BSEP-99-0066, Submits Revised Relief Requests Which Provides Alternative to ASME B&PV Code Requirements for Insp of Containments. Revised Copies of Relief Requests CIP-03,CIP-04,CIP-05, CIP-10,CIP-16 & CIP-17 Provided

Submits Revised Relief Requests Which Provides Alternative to ASME B&PV Code Requirements for Insp of Containments. Revised Copies of Relief Requests CIP-03,CIP-04,CIP-05, CIP-10,CIP-16 & CIP-17 Provided

ML20206G739
Person / Time
Site:	Brunswick
Issue date:	05/04/1999
From:	Jury K CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-99-0066, BSEP-99-66, TAC-MA4166, TAC-MA4167, NUDOCS 9905100130
Download: ML20206G739 (26)

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CP&L  !

l Carolina Power & Ught Company P.o. Box 10429 Southport, NC 28461-0429 i

i MAY 0 41999 10 CFR 50.55a(a)(3) 10 CFR 50.55a(g)(5) )

l SERIAL: BSEP 99-0066 l

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 BRUNSWICK STEAM ELECTRIC PLANT, UN1"NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324/ LICENSE NOS. DPR-7i AND DPR-62 REQUEST TO USE ALTERNATIVES TO THE ASME BOILER AND PRESSURE VESSEL CODE, SECTION XI, FOR CONTAINMENT INSPECTION (NRC TAC NOS. MA4166 AND MA4167)

Gentlemen:

The purpose of this letter is to submit revised relief requests which provide alternatives to American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirements for inspection of containments. The revised relief requests apply to Carolina Power & Light (CP&L) Company's Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2.

On September 9,1998,10 CFR 50.55a, " Codes and standards," was amended to incorporate, by reference, the 1992 Edition of the ASME Code with the 1992 Addenda of Subsection IWE,

" Requirements for Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Power Plants," and Subsection IWL, " Requirements for Class CC Concrete Components of Light-Water Cooled Power Plants" of the ASME Code. The amended regulation required licensees to incorporate Subsection IWE and Subsection IWL into their inservice inspection program and to complete expedited implementation of containment inspections within five years of the effective date of the amended regulation.

By letter dated October 28,1998 (Serial: BSEP 98-0199), CP&L requested approval of eighteen alternatives, applicable to BSEP, Units 1 and 2, to the containment inspection requirements contained in Subsections IWE and IWL of the ASME Code. These alternatives were designated as Relief Requests CIP-01 through CIP-18.

Based on NRC comments receivedidu'rinhdekview of other alternatives for th Inspection Program, CP&L has determined that seven of the eighteen relief requests should be revised to clarify the regulatory basis under which they are being submitted (i.e., that they are being requested as altematives rather than being based on impracticality or unusual difficulty).

Although revised, the technical bases for these requests did not change. Revised copies of Relief

! Requests CIP-03, CIP-04, CIP-05, CIP-07, CIP-10, CIP-16, and CIP-17 are provided in , p 9905100130'990504' . l, i PDR P

ADOCK 05000324 PDR 9 '

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n, Document Control Desk BSEP 99-0066 / Page 2 Enclosure 1. An updated list of the Containment Inspection Program relief requests is provided in Enclosure 2.

Please refer any questions regarding this submittal to Mr. Warren J. Dorman, Supervisor -

Licensing, at (910) 457-2068.

Sincerely,

'GL d.

Keith R. Jury Manager - Regulatory Affairs Brunswick Steam Electric Plant WRM/wrm

Enclosures:

1. Revised Relief Requests

2. List of Containment Inspection Program Relief Requests cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-3415 U. S. Nuclear Regulatory Commission ATTN: Mr. Theodore A. Easlick, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission ATfN: Mr. Allen G. Hansen (Mail Stop OWFN 8G9) )

11555 Rockville Pike l Rockville, MD 20852-2738 I

Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 l

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- Document Control Desk -

BSEP 99-0066 / Page 3 Division of Boiler and Pressure Vessel North Carolina Department of Labor j ATTN: Mr. Jack Given, Assistant Director of Boiler.& Pressure Vessels j 4 West Edenton Street Raleigh, NC 27601-1092 4

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ENCLOSURE 1 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2

) DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 REQUEST TO USE ALTERNATIVES TO THE ASME BOILER AND PRESSURE VESSEL CODE, SECTION XI, FOR CONTAINMENT INSPECTION (NRC TAC NOS. MA4166 AND MA4167) l Revised Relief Reauests l

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RELIEF REQUEST: CIP-03 (RIv. 0)

TITLE: ACCESSIBILITY FOR EXAMINATION OF SINGLE-WELDED BUTT JOINTS COMPONENTS FOR WHICH RELIEF IS REQUESTED:

This request for relief is applicable to single-welded butt joints subject to the requirements of IWE-1231(a)(3). This request for relief will apply to single-welded butt joints at the Brunswick Steam Electric Plant (BSEP), Units 1 and 2.

ASME CODE, SECTION XI REQUIREMENT:

Paragraph IWE-1231(a)(3) requires that single-welded butt joints remain accessible for either direct or remote visual examination, from at least one side of the vessel, for the life of the plant.

REQUESTED RELIEF:

Relief is requested from the requirement of paragraph IWE-1231(a)(3) to have single-welded butt joints remain accessible for either direct or remote visual examination, from at least one side of the vessel, for the life of the plant.

BASIS FOR REQUESTING RELIEF:

In accordance with 10 CFR 50.55a(a)(3)(i), Carolina Power & Light (CP&L) Company is requesting approval to implement an alternative to the requirement specified in paragraph IWE-1231(a)(3). As an acceptance alternative, CP&L will ensure that single-weld butt joints are included in the requirement to maintain at least 80% of the pressure retaining boundary, as defined in Table IWE-2500-1, Examination Category E-A, accessible for examination for the life of the plant.

This acceptable alternative has been evaluated by CP&L, and CP&L has determined that implementing this alternative requirement will provide an acceptable level of quality and safety for the following reasons:

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1. The requirement to maintain single-welded butt joints accessible from at least one side for the life of the plant, to allow for the examination of pressure retaining welds, is no longer warranted. As originally published in 1981, the rules and requirements of Subsection IWE focused on the examination of welds. This weld-based examination philosophy was established in the 1970s as plants were being constructed. This examination philosophy was based on the premise that the welds in pressure vessels  !

and piping were the areas of greatest concern. Thus, the requirement of IWE-  !

1231(a)(3) was established to assure the examination specified in Examination j Category E B and E-F could be met.

As clarified in the amendment to 10 CFR 50.55a (i.e.,61 FR 41303), degradation of base metal, rather than welds, has been found to be the issue of concern as containments have aged. Thus, the NRC conc!uded that requiring the examinations specified by Examination Category E-B and E-F was not appropriate. For this reason, the amendment to 10 CFR 50.55a provided a modification (10 CFR 50.55a(b)(2)(x)(C))

' to make the examination of welds per these examination categories optional. Since there is no requirement to examine welds per Examination Category E-B or E-F, the requirement specified in IWE-1231(a)(3) is no longer warranted.

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RELIEF REQUEST: CIP-03 (Riv. 0)

TITLE: ACCESSIBILITY FOR EEAMINATION OF SINGLE-WELDED BUTT JOINTS 1

2. The containment vessels at BSEP contain single-welded butt joints, and those portions that contain these welds are backed up by reinforced concrete. Thus, one side of the butt joint is inaccessible. Mandating this requirement could prevent CP&L from installing a safety-related modification that would make these welds inaccessible.

3. The examination of ASME Class MC components is a requirement of subarticle IWE 2500. As required by Examination Category E-A, accessible surface areas, which includes welds and base metal, are to be examined periodically. Although the requirement of paragraph IWE-1231(a)(3) to maintain single-welded butt joint accessible can be deleted, these welds are considered part of the pressure retaining boundary and are required to be examined in accordance with Examination Category E-A. For this reason, CP&L must include these welds into the 80% of the surface area required to be maintained accessible for examination in accordance with paragraph IWE 1231(a)(4).

4. The ASME Main Committee and the Board of Nuclear Codes and Standards have also determined that the requirement to maintain single-welded butt joints accessible from at least one side for the life of the plant is no longer warranted. Both organizations have approved a rewrite of Subsection IWE which eliminated this requirement. This rewrite of Subsection IWE was published in the 1998 Edition of the ASME Code,Section XI.

l PROPOSED ALTERNATIVE:

During the First Containment inspection Interval, CP&L will include the accessible surface areas of single-weld butt joints into the applicable requirement of paragraph IWE-1231(a)(4). Thus, CP&L will maintain at least 80% of the pressure retaining boundary accessible for either direct or remote visual examination for the life of the plant.

REFERENCES:

1. ASME Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," 1992 Edition with 1992 Addenda and 1998 Edition.

2. Part 50.55a, " Codes and Standards," of Title 10 of the Code of Federal Regulation (10 CFR 50.55a).  ;

3 Federal Register,61 FR 41303, Dated: August 8,1996. )

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RELIEF REQUEST: CIP-04 (Riv. 0)

TITLE: VISUAL EXAMINATION OF SEALS AND GASKETS COMPONENTS FOR WHICH RELIEF IS REQUESTED:

This request ior relief is aoplicable to seals and gaskets subject to examination per Table IWE 2500-1, Examination Category E D (item Nos. E5.10 and E5.20). This request for relief will apply to the seals and gaskets at the Brunswick Steam Electric Plant (BSEP), Units 1 and 2.

ASME CODE, SECTION XI HEQUIREMENT:

Table IWE-2500-1, Examination Category E-D (Item Nos. E5.10 and E5.20) requires a VT-3 f visual examination of seals and gaskets during the Inspection Interval.

l REQUESTED RELIEF:

Relief is requested from performing the VT-3 visual examination of the seals and gaskets subject to examination per Table IWE 2500-1, Examination Category E D (Item Nos. E5.10 (

and E5.20). l BASIS FOR REQUESTING RELIEF:

In accordance with 10 CFR 50.55a(a)(3)(i), Carolina Power & Light (CP&L) Company is )

requesting approval to implement an alternative to the requirement of Table IWE-2500-1, l Examination Category E-D (item Nos. E5.10 and E5.20). CP&L proposes to verify the leak-  !

tightness of these seats and gaskets in accordance with the testing requirements specified in j 10 CFR 50, Appendix J.

The proposed alternative for assuring the leak-tight integrity of primary containment has been evaluated by CP&L, and CP&L has determined that the implementation of the alternative requirement will provide an acceptable level of quality and safety for the following reasons: l

1. Seals and gaskets, subject to examination per the ASME Code,Section XI, are those used on penetrations (e.g., airlocks, hatches) that are required to assure containment leak-tight integrity. As required by 10 CFR 50, Appendix J, these same seals and gaskets are required to be leak rate tested (i.e., Type B test). The purpose of the Type B test is to detect local leaks at containment peak accident pressure and to measure leakage across the leakage-limiting boundary of containment penetrations whose desion incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations fitted with flexible metal seal assemblies. When compared to a visual examination, CP&L considers a leak rate test at containment peak accident pressure a superior and proven method for identifying degradation that may cause containment leakage. If unacceptable leakage is identified during the test, corrective measures would be taken and the connection retested. The performance of a visual examination, in addition to this leak test, would provide no compensating increase in quality and safety.

2. For those penetrations (e.g., Drywell Head, Torus Access Hatches, Equipment Hatch) that are routinely disassembled during a refueling outage, a Type B test is required upon final assembly and prior to start-up. The mechanical connection associated with these penetrations employs a tongue and groove or ring joint configuration. Thus, the seals or gaskets are not accessible for examination when the connection is assembled. For this reason, a VT-3 examination of the seal cr gasket would have to be performed prior to final assembly. Since potential damage to the seal or gasket would most likely occur during the Page 1 of 3

r RELIEF REQUEST: CIP-04 (Riv. 0)

TITLE: VISUAL EXAMINATION OF SEALS AND GASKETS final assembly of the connection, the visual examination provides no compensating increase in quality and safety. Failure of the seal or gasket would be identified during the Type D test.

3. Performance of the visual examination of the seals or gaskets would require disassembly and re-assembly of the mechanical connection for those penetrations (e.g., Personnel Airlock-to-Drywell, Drywell Head Access Hatch) that are not routinely disassembled during a refueling outage. The seals or gaskets associated with these penetrations are also not accessible for examination when the connection is assembled. For this reason, the connection woulo require disassemb!y for the sole purpose of performing the visual examination, Since these connections are periodically Type B tested in accordance with 10 CFR 50, Appendix J to verify their leak-tight integrity, CP&L considers the physical wear of the components and the possibility of component damage that could be associated with the disassembly and re-assembly activity unwarranted.

4. The more stringent requiremerus outlined for a VT-3 visual examination are not appropriate for the examinatiori of seals anj gaskets. The VT-3 visual examination requirements outlined in IWA-2210 were writien primarily for detecting flaws in metallic components (e.g.,

welds, supports). As defined in IWA-2213, a VT-3 visual examination is conducted to

' determine the general mechanical and structural condition of components and their support.

This examination is accomplished by verifying parameters such as clearances, settings, and physical displacement; and provides detection of discontinuities and imperfections (e.g., loss of integrity at bolted or welded connections). The seals and gaskets at BSEP are made of a non-metallic material and are not subject to the same degradation mechanisms as a component made of a metallic material. Therefore, a VT-3 visual examination of seals and gaskets is not warranted nor would it provide a compensating increase in quality and safety.

5. Option B of 10 CFR 50, Appendix J has been implemented at BSEP. During the implementation of Option B, a review of those penetrations containing seals and gaskets was performed. The review of corrective action work orders and "as-found" test results identified no service induced anomalies. Since these penetrations are in a static environment during normal operation and are periodically tested per Appendix J, disassembly of a penetration for the sole purpose of visual examination is not warranted.

6. Upon implementation of 10 CFR 50, Appendix J, Option B, the Type B test frequency for those penetrations not routinely disassembled each refueling outage was extended from once every 24 months to once every three refuel cycles. For the containment personnel airlock seals, the test frequency was extended to at least once every 30 months. Based on the performance history of BSEP's containments, the Type A test frequency was also extended to at least once per 10 years. Since these penetrations are Type B tested and also tested during the performance of the Type A test, their leak tight integrity will be verified at least twice during the First Ccntainment inspection Interval. The VT-3 examination per Table IWE-2500-1, Examination Category E-D (Item Nos. E5.10 and E5.20) of these same seals and gaskets would only be performed once during this same time period. CP&L considers verification of the leak-tight integrity of these seals and gaskets at least twice during the Inspection Interval appropriate. Performance of a visual examination, in addition to these leak rate tests, will provide no compensating increase in quality and safety.

7. The ASME Main Committee and the Board of Nuclear Codes and Standards have also determined that a VT-3 visual examination of the seals and gaskets are no longer warranted.

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RELIEF REQUEST: CIP-04 (Riv. 0)

TITLE: VISUAL EXAMINATION OF SEALS AND GASKETS l Both organizations have approved the rewrite of Subsection IWE that deleted the requirement for performing a VT-3 visual examination of these items. This rewrite of Subsection IWE was published in the 1998 Edition of the ASME Code,Section XI. The alternative proposed by CP&L is consistent with the approved rewrite of Subsection IWE.

PROPOSED ALTERNATIVE:

During the First Containrnent inspection Interval, CP&L will verify the leak-tight integrity of seats and gaskets, utilized on penetrations (e.g., airlocks, hatches) that are required to assure containment leak-tight integrity, in accordance with the applicable requirements of 10 CFR 50, Appendix J.-

REFERENCES:

1. ASME Code,Section XI, " Rules for Inservice inspection of Nuclear Power Plant Components," 1992 Edition with 1992 Addenda and 1998 Edition.

2. Part 50 of Title 10 of the Code of Federal Regulation (10 CFR 50), Appendix J, " Primary Reactor Containment Leakage Testing of Water-Cooled Power Reactors."

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RELIEF REQUEST: CIP-05 (R3v. 0)

, TITLE: SUCCESSIVE EXAMINATIONS FOLLOWING A REPAIR

! COMPONENTS FOR WHICH RELIEF IS REQUESTED: l i

This request for relief'is applicable to all components classified as Class MC and subject to l

the requirements of paragraphs IWE 2420(b) and (c). This request for relief will apply to Class MC components at the Brunswick Steam Electric Plant (BSEP), Units 1 and.2.

1 ASME CODE, SECliON XI REQUIREMENT- 1 Paragraph IWE-2420(b) requires successive examinations for components whose l examination results require evaluation of fiaws, areas of degradation, or repairs in accordance with IWE-3000. Paragraph IWE-2420(c) states that if the flaws, areas of degradation, or repairs remain essentially unchanged for three consecutive inspection i periods, the component no longer requires augmented examin1 tion per Examination j Category E-C.

REQUESTED REllEF:

ReNef is requested from the requirement of paragraphs IWE-2420(b) and (c) to perform successive examinations of repaired areas in accordance with Examination Category E-C.

BASIS FOR REQUESTING RELIEF:

In accordance with 10 CFR 50.55a(a)(3)(i), Carolina Power & Light (CP&L) Company is requesting approval to implement an alternative to the requirement specified in paragraphs IWE-2420(b) and (c) to perform successive examinations of repaired areas. As an acceptable alternative, CP&L will perform the repair of degraded areas in accordance with an approved Repair / Replacement Program.

This acceptable alternative has been evaluated by CP&L, and CP&L has determined that the implementation of this alternative requirement will provide an acceptable level of quality and safety for the following reasons:

1. Article IWE-3000 allows acceptance by repair for those components whose examination results reveal flaws or areas of degradation exceeding the acceptance standards listed in Table IWE-2500-1. Paragraph IWE-3124 requires that the repair comply with the requirements of Article IWA-4000, " Repair and Replacement." Paragraph IWA-4150 requires CP&L to conduct an evaluation of the suitability of the repair including the consideration of the cause of failure. Thus, the purpose of the repair is to restore the component to an acceptable condition for continued service and prevent recurrence.

Following the repair, preservice examination is performed in accordance with IWE-2000.

Acceptance of this preservice examination will confirm the absence of the unacceptable condition or reveal that the condition no longer exceeds the established acceptance standards. In both cases, this examination verifies that the repair has restored the component to an acceptable condition and can be returned to service. Once the repair has been verified as acceptable, successive examinations of the repaired area per Examination Category E-C is not warranted.

2. The requirement for successive examinations of repaired areas of Class MC components is not consistent with the requirements for Class 1,2 and 3 components.

Page 1 of 2

REllEF REQUEST: CIP-05 (R:v. 0) )

TITLE: SUCCESSIVE EXAMINATIONS FOLLOWING A REPAIR l

Neither paragraphs IWB-2420, IWC-2420, or IWD-2420 requires a repaired area to be l subject to successive examinations. A repair to a Class MC component is subject to the same general requkements as the Class 1,2, or 3 components. If a repair to the l reactor coolant pressure boundary 1s acceptable without the performance of successive  !

examinations, a repair to a Class MC component is also acceptable without the performance of successive examinations.  ;

3. In Attachment 6, Resolution of Public Comment, of SECY-96-080, the response to  !

comment 3.3 states 'The purpose of IWE-2420(b) is to manage components found to be acceptable for continued service (meaning no mpair or replacement at this time) as a ]

Examination Category E-C component... If the component had been repaired or l replaced, then a more frequent examination would not be needed." CP&L agrees with  !

this conclusion, j

4. The ASME Main Committee and the Board of Nuclear Codes and Standards have also  !

determined that the requirement to perform successive examinations of repaired areas  !

per Examination Category E-C to be no longer warranted. Both organizations have J approved the rewrite of Subsection IWE which eliminated this requirement. This rewrite of Subsection IWE was published in the 1998 Edition of the ASME Code,Section XI.

PROPOSED ALTERNATIVE: ,

l During the First Containment inspection interval, CP&L will perform the repair of degraded >

areas in accordance with an approved Repair / Replacement Program. For degraded areas that are accepted by engineering evaluation, the applicable successive inspection requirements specified in paragraph IWE 2420 will be met.

REFERENCES:

1. ASME Code, Section >'t, " Rules for Inservice Inspection of Nuclear Power Plant '

Components," 1992 Edition with 1992 Addenda and 1998 Edition.

2. SECY 96-080,' issuance of Final Amendment to 10 CFR 50.55a to incorporate by Reference the ASME Boller and Pressure Vessel Code,Section XI, Division 1, Subsection IWE and Subsection IWL.

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RELIEF REQUEST: CIP 07 (R;v. 0)

TITLE: TORQUE / TENSION TEST OF PRESSURE RETAINING BOLTING COMPONENTS FOR WHICH RELIEF IS REQUESTED:

This request for relief is applicable to pressure retaining bolting subject to torque or tension test per Table IWE-2500-1, Examination Category E G (Item No. E8.20). This request for relief will apply to the pressure retaining bolting at the Brunswick Steam Electric Plant (BSEP), Units 1 and 2.

l ASME CODE, SECTION XI REQUIREMENT:

Table IWE-2500-1, Examination Category E-G (Item No. E8.20) requires a torque or tension tost of bolted connections that have not been disassembled and reassembled during the l Inspection Interval.

! REQUESTED RELIEF:

Relief is requested from performing the torque or tension test per Table IWE 2500-1, Examination Category E-G (Item No. E8.20).

BASIS FOR REQUESTING RELIEF:

In accordance with 10 CFR 50.55a(a)(3)(i), Carolina Power & Light (CP&L) Company is requesting approval to implement an alternative to the requirement specified in Table 2500-1, Examination Category E-G (Item E8.20). As an acceptable alternative, CP&L will verify the i integrity of bolted connections in accordance with the applicable requirements of 10 CFR 50,

l. Appendix J. 4 This proposed alternative has been evaluated by CP&L, and CP&L has determined that the implementation of this alternative requirement will provide an acceptable level of quality and

. safety for the following reasons:

l 1. The bolted connections, subject to torque or tension test, are those that are required to assure containment leak-tight integrity. As required by 10 CFR 50, Appendix J, these same bolted connections are required to be leak rate tested (i.e., Type B test). The purpose of the Type B test is to detect local leaks at containment peak accident pressure and to measure leakage across the leakage-limiting boundary of containment penetrations whose design incorporates resilient seals, gaskets, sealant compounds, and electrical penetrations ~

' fitted with flexible metal seal assemblies. When compared to a torque or tension test, CP&L considers a leak rate test at containment peak accident pressure a superior and proven method for identifying degradation that may cause containment leakage if unacceptable leakage is identified during the test, corrective measures would be taken and the connection re-tested.

l 2. The torque or tension test is only required for those bolted connections that are not l~ disassembled and reassembled during the Inspection Interval. To accomplish this test, CP&L would be required to un-torque the bolts and then re-torque or re-tension them.

Thus, this task would be required for the sole purpose of performing this test. Since the integrity of the bolted connections are verified by 10 CFR 50, Appendix J testing and, if acceptable, demonstrates that the bolt torque or tension is adequato, the torque or tension test is not warranted, i-Page 1 of 2

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s RELIEF RECUEST: ClP-07 (Riv. 0) l TITLE: TORQUE / TENSION TEST OF PRESSURE FtETAINING BOLTING _ {

3. The bolted connections associated with the containment were designed and constructed to '

withstand the peak accident pressure and temperature without loss of their leak-tight integrity and no yielding of the bolting would occur.

'4. Option B of 10 CFR 50, Appendix J has been implemented at BSEP. During the implementation of Option B, a review of bolted connections subject to the requirements of I Appendix J was performed. This r6 view of corrective action work orders and "as-found test '

results identified no service induced ancmalies. Since these bolted connections are in a .

static environment dunng normal operation and are periodically tested per 10 CFR 50, l Appendix J, performing an additional torque or tension test is not warranted.  !

5. lipon implementation of Option B. the Type B test frequency was extended from once every  ;

' 24 months to once every three refuel cycles. Based on the performance history of BSEP's I containment, the Type A test frequency was also extended (i.e., at least once every

-10 years). Sir.ce these bolted connections are Type B tested and also tested during the performance of the Type A test, their leak-tight integrity will be verified at least twice during )

the First Containment Ins'section Interval. The torque or tension tests of these same bolted connections would only be performed once during this same time period. CP&L considers verification of the leak-tight integrity of these connections at least twice during the inspection !nterval appropriate. Performance of a torque or tension test, in addition to these leak rate tests, will provide no compensating increase in quality and safety.

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6. The ASME Main Committee and the Board of Nuclear Codes and Standards have also determined that the torque or tansion test of bolting was not appropriate and has approved

- the rewrite of Subsection IWE which eliminated this requirement. This rewrite of  ;

Subsection IWE was published in the 1998 Edition of the ASME Code,Section XI. '

PROPOSED ALTERNATIVE:

During the First Containment inspection Interval, CP&L will verify the leak-tight integrity of bolted connections that are required to assure containment leak tight integrity in accordance with the applicable requirements of 10 CFR 50, Appendix J.

REFERENCES:

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?. ASME Code,Section XI, " Rules for Inservice inspection of Nuclear Power Plant Components," 1992 Edition with 1992 Addenda and 1998 Edition.

2. Part 50 of Title 10 of the Code of Federal Regulation (10 CFR 50), Appendix J," Primary Reactor Containment Leakage Testing of Water-Cooled Power Reactors."

3. BSEP Updated Final Safety Analysis Report, Section 3.8.2.4.1.

Page 2 of 2

RELIEF RECUEST: CIP 10 (Riv. 0)

TITLE: VT-2 EXAMINATION PERSONNEL QUALIFICATIONS (CODE CASE N-546)

COMPONENTS FOR WHICl! RELIEF IS REQUESTED:

This request for relief is applicable to the qualification of personnel performing visual (VT-2) examination of Class MC components at the Brunswick Steam E!ectric Plant (BSEP), Units 1 and 2.

ASME CODE, SECTION XI REQUIREMENT:

Subarticle IWA-2300 provides the qualifications of nondestructive examination (NDE) personnel.

REQUESTED RELIEF:

Relief is requested from the applicable qualification requirements for personnel performing visual (VT-2) examination of Class MC components specified in subarticle IWA-2300.

BASIS FOR REQUESTING RELIEF:

In accordance with 10 CFR 50.55a(a)(3)(i), Carolina Power and Light (CP&L) Company is requesting approval to use alternative requirements for the qualification of visual (VT 2) examination personnel to those specified in paragraph IWA-2300. CP&L proposes to implement the alternative requirements outlined in ASME Code Case N-546, " Alternative Requirements for Qualification of VT-2 Examination Personnel."

ASME Code Case N-546 has been evaluated by CP&L, and CP&L has determined that implementation of this ASME Code Case for the visual (VT-2) examination of Class MC components will provide an acceptable level of quality and safety for the following reasons:

1. The purpose of a visual (VT-2) examination is to locate evidence of leakage from pressure retaining components during the conduct of a system pressure test. Unlike other visual examinations (i.e., VT-1 or VT-3), personnel locating evidence of leakage do not require the same level of qualification requirements needed to determined the mechanical and structural condition of components. The plant experience, training, and visual acuity requirements specified in this ASME Code Case provide adequate qualification for personnel performing visual (VT-2) examinations at BSEP.

2. This ASME Code Case allows the visual (VT-2) examination to be performed by properly trained personnel that are already present during the performance of a system pressure test (i.e., Engineering personnel). Implementation of this ASME Code Case would eliminate requiring personnel, such as Quality Control personnel, who only perform the VT-2 examination to enter a radiation field. This reduction in number of personnelinvolved in the pressure test will reduce excessive personnel exposure at BSEP.

3. To ensure proper implementation of this Code Case, CP&L will develop procedural guidelines for performing consistent and quality leakage examinations. CP&L will also document and maintain records to verify the qualification of personnel performirig these examinations.

4. ASME Code Case N-546 was approved by the ASME's Main Committee and the Board of Nuclear Codes and Standards on August 24,1995. This approval signifies the requirements outlined in this ASME Code Case will provide an acceptable level of quality and safety for nuclear power plants.

Page 1 of 2

RELIEF REQUEST: CIP 10 (Rrv. 0)

TITLE: VT-2 EXAMINATION PERSONNEL QUAllFICATIONS (CODE CASE N 546)

PROPOSED ALTERNATIVE:

During the First Containment inspection Interval, CP&L will implement the alternative requirements of ASME Code Case N-546. If required, corrective measures will be performed in accordance with the applicable requirements of paragraph IWE-5250.

REFERENCES:

1. ASME Code Case N-546," Alternative Requirements for Qualification of VT-2 Examination Personnel,"(Approved Date: August 24,1995).

2. ASME Code,Section XI," Rules for Inservico Inspection of Nuclear Power Plant Components," 1992 Edition with 1992 Addenda.

Page 2 of 2

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RELIEF REQUEST: CIP-16 (R;v. 0)

TITLE: EXAMINATION METHOD FOR SURFACE AREAS REQUIRING AUGMENTED EXAMINATION COMPONENTS FOR WHICH RELIEF IS REQUESTED:

This request for relief is applicable to containment surface areas requiring augmented examination per paragraphs IWE 1240 and IWE-2420 at the Brunswick Staam Electric Plant (BSEP), Units 1 and 2.

ASME CODE, SECTION XI REQUIREMENT:

Parag,aph IWE 2500(c) and Table IWE-2500-1, Examination Category E-C specifies the examination requirement for containment surface areas requiring augmented examination per IWE-1240 and IWE-2420. In summary, surface areas accessible from both sides are to be visually examined using a VT-1 visual examination method. Surface areas accessible from one side only are to be examined for wall thinning using an ultrasonic thickness measurement method in accordance with the ASME Code,Section V, T 544.

REQUESTED RELIEF:

Relief is requested from performing a visual (VT-1) examination in accordance with IWE-2500(c)(1) from both sides when only one sido is subject to conditions that warrant augmented examination. Reliefis also requested from performing ultrasonic thickness measurements in accordance with IWE-2500(c)(2) when the surface area subject to conditions that warrant augmented examination is accessible for visual (VT-1) examination and the inaccessible surface area is not subject to conditions that warrant augmented examination.

BASIS FOR REQUESTING RELIEF:

In accordance with 10 CFR 50.55a(a)(3)(i), Carolina Power & Light (CP&L) Company is j requesting approval to implement alternative examination methods to those specified in paragraph IWE-2500(c). CP&L proposes to perform a visual (VT-1) examination on accessible interior and/or exterior surface areas requiring augrnented examination per IWE-1242 and/or IWE-2420. If the surface area is not accessible (e.g., backed up by reinforced concrete) for visual examination, CP&l. will perform ultrasonic thickness measurements in accordance with ,

the applicable requirements of IWE-2500(c).  !

The proposed alternative examination methods described above have been evaluated by l CP&L, and CP&L has determined that the implementation of these alternative methods will j provide an acceptable level of quality and safety for the following reasons:

1. The containments at BSEP are concrete reinforced and for this reason, the majority of the exterior surfaces of the metallic liner are inaccessible for examination. Pursuant to IWE-2500(c)(2), surface areas subject to augmented examination and accessible from one side only shall be examined for wall thinning using an ultrasonic thickness measurement method. To perform these wall thinning measurements, a grid system (i.e., one foot square grids) is required per IWE-2500(c)(3). When only the accessible side is subject to conditions that warrant augmented examination per IWE-1240 and/or IWE-2420, the performance of the ultrasonic thickness measurements result in additional personnel exposure and do not provide an increase in quality and safety. CP&L proposen to perform a visual (VT-1) examination of these accessible areas. A visual (VT-1) examination is a Page 1 of 3

s >

RELIEF REQUEST: CIP-16 (R;v. 0)

TITLE: EXAMINATION METHOD FOR SURFACE AREAS REQUIRING AUGMENTED EXAMINATION proven method for detecting degradation and will provide an acceptable level of quality and safety.

2. lWE 2500(c)(1) requires that surface areas accessible from both sides be visually examined using a visual (VT-1) examination method. This Code provision implies that both sides of the affected surface area require a visual examination. When only one side is subject to augmented examination per IWE-1240 and/or IWE-2420, the performance of the visual examination results in additional personnel exposure and does not provide an increase in quality and safety. A v!sual examination of both sides should only be performed when both sides are subject to conditions that warrant augmented examination.

3. As required by IWE 1240, CP&L has evaluated containment surface areas to determine if

. they were likely to experience accelerated degradation and aging. This evaluation included both inaccessible and accessible surfaces. If a surface is subject to augmented  ;

examination and not accessible for visual (VT-1) examination, CP&L will perform ultrasonic thickness measurements in accordance with the applicable requirements of IWE-2500(c)(2). If this evaluation concluded that only the accessible surface is subject to ) 1 augmented examination, performance of ultrasonic thickness measurements is unwarranted 4 and CP&L will only perform a visual (VT-1) exam! nation. The performance of the ultrasonic thickness measurements on inaccessible surfaces (e.g., backed up by reinforced concrete) and a visual (VT-1) examination of interior and/or exterior accessible surfaces will provide .

an acceptable level of quality and safety. l l

4. As required by IWE-247,0, surface areas that requiro an engineering evaluation or repair for continued service are also subject to the requirements of IWE-2500(c). Although the degradation was detected by a visual examination, IWE-2500(c) would mandate ultrasonic thickness measurements for wall thinning when the surface area is only accessible from one side. As stated earlier, CP&L considers this ASME Code,Section XI provision unwarranted if the inaccessible side has been evaluated and determined to not be subject to the same conditions as the affected side. As specified by 10 CFR 50.55a(b)(2)(x)(A),

CP&L is required to evaluate the acceptability of inaccessible areas when conditions exist in

. accessible areas that could indicate the presence of or results in degradation to such inaccessible areas. 'If the inaccessible surface is determined to be subject to the same condition, ultrasonic thickness measurements are warranted and CP&L will perforrn this

. examination. If the evaluation determined the inaccessible surface is not affected, CP&L 1 will only perform a visual (VT 1) examination. Performing the same examination method (i.e., visual) that detected the original degradation during successive examinations is consistent with other sections (e.g., Subsections IWB and IWC) of the ASME Code,  !

Section XI and will provide an acceptable tevel of quality and safety. If degradation is l detected during the successive examinations, supplemental examinations in accordance with IWE-3200 will be performed.

PROPOSED ALTERNATIVE:

During the First Containment inspection Interval, CP&L will perform a visual (VT-1) examination on accessible interior and/or extarior surface areas requiring augmented examination per IWE-1242 and/or IWE-2420. If the surface areas is not accessible (e.g., backed up by 1

.. t Page 2 of 3

s RELIEF REQUEST: CIP-16 (Riv. 0)

TITLE: EXAMINATION METHOD FOR SURFACE AREAS REQUIRING AUGMENTED EXAMINATION reinforced concreto) for visual examination, CP&L will perform ultrasonic thickness measurements in accordance with the applicable requirements of IWE-2500(c). I

REFERENCES:

1. ASME Code,Section XI, " Rules for Inservice inspection of Nuclear Power Plant Components," 1992 Edition with 1992 Addenda.

Page 3 of 3

l RELIEF REQUEST: CIP-17 (R ;v. 0)

TITLE: VISUAL (VT 2) EXAMINATION OF SURFACE AREAS NOT ACCESSIBLE DURING THE PERFORMANCE OF THE LEAKAGE TEST COMPONENTS FOR WHICH RELIEF IS REQUESTED:

This request for relief is applicable to components classified as Class MC and subject to the requirements of IWE 5240 at the Brunswick Steam Electric Plant (BSEP), Units 1 and 2.

ASME CODE, SECTION XI REQUIREMENT:

IWE-5240 otates "The requirements of IWA-5246 [ Note: The reference IWA-5246 is a typographical error and actually refers to IWA-5240.] for visual examination are applicaole."

IWA-5240 requires visual examination of accessible exposed surfaces of pressure retaining comoonents.

REQUESTED RELIEF:

l Relief is requested from the requirement of IWE-5240 to perform a visual (VT-2) examination of those surface areas that are not accessible during the performance of the pneumatic leakage j test per 10 CFR 50, Appendix J.

l BASIS FOR REQUESTING RELIEF:

l In accordance with 10 CFR 50.55a(a)(3)(i), Carolina Power & Light (CP&L) Company is requesting approval to implement an alternative to the requirement for performing a visual i (VT-2) examination of surface areas that are not accessible during the performance of the pneumatic leakage test per 10 CFR 50, Appendix J. As an acceptable altemative, CP&L will perform the required examinations and testing of these affected surfaces in accordance with the applicable requirements specified in the Construction Code, Design Specification, ASME Code,Section XI, and 10 CFR 50, Appendix J. For those affected surface areas that are accessible during the performance of pneumatic leakage test, CP&L will comply with the applicable requirements of IWE 5240.

This proposed altamative has been evaluated by CP&L, and CP&L has ' determined that the implementation of inis alternative requirement will provide an acceptable level of quality and safety for the fo!! awing reasons:

1. The containments (i.e., Drywell and Suppression Chamber) at BSEP are concrete reinforced. For this reason, the majority of the exterior surfaces of the metallic liner and penetration sleeves are embedded in concrete and inaccessible for examination. if a repair or replacement activity was performed on the concrete reinforced component, the activity would be performed on the interior surface and would be subject to a pneumatic leakage j test per Examination Category E-P and 10 CFR 50, Appendix J. In addition to the leakage '

test, IWE-5240 and IWA 5240 would require a visual (VT 2) examination on the external surfaces for evidence of leakags during the performance of the test. CP&L considers this requirement impractical for those surfaces not accessible during the performance of the leakage test. For example, the affected containment surface area would be pressurized to peak accident pressure, P , during the performance of the leakage test. Thus, the repaired or replaced surface area of the component reinforced with concrete would not be accessible by the examiner. Although the requirements of 10 CFR 50, Appendix J and IWE 5221 would be met, literal compliance to the requirement of IWE-5240 could not be met. The 10 CFR 50, Appendix J leak rate test at peak accident pressure is considered by CP&L as a superior and proven method for assuring the structuralintegrity and leak tightness of Page 1 of 3 I

f.,.

RELIEF REEUEST: CIP 17 (RI.v. 0)

TITLE: VISUAL (VT-2) EXAMINATION OF SURFACE AREAS NOT ACCESSIBLE DURING l THE PERFORMANCE OF THE LEAKAGE TEST Primary Containment. In this case, not performing the visual (VT-2) examination of these surfaces areas would not decrease the level of quality and safety at BSEP.

2. Repairs and/or replacements of components classified as Class MC will be performed in accordance with an approved Repair / Replacement Program and the applicable l requirements of the ASME Code,Section XI,1992 Edition with 1992 Addenda. Thus, the i repair or replacement activity would meet the applicable inspection requirements of the  ;

Construction Code and Design Specification in addition to those requirements specified in J the ASME Code,Section XI. For those welded repairs and/or replacements affecting the structuralintegrity or !eak tightness of the containment, the Construction Code and/or '

Design Specification would require an examination (e.g., surface examination, volumetric examination) following the completion of the activity. This examination would be in addition to the preservice visual examination required by IWE-2200 and the leakage test required by 10 CFR 50, Appendix J. CP&L considers the examination required by the Construction Code and/or Design Specification, the preservice visual examination required by IWE-2200, 1 and the 10 CFR 50, Appendix J ieak rate test at peak accident pressure adequate for assuring the structuralintegrity and leak-tightness of Primary Containment. The satisfactory performance of these examinations and the leakage test would provide an acceptable level of quality and safety of the affected surfaces.

3. As required by 10 CFR 50, Appendix J and IWE-5250, CP&L will take the necessary corrective actions to locate and correct the source of leakage if the leakage test does not meet the established acceptance criteria. If additional repairs are required, CP&L will perform them in accordance with an approved Repair / Replacement Program and the applicable requirements of the ASME Code,Section XI,1992 Edition with 1992 Addenda.

The required leakage test will be performed in accordance with the applicable requirements of 10 CFR 50, Appendix J and IWE-5250 prior to retuming the component to service.

4. For those surface areas affected by a repair and/or replacement activity and accessible during the performance of pneumatic leakage test, CP&L will comply with the applicable requirements of IWE-5240.

PROPOSED ALTERNATIVE:

During the First Containment inspection interval, CP&L will not perform a visuai (VT 2) exe.mination of those surface areas affected by a repair and/or replacement activity and not accessible during the performanca of the pneumatic leakage test per 10 CFR 50, Appendix J.

CP&L will perform the required examinations and testing of these affected surface areas in accordance with the Construction Code and/or Design Specification, ASME Code,Section XI, and 10 CFR 50, Appendix J. For those affected surface areas that are accessible during the performance of pneumatic leakage test, CP&L will comply with the ap# cable requirements of IWE-5240.

REFERENCE:

1. ASME Code, Section Xt, " Rules for Inservice inspection of Nuclear Power Piant Componer,ts," 1992 Edition with 1992 Addenda.

2. ASME Code, Section ill," Rules of Construction of Nuclear Power Plant Components," 1968 Edition with Summer 1968 Addenda.

3. ASME Code, Section Vill," Pressure Vessels," 1968 Edition with Summer 1968 Addenda.

Page 2 of 3

T - , .

i RELIEF REQUEST: CIPo17 (Rev. 0)

TITLE: VISUAL (VT-2) EXAMINATION OF SUHFACE AREAS NOT ACCESSIBLE DURING THE PERFORMANCE OF THE LEAKAGE TEST

4. Part 50 of Title 10 of the Code of Federal Regulation (10 CFR 50), Appendix J ' Primary ,

Reactor Containment Leakage Testing of Water-Cooled Power Reactors."  !

5. Specification 9527-01-015-001," Specification for Containment Structural Steel Liners." 1 I

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Page 3 of 3

ENCLOSURE 2 i

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BRUNSWICK. STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 l REQUEST TO USE ALTERNATIVES TO THE ASME BOILER AND PRESSURE VESSEL J l CODE, SECTION XI, FOR CONTAINMENT INSPECTION )

(NRC TAC NOS. MA4166 AND MA4167) l l

l List Of Containment inspection Procram l Relief Reauests i I 1

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l CONTAINMENT INSPECTION PROGRAM RELIEF REQUESTS BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 i

ASME

, Code, 4 1

Class' <

j Request Title MC CC Remarks .

Number i i

CIP-01 Visual Examination of / This relief request is being submitted  !

(Rev. 0) Moisture Barriers for approval in accordance with i0 CFR l 50.55a(a)(3)(i).

CIP-02 Acceptance Standard for / This milef request is being submitted (Rev. 0) Pressure Retaining Bolting for approvalin accordance with 10 CFR 50.55a(a)(3)(i).

CIP-03 Accessibility for Examination / This relief request is being submitted j (Rev. 0) of Single-Welded Butt Joints for approval in accordance with 10 CFR 50.55a(a)(3Xa.

CIP-04 Visual Examination of Seals / This relief request is being submitted (Rev. 0) and Gaskets for approval in accordare with 10 CFR 50.55a(a)(3)(i). This reliefis similar to relief request RR-El for the Davis-Besse Nuclear Power Station, which was approved by an NRC lette: dated June 30,1998.

CIP-05 Successive Examinations / This relief request is being submitted (Rev.0) Following A Repair for approval in accordance with 10 CFR 50.55a(a)(3)(i). This reliefis similar to relief request RR-E6 for the Davis-Besse Nuclear Power Station, which was approved by an NRCletter dated June 30,1998.

CIP-06 Visual Examination of / This relief request is being submitted (Rev. 0) Pressure Retaining Bolting for approval in accordance with 10 CFR 50.55a(a)(3)(i).

[ ,

1 ASME Code l L  : Class

! l i Request Title MC CC Remarks l Number CLP 07 Torque /rension Test of / This relief request is being submitted (Rev. 0) Pressure Retaining Bolting for approval in accordance with 10 CFR )

50.55a(a)(3)(i). This reliefis similar to I l

relief request RR-E7 for the Davis-Besse Nuclear Power Station, which

)i

) was approved by an NRC letter dated l L June 30,1998.

CIP-08 Documentation Requirements / / This relief request to use Code Case for Inservice Inspection, I (Rev. 0) N 532 is being submitted for approval l

Repair, and Replacement in accordance with 10 CFR  !

Activities (Code Case N-532) 50.55a(a)(3)(i). This Code Case was approved for use during the Second Inspection Interval and resubmitted with ,

the Third Interval Inservice Inspection  !

Program for Class 1,2 and 3 q components (

Reference:

CP&L letter dated April 23,1998, Serial No. BSEP 98-0087). 1 CIP-09 Transfer of Procedure / This relief request to use Code Case (Rev. 0) Qualification Records (Code N-573 is being submitted for approval Case N-573) in accordance with 10 CFR i 50.55a(a)(3)(i). This Code Case was also submitted with the Third Interval Inspection Program for Class 1,2 and 3 j components (

Reference:

CP&L letter dated April 23,1998, Serial No. BSEP 98-0087).

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ASME Code Class Request Title MC CC Remarks -

Number CIP-10 VT-2 Examination Personnel / This relief request to use Code Case (Rev. 0) Qualifications (Code N-546 is being submitted for approval I Case N-546) in accordance with 10 CFR I

50.55a(a)(3)(i). This Code Case was also submitted with the Third Interval Inspection Program for Class 1,2 and 3 components (

Reference:

CP&L letter dated April 23,1998, Serial No. BSEP 98-0087). i

/ l CIP-il Visual Examination of This relief request is being submitted l (Rev. 0) Accessible Surface Areas of for approval in accordance with 10 CFR I the Containment Vessel and 50.55a(a)(3)(i). I Vent System l

r CIP-12 Preservice Examination of / This relief request is being submitted (Rev 0) Paints and Coatings for approval in accordance with 10 CFR j

50.55a(a)(3)(i). This reliefis similar to 1 l relief request RR-E3 for the Davis-Besse Nuclear Power Station, which was approved by an NRC letter dated June 30,1998.

l l CIP-13 Examination of Paints and / This relief request is being submitted l l (Rev 0) Coatings Prior to Removal for approval in accordance with 10 CFR 50.55a(a)(3)(i). This reliefis similar to j relief request RR-E4 for the Davis-Besse Nuclear Power Station, which  !

was approved by an NRC letter dated June 30,1998, l

CIP-14 Visual Examination of / This relief request is being submitted (Rev. 0) Accessible Concrete Surface for approval in accordance with 10 CFR Areas 50.55a(a)(3)(i).

CIP-15 Inservice Inspection Schedule / This relief request is being submitted l (Rev. 0) for Successive Concrete for approval in accordance with 10 CFR Examinations 50.55a(a)(3)(i).

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ASME Code

! Class l Request Title MC CC Remarks Number Cle-16 Examination Method for / This relief request is being submitted (Rev. 0) Surfa:e Areas Requiring for approval in accordance with 10 CFR Augniented Examination 50.55a(a)(3)(i).

CIP-17 Visual (VT-2) Examination of / This relief request is being submitted (Rev. 0) Surface Areas Not Accessible for approval in accordance with 10 CFR During the Performance of the 50.55a(a)(3)(i).

Leakage Test CIP-18 Inservice Inspection Schedule / This relief request is being submitted (Rev. 0) (IWA-2430) for approval in accordance with 10 CFR 50.55a(a)(3)(i).

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