ML16320A460

09/07/2016 Summary of Meeting with Virginia Electric and Power Company Regarding Pre-Submittal Information on Proposed Alternative to ASME Code to Repair Safety-Related Piping Using Carbon Fiber Reinforced Polymer at Surry Power Station, 1

ML16320A460
Person / Time
Site:	Surry
Issue date:	12/07/2016
From:	Cotton K R Plant Licensing Branch II
To:	Dominion
Cotton K R, NRR/DORL/LPLII-1, 415-1438
References
Download: ML16320A460 (4)

Text

LICENSEE: FACILITY:

SUBJECT:

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 7, 2016 Virginia Electric and Power Company (Dominion) Surry Power Station, Unit Nos. 1 and 2 SUMMARY OF SEPTEMBER 7, 2016, MEETING WITH VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) REGARDING PRE-SUBMITTAL INFORMATION ON PROPOSED ALTERNATIVE TO ASME CODE TO REPAIR SAFETY-RELATED PIPING USING CARBON FIBER REINFORCED POLYMER On September 7, 2016, a Category 1 meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Virginia Electric and Power Company (Dominion, the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. This purpose of the meeting was to discuss Dominion's proposed relief request (RR) approach for use of Carbon Fiber Reinforced Polymer (CFRP) as the pressure boundary in safety-related service water piping. The meeting notice and agenda, dated August 12, 2016, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML 16225A547. A list of attendees is enclosed. The licensee's presentation slides are available at ADAMS Accession No. ML 16320A523. The licensee's presentation to propose the application of an internal CFRP repair system to repair/upgrade selected safety-related piping systems included an overview of the CFRP process and procedures, a scope of the proposed alternative request, the technical basis, duration of the proposed alternative, precedents, references, and the regulatory procedures. A summary of certain discussion points follows. The licensee indicated in its presentation that the piping would include safety-related circulating water (CW) inlet piping and service water (SW) system pipe headers. The CW piping is 96" in diameter from the inlet canal to the main steam condensers and the SW pipe is 24", 30", 36", 42", and 48" diameter pipe headers from the CW system to the supply lines of the recirculation spray and component cooling heat exchangers. The lines are concrete encased, buried, and designed as Seismic Category 1 structures. The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," 2004 Edition, with no addenda, is the applicable code. The code requirement states that during the process of repairing this carbon steel piping, Article IWA-4000, subparagraph IWA-4221(b), requires that items used during a repair/replacement activity meet the original construction code. There are no provisions in ASME Code,Section XI, or in an approved code case for installing CFRP piping as a replacement for carbon steel piping during a repair/replacement activity. Therefore, Dominion must submit an inservice inspection (ISi) alternative RR for NRC approval in order to use CFRP material for repair of the piping sections. The licensee also included in the presentation the technical basis for the RR. The technical basis includes ASME Code components affected, material inspection and controls, design basis, installation, examination and testing, qualification and training operational experience, and ISi.

The licensee did not identify any precedents to this type of RR. The use of CFRP in nuclear safety-related piping is a first-of-a-kind submittal. The purpose of the meeting was an initial step for Dominion to discuss the scope and content of the alternative request in accordance with Title 10 of the Code of Federal Regulations 50.55a(z)(1 ), "Acceptable level of quality and safety." The NRC staff discussed with the licensee the importance of specifying exactly what it is asking for in the RR. The construction timeframe for the RR is from spring 2018 to fall 2025. There were questions from the general public regarding the NRR staff review procedures. Based on the licensee's current projections, the CFRP RR is expected to be finalized and submitted for NRC review by the end of 2016. No regulatory decisions or commitments were made at the meeting. No public feedback meeting forms were received. Please direct any inquiries to me at 301-415-1438 or by e-mail to Karen.Cotton@nrc.gov. Docket Nos. 50-280 and 50-281

Enclosure:

List of Attendees cc w/enclosure: Distribution via Listserv Sincerely, Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation LIST OF ATTENDEES SEPTEMBER 7, 2016, MEETING WITH VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION) ALTERNATE SOURCE TERM PROPOSED RELIEF REQUEST SURRY POWER STATION, UNIT NOS. 1 AND 2 NAME ORGANIZATION Michael Markley NRC V. Sreenivas NRC Karen Cotton Gross NRC Lars Gordon Dominion Johnny Henderson Dominion Janean Sealey Dominion Raska Osdrovic SG Gary Miller Dominion Jason Alexander Structural Anna Pridmore Structural Leo Nadeau Structural John Tsao NRC Dan Widrevitz NRC Jay Collins NRC Robert Hsu NRC David Pilley NRC Michael Breach NRC Roger Kalikian NRC Keith Hoffman NRC C. Basavaraju NRC Yong Li NRC Enclosure The licensee did not identify any precedents to this type of RR. The use of CFRP in nuclear safety-related piping is a first-of-a-kind submittal. The purpose of the meeting was an initial step for Dominion to discuss the scope and content of the alternative request in accordance with Title 10 of the Code of Federal Regulations 50.55a(z)(1), "Acceptable level of quality and safety." The NRC staff discussed with the licensee the importance of specifying exactly what it is asking for in the RR. The construction timeframe for the RR is from spring 2018 to fall 2025. There were questions from the general public regarding the NRR staff review procedures. Based on the licensee's current projections, the CFRP RR is expected to be finalized and submitted for NRC review by the end of 2016. No regulatory decisions or commitments were made at the meeting. No public feedback meeting forms were received. Please direct any inquiries to me at 301-415-1438 or by e-mail to Karen.Cotton@nrc.gov. Docket Nos. 50-280 and 50-281

Enclosure:

List of Attendees Sincerely, IRA/ Karen R. Cotton, Project Manager Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation cc w/enclosure: Distribution via Listserv DISTRIBUTION: PUBLIC LPL2-1 R/F RidsACRS_MailCTR Resource MBreach, NRR CBasavaraju, NRR KHsu JTsao, NRR RKalikian, NRR RidsNrrDorllpl2-1 Resource RidsNrrDraArcb Resource RidsNrrLALRonewicz Resource RidsNrrPMSurry Resource Yli,NRO RidsRgn2MailCenter Resource RidsNrrDeEpnb KHoffman, NRR JBowen, OEDO JCollins, NRR DWidrevitz, NRO VSreenivas, NRR TWertz, NRR ADAMS Accession No.: ML 16320A460 Meetin Notice ML 16225A547 Handouts ML 16320A523 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DORL/LPL NAME KCotton LRonewicz MMarkley DATE 11/29/2016 12/07/2016 12/07/2016 OFFICIAL RECORD COPY R/DORL/LPL2 Cotton 12/07/2016