RNP-RA/12-0100, Review Request for the PWR Vessel Internals Program Plan for Aging Management of Reactor Internals

Review Request for the PWR Vessel Internals Program Plan for Aging Management of Reactor Internals

ML12278A398
Person / Time
Site:	Robinson
Issue date:	09/26/2012
From:	Wheeler S Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RNP-RA/12-0100
Download: ML12278A398 (3)

Text

jProgress Energy 10 CFR 54.21 Serial: RNP-RA/12-0100 SEP 2.6 2012 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 REVIEW REQUEST FOR THE PWR VESSEL INTERNALS PROGRAM PLAN FOR AGING MANAGEMENT OF REACTOR INTERNALS AT ROBINSON NUCLEAR PLANT

Dear Sir or Madam:

In a letter dated August 10, 2011 (Serial: RNP-RA/1 1-0029), WITHDRAWAL OF REACTOR VESSEL INTERNALS AGING MANAGEMENT PROGRAM INSPECTION PLAN (TAC NO. ME2362), Carolina Power and Light Company (CP&L), now doing business as Progress Energy, had expressed its intention to withdraw the Reactor Vessel Internals Aging Management Program Inspection Plan submittal, dated September 24, 2009.

Pursuant to the provisions of Renewed Operating License DPR-23 and consistent with the recommendation of U.S. Nuclear Regulatory Commission ML111990086, "NRC Regulatory Issue Summary 2011-07, License Renewal Submittal Informationfor Pressurized Water Reactor InternalsAging Management," July 21, 2011, CP&L hereby requests NRC approval of the following:

1. Withdrawal of the previously submitted Reactor Vessel Internals Aging Management Program Inspection Plan based on the draft Revision 0 of MRP-227, MaterialsReliability Program: "PressurizedWater Reactor InternalsInspection and Evaluation Guidelines."

2. The enclosed PWR Vessel Internals Program Plan for Aging Management of Reactor Internals at Robinson Nuclear Plant, which is developed in accordance with the requirements and expectation contained in MRP-227-A.

Progress Energy Carolinas, Inc.

Robinson Nuclear Plant 74 0c )

3581 West Entrance Road Hartsville, SC 29550

U.S. Nuclear Regulatory Commission Serial: RNP-RA/12-0100 Page 2 of 3 Through utilization of the NRC guidance and expectation, as reflected in Licensee/Action Item 2 of the NRC SE on MRP-227, Revision 0, the Robinson Nuclear Plant (RNP) Aging Management Program Plan (AMP) analysis has concluded that the requirement for application of MRP-227-A as a strategy for managing age-related material degradation in reactor internals components is warranted.

H. B. Robinson Steam Electric Plant Unit No. 2 (HBRSEP), also known as RNP, entered the license renewal period on August 1, 2010. The enclosed AMP is submitted prior to the required submittal date of October 1, 2012. The enclosed AMP for the RNP reactor internals demonstrates that the program adequately manages the effects of aging for reactor internals components and establishes the basis for providing reasonable assurance that the internals components will continue to perform their intended function through the RNP license renewal period of extended operation. RNP has developed this AMP in conformance with the 10 attributes reflected in, U.S. Nuclear Regulatory Commission NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," Revision 2. Consistent with the protocols of NEI 03-08, Revision 2, "Guidelinesfor the Management of MaterialsIssues," RNP adopts MRP-227-A and MRP-228 for development and implementation of its AMP for reactor internals.

The RNP AMP utilizes a combination of prevention, mitigation, and condition monitoring.

Where applicable, credit is taken for existing programs such as water chemistry, inspections prescribed by the ASME Section XI In-service Inspection Program, thimble tube inspections, and mitigation projects such as split pin replacement, combined with augmented inspections or evaluations as recommended by MRP-227-A.

CP&L has actively participated in past and ongoing Electric Power Research Institute (EPRI) and Pressurized Water Reactor Owners Group (PWROG) Reactor Vessel Internals (RVI) activities. CP&L will continue to maintain cognizance of industry activities related to PWR internals inspection and aging management; and will address/implement industry guidance, stemming from those activities, as appropriate under NEI 03-08 practices. CP&L will further develop, maintain and implement an AMP program, which is compliant and consistent with the requirements and expectation of top-tier regulatory drivers in which it is rooted.

This letter satisfies CP&L's commitment to submit a new AMP no later than October 1, 2012.

This letter contains no new commitments.

It is noted, the dates in Table 7-1 of the enclosure are provided for informational purposes to reflect the current projected dates for the performance of these inspections as currently known.

The preamble to the table and Note 1 at the end of the table was provided to explain that these dates are subject to change based on plant operation. However, the requirements of MRP-227-A shall continue to be met. Also, as merger activities between Progress Energy and Duke Energy proceed, additional changes to engineering organizational structure and responsibilities will continue to evolve. This evolution of the organization will facilitate ongoing review of this enclosed document. As these reviews proceed it is possible that administrative changes to the document may be warranted.

U.S. Nuclear Regulatory Commission Serial: RNP-RA/12-0100 Page 3 of 3 RNP's strategy will continue to be bounded by the parameters given in the enclosed AMP to ensure aging management strategy reflected in the AMP is not negated, the assumptions and the conclusions of the AMP are not rendered invalid, and no undue risk to the workers, the public and the environment is posed.

The RNP AMP ensures the long-term integrity and safe operation of the reactor internals components. The RNP AMP will manage aging effects of the RVIs so that the intended functions will be maintained consistent with the current licensing basis for the period of extended operation. The Enclosure provides the basis for the preceding statements.

If you should have any questions regarding this submittal, please contact Mr. Richard Hightower, Supervisor - Regulatory Affairs at (843) 857-1329.

I declare under penalty of perjury that the foregoing is true and correct. Executed On:

Sincerely, Sharon A. Wheeler Manager - Support Services - Nuclear SAW/am Enclosure

1. Westinghouse Report, WCAP-1 7077-NP, Revision 1, "PWR Vessel Internals Program Plan for Aging Management of Reactor Internals at Robinson Nuclear Plant," August 2012.

cc: Mr. V. M. McCree, NRC Region II Ms. A. T. Billoch-Colon, NRC Project Manager, NRR NRC Resident Inspectors, HBRSEP