BSEP 09-0125, Response to Request for Additional Information Regarding Third 10-Year Inservice Inspection Interval Request for Relief RR-46

Response to Request for Additional Information Regarding Third 10-Year Inservice Inspection Interval Request for Relief RR-46

ML093440850
Person / Time
Site:	Brunswick
Issue date:	12/02/2009
From:	Mentel P Progress Energy Carolinas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BSEP 09-0125, TAC ME1249, TAC ME1250
Download: ML093440850 (25)

Text

r)Progress Energy DEC 0 2 2009 SERIAL: BSEP 09-0125 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit Nos. 1 and 2 Renewed Facility Operating License Nos. DPR-71 and DPR-62 Docket Nos. 50-325 and 50-324 Response to Request for Additional Information Regarding Third 10-Year Inservice Inspection Interval Request for Relief RR-46 (NRC TAC Nos. ME 1249 andME 1250)

Reference:

Letter from Phyllis N. Mentel to U.S. Nuclear Regulatory Commission, ProposedAlternativefor the Third 10-Year Inservice Inspection Program, dated May 8, 2009 (ADAMS Accession Number ML091340100)

Ladies and Gentlemen:

By letter dated May 8, 2009, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., submitted a 10 CFR 50.55a request for the Brunswick Steam Electric Plant, Unit Nos. 1 and 2. On October 21, 2009, the NRC provided an electronic version of a request for additional information (RAI) concerning the proposed Inservice Inspection Program alternatives. The response to this RAI is enclosed.

No regulatory commitments are contained in this letter. Please refer any questions regarding this submittal to Ms. Annette Pope, Supervisor - Licensing/Regulatory Programs, at (910) 457-2184.

Sincerely, Phy lis N. Mentel Manager - Support Services Brunswick Steam Electric Plant 0c4 7 Progress Energy Carolinas, Inc.

Brunswick Nuclear Plant PO Box 10429 Southport, NC28461

Document Control Desk BSEP 09-0125 / Page 2 WRM/wrm

Enclosure:

Response to Request for Additional Information Regarding Third 10-Year Inservice Inspection Interval Request for Relief RR-46 cc (with enclosure):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931 U. S. Nuclear Regulatory Commission ATTN: Mr. Philip B. O'Bryan, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U. S. Nuclear Regulatory Commission (Electronic Copy Only)

ATTN: Mrs. Farideh E. Saba (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission P.O. Box 29510 Raleigh, NC 27626-0510 Mr. Jack M. Given, Jr., Bureau Chief North Carolina Department of Labor Boiler Safety Bureau 1101 Mail Service Center Raleigh, NC 27699-1101

BSEP 09-0125 Enclosure Page 1 of 3 Response to Request for Additional Information Regarding Third 10-Year Inservice Inspection Interval Request for Relief RR-46

Background

By letter dated May 8, 2009, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., submitted a 10 CFR 50.55a request for the Brunswick Steam Electric Plant (BSEP), Unit Nos. 1 and 2. On October 21, 2009, the NRC provided an electronic version of a request for additional information (RAI) concerning the proposed Inservice Inspection Program alternative (i.e., Relief Request RR-46). The response to this RAI follows.

NRC Question 1 Provide copies of Attachments 1, 2, and 3 to Relief Request No. RR-46 which are more legible.

If necessary provide enlarged copies of these Attachments.

Response to NRC Question ]

Enlarged copies of the requested plant drawings, which were previously provided in Attachments 1, 2, and 3 CP&L's letter dated May 8, 2009, are provided in Attachment 1.

NRC Question 2 On Attachments 2 and 3 to Relief Request No. RR-46, indicate, i.e., circle, all of the relevant (control rod drive) CRD housings.

Response to NRC Question 2 The drawings provided in Attachments 2 and 3 were functionally equivalent, with Attachment 2 being a Unit 1 drawing and Attachment 2 being a Unit 2 drawing. As a result, only the drawing previously provided in Attachment 3 of CP&L's letter dated May 8, 2009, has been annotated to indicate the relevant CRYD housing features. The annotated figure is provided in Attachment 2.

NRC Question 3 On Attachment 1 to Relief Request No. RR-46, clearly identify both the housing-to-flange weld and the housing tube-to-tube weld.

BSEP 09-0125 Enclosure Page 2 of 3 Response to NRC Question 3 A portion of a different drawing is provided in Attachment 3 and depicts the same CRD feature-of-interest as shown in the previously submitted Attachment 1. The drawing in Attachment 3 has been annotated to identify both the housing tube-to-tube weld and the housing-to-flange weld.

NRC Question 4 For Figures 1 and 2 in Attachment 4, clearly identify one housing-to-flange weld and one housing tube-to-tube weld on each photo. Provide enlarged photos, if necessary.

Response to NRC Question 4 The welds are not visible in the Figure 1 contained in CP&L's letter dated May 8, 2009. Figure 1 shows the general under-vessel area with various instrumentation cabling. The CRD flanges are located in the shoot out steel above this cabling. Figure 2 in CP&L's letter dated May 8, 2009, depicts the CRD flanges looking up from under vessel. It was provided to show the obstructions and interferences that are limiting our access. Photographs are provided in Attachment 4 of this letter. These photos are annotated to indicate applicable features of interest.

NRC Question 5 Is it possible to examine any portion of the lower housing-to-flange weld on any peripheral CRD housing? If not please provide specific details as to why this is not possible.

Response to NRC Question 5 As can be seen from the photograph provided in response to Question 4 above, a partial examination is not possible due to the limited access and obstructions.

NRC Question 6 Provide specific details as to why this equipment was not designed for Inservice Inspection (ISI) as required by 10 CFR 50.55a(g)(2).

Response to NRC Question 6 BSEP's piping systems and associated components were designed and fabricated before the examination requirements of American Society of Mechanical Engineers (ASME) Code,Section XI were formalized and published. Since the plant was not specifically designed to meet the requirements of the ASME Code,Section XI, literal compliance is not feasible or practical within the limits of the current plant design.

BSEP 09-0125 Enclosure Page 3 of 3 NRC Question 7 The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1989 Edition with no Addenda, Sub-article IWB-2500, Table IWB-2500-1, Examination Category B-O, Item No. B 14.10 requires 100 percent volumetric or surface examination of 10 percent of the peripheral control rod drive (CRD) housing welds. On page 1 of Relief Request No. RR-46 in Section, 1, "ASME Code Components Affected" under the subsection titled, "Description," the request states "Volumetric Examination Coverage," yet as stated above "volumetric or surface examination" is required. Please address this discrepancy.

Response to NRC Question 7 A revised copy of Relief Request RR-46 is provided in Attachment 5 to address the change to the "Description" title.

BSEP 09-0125 Attachments Attachment 1 (Supporting the Response to NRC Question 1)

BSEP 09-0125 Attachments Attachment 2 (Supporting the Response to NRC Question 2)

BSEP 09-0125 Attachments Attachment 3 (Supporting the Response to NRC Question 3)

BSEP 09-0125 Attachments Attachment 4 (Supporting the Response to NRC Question 4)

L1 Lue it CiCltdLIUII ising 4pproximately 2" dia.

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Upper CRD welds at the manway. RV can be seen in the background.

Insulation support can be seen below.

BSEP 09-0125 Attachments Attachment 5 (Supporting the Response to NRC Question 7)

BSEP 09-0125 Page 1 of 8 10 CFR 50.55a Request Number RR-46 Proposed Alternative In Accordance with 10 CFR 50.5 5a(g)(5)(iii)

- Inservice Inspection Impracticality -

1. ASME Code Components Affected Code Class: 1

References:

Subarticle IWB-2500, Table IWB-2500-1 Examination Categories: B-O, "Pressure Retaining Welds in Control Rod Housings" Item Numbers: B14.10, "Welds in CRD Housing"

Description:

Volumetric or Surface Examination Coverage Component Numbers: 1CI1-CRD06-11-SW1 CRD Housing Weld 1C 11-CRD06-15-SW 1 CRD Housing Weld 1C II-CRD 10-07-SW 1 CRD Housing Weld 1C 1I -CRD 14-07-SW 1 CRD Housing Weld 2C11-CRD38-47-SW1 CRD Housing Weld 2C 11 -CRD42-47-SW1 CRD Housing Weld 2C11-CRD46-39-SW1 CRD Housing Weld 2C11-CRD46-43-SW1 CRD Housing Weld

2. Applicable Code Edition and Addenda

The Inservice Inspection Program for the third 10-year inservice inspection interval was based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1989 Edition with no Addenda.

3. Applicable Code Requirement

Sub-article IWB-2500, Table IWB-2500-1, requires essentially 100 percent volumetric or surface examination of 10 percent of the peripheral control rod drive (CRD) housing welds (Examination Category B-O, Item No. B14.10, as defined by Figure IWB-2500-18).

Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., elected to perform surface examinations on the selected CRD housing welds.

4. Imnracticalitv of Comnliance I I I In accordance with 10 CFR 50.55a(g)(5)(iii), relief is requested from the requirement of the ASME Code,Section XI, Sub-article IWB-2500, Table IWB-2500-1 (Volumetric or Surface Examination Category B-O, "Pressure Retaining Welds in Control Rod Drive Housings"),

BSEP 09-0125 Page 2 of 8 Examination Item Number B 14.10, "Welds in CRD Housing." Limited accessibility for the 36 peripheral CRD housing welds is due to the close proximity of adjacent CRD housing flanges, neutron monitoring instrumentation and associated cabling, and horizontal beams, support bars and grids.

5. Burden Caused by Compliance Compliance with the examination coverage requirements of the ASME Code,Section XI, would require modification, redesign, or replacement of components where geometry is inherent to the component design.

6. Proposed Alternative and Basis for Use Proposed Alternative In accordance with 10 CFR 50.55a(g)(5)(iii), CP&L is requesting relief for the components listed above on the basis that the required examination coverage of "essentially 100 percent" is impractical due to physical obstructions and severely limited access in the work area. As an alternative, CP&L proposes selecting the four additional upper CRD housing welds, listed below, in lieu of the four lower housing-to-flange welds. This would provide the same total number of CRD housing welds for examination (i.e., eight welds) and will be an equivalent 100 percent inspection of 10 percent of the peripheral housings.

Unit 1 Additional CRD Unit 2 Additional CRD Housing Weld Examinations Housing Weld Examinations 1CI1-CRD38-47-SW2 2C1 1-CRD06-1 1-SW2 1C II-CRD42-47-SW2 2C 11 -CRD06-15-SW2 IC 11-CRD46-39-SW2 2C 11-CRDIO-07-SW2 IC 11-CRD46-43-SW2 2C 11-CRD14-07-SW2 Basis for Use The ASME Code,Section XI, Sub-article IWB-2500, Table IWB-2500-1, requires essentially 100 percent volumetric or surface examination of 10 percent of the peripheral CRD housing welds (Examination Category B-O, Item No. B 14.10, as defined by Figure IWB-2500-18).

Each CRD housing contains two pressure retraining welds. Table IWB-2500-1 requires both the upper and lower welds of each of the selected CRD housings to be examined.

BSEP 09-0125 Page 3 of 8 BSEP has 36 peripheral CRD housings; therefore, this requires four CRD housings (i.e., a total of eight CRD housing welds) to be examined. As previously stated, each CRD housing contains two pressure retaining welds: the housing-to-flange weld and the housing tube-to-tube weld. The housing-to-flange weld is located in the inaccessible lower section of the CRD housing, whereas the housing tube-to-housing tube weld is located in the accessible upper section of the CRD housing (i.e., shown on Drawings 0-FP-05609; C-24004, Sheet 26-1; and C-02404, Sheet 26-1; provided in Attachments 1, 2, and 3, respectively).

Limited access for the 36 peripheral CRD housing-to-flange weld welds is due to the work area under the reactor vessel being highly congested, as shown in the photographs in . Physical obstructions imposed by design, geometry, and materials of construction include vessel appurtenances, insulation support rings, structural and component supports, adjacent CRD housing flanges, and neutron monitoring instrumentation and associated cabling. These obstructions are not practical to remove or replace to achieve 100 percent volumetric or surface coverage of the welds in the CRD housings. The upper housing welds are without obstruction and can be completely examined.

Therefore, as an alternative, CP&L proposes selecting four additional upper CRD housing welds in lieu of the four lower housing-to-flange welds. This would provide the same total number of CRD housing welds for examination (i.e., eight welds).

CP&L performed qualified surface examinations that achieved the maximum, practical amount of coverage obtainable within the limitations imposed by the design of the components. The examinations conducted confirmed satisfactory results, with no unacceptable flaws being identified and no evidence of degradation mechanisms.

Percent of Code-Required Volume Achieved Original Sample Additional Sample ICI 1-CRD06-1 I-SW2 100% Coverage Achieved ICIl-CRD38-47-SW2 100% Coverage Achieved ICI 1-CRD06-15-SW2 100% Coverage Achieved ICI1-CRD42-47-SW2 100% Coverage Achieved ICI 11-CRDI0-07-SW2 100% Coverage Achieved IC 11-CRD46-39-SW2 100% Coverage Achieved ICI 1-CRDI4-07-SW2 100% Coverage Achieved ICI1-CRD46-43-SW2 100% Coverage Achieved 2C1 1-CRD38-47-SW2 100% Coverage Achieved 2C II-CRD06-1 1-SW2 100% Coverage Achieved 2C1 1-CRD42-47-SW2 100% Coverage Achieved 2Cll-CRD06-15-SW2 100% Coverage Achieved 2C I-CRD46-39-SW2 100% Coverage Achieved 2ClI-CRDI0-07-SW2 100% Coverage Achieved 2C] 1-CRD46-43-SW2 100% Coverage Achieved 2Cll-CRD14-07-SW2 100% Coverage Achieved As Class 1 Examination Category B-O components, a visual (VT-2) examination is also performed on these components during system pressure tests each refueling outage. This was completed during the Unit 1 2008 refueling outage (i.e., the BI 17R1 outage) and Unit 2 2009 refueling outage (i.e., the B219R1 outage), and no evidence of leakage was identified for these components. Reactor coolant system leak rate limitations and atmospheric particulate radioactivity monitoring also ensure that any leakage would be detected prior to gross failure.

BSEP 09-0125 Page 4 of 8

7. Duration of the Proposed Alternative Use of the proposed alternative is applicable to the third 10-year inservice inspection interval at BSEP, Units 1 and 2. The third 10-year interval began on May 11, 1998, and ended on May 10, 2008, for Unit 1 and will end on May 10, 2009, for Unit 2.

8. Precedents Similar relief request was granted for the Pilgrim Nuclear Power Station, as listed in Reference 1.

9. References

1. Letter from U.S. Nuclear Regulatory Commission (USNRC) to Entergy Nuclear Operations, Inc., Third 10-Year Interval Inservice Inspection Program Plan Request for Relief Request No. PRR-42, Revision 1 - Pilgrim Nuclear Power Station (TAC No. MD6767), dated June 27, 2008, ADAMS Accession Number ML081300415.

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BSEP 09-0125 Page 8 of 8 ATTACHMENT 4 Figure 1 - Under-Vessel Area Figure 2 - Under-Vessel Area, Looking Upwards