RA-21-0032, Duke Energy - Response to Requests for Additional Info for Request to Use a Provision of Later Edition & Addenda of the ASME Boiler & Pressure Vessel Code, Section XI for Repair/Replacement Activities in Accordance with 10 CFR 50.55a(g)(4

Duke Energy - Response to Requests for Additional Info for Request to Use a Provision of Later Edition & Addenda of the ASME Boiler & Pressure Vessel Code,Section XI for Repair/Replacement Activities in Accordance with 10 CFR 50.55a(g)(4)(

ML21042A001
Person / Time
Site:	Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire
Issue date:	02/11/2021
From:	Snider S Duke Energy Carolinas, Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-21-0032
Download: ML21042A001 (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-21-0032 February 11, 2021 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:

Response to Requests for Additional Information for 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)

References:

Duke Energy Letter, 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), dated September 16, 2020 [Accession No. ML20260H326]

NRC email, Request for Additional Information - Duke Fleet RA-20-0263 - Use of Later ASME B&PV, XI for Repair-Replacement (L-2020-LLR-0124), dated February 1, 2021 By letter dated September 16, 2020 (Reference 1), Duke Energy Carolinas, LLC and Duke Energy Progress, LLC (referred to collectively as Duke Energy) requested 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, Duke Energy 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 2, and 3 components. By email dated February 1, 2021 (Reference

2) the NRC requested additional information to complete its review.

RA-21-0032 Page 2 The Enclosure to this submittal provides Duke Energys response to the requests for additional information.

This document contains no new regulatory commitments. 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

Enclosure:

Response to Request for Additional Information 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 M. Mahoney, NRR Project Manager

RA-21-0032 Enclosure Duke Energy Carolinas, LLC Duke Energy Progress, LLC Response to Requests for Additional Information (3 pages including cover page)

RA-21-0032 Enclosure Page 2 of 3 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.

Duke Energy Response to RAI - 1 The scope of the request does not include repair and replacement activities for Class 1 components.

RA-21-0032 Enclosure Page 3 of 3 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 met.

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.

Duke Energy Response to RAI - 2 Duke Energys use of paragraph IWA-4340 will meet all related requirements of ASME Code,Section XI, 2017 Edition.