Text

Proposed Alternatives for the Third 10-Year Inservice Inspection Program
	ML102150345
Person / Time
Site:	Brunswick
Issue date:	07/23/2010
From:	Mentel P; Progress Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BSEP 10-0043
	Download: ML102150345 (51)
	v • d • e

jProgress Energy JUL 2 32010 SERIAL: BSEP 10-0043 10 CFR 50.55a(g)(5)(iii)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Brunswick Steam Electric Plant, Unit No. 2 Renewed Facility Operating License No. DPR-62 Docket No. 50-324 Proposed Alternatives for the Third 10-Year Inservice Inspection Program

References:

1. Letter from Keith R. Jury to U.S. Nuclear Regulatory Commission, Inservice Inspection Programfor the Third Ten-Year Interval, dated April 23, 1998.

2. Letter from Phyllis N. Mentel to U.S. Nuclear Regulatory Commission, ProposedAlternativefor the Third 10- Year Inservice Inspection Program, dated April 27, 2009, ADAMS Accession Number ML091260502.

3. Letter from Douglas A. Broaddus (NRC) to Michael J. Annacone (CP&L), Brunswick Steam Electric Plant, Unit I - Relief Requests RR-42, RR-43, RR-44, and RR-45 for the Third 10-Year Interval Inservice Inspection ProgramPlan (TAC Nos. ME))43, ME1144, ME]145, and ME]146), dated April 30, 2010, ADAMS Accession Number ML100960547.

Ladies and Gentlemen:

By letter dated April 23, 1998, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., submitted the third 10-year Inservice Inspection Program for the Brunswick Steam Electric Plant (BSEP), Units 1 and 2. During the third inspection interval, the 1989 Edition of the American Society of Mechanical Engineers (ASME) Code,Section XI, with no addenda, was used for Class 1, 2, and 3 components, unless otherwise permitted.

During the third 10-year interval, CP&L completed the required inservice examinations for BSEP, Unit 2, in accordance with the plan, except that certain components could not fully meet the examination requirements specified in the 1989 ASME Code,Section XI, including the clarifications provided in ASME Code Case N-460. CP&L has determined that conformance to the Code requirement of essentially 100 percent coverage of weld volume or area examined was impractical due to various constraints and limitations.

Progress Energy Carolinas. Inc.

Brunswick Nuclear Plant P Bus O 10429 Southport, NC28461

Document Control Desk BSEP 10-0043 / Page 2 Accordingly, in accordance with 10 CFR 50.55a(a)(g)(5)(iii), CP&L requests NRC approval of four 10 CFR 50.55a Requests for BSEP, Unit 2, copies of which are provided in Enclosures 1 through 4.

The third 10-year inservice inspection interval began on May 11, 1998. As allowed by subarticle IWA-2430(d) of the ASME Code,Section XI, the third 10-year inspection interval was extended for one year. This extension enabled the examination of Unit 2 components to coincide with the March 2009 B219R1 refueling outage. The third 10-year inspection interval for BSEP, Unit 2 concluded on May 10, 2009. Similar alternative requests for BSEP Unit 1 were submitted by CP&L's letter dated April 27, 2009, and subsequently approved by NRC letter dated April 30,'2010.

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, Phyllis N. Mentel Manager - Support Services Brunswick Steam Electric Plant WRM/wrm

Enclosures:

1. 10 CFR 50.55a Request Number RR-47

2. 10 CFR 50.55a Request Number RR-48

3. 10 CFR 50.55a Request Number RR-49

4. 10 CFR 50.55a Request Number RR-50

Document Control Desk BSEP 10-0043 / Page 3 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Luis A. Reyes, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 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 10-0043 Enclosure 1.

Page 1 of 16 10 CFR 50.55a Request Number RR-47 Proposed Alternative In Accordance with 10 CFR 50.55a(g)(5)(iii)

- Inservice Inspection Impracticality -

1. ASME Components Affected Code Class: 1

References:

Subarticle IWB-2500, Table IWB-2500-1 Examination Categories: B-D Item Numbers: B3.90

Description:

Volumetric Examination Coverage Component Numbers: Listed in Table RR-47-1, attached.

2. Applicable Code Edition and Addenda

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1989 Edition with no Addenda.

3. Applicable Code Requirement

Subarticle IWB-2500 states, in part: "Components shall be examined and tested as specified in Table IWB-2500-1 ." Table IWB-2500-1 requires a volumetric examination or a surface and volumetric examination be performed on the component based on Category and Item Number.

Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., adopted and applied ASME Code Case N-460, Alternative Examination Coveragefor Class 1 and Class 2 Welds,Section XI, Division 1, (i.e., Reference 1) at the Brunswick Steam Electric Plant (BSEP) during the third 10-year inservice inspection interval. Code Case N-460 is applicable when the entire examination volume or area cannot be examined due to interference by another component or part geometry. Under such circumstances, a reduction in examination coverage on any Class 1 or Class 2 weld may be accepted provided that the reduction in coverage for that weld is less than 10 percent.

In October 2007, the NRC issued Regulatory Guide (RG) 1.147, Revision 15, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1 (i.e., Reference 2). In RG 1.147, the NRC identifies the ASME Code Cases they have determined to be acceptable alternatives to applicable sections of Section XI, and that those Code Cases may be used by licensees without requesting NRC authorization provided they are used with any identified

BSEP 10-0043 Enclosure 1 Page 2 of 16 limitations or modifications. Table 1 of RG 1.147 lists the following Code Case as acceptable for use by a licensee with no identified limitations or modifications:

Code Case N-460, Alternative Examination Coveragefor Class] and Class 2 Welds,Section XI, Division]

Code Case N-460 states, in part:

When the entire examination volume or area cannot be examined due to interference by another component or part geometry, a reduction in examination coverage on any Class 1 or Class 2 weld may be accepted provided the reduction in coverage for that weld is less than 10 percent.

NRC Information Notice (IN) 98-42 (i.e., Reference 3) states that the NRC determined that a reduction in coverage of less than 10 percent to be "essentially 100 percent." IN 98-42 states, in part:

The NRC has adopted and further refined the definition of 'essentially 100 percent' to mean 'greater than 90 percent' in 10 CFR 50.55a(g)(6)(ii)(A)(2) for required examination coverage of reactor pressure vessel welds. This standard has been applied to all examinations of welds and other areas required by ASME Section XI.

The applicable examination area or volume and method required from Table IWB-2500-1, for the affected components, is shown in Table RR-47-1.

4. Impracticality of Compliance BSEP, Unit 2 systems and components were designed and fabricated before the examination requirements of the ASME Code,Section XI, were formalized and published. Therefore, the BSEP was not specifically designed to meet the requirements of the ASME Code,Section XI, and full compliance is not feasible or practical within the limits of the current plant design.

10 CFR 50.55a recognizes the limitations to inservice inspection of components in accordance with Section XI of the ASME Code that are imposed due to early plants' design and construction, as follows:

10 CFR 50.55a(g)(1):

For a boiling or pressurized water-cooled nuclear power facility whose construction permit was issued before January 1, 1971, components (including supports) must meet the requirements of paragraphs (g)(4) and (g)(5) of this section to the extent practical.

BSEP 10-0043 Enclosure 1 Page 3 of 16 10 CFR 50.55a(g)(4):

Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components (including supports) which are classified as ASME Code Class 1, Class 2 and Class 3 must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code and Addenda that become effective subsequent to editions specified in paragraphs (g)(2) and (g)(3) of this section and that are incorporated by reference in paragraph (b) of this section, to the extent practical within the limitations of design, geometry and materials of construction of the components.

10 CFR 50.55a(g)(5)(iii):

If the licensee has determined that conformance with certain code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in § 50.4, information to support the determinations.

In accordance with 10 CFR 50.55a(g)(5)(iii), CP&L has determined that it is impractical to meet the examination coverage requirements of ASME Code Case N-460. The ASME Code,Section XI, requires volumetric (i.e., UT) examination of nozzle-to-vessel welds from two sides of the weld in order to be 100 percent complete. Due to nozzle configurations of these components, ultrasonic examinations are limited to scanning on the shell-side of the nozzle welds.

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), relief is requested for the components listed in Table RR-47-1 on the basis that the required examination coverage of "essentially 100 percent" is impractical due to physical obstructions and the limitations imposed by design, geometry and materials of construction. No alternative examination is being proposed.

CP&L performed qualified examinations that achieved the maximum, practical amount of coverage obtainable within the limitations imposed by the design of the components.

Additionally, as Class 1 examination Category B-P components, a visual (VT-2) examination is performed on these Reactor Coolant Pressure Boundary (RCPB) components during

BSEP 10-0043 Enclosure 1 Page 4 of 16 system pressure tests each refueling outage. This was completed during the 2009 refueling outage (i.e., the B219R1 outage), and no evidence of leakage was identified for these components.

Therefore, in accordance with 10 CFR 50.55a(g)(5)(iii), CP&L requests relief from the requirements of the ASME Code,Section XI, Table IWB-2500-1, Category B-D, Item B3.90, and proposes to credit the completed exams as acceptable alternatives that provide reasonable assurance of continued structural integrity.

Basis for Use Due to the design of these welds it was not feasible to effectively perform a volumetric examination of "essentially 100 percent" of the required volume. The nozzle-to-vessel welds are accessible from the vessel plate side of the weld and are examined to the extent practical.

The nozzle design at BSEP does not allow for examination on the nozzle side of the weld.

The outside blend radius of the nozzle forgings varies from 2.75 inches to 5 inches on the nozzles in question. The curvature of the surface prevents the transducer from maintaining contact and proper coupling. Additional coverage for the limited areas was not achievable or practical, based on the latest qualified ultrasonic technology, -norby other considered examinations methods, such as radiography. Figure RR-47-4 provides a plant nozzle configuration drawing which shows the nozzle curvature and weld preparation that is typical on all nozzles.

The volumetric examinations which were completed were performed with the following insonification angles (i.e., nominal) and modes of propagation.

0' Longitudinal 450 Shear 600 Shear These examinations identified no indications (i.e., see Table RR-47-1).

CP&L has concluded that if significant degradation existed in the subject welds, it would have been identified by the examinations performed.

The BSEP reactor vessel water chemistry is controlled in accordance with the 2008 revision to the BWR Water Chemistry Guidelines (i.e., Reference 4). Also, a Hydrogen Water Chemistry System is used to reduce the oxidizing environment in the reactor coolant. These additional measures provide added assurance against the initiation of cracking or corrosion from the inside surface of the reactor vessel. An inerted primary containment environment during operation provides assurance of corrosion protection on the outside surface of the reactor vessel.

The provisions described above as an alternative to the Code requirement will continue to provide reasonable assurance of the structural integrity of the subject welds. The

BSEP 10-0043 Enclosure 1 Page 5 of 16 examinations were completed to the extent practical and no reportable indications were present. VT-2 examinations performed on the subject components during system pressure testing each refueling outage, in accordance with Examination Category B-P, provide continued assurance that the structural integrity of the subject components is maintained.

Additionally, the BSEP Water Chemistry Program and inerted primary containment environment provide added measures of protection for the component materials.

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

7. Precedents

1. CP&L submitted a similar relief request in the second 10-year interval (i.e., see CP&L's letter dated February 19, 1999, Serial: BSEP 99-0009, which submitted Relief Request RR-12, Revision 1). In a Safety Evaluation Report issued February 1, 2000, TAC No. MA4869 and MA4870, Relief Request RR-23 was approved.

2. CP&L submitted a similar relief request for BSEP, Unit 1 applicable to the third 10-year interval (i.e., see CP&L's letter dated April 27, 2009, Serial: BSEP 09-0024, ADAMS Accession Number ML091260502, which submitted Relief Request RR-42).

8. References

1. Code Case N-460, Alternative Examination Coveragefor Class ] and Class 2 Welds,Section XI, Division].

2. NRC Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 15, October 2007.

3. NRC Information Notice 98-42, Implementation of 10 CFR 50.55a(g) Inservice Inspection Requirements, December 1, 1998.

4. BWRVIP-190: BWR Vessel and Internals Project, BWR Water Chemistry Guidelines-2008 Revision, Electric Power Research Institute Topical Report TR- 10 16579.

BSEP 10-0043 Enclosure 1 Page 6 of 16 TABLE RR-47-1 Ultrasonic Technique System and S=Shear Wave Required Percent Component L=Longitudinal Examination Coverage Examination Component ID Description Wave Volume Obtained Results Remarks 2B11-RPV-N3A Reactor Vessel, Main 0, 45S, 60S, ASME Code, Figure 51.7% No Reportable Examination limited due Steam Nozzle N3A IWB-2500-7(b) Indications to nozzle configuration.

Examination performed prior to implementation of Appendix VIII, Supplements 4 and 6.

2B11-RPV-N3B Reactor Vessel, Main 0,45S,60S, ASME Code, Figure 51.7% No Reportable Examination limited due Steam Nozzle N3B IWB-2500-7(b) Indications to nozzle configuration.

Examination performed prior to implementation of Appendix VIII, Supplements 4 and 6.

2B11-RPV-N3C Reactor Vessel, Main 0,45S,60S, 70L ASMECode, Figure 51.7% No Reportable Examination limited due Steam Nozzle N3C IWB-2500-7(b) Indications to nozzle configuration.

Examination performed prior to implementation of Appendix VIII, Supplements 4 and 6.

2B11-RPV-N3D Reactor Vessel, Main 0,45S,60S, 70L ASME Code, Figure 51.7% No Reportable Examination limited due Steam Nozzle N3D IWB-2500-7(b) Indications to nozzle configuration.

Examination performed prior to implementation of Appendix VIII, Supplements 4 and 6.

2B11-RPV-N6A Reactor Vessel, Head 0,45S,60S, 70L ASME Code, Figure 50.1% No Reportable Examination limited due Spray Nozzle N6A IWB-2500-7(b) Indications to nozzle configuration.

Examination performed prior to implementation of Appendix VIII, Supplements 4 and 6.

BSEP 10-0043 Enclosure 1 Page 7 of 16 TABLE RR-47-1 Ultrasonic Technique System and S=Shear Wave Required Percent Component L=Longitudinal Examination Coverage Examination Component ID Description Wave Volume Obtained Results Remarks 2B11-RPV-N6B Reactor Vessel, Head 0, 45S, 60S, 70L ASME Code, Figure 50.-1% No Reportable Examination limited due Spray Nozzle N6B IWB-2500-7(b) Indications to nozzle configuration.

Examination performed prior to implementation of Appendix Vill, Supplements 4 and 6.

2B11-RPV-N7 Reactor Vessel, Head 0,45S, 60S, 70L ASME Code, Figure 50.1% - No Reportable Examination limited due Instrument Penetration IWB-2500-7(b) Indications to nozzle configuration.

Nozzle N7 Examination performed prior to implementation of Appendix Vill, Supplements 4 and 6.

2B11-RPV-N10 Reactor Vessel, Core 0,45S,60S, 70L ASME Code, Figure 44.5% No Reportable Examination limited due Differential Pressure IWB-2500-7(b) Indications to nozzle configuration.

Instrumentation, Examination performed Nozzle NO 10prior to implementation of Appendix VIII, Supplements 4 and 6.

2B 11-RPV-N 12A Reactor Vessel, Level 0,45S,60S, ASME Code, 44.5% No Reportable Examination limited due Instrumentation, Figure IWB-2500-7(b) Indications to nozzle configuration.

Nozzle Nl12A Examination performed prior to implementation of Appendix VIII, Supplements 4 and 6.

BSEP 10-0043 Enclosure 1 Page 8 of 16 TABLE RR-47-1 Ultrasonic Technique System and S=Shear Wave Required Percent Component L=Longitudinal Examination Coverage Examination Component ID Description Wave Volume Obtained Results Remarks 2B11-RPV-N12B Reactor Vessel, Level 0, 45S, 60S, 70L ASME Code, 44.5% No Reportable Examination limited due Instrumentation, Figure IWB-2500-7(b) Indications to nozzle configuration.

Nozzle N 12B Examination performed prior to implementation of Appendix VIII, Supplements 4 and 6.

BSEP 10-0043 Enclosure 1 Page 9 of 16 COVERAGE CALCULATION FOR r i 2B1 1-RPV-N3A, N3B, N3C, N3D See Figure RR-47-1 for examination areas and coverage 00(JNMD) WRV (AEHD) =51.4 in 2 30.6 in2= 59.5/% Weld (BCFG) 8.4 in 2 = 16.3% of WRV 450 Circ. CW (JMID)

Base Metal = (51.4 - 8.4) = 43 in 2 = 83.7%

WELD = 100% of WRV BM = 22.2 in2 = 51.6%

=> 450 Circ CW coverage = 16.3 + (.516)(83.7) = 59.50//o 450 Circ. CCW (JMHD) 0 WELD = 100%

BM = 22.2 in2 = 51.6%

=> 45' Circ CW coverage = 16.3 + (.516)(83.7) = 59.5/

600 Circ. CW (JMHD)

/

WELD = 100%

BM 22.2 in2 = 51.6%

=> 450 Circ CW coverage = 16.3 + (.516)(83.7) = 59.5° 600 Circ. CCW (JMHD)

WELD = 100%

BM = 22.2 in2 = 51.6%

=> 450 Circ CW coverage = 16.3 + (.516)(83.7) = 59.59 'C0 450 axial in (BbEHD)

WELD = 100%

BM = 33.2 in2 = 77.2%

=> 450 axial in coverage = 16.3 + (.772)(83.7) = 80.9%

450 axial out = 0%

600 axial in (BaEHD)

WELD = 100%

BM = 36.4 in2 = 84.7%

=> 60' axial in coverage = 16.3 + (.847)(83.7) = 87.2%

600 axial out = 0%

TOTAL COVERAGE = (59.5 +59.5 + 59.5 + 59.5 + 59.5 +80.9 + 87.2 + 0 + 0)/9

Total Coverage = 51.7%

BSEP 10-0043 Enclosure 1 Page 10 of 16 COVERAGE CALCULATION FOR 2B 11 -RPV-N6A, N6B, N7 See Figure RR-47-2 for examination areas and coverage WRV (AEFK) = 14.3 in 2 00 Coverage (LcKE)

Weld (CDJH) 2.25 in 2 =15.7% of WRV 7.8 in2= 54.5%

450 Circ. CW (LcKE) Base Metal = (14.3 - 2.25) = 12.05 in2 =84.3% of WRV WELD (CHJD) = 100%

BM (DJKE)= 5.9 in2 = 52.7% = > 15.7 + (.527)(84.3) = 59.6%

450 Circ. CCW (LcKE)

WELD (CHJD) = 100%

BM (DJKE)= 5.9 in2 = 52.7% = > 15.7 + (.527)(84.3) = 59.6 600 Circ. CW (LcKE)

WELD (CHJD) = 100%

BM (DJKE)= 5.9 in2 = 52.7% = > 15.7 + (.527)(84.3) = 59.6 600 Circ. CCW (LcKE)

WELD (CHJD) = 100%

BM (DJKE)= 5.9 in2 = 52.7% => 15.7 + (.527)(84.3) = 59.6 450 axial in (CbFKE)

WELD (DCcGJ)= 100%

BM (ECfFK) = 8.07 in2 = 71.7% => 16.7 + (.717)(84.3) = 76. 1%

450 axial out(weld) = 0%

600 axial in (CaFKE)

WELD(DCaGJ) = 100%

BM = 8.81 in2 = 78.3% => 16.7 + (.783)(84.3) 81.7%

600 axial out = 0%

TOTAL COVERAGE = (54.5 + 59.6 + 59.6 59.6 + 59.6 + 76.1 + 81.7+0 + 0)/9

Total Coverage = 50.1%

BSEP 10-0043 Enclosure 1 Page 11 of 16 COVERAGE CALCULATION FOR 2B1 I-RPV-N 10, N 12A, N12B See Figure RR-47-3 for examination areas and coverage 00 Coveraje (DBcH) WRV (AEHD) = 52.7 in2 24.6 in2==46.7% Weld (BCFG) = 8.5 in2 = 16.1% of WRV Base Metal = (52.7 - 8.5) = 44.2 in2 = 83.9% of WRV 450 Circ. CW (BcHD)

WELD (CBcG)= 5.5 in2 = 64.7%

BM = 19.8 in2 = 44.7%

=> 450 Circ CW coverage = (.647)16.1 + (.447)83.9 = 47.9%

450 Circ. CCW (BcHD)

WELD (CBcG)= 5.5 in2 = 64.7%

BM = 19.8 in 2 = 44.7%

=> 450 Circ CCW coverage = (.647)16.1 + (.447)83.9 47.9%

600 Circ. CW (BcHD)

WELD (CBcG)= 5.5 in2 = 64.7%

BM = 19.8 in2 = 44.7%

=> 600 Circ CW coverage = (.647)16.1 + (.447)83.9 = 47.9%

600 Circ. CCW (BcHD)

WELD (CBcG)= 5.5 in2 = 64.7%

BM = 19.8 in2 =-44.7%

=> 600 Circ CCW coverage = (.647)16.1 + (.447)83.9 = 47.9%

450 axial in (BbEHD)

WELD (BCGF)= 100%

BM = 32.3 in2 = 73.1%

=> 450 axial in coverage = 16.1 + (.731)(83.9) = 77.4%

BSEP 10-0043 Enclosure 1 Page 12 of 16 450 axial out = 0%

600 axial in WELD (BCGF)= 100%

BM = 36.3 in 2 = 82.1%

=> 600 axial in coverage 16.1 + (.821)(83.9) 85%

600 axial out = 0%

TOTAL COVERAGE = (46.7 +49.7 + 49.7 + 49.7 + 49.7 +77.4 + 85 + 0 + 0)/9 Total Coverage = 44.5%

BSEP 10-0043 Enclosure 1 Page 13 of 16 E MF G H N3 NOZZLE COVERAGE FIGURE RR-47-1 SCALE 1:2

BSEP 10-0043 Enclosure 1 Page 14 of 16 F cHl- I K*

N6 AND N7 NOZZLE COVERAGE FIGURE RR-47-2

BSEP 10-0043 Enclosure 1 Page 15 of 16 I

I I

E C G H N10 AND N12 NOZZLE COVERAGE FIGURE RR-47-3

BSEP 10-0043 Enclosure 1 Page 16 of 16 Typical Nozzle Configuration Drawing Figure RR-47-4

BSEP 10-0043 Enclosure 2 Page 1 of 10 10 CFR 50.55a Request Number RR-48 Proposed Alternative In Accordance with 10 CFR 50.55a(g)(5)(iii)

- Inservice Inspection Impracticality -

1. ASME Components Affected Code Class: 1

References:

Subarticle IWB-2500, Table IWB-2500-1 Examination Categories: As listed in Table RR-48-1, attached.

Item Numbers: Listed in Table RR-48-1, attached.

Description:

Limited Coverage for Welds in Examination Category B-J and R-A, Pressure Retaining Piping Welds Component Numbers: As listed in Table RR-48-1, attached.

2. Applicable Code Edition and Addenda

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 1989 Edition with no Addenda.

3. Applicable Code Requirement

By letter dated April 20, 2001 (i.e., Reference 1), Carolina Power & Light Company (CP&L),

now doing business as Progress Energy Carolinas, Inc., submitted the initial risk-informed inservice inspection (RI-ISI) Program for the Brunswick Steam Electric Plant (BSEP). The initial RI-ISI program was developed using the process described in Electric Power Research Institute (EPRI) Topical Report (TR) 112657, Revision B-A, Revised Risk-Informed Inservice Inspection Evaluation Procedure,and using ASME Code Case N-578, Risk-Informed Requirementsfor Class 1, Z and 3 Piping,Method B (i.e., Reference 2). The program was approved for use by the NRC in a Safety Evaluation issued by letter dated November 28, 2001 (i.e., Reference 3).

This relief request applies to eight (8) ASME Code Class 1 pressure-retaining piping welds.

These welds were examined after the implementation of RI-ISI. In the BSEP RI-ISI program, these seven welds correspond to Examination Category R-A, Item R1.20 welds using the format in ASME Code Case N-578-1. Use of Code Case N-578-1 nomenclature is not intended to imply that the BSEP RI-ISI program is based on Code Case N-578-1. Code Case N-578-1 is an unapproved code case, as shown in Regulatory Guide 1.193 (i.e.,

Reference 4), and BSEP has not requested nor received approval to implement Code Case N-578-1. Rather, to maintain consistency with established ASME Code,Section XI

BSEP 10-0043 Enclosure 2 Page 2 of 10 conventions, the weld categorization scheme of Code Case N-578-1 was adopted at BSEP to assist in assigning weld examination requirements. Code Case N-578-1 establishes a "R-A" weld category and weld item numbers Ri. 10 through R1.20, which allows BSEP to categorize RI-ISI piping welds in a manner similar to the standard ASME Section XI pipe weld program. The applicable ASME Code Examination Category and Item Numbers, and RI-ISI program Examination Category and Item Number, are shown in the attached Table RR-48-1.

Subarticle IWB-2500 states, in part: "Components shall be examined and tested as specified in Table IWB-2500-1 ." Table IWB-2500-1 requires a volumetric examination or a surface and volumetric examination be performed on the components based on their category and

'item numbers.

Figure IWB-2500-8 requires a volumetric examination of a minimum volume of the inner one-third thickness of the weldment. The weldment consists of the weld and the base material on each side of the weld equal to a distance of 1/4-inch on each side of the weld crown. In addition, the ultrasonic examination must meet the performance demonstration requirements in the ASME Code,Section XI, Appendix VIII. Essentially 100 percent of the required volume of each weld must be inspected. Code Case N-460, Alternative Examination Coveragefor Class 1 and Class 2 Welds (i.e., Reference 5), is applicable when the entire examination volume or area cannot be examined due to interference by another component or part geometry. Under such circumstances, a reduction in examination coverage on any Class 1 or Class 2 weld may be accepted provided that the reduction in coverage for that weld is less than 10 percent.

In October 2007, the NRC issued Regulatory Guide 1.147, Revision 15, Inservice Inspection Code Case Acceptability,ASME Section XI, Division I (i.e., Reference 6). In Regulatory Guide 1.147, the NRC identifies the ASME Code Cases they have determined to be acceptable alternatives to applicable sections of Section XI, and that those Code Cases may be used by licensees without requesting NRC authorization provided they are used with any identified limitations or modifications. Table 1 of Regulatory Guide 1.147 lists the following Code Case as acceptable for use by a licensee with no identified limitations or modifications:

Code Case N-460, Alternative Examination Coveragefor Class ] and Class 2 Welds,Section XI, Division]

Code Case N-460 (i.e., Reference 5) states, in part:

When the entire examination volume or area cannot be examined due to interference by another component or part geometry, a reduction in examination coverage on any Class I or Class 2 weld may be accepted provided the reduction in coverage for that weld is less than 10 percent.

BSEP 10-0043 Enclosure 2 Page 3 of 10 NRC Information Notice 98-42 (i.e., Reference 7) states that the NRC determined that a reduction in coverage of less than 10 percent to be "essentially 100 percent." Information Notice 98-42 states, in part:

The NRC has adopted and further refined the definition of 'essentially 100 percent' to mean 'greater than 90 percent' in 10 CFR 50.55a(g)(6)(ii)(A)(2) for required examination coverage of reactor pressure vessel welds. This standard has been applied to all examinations of welds and other areas required by ASME Section XI.

4. Impracticality of Compliance The BSEP, Unit 2 systems and components were designed and fabricated before the examination requirements of the ASME Code,Section XI, were formalized and published.

Therefore, the BSEP was not specifically designed to meet the requirements of the ASME Code,Section XI, and full compliance is not feasible or practical within the limits of the current plant design.

10 CFR 50.55a recognizes the limitations to inservice inspection of components in accordance with Section XI of the ASME Code that are imposed due to early plants' design and construction, as follows:

10 CFR 50.55a(g)(1):

For a boiling or pressurized water-cooled nuclear power facility whose construction permit was issued before January 1, 1971, components (including supports) must meet the requirements of paragraphs (g)(4) and (g)(5) of this section to the extent practical.

10 CFR 50.55a(g)(4):

Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components (including supports) which are classified as ASME Code Class 1, Class 2 and Class 3 must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of editions of the ASME Boiler and Pressure Vessel Code and Addenda that become effective subsequent to editions specified in paragraphs (g)(2) and (g)(3) of this section and that are incorporated by reference in paragraph (b) of this section, to the extent practical within the limitations of design, geometry and materials of construction of the components.

10 CFR 50.55a(g)(5)(iii):

If the licensee has determined that conformance with certain code requirements is impractical for its facility, the licensee shall notify the Commission and submit, as specified in § 50.4, information to support the determinations.

BSEP 10-0043 Enclosure 2 Page 4 of 10 In accordance with 10 CFR 50.55a(g)(5)(iii), CP&L has determined that it is impractical to meet the examination coverage requirements of Code Case N-460. The ASME Code,Section XI, requires volumetric (i.e., UT) examination of the welds from two sides of the weld in order to be 100 percent complete.

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), relief is requested for the components listed in Table. 2 on the basis that the required examination coverage of "essentially 100 percent" is impractical due to physical obstructions and the limitations imposed by design, geometry, and materials of construction. No alternative examination is being proposed.

BSEP was at the end of the first period of the third 10-year inspection interval when RI-ISI was approved (i.e., ADAMS Accession Number MLO 13320632) and implemented (i.e., see the discussion in paragraph 3, page 2 of the NRC Safety Evaluation). Prior to the transition to a risk-informed inspection program, weld examinations required performance of surface examinations in accordance with Section XI of the ASME Code. Until the transition point (i.e., the end of the first period of the third inspection interval), 8 percent of the examinations required by the ASME Code,Section XI had been completed for Examination Category B-F and B-J piping welds. Beginning in the second period of the third interval, the components selected by the RI-ISI process replaced those formerly selected in accordance with the ASME Code,Section XI criteria. Since 8 percent of the examinations had been completed during the first period of the third interval, 92 percent of the RI-ISI examinations were performed during the second and third periods. Under the RI-ISI program, 61 Class 1 piping welds are required to be examined over a complete 10-year interval. Due to the mid-interval implementation of RI-ISI, 56 welds were required to be examined to complete the remainder of the interval. Of those 56 welds examined, BSEP is seeking relief on 8 welds.

Additionally, as Class I examination Category R-A components, a visual (i.e., VT-2) examination is performed on the subject components of the Reactor Coolant Pressure Boundary during system pressure tests each refueling outage. This was completed during the 2009 refueling outage (i.e., the B219R1 outage) and no evidence of leakage was identified for these components.

The sound beam modes and insonification angles used complied with the requirements of ASME Code,Section XI, Appendix VIII. Table 2 includes information on the sound beam

BSEP 10-0043 Enclosure 2 Page 5 of 10 modes and insonification angles. Coverage volumes are summarized in Table RR-48-1.

Because the examinations were completed from one side (i.e., 50 percent maximum coverage), examination coverage plots were not generated.

The ultrasonic examinations of welds in the R-A Category, that are limited, were for austenitic components. These components were examined using an ultrasonic examination procedure based on the requirements of "PDI Generic Procedure for the Ultrasonic Examination of Austenitic Pipe Welds UT-PDI-2." This procedure states, "Where dual side access is not possible, the examination shall be performed from a single side of the weld." In situations where components were limited to single side access due to configuration (i.e., as described in Table RR-48-1), BSEP has only taken credit for 50 percent of examination.

Therefore, in accordance with 10 CFR 50.5 5a(g)(5)(iii), CP&L requests relief from the requirements of the ASME Code,Section XI, Table IWB-2500-1, Category B-J, Items B9.11 and B9.31, and ASME Code Case N-578-1, Category R-A, Item R1.20. CP&L proposes to utilize the completed exams as acceptable alternatives that provide reasonable assurance of continued structural integrity CP&L has performed qualified examinations that achieved the maximum, practical amount of coverage obtainable within the limitations imposed by the design of the components. All other ASME Code Class 1 piping examinations in the RI-ISI Program have been completed in accordance with ASME Code volumetric requirements.

Basis for Use The CP&L Nondestructive Examination (NDE) procedures incorporate inspection techniques qualified under Appendix VIII of the ASME Code,Section XI, by the Performance Demonstration Initiative (PDI) for examination of the subject welds. For welds listed in Table 2, an ultrasonic examination was performed with examination personnel and examination procedures qualified to ASME Code, Appendix VIII, as administered by the EPRI PDI.

Additionally, as Class I examination category B-P components, VT-2 examinations were performed on the subject components in association with the Reactor Coolant Pressure Boundary system pressure test performed during the 2009 refueling outage. No evidence of leakage was identified during this system test.

The provisions described above as an alternative to the Code requirement will continue to provide reasonable assurance of the structural integrity of the subject welds. Therefore, in accordance with 10 CFR 50.55a(g)(5)(iii), CP&L requests relief from the ASME Code,Section XI, examination requirements for the subject welds..

BSEP 10-0043 Enclosure 2 Page 6 of 10

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

7. References

1. Letter from David C. Dicello (CP&L) to the U.S. Nuclear Regulatory Commission Document Control Desk, Third 10-Year Inservice Inspection Program- Requestfor Approval of Risk-Informed Inservice Inspection Program,April 20, 2001, ADAMS Accession Number ML011170157.

2. Electric Power Research Institute (EPRI) Topical Report (TR) 112657, Revision B-A, Revised Risk-Informed Inservice Inspection EvaluationProcedure, and using ASME Code Case N-578, Risk-Informed Requirementsfor Class 1, 2, and 3 Piping,Method B.

3. Letter from Richard P. Correia (NRC) to J. S. Keenan (CP&L), Safety Evaluationfor the Risk-Informed Inservice Inspection (RI-ISI) Program (TAC Nos. MB] 760 and MB] 761),

November 28, 2001, ADAMS Accession Number ML013320632.

4. NRC Regulatory Guide 1.193, ASME Code Cases Not Approvedfor Use, Revision 2, October 2007.

5. Code Case N-460, Alternative Examination Coveragefor Class ] and Class 2 Welds,Section XI, Division 1.

6. NRC Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability,ASME Section XI, Division 1, Revision 15, October 2007.

7. NRC Information Notice 98-42, Implementation of 10 CFR 50.55a(g) Inservice Inspection Requirements, December 1, 1998.

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BSEP 10-0043 Enclosure 2 Page 7 of 10 TABLE RR-48-1 ASME ASME Code Case Ultrasonic IWB-2500 N-578-1 Technique Exam Exam Category S=Shear Wave Category and and L=Longitudinal Weld Item No. Item No. Description Coverage Wave Limitation 2B32RECIRC-28-B-8 N/A R-A Elbow - Valve 50% 45S, 60S,60L Access limited to elbow side of weld only R1.20 due to valve to elbow weld configuration Per PDI, the amount of coverage allowed for one sided examinations is 50%

2B32RECIRC-28-B-9BC N/A R-A branch connection 50% 35S, 45S, 60L Access limited to pipe side of weld only R1.20 (weld-o-let) due to Branch Connection weld configuration Per PDI, the amount of coverage allowed for one sided examinations is 50%

2B32RECIRC-28-A-9 N/A R-A Valve - Pipe 50% 45S, 60L Access limited to pipe side of weld only R1.20 due to pipe to valve weld configuration Per PDI, the amount of coverage allowed for one sided examinations is 50%

2B32RECIRC-28-A-9BC-1 N/A R-A branch connection 50% 35S, 45S, 60L Access limited to pipe side of weld only R1.20 (weld-o-let) due to Branch Connection weld configuration Per PDI, the amount of coverage allowed for one sided examinations is 50%

2EI1l0-9-10-SWA N/A R-A branch connection 42.25% 45S, 60L Access limited to pipe side of weld only R1.20 (weld-o-let) due to Branch Connection weld configuration and surface contour 2G31AYI-1-FWRIOA N/A R-A branch connection 50% 45S, 70S Access limited to pipe side of weld only R1.20 (weld-o-let) due to Branch Connection weld configuration Per PDI, the amount of coverage allowed for one sided examinations is 50%

BSEP 10-0043 Enclosure 2 Page 8 of 10 TABLE RR-48-1 ASME ASME Code Case Ultrasonic IWB-2500 N-578-1 Technique Exam Exam Category S=Shear Wave Category and and L=Longitudinal Weld Item No. Item No. Description Coverage Wave Limitation 2B32FF-12-FWRRA1OA N/A R-A branch connection 50% 45S, 60L Access limited to pipeside of weld only R1.20 (sweep-o-let) due to Branch Connection weld configuration Per PDI, the amount of coverage allowed for one sided examinations is 50%

2B32FF-12-FWRRB13A N/A R-A branch connection 50% 45S,.60S Access limited to pipe side of weld only R1.20 (sweep-o-let) due to Branch Connection weld I _configuration

BSEP 10-0043 Enclosure 2 Page 9 of 10 Weld 2B32RECIRC-28-B-8 This is a stainless steel elbow-to-valve weld. Due to configuration this is a one-sided examination. The risk category for this weld is 4(2) and the BWRVIP-75-A, IGSCC Category is C. This weld was examined after implementation of risk-informed ISI.

An ultrasonic examination was performed with examination personnel and examination procedures qualified to ASME Code, Appendix VIII, as administered by the EPRI Performance Demonstration Initiative (PDI), achieving limited coverage. Per PDI, the amount of Code-required volume allowed for one sided examinations is 50%.

Weld 2B32RECIRC-28-B-9BC This is a stainless steel-to-stainless steel branch connection (weld-o-let) weld. Due to configuration this is a one-sided examination. The risk category for this weld is 4(2) and the BWRVIP-75-A, IGSCC Category is D. As part of the BWRVIP-75-A, IGSCC Category D, this weld was examined twice during the third inspection interval.