RNP-RA/17-0042, Submittal of the PWROG-14048-P, Revision 1, to Satisfy the Regulatory Commitment Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals

Submittal of the PWROG-14048-P, Revision 1, to Satisfy the Regulatory Commitment Related to the Pressurized Water Reactor Internals Program Plan for Aging Management of Reactor Internals

ML17180A384
Person / Time
Site:	Robinson
Issue date:	06/29/2017
From:	Kapopoulos E Duke Energy Progress
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PWROG-14048-P, Rev 1, RNP-RA/17-0042, TAC ME9633
Download: ML17180A384 (5)

Text

Ernest J. Kapopoulos, Jr.

H. B. Robinson Steam Electric Plant Un# 2 Sffe Vice President Duke Energy 3581 West Entrance Road Hartsville, SC 29550 0 843 8571701 F: 843 8571319 Ernit.Kap11puu/os @dukt-tntrgy.c11m 10 CFR 54.21 Serial: RN P-RA/17-0042 JUN 2 9 2017 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/RENEWED LICENSE NO. DPR-23 SUBMITIAL OF THE PWROG-14048-P, REVISION 1, TO SATISFY THE REGULATORY COMMITMENT RELATED TO THE PRESSURIZED WATER REACTOR INTERNALS PROGRAM PLAN FOR AGING MANAGEMENT OF REACTOR INTERNALS (TAC NO. ME9633)

References:

1. Pressurized Water Reactor Owners Group letter to NRC. "PWR Owners Group Submittal of PWROG-14048-P, Revision 1, "Functionality Analysis: Lower Support Columns," dated March 1, 2017 (ADAMS Accession No. ML17066A266)

Ladies and Gentlemen:

By letter dated February 08, 2016 (ADAMS Accession Number: ML16019A053), the NRC requested that Duke Energy, respond to a request for additional information (RAI) regarding the Aging Management Program for the Reactor Vessel Internals at H.B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2.

The Duke Energy response to this request (RAl-5(b)-1-2) was provided in Enclosures 1 and 2 of the Duke Energy letter, dated February 18, 2016 (ADAMS Accession Number: ML16054A159).

In particular, Enclosure 2 of the Response to RAl-5(b)-1-2, contained a regulatory commitment for the Staff's consideration, related to the HBRSEP, Unit No. 2, Cast Austenitic Stainless Steel(CASS)

Lower Support Columns (LSC) in the Reactor Vessel.

By letter dated December 15, 2016, the NRC issued a Staff Assessment (ADAMS Accession Number: ML16281A510), which concluded the HBRSEP, Unit No. 2, Reactor Vessel Internals Aging Management Program Plan is acceptable because it is consistent with the inspection and evaluation guidelines of Materials Reliability Program Report (MRP)-227-A, "Pressurized Water Reactor Internals Inspection and Evaluation Guidelines" and it has adequately addressed all eight specified licensee action items.

United States Nuclear Regulatory Commission Serial: RNP-RA/17-0042 Page 2 of 3 In the Staff Assessment, the NRG concurred with the establishment of the above mentioned commitment and the Duke Energy's HBRSEP, Unit No. 2, approach to utilize the industry PWROG-14048-P report to provide justification of plant-specific applicability related to HBRSEP, Unit No. 2, specific parameters and operating conditions. The HBRSEP, Unit No. 2, made a commitment to submit a revised version of the PWROG-14048-P, Revision 0, report by June 30, 2017.

The technical report associated with tasks related to PWROG-14048-P, has been revised and submitted to the NRG via the PWR Owners Group, for information only, as detailed in Reference 1.

It is noted, HBRSEP, Unit No. 2, is identified as Plant Jin the stated analysis. This analysis concludes that there is reasonable assurance that the Lower Support Columns (LSCs) will remain functional through the period of extended operation, the LSCs show considerable tolerance to the existence of potential flaws, and that inspections are not necessary to ensure the functionality of the LSCs through the period of extended operation.

A copy of the regulatory commitment originally made in Response to RAl-S(b)-1-2, and explicitly referred to in the Staff Assessment, is reproduced in the Enclosure to this letter. The submittal of the PWROG-14048-P, Revision 1, hereby satisfies the regulatory commitment related to the Staff Assessment and the RAl-S(b)-1-2. There are no additional regulatory commitments made in this submittal. If you have any questions regarding this submittal, please contact Mr. Tony Pilo, Manager - Nuclear Regulatory Affairs, at (843) 857-1409.

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

Executed On: t,.q'fut-J~-iot7 Sincerely, Ernest J. Kapopoulos, Jr.

Site Vice President

United States Nuclear Regulatory Commission Serial: RNP-RA/17-0042 Page 3 of 3 EJK/am

Enclosure:

Regulatory Commitment (reproduced from RAl-S(b)-1-2) cc: NRC Regional Administrator, NRC, Region II D. Galvin, NRC Project Manager, NRR (w/o Enclosures)

NRC Resident Inspector, HBRSEP Unit No. 2

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/17-0042 2 Pages (including cover page)

REGULATORY COMMITMENT (REPRODUCED FROM RAl-S(b)-1-2)

United States Nuclear Regulatory Commission Enclosure to Serial: RNP-RA/17-0042 REGULATORY COMMITMENT The following table identifies the action committed to by H. B. Robinson Steam Electric Plant (HBRSEP), Unit No. 2, in this submittal. All other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE (Check One) SCHEDULED COMMITMENT ONE- COMPLETION CONTINUING DATE/EVENT TIME COMPLIANCE ACTION 1 Robinson will submit a copy of the x June 30, 2017 Technical Report associated with tasks related to PWROG PA-MSC-1103, Revision 2, to the NRC by Uune 30, 2017.

lrhe stated Technical Report will

~ontain RNP applicable flaw tolerance analysis developed based upon PWROG-14048-P, as reflected in RAl-S(b)-1-2, of the NRC Letter, dated February 08, 2016 (ADAMS Accession Number: ML16019A053}.

In particular, this Technical Report Will address Action Item 7 from the NRC final safety evaluation (SE)

(ADAMS Accession No. ML11308A770) of the Materials Reliability Program (MRP)-227-A report, "Pressurized Water Reactor Internals Inspection and Evaluation Guidelines" (ADAMS

~ccession No. ML120170453) in reference to the functionality of the Lower Support Columns.