RA-20-0263, Duke Energy Corp. - Request to Use Provision of Later Edition and Addenda of ASME Boiler and Pressure Vessel Code, Section XI for Repair/Replacement Activities in Accordance with 10 CFR 50.55a(g)(4)(iv)

Duke Energy Corp. - Request to Use Provision of Later Edition and Addenda of ASME Boiler and Pressure Vessel Code,Section XI for Repair/Replacement Activities in Accordance with 10 CFR 50.55a(g)(4)(iv)

ML20260H326
Person / Time
Site:	Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire
Issue date:	09/16/2020
From:	Snider S Duke Energy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-20-0263
Download: ML20260H326 (5)

Text

Steve Snider Vice President Nuclear Engineering 526 South Church Street, EC-07H Charloote, NC 28202 980-373-6195 Steve.Snider@duke-energy.com Serial: RA-20-0263 September 16, 2020 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2, DOCKET NOS. 50-325, 50-324 CATAWBA NUCLEAR STATION, UNITS 1 AND 2, DOCKET NOS. 50-413, 50-414 MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, DOCKET NOS. 50-369, 50-370 OCONEE NUCLEAR STATION, UNITS 1, 2 AND 3, DOCKET NOS. 50-269, 50-270, 50-287 H.B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2, DOCKET NO. 50-261 SHEARON HARRIS NUCLEAR POWER PLANT, UNIT 1, DOCKET NO. 50-400

SUBJECT:

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)

In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv), and the guidance provided in NRC Regulatory Issue Summary (RIS) 2004-16, "Use of Later Editions and Addenda to ASME Code Section XI for Repair/Replacement Activities", dated October 19, 2004, Duke Energy Carolinas, LLC and Duke Energy Progress, LLC (hereafter referred to collectively as Duke Energy), 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. The request is provided as the Attachment to this submittal.

Duke Energy requests approval of this request by September 30, 2021. There are no regulatory commitments in this letter.

RA-20-0263 Page 2 If you have any questions concerning this request, please contact Art Zaremba, Director - Fleet Licensing, at (980) 373-2062.

Sincerely, Steve Snider Vice President - Nuclear Engineering

Attachment:

Request to Use Provisions of a Later Edition and Addenda of the ASME Code per 10 CFR 50.55a(g)(4)(iv) and RIS 2004-16 cc: L. Dudes, Regional Administrator USNRC Region II G. Smith, USNRC Senior Resident Inspector - BNP J. D. Austin, USNRC Senior Resident Inspector - CNS J. Zeiler, USNRC Senior Resident Inspector - HNP G. A. Hutto, USNRC Senior Resident Inspector - MNS J. Nadel, USNRC Senior Resident Inspector - ONS M. Fannon, USNRC Senior Resident Inspector - RNP A. Hon, NRR Project Manager

Attachment Duke Energy Carolinas, LLC Duke Energy Progress, LLC RA-20-0263 Request to Use a Provision of a Later Edition and Addenda of the ASME Code,Section XI per 10 CFR 50.55a(g)(4)(iv) and RIS 2004-16

Page 1 of 2

1. Applicable Code Edition & Requirements The applicable Edition and Addenda of the ASME Code,Section XI is identified in Table 1.

Table 1 ISI ASME Section XI Plant/Unit(s) Interval Start Date Interval End Date1 Interval Code Edition/Addenda Brunswick Steam 2007 Edition, Through Electric Plant, Units 1 Fifth 05/11/2018 05/10/2028 2008 Addendum and 2 Catawba Nuclear 2007 Edition, Through 12/06/2024 (Unit 1)

Fourth 08/19/2015 Station, Units 1 and 2 2008 Addendum 02/24/2026 (Unit 2)

H.B. Robinson Steam 2007 Edition, Through Fifth 07/21/2012 02/19/2023 Electric Plant, Unit 2 2008 Addendum McGuire Nuclear 2007 Edition, Through 12/01/2011 (Unit 1) 11/30/2021 (Unit 1)

Fourth Station, Units 1 and 2 2008 Addendum 07/15/2014 (Unit 2) 02/29/2024 (Unit 2)

Oconee Nuclear Station, 2007 Edition, Through Fifth 07/15/2014 07/15/2024 Units 1, 2, and 3 2008 Addendum Shearon Harris Nuclear 2007 Edition, Through Fourth 09/09/2017 09/08/2027 Power Plant, Unit 1 2008 Addendum Note 1: Date listed is the currently planned interval end date. In accordance with IWA-2430(c)(1), this end date may be extended or shortened as necessary.

Paragraph IWA-4340 of the ASME Section XI 2001 Edition through the 2010 Addenda, is prohibited for use by 10CFR50.55a(b)(2)(xxv)(A) which excludes mitigation of defects by modification as a repair option.

2. Proposed Alternative Code Edition and Requirements Pursuant to 10 CFR 50.55a(g)(4)(iv), Duke Energy requests permission to use paragraph IWA-4340 of the 2017 Edition as conditioned by 10CFR50.55a(b)(2)(xxv)(B) for repair/replacement activities, as published in the rulemaking dated 05/04/2020 (Ref. 2).

ASME Section XI 2017 Edition, paragraph IWA-4340 is approved for use with the conditions stipulated in 10CFR50.55a(b)(2)(xxv)(B). Mitigation of defects by modification provides an alternative solution for defect removal in instances where immediate repair or replacement cannot be executed due to time constrains or plant operational challenges. Approval of this request also eliminates the need for submittal and approval of emergent relief requests to utilize these provisions on a case by case basis.

The use of ASME Section XI 2017 Edition IWA-4340 with conditions in 10CFR50.55a(b)(2)(xxv)(B), will provide an acceptable level of quality and safety, while also offering alternative repair/replacement opportunities.

Page 1 of 2 Duration of Proposed Request The duration of this is for the remainder of the current Inservice Inspection intervals listed in Table 1.

References NRC Regulatory Issue Summary 2004-16, "Use of Later Editions and Addenda to ASME Code Section XI for Repair/Replacement Activities," dated October 19, 2004.

Federal Register, 85 FR 26540, dated May 4, 2020.