Unit 1 fifth 10-year Interval, and shall comply with all applicable limitations and modifications specified in 10 CFR 50.55a(b)(2).

3.3. The proposed alternative includes continued use of relief requests submitted and approved for McGuire Unit 1 in the 2nd and 3rd periods of the fourth 10-year Interval, during the 1st period of the fifth 10-year Interval.

3.4. The proposed alternative includes continued use of a risk-informed ISI (RI-ISI) program as authorized by letter dated July 14, 2014 (ML14188C348).

The RI-ISI program is implemented in accordance with ASME Code Case N-716, Rev. 0, and associated relief request 13-MN-002.

3.5. When implementing this alternative, the following requirements shall apply:

3.5.1. During the 1st Period of the fifth interval, Duke Energy shall comply with all NRC limitations and modifications specified in 10 CFR 50.55a(b)(2) applicable to the Edition and Addenda of Section XI being used for the previously implemented 2nd and 3rd Period.

3.5.2. Code Cases, if used, shall comply with the requirements specified in Regulatory Guide 1.147.

Relief Request RA-20-0031 Enclosure 1 Page 4 of 5 4.0 BASIS FOR USE OF ALTERNATIVE 4.1. ASME Section XI activities [e.g., ISI, repair/replacement, pressure testing, and Non-Destructive Examination (NDE)] for McGuire Units 1 and 2 are standardized and administered by a centralized ISI organization at Duke Energy. Both Unit 1 and Unit 2 use a common Code of Record, which simplifies program administration, requiring fewer programs and procedures than would otherwise be needed to implement requirements of different Code Editions and Addenda. Standardizing these programs using a common Code of Record also minimizes the risk that errors will occur during program development and implementation.

4.2. Because the 2013 Edition of the ASME Code,Section XI has been incorporated by reference in 10 CFR 50.55a, Duke Energy is required to update the McGuire Unit 1 ISI program to this edition of the Code, unless 10 CFR 50.55a is amended to incorporate by reference a later edition and addenda, prior to December 1, 2020.

Consequently, the regulation will require Duke Energy to maintain ISI programs using an ASME Section XI Code for Unit 1 that is different from that in use at McGuire Unit 2. This regulation affects the 1st Period for Unit 1 at McGuire during the fifth 10-year interval.

4.3. Although many changes occurred in ASME Section XI between the 2007 Edition through the 2008 Addenda and the 2013 Edition, both editions continue to ensure an acceptable level of quality and safety. In addition, the changes were not incorporated to address a deficiency in the Code that adversely impacted safety.

4.4. The Augmented ISI requirements in 10 CFR 50.55a(g)(6)(ii) that have been deemed by the NRC as necessary to provide added assurance of structural reliability will continue to be met.

4.5. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

4.6. For the reasons stated above, Duke Energy believes that the proposed alternative provides an acceptable level of quality and safety.

5.0 DURATION OF PROPOSED ALTERNATIVE Use of the proposed alternative is requested for the 1st Period of the fifth 10-year Interval at McGuire Unit 1 (currently scheduled to start on December 1, 2021).

Relief Request RA-20-0031 Enclosure 1 Page 5 of 5 6.0 RELATED INDUSTRY RELIEF REQUESTS Virginia Electric and Power Company (Dominion), Surry Power Station, Request for Relief No. S1-15-ISI-01 submitted April 25, 2012 (ML12130A216), approved April 29, 2013 (ML13100A049).

Entergy Operations, Inc., Arkansas Nuclear One Unit 2 Request for Relief No. ANO2-ISI-021, submitted February 27, 2019 (ML19058A252), approved June 11, 2019 (ML19156A400).

Duke Energy, McGuire Unit 1, Request for Relief No. 10-MN-001, submitted August 30, 2010 (ML102510186), approved March 3, 2011 (ML110550770).