Text

Response to Request for Additional Information - Proposed Alternatives for the Third 10-Year Inservice Inspection Program
	ML110400192
Person / Time
Site:	Brunswick
Issue date:	01/28/2011
From:	Mentel P; Progress Energy Carolinas
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BSEP 11-0011, TAC ME4343, TAC ME4344, TAC ME4345, TAC ME4346
	Download: ML110400192 (11)
	v • d • e

Progress Energy JAN 2'8 2011 SERIAL: BSEP 11-0011 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 Response to Request for Additional Information - Proposed Alternatives for the Third 10-Year Inservice Inspection Program (NRC TAC Nos. ME4343, ME4344, ME4345, and ME4346)

Reference:

Letter from Phyllis N. Mentel to the U.S. Nuclear Regulatory Commission, ProposedAlternativesfor the Third 10-Year Inservice Inspection Program, dated July 23, 2010, ADAMS Accession Number ML102150345.

Ladies and Gentlemen:

By letter dated July 23, 2010, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., submitted four 10 CFR 50.55a requests for the Brunswick Steam Electric Plant, UniftNo. 2. On December 9, 2010, via electronic mail, the NRC staff provided a request for additional information (RAI) concerning the proposed inservice inspection program alternatives. The response to the RAI is provided in .

No regulatory commitments are contained in this letter. Please refer any questions regarding this submittal to Mr. Lee Grzeck, Acting Supervisor - Licensing/Regulatory Programs, at (910) 457-2487.

Sincerely, Phyllis N. Mentel Manager - Support Services Brunswick Steam Electric Plant Progress Energy Carolinas, Inc.

Brunswick Nuclear Plant PO Box 10429 Southport, NC28461

Document Control Desk BSEP 11-0011 / Page 2 WRM/wrm

Enclosures:

1. Response to Request for Additional Information

2. Revised Table RR-47-1 cc (with enclosures):

U. S. Nuclear Regulatory Commission, Region II ATTN: Mr. Victor M. McCree, 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. W. Lee Cox, III, Section Chief Radiation Protection Section North Carolina Department of Environment and Natural Resources 1645 Mail Service Center Raleigh, NC 27699-1645 Mr. Jack M. Given, Jr., Bureau Chief North Carolina Department of Labor Boiler Safety Bureau 1101 Mail Service Center Raleigh, NC 27699-1101

BSEP 11-0011 Enclosure 1 Page 1 of 5 Response to Request for Additional Information

Background

By letter dated July 23, 2010, Carolina Power & Light Company (CP&L), now doing business as Progress Energy Carolinas, Inc., submitted four 10 CFR 50.55a requests for the Brunswick Steam Electric Plant, Unit No. 2. On December 9, 2010, via electronic mail, the NRC staff provided a request for additional information (RAI) concerning the proposed inservice inspection program alternatives. The response to this RAI follows.

NRC Question 1 RR-47

1. 10 CFR 50.55a(g)(6)(ii)(C)(1), "Implementation of Appendix VIII to Section XI," states that, "Appendix VIII and the supplements to Appendix VIII to Section XI, Division 1, 1995 Edition with the 1996 Addenda of the ASME Boiler and Pressure Vessel Code must be implemented in accordance with the following schedule: Appendix VIII and Supplements 1, 2, 3, and 8 - May 22, 2000; Supplements 4 and 6 - November 22, 2000; Supplement 11 - November 22, 2001; and Supplements 5, 7, and 10 - November 22, 2002."

10 CFR 50.55a(g)(6)(ii)(C)(2) states that, "[l]icensees implementing the 1989 Edition and earlier editions and addenda of IWA-2232 [(stating that ultrasonic examinations shall be conducted in accordance with Appendix I, 'Ultrasonic Examinations,' to Section XI of the ASME Code)] of Section XI, Division 1, of the ASME [Code] must implement the 1995 Edition with 1996 Addenda of Appendix VIII and the supplements to Appendix VIII of Section XI, Division 1, of the ASME [Code]."

Table RR-47-1 in Relief Request RR-47 includes a remark in the line entries for each of the subject nozzle-to-reactor vessel (RV) welds stating that the "[e]xamination [was]

performed prior to implementation of [ASME Code,Section XI,] Appendix VIII, Supplements 4 and 6."

a. Please clarify whether this statement applies specifically to the limited-scope ultrasonic exams (e.g., those exams where examination coverage was limited to 51.7%, 50.1%, and 44.5%) of the subject nozzle-to-RV welds discussed in Request RR-47.

b. Taking into consideration the 10 CFR 50.55a(g)(6)(ii)(C)(1)-(2) requirements quoted above, please provide additional information concerning the ASME Code,Section XI, Appendix VIII performance demonstration requirements to which ultrasonic examination personnel, procedures, and equipment were qualified for performing these limited scope nozzle-to-RV weld examinations, as follows:

BSEP 11-0011 Enclosure 1 Page 2 of 5 (i) State whether the qualification of ultrasonic examination personnel, procedures, and equipment was performed in accordance with ASME Code,Section XI, Appendix VIII, Articles VIII-1000 through VIII-5000, including all ASME Code,Section XI, Appendix VIII supplements that are applicable to the performance of ultrasonic examinations on nozzle-to-RV welds.

(ii) If ultrasonic examination personnel, procedures, and equipment were not qualified in accordance with the requirements listed in (i) above, please state the ASME Code,Section XI requirements to which the ultrasonic examination personnel, procedures, and equipment were qualified when performing the limited scope examinations of the subject welds. Please provide justification for the use of these qualification standards based on the requirements of 10 CFR 50.55a(b)(2)(xiv)-(xvi) and 10 CFR 50.55a(g)(6)(ii)(C)(1)-(2).

2. Please provide data for the examination coverage achieved for the Examination Category B-D, Item No. B3. 100 RV Nozzle Inside Radius Sections. Please discuss the results of these examinations, including whether any relevant flaws were found that required screening using the ASME Code,Section XI, IWB-3500 acceptance standards.

Response to Part L.a The remarks contained in Table RR-47-1 have been revised to clarify when the component weld inspections were performed and the requirements applicable to those inspections.

Beginning November 22, 2000, 10 CFR 50.55a(g)(6)(ii)(C) required that personnel performing reactor pressure vessel (RPV) weld examinations meet the qualification requirements of Supplements 4 and 6 to Appendix VIII to Section XI, 1995 Edition with the 1996 Addenda of the ASME Boiler and Pressure Vessel Code. Supplement 4 applies to qualifications for RPV clad-to-base metal examinations within the inner 15 percent of the RPV thickness and Supplement 6 applies to qualifications for RPV clad-to-base metal examinations in the outer 85 percent of the RPV thickness. Supplements 4 and 6 provide examination requirements for the RPV horizontal and vertical welds and are not applicable to nozzle-to-shell welds.

Starting November 22, 2002, 10 CFR 50.55a(g)(6)(ii)(C) required that personnel performing RPV nozzle-to-shell weld examinations meet the qualification requirements of Supplement 7 to Appendix VIII to Section XI, 1995 Edition with the 1996 Addenda of the ASME Boiler and Pressure Vessel Code. To satisfy the Supplement 7 requirements, licensees can follow the requirements of 10 CFR 50.55a(b)(2)(K), which addresses provisions which must be used when the requirements contained in Supplement 7 to Appendix VIII are applied for nozzle-to-vessel welds in conjunction with Supplement 4 to Appendix VIII, with Supplement 6 to Appendix VIII, or combined Supplement 4 and Supplement 6 qualifications.

The nozzle-to-shell welds identified in Table RR-47-1 were examined in February 2001 and May 1999, which was prior to the required implementation date for Supplement 7 to

BSEP 11-0011 Enclosure 1 Page 3 of 5 Appendix VIII. Furthermore, all but three of the nozzle-to-shell weld examinations were conducted before any Appendix VIII requirements became applicable.

The Table RR-47-1 remark regarding Appendix VIII, Supplements 4 and 6 was intended to indicate that the RPV nozzle-to-shell welds were examined prior to using the Supplement 4 and Supplement 6 requirements as modified by 10 CFR 50.55a(b)(2)(K). To clarify the requirements applicable to these examinations, the Table RR-47-1 remarks column has been revised to include the month and year that each listed weld was examined, and to indicate these examinations were performed prior to implementation of the Appendix VIII requirements applicable to the nozzle-to-shell welds. A revised Table RR-47-1 is provided in Enclosure 2.

Response to Part 1.b Those examinations listed in Table RR-47-1 were performed in accordance with the 1989 Edition of the ASME Boiler and Pressure Vessel Code. These examinations were performed prior to the November 22, 2002, implementation date for Supplement 7 of Appendix VIII to Section XI, 1995 Edition with the 1996 Addenda of the ASME Boiler and Pressure Vessel Code.

Response to Part 2 Because there were no limited examinations (i.e., no coverage issues) for the Examination Category B-D, Item No. B3.100 RPV nozzle inner radius sections (i.e., essentially 100 percent coverage was achieved), detailed examination data is not being provided. No relevant flaws were detected in any Category D, Item No. B3.100 RPV nozzle inner radius sections.

NRC Question 2 RR-49 Request RR-49 states that the limited-scope ultrasonic examination achieved 64% of the ASME Code, Section XI-required volumetric coverage of the RV shell-to-flange weld (Welds 2B 11 -RPV-F 1 and 2B 11 -RPV-F2) and were performed in calendar year 2000, using the industry-accepted technology that was available. RR-49 also states that "[t]hese weld examinations were completed prior to the implementation of inspection techniques qualified under Appendix VIII of the ASME Code,Section XI, administered by the EPRI PDI."

If ultrasonic examination personnel, procedures, and equipment were not qualified in accordance with the requirements of Appendix VIII of the ASME Code,Section XI, including the Appendix VIII Supplements applicable to the performance of the exams of the RV shell-to-flange weld, then please state the ASME Code,Section XI requirements to which ultrasonic examination personnel, procedures, and equipment were qualified when performing the limited scope examination of the subject component. Please provide justification for the use of these qualification standards based on the requirements of 10 CFR 50.55a(b)(2)(xiv)-(xvi), and 10 CFR 50.55a(g)(6)(ii)(C)(l)-(2).

BSEP 11-0011 Enclosure 1 Page 4 of 5

Response

The Unit 2 RPV shell-to-flange weld examinations were performed in calendar year 2001, rather than calendar year 2000, as stated in the July 23, 2010, submittal.

10 CFR 50.55a(g)(6)(ii)(C)(1) stipulates that Supplements 1, 2, 3, 4, 5, 6, 7, 8, 10, and 11 of Appendix VIII of the ASME Boiler and Pressure Vessel Code be implemented in accordance with the schedules specified. None of the Supplements of Appendix VIII identified in 10 CFR 50.55a(g)(6)(ii)(C)(1) applied to the RPV shell-to-flange weld examinations; therefore, neither 10 CFR 50.55a(g)(6)(ii)(C)(l) nor 10 CFR 50.55a(g)(6)(ii)(C)(2) were applicable to the examination of RPV shell-to-flange weld 2B 11 -RPV-F 1 and 2B 11 -RPV-F2 and the welds were instead examined in accordance with the code of record for the third ISI interval (i.e., the ASME Code,Section XI, 1989 Edition with no Addenda).

NRC Question 3 RR-50

1. Request RR-50 states that the limited-scope ultrasonic examination achieved 47.9% of the ASME Code, Section XI-required coverage for the subject Residual Heat Removal System (RHR) heat exchanger nozzle-to-shell weld (Weld 2El 1HX-2A-SWN4).

Table RR-50-1 includes a statement under the "Examination Results" column stating that there were "[n]o service induced indications." The staff requests further detail concerning the results of the limited-scope examination of this weld.

(a) Please state whether any recordable indications were found as a result of the limited scope volumetric examination or the full-scope (100%) surface examination. The staff defines recordable indications as any indications not due to component design or geometry requiring screening under ASME Code,Section XI, IWC-3500 acceptance standards (regardless of whether the indications are fabrication-related or service-induced).

(b) If any recordable indications were found in the subject weld as a result of the limited-scope volumetric examination or the full-scope surface examination, please state whether any of these flaws were found to be unacceptable for continued service (without repair or analytical evaluation) in accordance with ASME Code,Section XI, IWC-3500 acceptance standards. For any such unacceptable flaws, please discuss the disposition of such flaws including repairs made under ASME Code,Section XI, IWC-4000 and/or analytical evaluations performed under ASME Code,Section XI, IWC-3600. If any flaws in the subject weld were evaluated under ASME Code,Section XI, IWC-3600, please provide references for any flaw evaluation reports documenting analytical evaluations for acceptance of such flaws.

2. Please state whether the limited scope ultrasonic examination of the subject weld was conducted using personnel, procedures, and equipment that were qualified in accordance

BSEP 11-0011 Enclosure 1 Page 5 of 5 with the requirements of Appendix VIII of the ASME Code,Section XI, including the Appendix VIII Supplements applicable to the performance of examinations of the subject RI-R nozzle-to-shell weld. If the ASME Code,Section XI, Appendix VIII qualification requirements were not met for this examination, then please state the ASME Code,Section XI requirements to which ultrasonic examination personnel, procedures, and equipment were qualified when performing the limited scope examination of the subject weld. Please provide justification for the use of these qualification standards based on the requirements of 10 CFR 50.55a(b)(2)(xiv)-(xvi), and 10 CFR 50.55a(g)(6)(ii)(C)(1)-(2).

Response to Part L.a Fabrication indications have been detected in Residual Heat Removal System (RHR) heat exchanger nozzle-to-shell weld 2El1HX-2A-SWN4. The indications have been determined to be slag inclusions. They have been evaluated and found acceptable based on the acceptance standards of ASME Code,Section XI, IWC-3500. Since the initial detection of these flaws during pre-service examinations, no growth or change in flaw characteristics has been detected.

Response to Part L.b The fabrication flaws referenced in the response to Part L.a above were evaluated and found to be acceptable based on the ASME Code,Section XI, IWC-3500 acceptance standards.

Analytical evaluations performed under ASME Code,Section XI, IWC-3600 were not required.

Response to Part 2 Weld 2El HX-2A-SWN4 is a Code Class 2, Examination Category C-B component and is outside the scope of Appendix VIII of the ASME Boiler and Pressure Vessel Code.

Examinations of weld 2E1 1HX-2A-SWN4 were performed to the requirements of ASME Code,Section XI, 1989 Edition with no Addenda, which was the code of record for the third ISI interval.

BSEP 11-0011 Enclosure 2 Page 1 of 4 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 2BI 1-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 February 2001.