Ma DukeFifPower.

A Duke Energy Company

D.M. JAMILVice President

Duke PowerCatawba Nuclear Station4800 Concord Rd. / CNOI VPYork, SC 29745-9635

803 831 4251

803 831 3221 tax

January 27, 2005

U.S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, D.C. 20555

Subject: Duke Energy CorporationCatawba Nuclear Station, Units 1 and 2Docket Numbers 50-413 and 50-414Request for Relief Number 04-CN-004Reply to Request for Additional Information

Pursuant to 10 CFR 50.4, please find attached the subjectreply. The format of the reply is to restate the NRCquestion, followed by Catawba's response. The NRC questionswere transmitted via fax dated November 10, 2004.

There are no regulatory commitments contained in this letteror its attachment.

If you have any questions concerning this material, pleasecall L.J. Rudy at (803) 831-3084.

Very truly yours,

LJR/s

Attachment

www. dukepower. corn

Document Control DeskPage 2January 27, 2005

xc (with attachment):

W.D. Travers, Regional AdministratorU.S. Nuclear Regulatory Commission, Region IIAtlanta Federal Center61 Forsyth St., SW, Suite 23T85Atlanta, GA 30303

E.F. Guthrie, Senior Resident InspectorU.S. Nuclear Regulatory CommissionCatawba Nuclear Station

S.E. Peters, Project Manager (addressee only)U.S. Nuclear Regulatory CommissionMail Stop 0-8 G9Washington, D.C. 20555-0001

REQUEST FOR ADDITIONAL INFORMATIONCATAWBA NUCLEAR STATION UNITS 1 AND 2

SECOND 10-YEAR INSERVICE INSPECTION INTERVALREQUEST FOR RELIEF NUMBER 04-CN-004DOCKET NUMBERS 50-413 AND 50-414

In its letter dated May 18, 2004 Duke Energy Corporation(the licensee) submitted Request for Relief Number 04-CN-004proposing an alternative pursuant to 10 CFR 50.55a(a)(3)(ii)for portions of ASME Code Class 1 piping and componentsconnected to the Reactor Coolant System (RCS) that arenormally isolated from direct RCS pressure (2235 psig)during their normal operation. They are isolated from thereactor coolant loop by their location, either upstream of acheck valve, between 2 check valves or between 2 closedvalves that must remain closed during the unit's operation(or Startup) in Modes 3, 2 or 1.

The NRC staff has reviewed the licensee's request for reliefand has determined that additional information is necessaryto complete the review of the relief request. The requestfor additional information (RAI) is requested below:

1. State the 10-year inservice inspection (ISI) intervalin which Request for Relief 04-CN-004 applies andprovide the start and end dates of the applicable 10-year ISI interval.

Response to Question 1:

This relief is requested for Catawba Units 1 and 2,second 10-year inspection intervals.

The Unit 1 interval began June 29, 1995 and ends June29, 2005. Unit 1 has one more outage prior to the endof the interval.

The Unit 2 interval began August 19, 1996 and endsAugust 19, 2006. Unit 2 has one more outage prior tothe end of the interval.

2. In the request for relief Code Case N-498-1 was listedas an alternative to rules for system leakage testing.Was Code Case N-498-1 invoked under Regulatory Guide1.147, Revision 12 for the applicable 10-year ISIinterval program? Since Code Case N-498-4 is nowapproved for general use in Regulatory Guide 1.147,Revision 13 was it considered for this request forrelief?

Attachment Page 1

Response to Question 2:

Catawba is using Code Case N-498-1, "Alternative RulesFor Ten Year System Hydrostatic Testing For Class 1, 2,and 3 Systems." This Code Case is approved for use byRequest for Relief Serial #94-GO-001. Regulatory Guide1.147, Revision 12 endorsed Code Case N-498-1 for usewith no limitations. Duke Energy Corporation evaluatedCode Case N-498-4 and determined that there was novalue added to that from currently used Code Case N-498-1.

3. In the request for relief the licensee referenced theCrane Technical Paper #410 published by the Crane ValveGroup of the Crane Valve Manufacturing Company.Provide a background regarding this paper as to how itapplies to the Catawba Nuclear Station, Units 1 and 2.Has this paper been approved by the NRC for the use atCatawba Nuclear Station, Units 1 and 2?

Response to Question 3:

Crane Technical Paper No. 410, titled, "Flow of FluidsThrough Valves, Fitting, and Pipe," 1988, is publishedby the Engineering Department of Crane Company. Thistechnical paper provides common mathematicalrelationships, through various formulas and nomographs,which can be applied to forced fluid flow. As such,this document presents mathematical equations that arecommonly accepted.

Request for Relief No. 04-CN-004, with reference toCrane Technical Paper No. 410, applied the followingformula to express the fluid pressure-flow relationshipfor fluid flow through a fixed orifice.

-xL =.33L2235

The above formula is derived from Equation 2-23, onpage 2-14, of Crane Technical Paper No. 410, 1988.

L(gpm) = CA 2g(144)dP(psi)2235

For the example presented in the Request for Relief, ifa leak (Li) were projected to be present at 2235 psig(dPi), that same leak would be present at 250 psig

Attachment Page 2

(dP2), but at only 33% of the original leak rate. Bymaintaining other variables constant and simplifyingfor like terms, Crane Equation 2-23 becomes:

LeakRate (L2)= xL1 x L .33L1dP 1 2235

As identified in the original Request for Relief,inspections that reveal no leakage at 250 psig (duringVT-2 examination) give high confidence that no leakagewould be present at 2235 psig.

4. In Section IV "Bases for Requesting Relief" of thelicensee's relief the licensee noted in general thatthere would be physical exposure to significant safetyhazards such as high temperatures, and pressures duringthe Code leakage testing. Provide additional detailfor each "Portion" of the relief regarding physicalsafety hazards to workers.

Response to Question 4:

Primary system pressure and temperature for CatawbaClass A piping is 2235 psig and 557 degrees F. Thesevalves are the first and second valves at the Class Aboundary extremity. Manipulation of these componentsto reactor coolant system pressure and temperaturewould subject personnel in these areas to a substantialsafety hazard.

5. In Section IV "Basis for Requesting Relief" of thelicensee's relief the licensee stated that there wouldbe additional radiation exposure if the Code systemleakage tests were performed, but dose rates were notprovided. Provide the dose rates that workers would beexposed to during the Code leakage tests for each"Portion" of the relief.

Response to Question 5:

Note: The following two-letter Duke Energy Corporationsystem designators are utilized in this and somesubsequent responses:

NC - Reactor Coolant SystemND - Residual Heat Removal/Low Head Injection SystemNI - Intermediate Head Injection SystemNV - Chemical and Volume Control/High Head InjectionSystem

Attachment Page 3

The following sketches give locations and dose ratesfor valves that are in Portions 1 through 7.

02203'.

Dose rates In his area are500 rnrevhrcontact and 200mremihr General Area

Attachment Page 4

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Attachment Page 5

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Attachment Page 6

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Attachment Page 8

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Attachment Page 9

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Attachment Page 10

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6. In Portion 3 the length of the segment of the pipingwas identified to be 3 inches. Provide the segmentlength of the piping in Portions 1, 2, 4, 5, 6, and 7in which relief is requested.

Response to Question 6:

The following are the approximate segment lengths forportions 1, 2, 3, 4, 5, 6, and 7.

Portion #1Portion #2Portion #3Portion #4Portion #5Portion #6Portion #7

= 97 feet= 302 feet= 32 feet= 765 feet= 383 feet= 77 feet= 20 feet

7. In the provided P&IDs attached to the licensee'srequest for relief the material of the piping was

Attachment Page 11

listed as stainless steel, but was not specificregarding the type of stainless steel nor were thereany discussions in the relief on corrosion mechanisms.Provide the material type for each "Portion" or pipingsegment of the relief and if any corrosion mechanismshave been identified during the service life of thesubject piping segments.

Response to Question 7:

Throughout the Question 7 response, the followingtemplate is utilized for the information transmitted(where applicable):

Catawba Pipe Specification (PS), Design Pressure,Design Temperature, Pipe Diameter and Schedule, ASMEPiping Materials Designation, Components in Portion orPiping Segment (e.g., fittings, socket welds (SW), buttwelds (BW)), Component Rating, ASME Component MaterialsDesignation

Portion 1:Auxiliary spray line, boundary valves INV37A, 1NV861,1NV38PS 2501.1, 2500 psia, 650 degrees F, 2" SA376 Grade304, fittings, SW, SA182, F304

Portion 2:Residual heat removal suction off reactor coolant loop,boundary valves 1ND1B, 1ND2A, 1ND36B, 1ND37APS 2501.1, 2500 psia, 650 degrees F, 12" SA376 Grade316, fittings, BW, SA403, 316

Portion 3:NV to NI safety injection to cold legs, boundary valves1NI351, 1NI15 (loop A), 1NI352, 1NI17 (loop B), 1NI353,1NI19 (loop C), INI354, INI21 (loop D)PS 2501.1, 2750 psia, 650 degrees F, 1-1/2" schedule160, SA376 Grade 304, fittings, SW, 6000 lb, SA182,F304

Portion 4:NI cold leg accumulator to cold legs, boundary valves1NI54A, 1NI60, INI181, INI165 (loop A), 1NI65B, INI71,1NI180, 1NI167 (loop B), 1NI76A, 1NI82, 1NI175, INI171(loop C), 1NI88B, lNI94, lNI176, lN1169 (loop D)PS 2501.1, 2500 psia, 650 degrees F, 10" schedule 140,SA376 Grade 316, fittings, BW, SA403, 316PS 2501.1, 2500 psia, 650 degrees F, 6" schedule 160,SA376 Grade 304, fittings, BW, SA403, 304

Attachment Page 12

PS 2501.1, 2500 psia, 650 degrees F, 2" schedule 160,SA376 Grade 304, fittings, SW, 6000 lb, SA182, F304

Portion 5A:NI safety injection to hot legs, boundary valves1NI157, 1NI156 (loop A), INI160, 1NI159 (loop D)PS 2501.1, 2500 psia, 650 degrees F, 6" schedule 160,SA376 Grade 304, fittings, BW, SA403, 304PS 2501.1, 2500 psia, 650 degrees F, 4" schedule 160,SA376 Grade 304, fittings, BW, SA403, 304PS 2501.1, 2500 psia, 650 degrees F, 2" schedule 160,SA376 Grade 304, fittings, SW, 6000 lb, SA182, F304

Portion 5B:NI safety injection to hot legs, boundary valvesINI129, 1N1128, INI134 (loop B), 1NI125, 1NI124, 1NI126(loop D)PS 2501.1, 2500 psia, 650 degrees F, 8" schedule 160,SA376 Grade 304, fittings, BW, SA403, 304PS 2501.1, 2500 psia, 650 degrees F, 6" schedule 160,SA376 Grade 304, fittings, BW, SA403, 304PS 2501.1, 2500 psia, 650 degrees F, 2" schedule 160,SA376 Grade 304, fittings, SW, 6000 lb, SA182, F304

Portion 6:Reactor coolant loop drain lines, boundary valves lNC4,lNC5 (loop A), 1NC94, 1NC95 (loop B), lNC13, iNC115,1NC106 (loop C), lNC19, 1NC20 (loop D)PS 2501.1, 2500 psia, 650 degrees F, 2" schedule 160,SA376 Grade 304, fittings, SW, 6000 lb, SA182, F304

Portion 7:Reactor coolant loop vent lines, boundary valves1NC298, lNC299, bypass valves lNC311, 1NC312PS 2501.1, 2500 psia, 650 degrees F, 3" schedule 160,SA376 Grade 304, fittings, BW, SA403, 304

The above listed materials are all austenitic stainlesssteel. These stainless steels have performed withoutevidence of general corrosive attack in pressurizedwater reactor coolant service. There are no knownconcerns with flow accelerated corrosion, erosion, orboric acid corrosion. Stress Corrosion Cracking (SCC)has been observed in isolated cases with Type 304 and316 stainless steels based on oxygenated reactorcoolant environments that experience long periods ofstagnation. However, there are restrictive controls onthe reactor coolant system chemistry, including oxygenand chlorides at Catawba during startup and operation.These controls, along with periodic flushes during

Attachment Page 13

refueling outages, limit the exposure of this piping tothis detrimental environment. Furthermore, Catawba hasno history of corrosion degradation of these lines andvolumetric examinations of the welds within this scopeof piping to date have not indicated any reportableindications.

8. Provide a discussion on the ASME Code, Section XInondestructive examinations, if any that the subjectpiping segments received or will receive during theplant's current 10-year inservice inspection programplan.

Response to Question 8:

Portion 1:Segments of this piping receive a surface examinationin accordance with Examination Category B-J, PressureRetaining Welds in Piping (B9.40).

Portion 2:Segments of this piping receive a volumetric andsurface examination in accordance with ExaminationCategory B-J, Pressure Retaining Welds in Piping(B9.11).

Portion 3:Segments of this piping receive a surface examinationin accordance with Examination Category B-J, PressureRetaining Welds in Piping (B9.40).

Portion 4:Segments of this piping receive a volumetric andsurface examination in accordance with ExaminationCategory B-J, Pressure Retaining Welds in Piping(B9.11, B9.12, B9.32, B9.40).

Portion 5:Segments of this piping receive a volumetric andsurface examination in accordance with ExaminationCategory B-J, Pressure Retaining Welds in Piping(B9.11, B9.21, B9.40).

Portion 6:Segments of this piping receive a surface examinationin accordance with Examination Category B-J, PressureRetaining Welds in Piping (B9.21, B9.40).

Portion 7:

Attachment Page 14

Segments of this piping receive a surface examination

in accordance with Examination Category B-J, Pressure

Retaining Welds in Piping (B9.21).

Attachment Page 15