RNP-RA/03-0023, Twenty-Day Response to Order EA-03-009 Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors

Twenty-Day Response to Order EA-03-009 Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors

ML030660603
Person / Time
Site:	Robinson
Issue date:	03/03/2003
From:	Fletcher B Progress Energy Carolinas
To:	Office of Nuclear Reactor Regulation, NRC/SECY/RAS
References
EA-03-099, RNP-RA/03-0023
Download: ML030660603 (3)

Text

10 CFR 2.202 t Progress Energy Serial: RNP-RA/03-0023 MAR 0 3 2003 Secretary, Office of the Secretary of the Commission U. S. Nuclear Regulatory Commission Attn: Rulemakings and Adjudications Staff Washington, DC 20555-0001 Director, Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-26 1/LICENSE NO. DPR-23 TWENTY-DAY RESPONSE TO ORDER ESTABLISHING INTERIM INSPECTION REQUIREMENTS FOR REACTOR PRESSURE VESSEL HEADS AT PRESSURIZED WATER REACTORS Ladies and Gentlemen:

An order issued by the U. S. Nuclear Regulatory Commission (NRC) has been received for H. B.

Robinson Steam Electric Plant (HBRSEP), Unit No. 2. The order, transmitted by letter dated February 11, 2003, and titled, "Issuance of Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors," states that the requirements of the order are effective immediately.

This response to the order is being provided in accordance with Sections IV.F and V of the order.

Section V requires that, in accordance with 10 CFR 2.202, the licensee must submit an answer to the order within 20 days of its issuance.Section IV.F states that in its response the licensee shall notify the NRC if it is unable to comply with the requirements in Section IV or if such requirements are unnecessary.Section V of the order states that the answer may consent to the order.Section V of the order also states that the licensee may request additional time to request a hearing and that a statement of good cause for the extension must be included with that request.

HBRSEP, Unit No. 2, has taken actions to assure the integrity of the reactor pressure vessel (RPV) head and associated RPV head penetration nozzles. These actions include the performance of a bare-metal qualified visual examination of the RPV head and associated head penetration nozzles during Refueling Outage 20 (RO-20) in April of 2001. Inspections performed during RO-21 in October and November of 2002 included a bare-metal qualified visual examination of the RPV head and associated head penetration nozzles, and non destructive examination (NDE) of the RPV head penetration nozzles. The RO-20 and RO-21 bare-metal qualified visual examinations of the RPV head and associated head penetration Progress Energy Carolinas, Inc.

3581 West Entrance Road Hartsville, SC 29550

United States Nuclear Regulatory Commission Serial: RNP-RA/03-0023 Page 2 of 2 nozzles did not identify evidence of leakage or cracking. The RO-21 NDE of the RPV head penetration nozzles found no service-related degradation.

The previous inspection results and materiel condition of the HBRSEP, Unit No. 2, RPV head are being reviewed to determine if there is sufficient technical basis to warrant relaxation of the order requirements. Additionally, the option of procuring a replacement RPV head is being studied, with the replacement decision and timing being predominantly dependent on the costs of on-going inspections compared to the costs of replacing the RPV head. These reviews will be completed within 120 days of the date of the order, and if it is determined that a request for relaxation of the order requirements will be pursued, such request will be submitted at that time

-pursuant to Section IV.F of the order...

In response to questions provided dunng the NRC public meeting on February 24, 2003, the NRC indicated that requests for relaxation of the order requirements may be made later and do not need to be included in the 20-day response. HBRSEP, Unit No. 2, therefore consents to the order subject to: (1) The understanding that it may seek relaxation of the requirements in Section IV of the order upon completion of the 120-day review described above, if the criteria in Section IV.F are met; and (2) reservation of the right of HBRSEP, Unit No. 2, to request a hearing on any requirements of the order that may be subject to such a relaxation request.

The attachment to this letter provides an Affirmation in accordance with the provisions of Section 182a of the Atomic Energy Act of 1954.

If you have any questions concerning this matter, please contact Mr. C. T. Baucom.

Sincerely, B. L. Fletcher III Manager - Support Services - Nuclear CTB/ctb Attachment c: Mr. L. A. Reyes, NRC, Region II Mr. C. Patel, NRC NRC Resident Inspector Assistant General Council for Materials Litigation and Enforcement, NRC Document Control Desk, NRC

United States Nuclear Regulatory Commission Attachment to Serial: RNP-RA/03-0023 Page 1 of 1 AFFIRMATION The information contained in letter RNP-RA/03-0023 is true and correct to the best of my information, knowledge and belief; and the sources of my information are officers, employees, contractors, and agents of Carolina Power and Light Company. I declare under penalty of perjury that the foregoing is true and correct.

Executed on: .. (Vh.,J ,

Vie P J W. Moyer V :ePresident, HBRSEP, Unit No. 2