BSEP 05-0148, Revised License Renewal Commitment List
| ML053500114 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/06/2005 |
| From: | Scarola J Progress Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BSEP 05-0148, TAC MC4639, TAC MC4640 | |
| Download: ML053500114 (15) | |
Text
S S-Progress Energy James Scarola Vice President Brunswick Nuclear Plant Progress Energy Carolinas. Inc.
December 6, 2005 SERIAL: BSEP 05-0148 10 CFR 54 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001
Subject:
References:
Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Docket Nos. 50-325 and 50-324/License Nos. DPR-71 and DPR-62 Revised License Renewal Commitment List (NRC TAC Nos. MC4639 and MC4640)
Letter from Cornelius J. Gannon to the U. S. Nuclear Regulatory Commission (Serial: BSEP 04-0006), "Application for Renewal of Operating Licenses," dated October 18, 2004 (ML043060406)
Ladies and Gentlemen:
On October 18, 2004, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., requested the renewal of the operating licenses for Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2, to extend the terms of their operating licenses an additional 20 years beyond the current expiration dates.
In recent discussions with the NRC, CP&L was asked to update the list of License Renewal Commitments, using a revised format, and to identify the source document for each commitment. The requested revised summary list of BSEP License Renewal Commitments is enclosed.
Please refer any questions regarding this submittal to Mr. Mike Heath, Supervisor - License Renewal, at (910) 457-3487.
I declare, under penalty of perjury, that the foregoing is true and correct. Executed on December 6, 2005.
Sincerely, James Scarola P.O.
Box 10429 Southport NC 28461 9-m{
T> 910.457.3698 F> 910.457.2803
Document Control Desk BSEP 05-0148 / Page 2 MIIFmhf
Enclosure:
BSEP License Renewal Commitments, Revision 7 cc:
U. S. Nuclear Regulatory Commission, Region II ATTN: Dr. William D. Travers, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear-Regulatory Commission ATTN: Mr. S. K. Mitra (Mail Stop OWFN 11F1) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATIN: Ms. Alicia R. Williamson (Mail Stop OWFN 11F1) 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission ATTN: Mr. Eugene M. DiPaolo, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)
ATTN: Ms. Brenda L. Mozafari (Mail Stop OWEN 8G9) 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Jo A. Sanford Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-05 10
BSEP 05-0148 Enclosure Page I of 13 1
The elements of corrective.action, confirmation process, and A.1.1 Prior to the period of Quality Assurance (QA) administrative controls in the BSEP QAProgram will be extended operation applied to required aging management activities for both safety LRA Section B.1.3 related and non-safety related structures and components subject to aging management review.
2 The BSEP FAC susceptibility analyses will be updated to A. 1.1.5 Prior to the period of Flow-Accelerated include additional components potentially susceptible to FAC.
extended operation Corrosion (FAC)
Program LRA Section B.2.5 3
The Bolting Integrity Program will be enhanced to: (1) add a A.1.1.6 Prior to the period of Bolting Integrity precautionary note to bolting guidelines to limit the sulfur extended operation Program content of compounds used on bolted connections, (2) include ASME,Section XI, activities identified in NUREG-1801, LRA Section B.2.6, Program XI.M18, and (3) incorporate monitoring and trending Commitment Items (2) criteria under Systems Monitoring for bolted connections and (3) were added in outside of ASME,Section XI, boundaries.
response to Audit Question (AQ) 3.2-4 in BSEP letter dated March 14, 2005
BSEP 05-0148 Enclosure Page 2 of 13 The Open-Cycle Cooling Water System Program will be enhanced to require that: (1) Program scope include portions of the Service Water (SW) System credited in the Aging Management Review, including non-safety related piping, (2) the Residual Heat Removal (RHR) Heat Exchangers will be subject to eddy current testing with results compared to previous testing to evaluate degradation and aging, (3) a representative sampling of SW Pump casings be inspected, (4) Program procedures be enhanced to include verification of cooling flow and heat transfer effectiveness of SW Pump Oil Cooling Coils, inspections associated with SW flow to the Diesel Generators (including inspection of expansion joints),
and inspection and replacement criteria for RHR Seal Coolers, (5) piping inspections will include locations where throttling or changes in flow direction might result in erosion of copper-nickel piping, and (6) performance testing of the RHR and Emergency Diesel Generator Jacket Water heat exchangers will he rwrf--nA to uprifty heat transfe-r eannailitv.
Prior to the period o0 extended operation vpen-%-ycie Cooling Water System Program LRA Section B.2.7, Commitment Item (6) was added in response to AQ B.2.7-1 in BSEP letter dated March 31, 2005.
5 Closed-Cycle Cooling Water System Program activities will be A. 1.1.8 Prior to the period of Closed-Cycle Cooling enhanced to assure that Preventive Maintenance activities extended operation Water System Program include inspections of Diesel Generator (DG) combustion air intercoolers and heat exchangers.
Administrative controls for the Program will be enhanced to:
A. 1.1.9 Prior to the period of Inspection of Overhead (1) include in the Program all cranes/platforms within the extended operation Heavy Load and Light scope of License Renewal, (2) specify an annual inspection Load Handling frequency for the Reactor Building Bridge Cranes and the Intake Structure Gantry Crane, and every fuel cycle for the LRA Section B.2.9 Refuel Platforms, (3) allow use of maintenance crane inspections as input for the condition monitoring of License Renewal cranes, (4) require maintenance inspection reports to be forwarded to the responsible engineer, and (5) include inspection of structural component corrosion and monitoring crane rails for abnormal wear.
BSEP 05-0148 Enclosure Page 3 of 13 riogram aduruiuulstuve contrils Will De Unnanced to require; (1) obtaining non-intrusive baseline pipe thickness measurements at various locations, and (2) replacing the remainder of the plant's sprinkler heads prior to 50 years of sprinkler head service life. The results of the non-intrusive Fire Water System piping thickness measurements will be trended throughout the extended period of operation; the specific measurement intervals will be determined by engineering evaluation performed after each inspection to detect degradation prior to the loss of intended function.
rriOr LU me purlm or extended operation r17e VUCt Program LRA Section B.2.11, Commitment was revised in BSEP letter dated July 18, 2005 based on the NRC License Renewalk Inspection of June 7 to 10, 2005.
8 The Aboveground Carbon Steel Tanks Program is a new aging A. 1.1.12 Prior to the period of Aboveground Carbon management program that will be implemented.
extended operation Steel Tanks Program LRA Section B.2. 12 9
The Fuel Oil Chemistry Program administrative controls will A. 1.1.13 Prior to the period of Fuel Oil Chemistry be enhanced to: (1) add a requirement to trend data for water extended operation Program and particulates, (2) verify the condition of the in-scope fuel oil tanks by means of thickness measurements under the One-LRA Section B.2.13 Time Inspection Program, and (3) perform an internal inspection of the Main Fuel Oil Storage Tank under the One-Time Inspection Program.
10 The Reactor Vessel Surveillance Program will be enhanced to A.1.1.14 Prior to the period of Reactor Vessel ensure that any additional requirements that result from the extended operation Surveillance Program NRC review of Boiling Water Reactor Vessel Internals Program (BWRVIP)-116 are addressed.
BSEP 05-0148 Enclosure Page 4 of 13 I ne 'me-lime iiIspiuun rrugram iS a new aging management program that will be implemented and will include:
(1) procedural controls to track, implement, complete, and report activities associated with one-time inspections, (2) inspection of the non-safety related core shroud head and separators and the surveillance capsule holder, (3) inspection of at least one of the four Emergency Diesel Engine Sumps, and at least one of the ten Service Water Pump Lubricating Oil Cooling Coils for corrosion products and evidence of moisture, and (4) application of inspection criteria consistent with NUREG-1801, Program XLM32, including identification of specific sampling techniques, inspection locations, sample size, identification of inspection locations, examination technique, acceptance criteria, and evaluation of the need for follow-up examinations to address aging management program effectiveness for less than four-inch piping and fittings within ASME Code Class 1 boundaries. Verification of aging management program effectiveness for less than four-inch Class 1 piping components will be implemented by means of a sample of limiting components, scheduled late in the current operating term, at locations based on physical accessibility, exposure levels, NDE techniques, and locations identified in NRC Information Notice 97-46, as applicable, and applying an inspection of the inside surfaces of piping by destructive examination of replaced plant piping during modifications or NDE to ensure that cracking has not occurred.
rnor to the period or extended operation J1iV-111 Program LRA Section B.2.15, Commitment Item (2) was added in response to Request for Additional Information (RAI) B.2.28-8 in, BSEP letter dated July 18, 2005. Item (3) was added in response to RAI 3.3-3 in BSEP letter dated August 11,2005. Item (4) was added in response to AQs B.2.15-1 and B.2.15-2 in BSEP letter dated March 14, 2005..
12 The Selective Leaching of Materials Program is a new aging A.1.1.16 Prior to the period of Selective Leaching of management program that will be implemented and will extended operation Materials Program require a sample population of susceptible components to be selected for inspection.
BSEP 05-0148 Enclosure Page 5 of 13 The Buried Piping and Tanks Inspection Program is a new aging management program that will be implemented and will include procedural requirements to: (1) ensure an appropriate as-found pipe coating and material condition inspection is performed whenever buried piping within the scope of the Buried Piping and Tanks Inspection Program is exposed, or, as a minimum, once every 10 years, (2) add precautions concerning excavation and use of backfill to the excavation procedure to include precautions for License Renewal piping, (3) add a requirement that coating inspection shall be performed by qualified personnel to assess its condition, and (4) add a requirement that a coating engineer or other qualified individual should assist in evaluation of any coating degradation noted during the inspection.
Prior to the period o extended operation Buried Piping and Tanks Inspection Program LRA Section B.2. 17, The 10-year period in Commitment Item (1) was added in response to AQ B.2-17-1 in BSEP letter dated March 14,2005.
14 The ASME Section X1, Subsection IWF Program will be A. 1.1.20 Prior to the period of ASME Section XI, enhanced to include the torus vent system supports within the extended operation Subsection IWF scope of the Program.
Program LRA Section B.2.20 15 The administrative controls for the Masonry Wall Program will A. 1.1.22 Prior to the period of Masonry Wall Program be enhanced to require inspecting all accessible surfaces of the extended operation walls for evidence of cracking.
BSEP 05-0148 Enclosure Page 6 of 13 16 The Structures Monitoring Program will be enhanced to:
A. 1.1.23 Prior to the period of Structures Monitoring (1) identify License Renewal systems managed by the Program extended operation Program and inspection boundaries between structures and systems, (2) require notification of the responsible engineer regarding LRA Section B.2.23, availability of exposed below-grade concrete for inspection and Commitment Items (7),
require that an inspection be performed, (3) identify specific (8), and (9) were added License Renewal commodities and inspection attributes, in response to AQ (4) require responsible engineer review of groundwater B.2.23-2 in.-
monitoring results, (5) specify that an increase in sample size BSEP letter dated:
for component supports shall be implemented (rather than March 14, 2005.
should be) commensurate with the degradation mechanisms found, (6) improve training of system engineers in condition monitoring of structures, (7) include inspections of submerged portions of the Service Water Intake Structure on a frequency not to exceed five years, (8) specify an annual groundwater monitoring inspection frequency for concrete structures, and (9) specify the inspection frequency for the Service Water Intake Structure and Intake Canal to not exceed five years.
17 The Protective Coating Monitoring an Maintenance Program A.l.1.24 Prior to the period of Protective Coating administrative controls will be enhanced to: (1) add a extended operation Monitoring and -
requirement for a walk-through, general inspection of Maintenance Program containment areas during each refueling outage, including all accessible pressure-boundary coatings not inspected under the LRA Section B.2.24 ASME Section XI, Subsection IWE Program, (2) add a requirement for a detailed, focused inspection of areas noted as deficient during the general inspection, (3) assure that the qualification requirements for persons evaluating coatings are consistent among the Service Level I coating specifications, inspection procedures, and application procedures, and meet the requirements of ANSI N 101.4, "Quality Assurance for Protective Coatings Applied to Nuclear Facilities," and (4) document the results of inspections and compare the results to previous inspection results and to acceptance criteria.
BSEP 05-0148 Enclosure Page 7 of 13 zi"4 g-'MH N
18 The Electrical Cables and Connections Not Subject to 10 CFR A. 1.1.25 Prior to the period of Electrical Cables and 50.49 Environmental Qualification Requirements Program is a extended operation Connections Not new aging management program that will be implemented.
Subject to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.25 19 The Electrical Cables and Connections Not Subject to 10 CFR A. 1.1.26 Prior to the period of Electrical Cables and 50.49 Environmental Qualification Requirements Used in extended operation Connections Not Instrumentation Circuits Program is a new aging management Subject to 10 CFR program that will be implemented and will include, for 50.49 Environmental radiation monitoring instrumentation cables not included in the Qualification BSEP EQ Program, a review of calibration or surveillance Requirements Used in results for indication of cable or connection degradation Instrumentation commencing before the end of the operating license term and Circuits Program at least once every 10 years thereafter. For cables in neutron flux instrumentation circuits testing frequency will be based on LRA Section B.2.26, engineering evaluation not to exceed 10 years.
Commitment was.
revised in response to AQ B.2.26-1 and AQ B.2.26-4 in BSEP letter dated March 14,2005.
BSEP 05-0148 Enclosure Page 8 of 13 I he inaccessible Medium voltage C.ables NOt SuDJect to i0 CFR 50.49 Environmental Qualification Requirements Program is a new aging management program that will be implemented and will include the provision that manholes containing medium-voltage cables in the scope of License Renewal will be inspected and accumulated water will be removed at least every two years by the Preventive Maintenance Program.
rriur lo tLc pnriuu v extended operation il MALfbblulV IVIVUIUIII Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program LRA Section B.2.27, Commitment was revised in response to AQ B.2.27-1 in BSEP letter dated March 14, 2005.
+
I 21 The Program will be enhanced to: (1) expand the Program scope to include an evaluation of each reactor coolant pressure boundary component included in NUREG/CR-6260, (2) provide preventive action requirements including requirement for trending and consideration of operational changes to reduce the number or severity of transients affecting a component, (3) include a requirement to reassess the locations that are monitored considering the RCPB locations that were added to the Program scope, (4) specify the selection criterion to be locations with a 60-year CUF value (including environmental effects where applicable) of 0.5 or greater, other than those identified in NUREG/CR-6260, (5) address corrective actions for components approaching limits, with options to include a revised fatigue analysis, repair or replacement of the component, or in-service inspection of the component (with prior NRC approval), and (6) address criteria for increasing sample size for monitoring if a limiting location is determined to be approaching the design limit.
A.1.1.28 Prior to the period of extended operation Reactor Coolant Pressure Boundary (RCPB) Fatigue Monitoring Program LRA Section B.3.1, Commitment Items (1) and (4) were revised in response to AQ B.3.1-1 in BSEP letter dated March 14, 2005.
BSEP 05-0148 Enclosure Page 9 of 13 The Reactor Vessel and Internals Structural Integrity Program will be enhanced to: (1) incorporate augmented inspections of the top guide using enhanced visual examination or other acceptable inspection methods that will focus on the high fluence region, (2) establish inspection criteria for the VT-3 examination of the Core Shroud Repair Brackets, (3) the scope of the program described in the UFSAR Supplement will be revised to state that the program implements the following or latest BWRVIP guidelines:
BWRVIP-03, BWRVIP-18, BWRVIP-25, BWRVIP-26, BWRVIP-27, BWRVIP-38, BWRVIP-41, BWRVIP-47, BWRVIP-48, BWRVIP-49, BWRVIP-74-A, BWRVIP-76, BWRVIP-94, and BWRVIP-139 (when reviewed and approved by the NRC) and (4) the scope of the program described in the UFSAR Supplement will be revised to state that:
- the Reactor Vessel and Internals Structural Integrity Program in conjunction with the Water Chemistry Program will be used to manage flow blockage due to fouling of the Core Spray lines and spargers (spray nozzles),
- the Reactor Vessel and Internals Structural Integrity Program will be used to manage the aging of the non-safety related steam dryers and feedwater spargers,
- loss of preload due to stress relaxation of the Unit 2 spring-loaded core plate plugs will be managed by replacing the plugs. Any evaluation to extend the service life of the spring-loaded core plate plugs will be submitted to the NRC for review and approval, and
- either an ultrasonic examination alone or with a visual examination will be performed for the Access Hole Cover welds until other specific guidance is provided by the BWRVIP.
Prior to the period of extended operation Reactor Vessel and Internals Structural Integrity Program LRA Section B.2.28, Commitment Items (1),
(3), and (4) were revised in;response to RAI B.2.28-15 in BSEP letter dated Junel4, 2005. Item (3) and bullets two and three of Item (4) were revised by RAI B.2.28-15 (Supplemental Response) in BSEP letter dated July 18, 2005. Bullet four of Item (4) was added in response to RAI B.2.28-6 in BSEP letter dated July 18, 2005.
.5.
a U
£
BSEP 05-0148 Enclosure Page 10 of 13 23 Aprocedure will be developed to implement: (1) inspection of A.1.1.31 Prior to the period of Systems Monitoring in-scope License Renewal components for identified aging extended operation Program effects, (2) guidelines for establishing inspection frequency requirements, (3) listing of inspection criteria in checklist form, LRA Section B.2.29 (4) recording of extent of condition during system walkdowns, and (5) addressing of appropriate corrective action(s) for degradations discovered.
24 Preventive maintenance activities will be incorporated into the A. 1.1.32 Prior to the period of Preventive Maintenance PM Program, as needed, to accomplish aging management extended operation (PM) Program activities for components. Program activities include:
(1) routine internal visual inspections for corrosion of the LRA Section B.2.30, Demineralized Water Tank, (2) regular monitoring and removal Commitment Item (1) of debris to manage accumulation of sludge, dirt/dust, rust, and was added in response other miscellaneous debris in the torus, (3) periodic inspection to AQ B.2.2-6 in of high-voltage insulators for water beading on silicone coating BSEP letter dated and for age related degradation, (4) routine sampling and March 14, 2005.
analysis to address corrosion concerns related to potential Item (2) was added in water intrusion into lubricating oil in the Service Water Pump response to AQ B.2.24-Motor Cooler Coils and the Emergency Diesel Engines Lube 1 in BSEP letter dated Oil System, and (5) inspections of floor drains periodically March 14,-.2005.
exposed to service water and roof drains exposed to coastal Item (3) was added in atmospheric conditions to address aging concerns related to response to RAI potential locally aggressive environments.
3.6.2.3-3 in BSEP letter dated June 14, 2005.
Item (4) was added in response to RAI 3.3-3 in BSEP letter dated August 11, 2005.
Item (5) was added in response to RAI 3.3.2-5-1 in BSEP letter dated August 11, 2005.
BSEP 05-0148 Enclosure Page 11 of 13 Iine rnase Bus Aging management Program is a new aging management program that will be implemented and will include: (1) inspecting the interior condition of the bus enclosure for foreign debris, excessive dust build up, and evidence of water intrusion, (2) use of the Structures Monitoring Program to inspect the external surfaces of the phase bus housing, and (3) checking accessible and inaccessible Phase Bus bolted connections for loose connections by thermography or by measuring connection resistance using a low range ohmmeter on a 10-year frequency.
Thermography will be performed while the bus is energized and loaded.
Prior to me period o0 extended operation rnase ous Aging Management Program LRA Section B.2.3 1, Commitment Items (1) and (2) were added in response to RAI 3.6.2.3-l in BSEP letter dated June 14, 2005.
Item (3) was added in response to RAI 3.6.2.3-I.b.3 in BSEP letter dated July 18. 2005.
26 The Fuel Pool Girder Tendon Inspection Program will be A. 1.1.34 Prior to the period of Fuel Pool Girder enhanced to: (1) specify inspection frequencies, numbers of extended operation Tendon Inspection tendons to be inspected, and requirements for expansion of Program sample size, (2) identify test requirements and acceptance criteria for tendon lift-off forces, measurement of tendon LRA Section B.2.32 elongation, and determination of ultimate strength, (3) specify inspections for tendons, tendon anchor assemblies, surrounding concrete, and grease, (4) require prestress values to be trended and compared to projected values, and (5) identify acceptable corrective actions for tendons that fail to meet testing criteria.
BSEP OS-0148 Enclosure Page 12 of 13 r-I uimit curves for use during the periods of extended operation of BSEP Units 1 and 2 will be submitted for NRC review and approval in accordance with the 10 CFR 50.90 license amendment process at least one year prior to expiration of the 32 EFPY P-T limit curves that are currently approved in the BSEP Technical Specifications. Also, if an exemption request to permit the use of ASME Code Case N-640 is required as part of the submittal, an exemption request will be included as part of the license amendment request.
As noted in the commitment Time Limited Aging Analysis (TLAA) -
RPV Operating Pressure-Temperature (P-T) Limits LRA Section 4.2.4, Commitment was added in response to RAI 4.2.4-1 in BSEP letter dated May 4, 2005, and revised in response to RAI 4.2.4-1 (Supplemental Response) in BSEP letter dated July 18. 2005.
28 Management of Core Plate Plug Spring Stress Relaxation will A. 1.2.1.7 As noted in the TLAA - Core Plate be performed by means of the Reactor Vessel and Internals A.1.1.30 commitment Plug Spring Stress Structural Integrity Program.
Relaxation LRA Section 4.2.8 29 A Fuel Pool Girder Tendon Inspection Program will be A. 1.2.6 Prior to the period of TLAA - Fuel Pool implemented to assure design basis anchor forces required for A.1.1.34 extended operation Girder Tendon Loss of the tendons to perform their intended function will continue to Prestress be maintained.
LRA Section 4.7.2 30 Measurements are planned, using the One-Time Inspection A.1.2.8 Prior to the period of TLAA - Torus Program, to verify by volumetric measurements the actual rate A.1.1.15 extended operation Component Corrosion of corrosion of the supports and platform steel in the torus.
Allowance I_
I I
LRA Section 4.7.4
I BSEP 05-0148 Enclosure Page 13 of 13 1 runtWic ite I'1ctl Plan AdFeSE 31 An evaluation of plant and industry operating experience will None One year prior to the Potential Aging be submitted for NRC review at least one year prior to the period of extended Effects/Mechanisms period of extended operation. The purpose of the evaluation Refer to the ACRS letter operation Resulting from Power will be to assure that relevant aging effects caused by operation report on license renewal of Uprate at power uprate conditions are adequately addressed by aging Dresden/Quad Cities, dated management programs.
September 16, 2004.
Commitment added in BSEP letter dated May 11, 2005 March 14, 2005 BSEP 05-0041 Response to Audit Questions - License Renewal NUREG-1801 Consistency Audit ML050810493 March 31, 2005 BSEP 05-0044 Response to Request for Additional Information - License Renewal ML050970259 May 4, 2005 BSEP 05-0050 Response to Request for Additional Information - License Renewal MLO51330020 May 11, 2005 BSEP 05-0055 Response to Request for Additional Information - License Renewal ML051370298 June 14,2005 BSEP 05-0071 Response to Request for Additional Information - License Renewal MIL051720468 July 18, 2005 BSEP 05-0097 Clarification of Responses to Requests for Additional Information -License Renewal ML052070762 August 11, 2005 BSEP 05-0112 Supplemental Responses to Requests for Additional Information - License Renewal ML052310238