View source for RA-19-0460, Revised Response to Request for Additional Information (RAI) Regarding Reactor Pressure Vessel (RPV) Surveillance Capsule Removal

{{Adams
| number = ML19353C963
| issue date = 12/19/2019
| title = Revised Response to Request for Additional Information (RAI) Regarding Reactor Pressure Vessel (RPV) Surveillance Capsule Removal
| author name = Nolan M
| author affiliation = Duke Energy Carolinas, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000261
| license number = 
| contact person = 
| case reference number = EPID L-2019-LLL-0021, RA-19-0460
| document type = Letter type:RA, Response to Request for Additional Information (RAI)
| page count = 6
| project = EPID:L-2019-LLL-0021
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:M. CHRISTOPHER NOLAN Vice President Nuclear Regulatory Affairs, Policy &
Emergency Preparedness 526 South Church Street, EC-07C Charlotte, NC 28202 704 382 7426 Chris.Nolan@duke-energy.com Serial: RA-19-0460                                                   10 CFR 50, Appendix H December 19, 2019 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

==SUBJECT:==
Revised Response to Request for Additional Information (RAI) Regarding Reactor Pressure Vessel (RPV) Surveillance Capsule Removal

==REFERENCES:==
: 1. Duke Energy Letter, Revision to Reactor Vessel Surveillance Capsule Removal Schedule, dated May 02, 2019 (ADAMS Accession No. ML19122A012).
: 2. NRC Email from Natreon Jordan to Art Zaremba, Draft Requests for Additional Information for H.B. Robinson LAR Regarding the Revision to the Reactor Pressure Vessel (RPV) Material Surveillance Program Withdrawal Schedule - RPV Surveillance Capsule Removal, dated October 15, 2019 (ADAMS Accession No. ML19288A294).
: 3. Duke Energy Letter, Response to Request for Additional Information (RAI) Regarding Reactor Pressure Vessel (RPV) Surveillance Capsule Removal, dated November 13, 2019 (ADAMS Accession No. ML19317D072).
Ladies and Gentlemen:
By letter dated May 02, 2019, Duke Energy Carolinas, LLC (Duke Energy) submitted a request for NRC approval of a proposed revision to the reactor pressure vessel (RPV) surveillance capsule removal schedule for the H.B. Robinson Steam Electric Plant, Unit 2 (Robinson)
(Reference 1). By letter dated October 15, 2019 the NRC requested additional information to complete its review of the request (Reference 2). By letter dated November 13, 2019 Duke energy responded to the request for information (Reference 3). The revised Duke Energy response to the request for information is provided in Enclosure 1.
This document contains the following regulatory commitment in Enclosure 2:
Capsule U will be withdrawn at either 41.3 effective full-power years (EFPY) or during the scheduled refueling outage after the capsule achieves a neutron fluence exposure equal to the peak, projected inside surface fluence for the reactor pressure vessel at 80-years operation.
The above commitment supersedes the regulatory commitment set forth in References 1 and 3.

RA-19-0460 Page 2 Should you have any questions concerning this letter, or require additional information, please contact Art Zaremba, Manager - Nuclear Fleet Licensing, at 980-373-2062.
Sincerely, M. Christopher Nolan Vice President Nuclear Regulatory Affairs, Policy & Emergency Preparedness

==Enclosure:==
: 1. Duke Energy Revised Response to NRC Request for Additional Information for the RPV Surveillance Capsule Removal
: 2. Regulatory Commitment cc:    (w/ enclosures)
L. Dudes, NRC Regional Administrator, Region II M. Barillas, NRR Project Manager, RNP M. Fannon, NRC Sr. Resident Inspector, RNP

RA-19-0460 Page 1 Enclosure 1 Duke Energy Revised Response to NRC Request for Additional Information for the RPV Surveillance Capsule Removal

RA-19-0460 Page 2 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 10 CFR PART 50, APPENDIX H WITHDRAWAL SCHEDULE CHANGE REQUEST DUKE ENERGY COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 DOCKET NUMBER 50-261 EPID: L-2019-LLL-0021 By letter dated May 2, 2019 (Agencywide Document Access and Management System (ADAMS) Accession No. ML19122A012), Duke Energy Company (the licensee) submitted a reactor pressure vessel (RPV) material surveillance program withdrawal schedule change for the H. B Robinson Steam Electric Plant, Unit 2. The licensee submitted its request in accordance with the reporting requirements specified in the 10 CFR Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements (Appendix H).
Specifically, the licensee proposes to amend the time for withdrawing RPV Capsule U from the reactor from 38 effective full power years (EPFY), when the capsule is projected to achieve an approximate neutron fluence exposure (at the time of removal) of 7.84 x 1019 n/cm2 (E > 1.0 MeV), to 41.3 EFPY, when the capsule is projected to achieve an approximate neutron fluence exposure of 8.09 x 1019 n/cm2 (E > 1.0 MeV).
The licensees submittal includes the following regulatory commitment (Commitment #1 in the submittal) in relation to the proposed capsule withdrawal schedule change:
Capsule U will be withdrawn at 41.3 effective full-power years (EFPY) or during the scheduled outage after the 80-year peak vessel fluence is reached, but prior to 57.1 EFPY.
Based on its review of the incoming submittal and the stated commitment, it is not clear when Capsule U will be withdrawn in accordance with the proposed withdrawal schedule for the capsule. For example, according to Section 4.0 of the licensees submittal, Capsule U will be withdrawn at either 41.3 EFPY (at a capsule fluence exposure of 8.09 x 1019 n/cm2 (E > 1.0 MeV)) or during the scheduled outage after the capsule has achieved a neutron fluence exposure equivalent to the peak neutron fluence projected in the RPV at 80 years of operation. However, per Note 1 on the proposed capsule withdrawal schedule and the commitment statement, the withdrawal of Capsule U could be deferred out to 57.1 EFPY. Given the uncertainty in the proposed withdrawal time for Capsule U, it is not evident how the proposed schedule meets the withdrawal schedule criteria of Appendix H.

RA-19-0460 Page 3

===RAI-1===
Please provide clarification as to how the proposed withdrawal schedule for Capsule U meets the requirements of Appendix H or modify the proposal to provide clarity concerning the proposed schedule.
Duke Energy Response Duke Energy has revised the regulatory commitment for the withdrawal schedule for Capsule U. The revised commitment shown in Enclosure 2 of this submittal clarifies that Capsule U will be withdrawn at 41.3 EFPY or during the scheduled refueling outage after the capsule achieves a neutron fluence exposure equal to the peak, projected inside surface fluence for the reactor pressure vessel at 80-years operation.

RA-19-0460 Page 1 Enclosure 2 Regulatory Commitment

==Subject:==
REVISION TO REACTOR VESSEL SURVEILLANCE CAPSULE REMOVAL SCHEDULE The action in this document committed to by H.B. Robinson Steam Electric Plant, Unit No. 2 (HBRSEP), is identified in the following table. Please direct any questions regarding this regulatory commitment to Art Zaremba, Manager - Nuclear Fleet Licensing.
Item       Commitment 1          Capsule U will be withdrawn at either 41.3 effective full-power years (EFPY) or during the scheduled refueling outage after the capsule achieves a neutron fluence exposure equal to the peak, projected inside surface fluence for the reactor pressure vessel at 80-years operation.}}