ML082630875
| ML082630875 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 09/29/2008 |
| From: | Boyce T Plant Licensing Branch II |
| To: | Waldrep B Carolina Power & Light Co |
| Saba F | |
| References | |
| TAC MD8114, TAC MD8115 | |
| Download: ML082630875 (7) | |
Text
September 29, 2008 Mr. Benjamin Waldrep, Vice President Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - RELIEF REQUEST ISI-01, REQUESTING TO USE ASME CODE CASE N-686-1 (TAC NOS. MD8114, MD8115)
Dear Mr. Waldrep:
By letter dated February 6, 2008, as supplemented by letter dated June 10, 2008, Carolina Power & Light Company (the licensee), submitted Relief Request (RR) ISI-01 requesting to use the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code) Case N-686-1 Alternative Requirements for Visual Examinations, VT-1, VT-2, and VT-3 at Brunswick Steam Electric Plant (BSEP), Units 1 and 2.
The Nuclear Regulatory Commission (NRC) staff has evaluated the submitted RR ISI-01 and concludes that the proposed alternative to use ASME Code Case N-686-1, in lieu of ASME Code,Section XI, paragraphs IWA-2210 through IWA-2216 will provide an acceptable level of safety and quality. Therefore, pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(i), the NRC authorizes the proposed alternative for the fourth 10-year inservice inspection interval for BSEP, Units 1 and 2.
The bases for the NRC staffs conclusion are contained in the enclosed Safety Evaluation. If you have any questions regarding this issue, please contact Farideh Saba at (301) 415-1447 or farideh.saba@nrc.gov.
Sincerely,
/RA/
Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324
Enclosure:
Safety Evaluation cc w/encl: See next page
September 29, 2008 Mr. Benjamin Waldrep, Vice President Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461
SUBJECT:
BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 - RELIEF REQUEST ISI-01, REQUESTING TO USE ASME CODE CASE N-686-1 (TAC NOS. MD8114, MD8115)
Dear Mr. Waldrep:
By letter dated February 6, 2008, as supplemented by letter dated June 10, 2008, Carolina Power & Light Company (the licensee), submitted Relief Request (RR) ISI-01 requesting to use the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code) Case N-686-1 Alternative Requirements for Visual Examinations, VT-1, VT-2, and VT-3 at Brunswick Steam Electric Plant (BSEP), Units 1 and 2.
The Nuclear Regulatory Commission (NRC) staff has evaluated the submitted RR ISI-01 and concludes that the proposed alternative to use ASME Code Case N-686-1, in lieu of ASME Code,Section XI, paragraphs IWA-2210 through IWA-2216 will provide an acceptable level of safety and quality. Therefore, pursuant to Title 10 of the Code of Federal Regulations, Section 50.55a(a)(3)(i), the NRC authorizes the proposed alternative for the fourth 10-year inservice inspection interval for BSEP, Units 1 and 2.
The bases for the NRC staffs conclusion are contained in the enclosed Safety Evaluation. If you have any questions regarding this issue, please contact Farideh Saba at (301) 415-1447 or farideh.saba@nrc.gov.
Sincerely,
/RA/
Thomas H. Boyce, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-325 and 50-324
Enclosure:
Safety Evaluation cc w/encl: See next page Distribution:
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- By memorandum NRR-106 OFFICE LPL2-2/PM LPL2-2/LA CPNB/BC* OGC NLO LPL2-2/BC w/ comments NAME FSaba CSola TChan MZobler TBoyce DATE 07/29/08 09/22/08 08/27/08 07/29/08 09/29/08 OFFICIAL RECORD COPY
Carolina Power & Light Company Brunswick Steam Electric Plant Units 1 and 2 cc:
David T. Conley Mr. Robert P. Gruber Associate General Counsel II - Executive Director Legal Department Public Staff - NCUC Progress Energy Service Company, LLC 4326 Mail Service Center Post Office Box 1551 Raleigh, North Carolina 27699-4326 Raleigh, North Carolina 27602-1551 Director, Site Operations Mr. William M. Sue, Chairperson Brunswick Steam Electric Plant Brunswick County Board of Commissioners Carolina Power & Light Company Post Office Box 249 Post Office Box 10429 Bolivia, North Carolina 28422 Southport, North Carolina 28461-0429 Resident Inspector Sandra Spencer, Mayor U. S. Nuclear Regulatory Commission City of Southport 8470 River Road 201 East Moore Street Southport, North Carolina 28461 Southport, North Carolina 28461 Mr. John H. ONeill, Jr. Mr. Warren Lee Pillsbury Winthrop Shaw Pittman, LLP Emergency Management Director 2300 N Street NW. New Hanover County Department of Washington, DC 20037-1128 Emergency Management Post Office Box 1525 Ms. Beverly Hall, Section Chief Wilmington, North Carolina 28402-1525 Division of Radiation Protection N.C. Department of Environment Mr. J. Paul Fulford and Natural Resources Manager, Performance Evaluation and 3825 Barrett Dr. Regulatory Affairs PEB5 Raleigh, North Carolina 27609-7721 Carolina Power & Light Company Post Office Box 1551 Mr. Edward L. Wills, Jr. Raleigh, North Carolina 27602-1551 Plant General Manager Brunswick Steam Electric Plant Robert J. Duncan II Carolina Power & Light Company Vice President, Nuclear Operations Post Office Box 10429 Progress Energy Southport, North Carolina 28461-0429 Post Office Box 1551 Raleigh, North Carolina 27602-1551 Public Service Commission State of South Carolina Brian C. McCabe Post Office Drawer 11649 Manager, Nuclear Regulatory Affairs Columbia, South Carolina 29211 Progress Energy Post Office Box 1551 Ms. Margaret A. Force Raleigh, North Carolina 27602-1551 Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOURTH 10-YEAR INTERVAL INSERVICE EXAMINATION PROGRAM FOR SNUBBERS RELIEF REQUEST ISI-03 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 DOCKET NUMBERS 50-325 AND 50-324
1.0 INTRODUCTION
By letter dated February 6, 2008, as supplemented by letter dated June 10, 2008, Carolina Power & Light Company (the licensee), submitted to the Nuclear Regulatory Commission (NRC)
Relief Request (RR) ISI-01 invoking paragraph 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations (10 CFR). This RR requests use of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Case N-686-1 Alternative Requirements for Visual Examinations, VT-1, VT-2, and VT-3 for Brunswick Steam Electric Plant (BSEP), Units 1 and 2.
ASME Code Case N-686 was approved by the ASME on February 14, 2003, and in October 2007, the NRC listed this code case in Revision 15 of Regulatory Guide (RG) 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, as acceptable for use. The regulatory need for this RR is that ASME Code Case N-686 cannot be used by the licensee, because the applicability of the Code Case N-686, as approved by the ASME, does not include the 2001 Edition with 2003 Addenda of ASME Section XI, which is the ASME Code of Record for the fourth 10-year inservice inspection (ISI) interval at BSEP, Units 1 and 2. A revision to Code Case N-686 (N-686-1) to extend the applicability of Code Case N-686-1 through the 2004 Edition of ASME Section XI was approved by ASME on January 10, 2007.
2.0 REGULATORY EVALUATION
The ISI of the ASME Code Class 1, 2 and 3 components must meet the requirements of the Section XI of editions of the ASME Addenda as required by 10 CFR 50.55a(g).
10 CFR 50.55a(g)(4) states that throughout the service life of a boiling or pressurized water cooled nuclear power facility, components classified as ASME Code Class 1, 2 and 3 including supports must meet the requirements, except design and access provisions and preservice examination requirements, specified in Section XI of editions of the ASME Code and Addenda Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry and materials of construction of the components.
Pursuant 10 CFR 50.55a(g)(4)(ii), inservice examination of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements in the latest edition and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b), 12 months before the start of the 120-month inspection interval, subject to Enclosure
the limitations and modifications listed therein. In accordance with this requirement, the Section XI ASME Code of Record for the fourth ISI interval at BSEP, Units 1 and 2, which began on May 11, 2008, is the 2001 Edition with the 2003 Addenda. Pursuant to 10 CFR 50.55a(g)(6)(i), a licensee may obtain relief from these ISI requirements when written relief is granted by the NRC. Pursuant to 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
3.0 LICENSEES EVALUATION 3.1 Components For Which Relief is Requested All ASME Code Class 1, 2, and 3 components requiring visual examinations under the requirements of paragraphs IWA-2210 through IWA-2216.
3.2 Code Requirements From Which Relief is Requested ASME Code Section XI, 2001 Edition, 2003 Addenda, paragraphs IWA-2210 through IWA-2216.
3.3 Licensees Basis for the Request Code Case N-686 was approved as an alternative to the visual inspection requirements of paragraphs IWA 2210 through IWA-2213 by the ASME on February 14, 2003. In October 2007, ASME Code Case N-686 was approved for use by the NRC and listed in Revision 15 of RG 1.147 as acceptable for implementation. However, ASME Code Case N-686 cannot be used at BSEP because its ASME Code of Applicability does not include the 2001 ASME Section XI Edition with 2003 Addenda. Therefore, the licensee requests NRC approval to use ASME Code N-686-1, which was approved by ASME on January 10, 2007, for the fourth 10-year inservice inspection.
The licensee, in its June 10, 2008 letter, stated that, with the exception of administrative changes, the technical requirements associated with ASME Code Case N-686-1 are the same as those specified in the original ASME Code Case N-686. Therefore, the licensee determined that the proposed alternative requirements of ASME Code Case N 686-1 provide an acceptable level of quality and safety as there is no significant difference in the requirements between those stated in ASME Code Case N-686 and its first revision, N-686-1. Therefore, the licensee concluded that the implementation of the alternative requirements of N-686-1 will provide an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i).
3.4 Duration of Requested Relief RR ISI-01 is proposed for the fourth 10-year ISI interval, which began on May 11, 2008, and will conclude on May 10, 2018.
4.0 NRC STAFF EVALUATION OF RR ISI-01 The licensee is requesting relief from ASME Code Section XI, 2001 Edition, 2003 Addenda, paragraphs IWA-2210 through IWA-2216 to use ASME Code Case N-686-1 for the fourth 10-year inservice inspection at BSEP 1 and 2. The previously NRC approved Code Case N-686 cannot be used because N-686 applicability does not include the 2001 Edition with the 2003 Addenda of the ASME code.
ASME Code Case N-686 was approved by the ASME on February 14, 2003 and provides an ASME-approved alternative to the existing ASME Code requirements of paragraphs IWA-2210 through IWA-2213. In October 2007, Code Case N-686 was accepted for implementation by the NRC as stated in Revision 15 of RG 1.147.
The licensee has requested to use ASME Code Case N-686-1, which was approved for use by ASME on January 10, 2007. ASME Code Case N-686-1, similar to N-686, provides an ASME-approved alternative to the visual inspection requirements of paragraphs IWA-2210 through IWA-2213. However, the licensee requests the alternative to cover IWA-2210 through IWA-2216. In the 2001 Edition with 2003 Addenda of the ASME Code there is no paragraph IWA-2214 and paragraph IWA-2216 was deleted. Paragraph IWA-2215 allows surface replication methods to be used, and no additional requirements are imposed. Therefore the NRC staff (the staff) finds that the applicability of N-686-1 would be the same as an alternative to paragraphs IWA-2210 through IWA-2213 as to paragraphs IWA-2210 through IWA-2216 of the 2001 Edition with the 2003 Addenda of the ASME Code,Section XI.
The staff compared ASME Code Case N-686-1 to N-686 and found only two minor differences.
Code Case N-686-1 requires use of the 2001 Edition of Section V, Article 9, Paragraphs T-941 and T-990 for written procedures and reporting of examination results, respectively. The requirements of Paragraphs T-941 and T-990 were removed from Section V of the ASME Code.
The revised Code Case simply corrects a citing disconnect between Sections V and XI of the ASME Code. The revision uses the code language of a version of Section V that was previously approved for use with the original NRC-approved Code Case N-686. With this change, the ASME approved Code Case N-686-1 with a Code of Applicability extended through to the 2004 Edition. The staff finds that the use of the 2001 Edition of Paragraphs T-941 and T-990 of Section V, Article 9, for a plant, under the ISI requirements of the 2001 Edition with the 2003 Addenda, would be the same as the previously NRC-approved implementation of ASME Code Case N-686.
The only other change noted by the staff was the inclusion of the metric conversion for illumination minimum requirement in Table 1. As the requirement does not change, the staff finds the minimum illumination requirements are the same from Code Case N-686 to N-686-1.
As the NRC had previously approved ASME Code Case N-686 for use as an alternative to the requirements of paragraphs IWA-2210 through IWA -2213, and the staff finds no technical difference between the implementation of ASME Code Case N-686 and N-686-1, therefore, the licensees proposed alternative to use ASME Code Case N-686-1 for the fourth ISI interval at BSEP, Units 1 and 2, provides an acceptable level of quality and safety. In accordance with 10 CFR 50.55a(a)(3)(i), the NRC authorizes the licensee to use ASME Code Case N-686-1,
instead of the requirements of the ASME Code,Section XI, paragraphs IWA-2210 through IWA-2216.
4.0 CONCLUSION
The staff has reviewed the licensees submittal and determined that the proposed alternative to use ASME Code Case N-686-1, in lieu of ASME Code,Section XI, paragraphs IWA-2210 through IWA-2216 will provide an acceptable level of safety and quality. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC authorizes the use of the licensees proposed alternative for the fourth 10-year ISI at BSEP, Units 1 and 2. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this RR remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributors: Jay Collins Date: September 29, 2008