BSEP 18-0040, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for End of Interval Leakage Test
| ML18082A037 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/23/2018 |
| From: | Wooten B Duke Energy Progress |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BSEP 18-0040 | |
| Download: ML18082A037 (12) | |
Text
(-, DUKE ENERGYe MAR 2 3 2018 Serial: BSEP 18-0040 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 Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 10 CFR 50.55a(z)(1)
Proposed Alternative In Accordance With 10 CFR 50.55a(z)(1) for End of Interval Leakage Test Ladies and Gentlemen:
In accordance with 1 O CFR 50.55a(z)(1 ), Duke Energy Progress, LLC (Duke Energy), hereby requests approval of an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, 2001 Edition through 2003 Addenda for the Brunswick Steam Electric Plant (BSEP), Unit No. 2.
The ASME Code,Section XI, paragraph IWB-5222(b), requires that the pressure retaining boundary system leakage test, conducted at or near the end of each inspection interval, be extended to all Class 1 pressure retaining components within the system boundary. The enclosed relief request is to allow the required Unit 2, fourth 10-year, end of interval leakage testing on portions of the Core Spray, High Pressure Coolant Injection, and Standby Liquid Control Systems to be completed no later than the end of refueling outage B2R24 (i.e., currently scheduled for March 2019). Approval of the proposed alternative is requested prior to the end of the fourth 10-year ISi interval, which is currently scheduled to end on May 10, 2018.
Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.
Sincerely, 157 _ c.1/~
Bryan B. Wooten Director - Organizational Effectiveness Brunswick Steam Electric Plant MAT/mat
Enclosure:
10 CFR 50.55a Request Number ISl-11
U.S. Nuclear Regulatory Commission Page 2 of 2 cc (with enclosure):
U.S. Nuclear Regulatory Commission, Region II ATTN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. Cliff Dautrich, Bureau Chief North Carolina Department of Labor Boiler Safety Bureau 1101 Mail Service Center Raleigh, NC 27699-1101
BSEP 18-0040 Enclosure Page 1 of 10 10 CFR 50.55a Request Number ISI-11 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)
Unit 2 End of Fourth Interval Leakage Test
- 1.
ASME Code Components Affected Unit(s) Affected:
Brunswick Steam Electric Plant (BSEP), Unit 2 Code Class:
ASME Code,Section XI, Class 1
References:
Subarticle IWB-5222(b)
Examination Categories:
B-P Item Number:
15.10, Pressure Retaining Components Component Numbers:
Piping between 2-E21-F006A and 2-E21-F005A Piping between 2-E21-F006B and 2-E21-F005B Piping between 2-E41-V159 and 2-E41-F006 Piping between 2-C41-F007 and 2-C41-F006
==
Description:==
Pressure Testing
- 2.
Applicable Code Edition The Inservice Inspection Program for the fourth 10-year inservice inspection (ISI) interval is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, 2001 Edition with 2003 Addenda. The fourth 10-year ISI interval began on May 11, 2008, and is currently scheduled to end on May 10, 2018.
- 3.
Applicable Code Requirement
The ASME Code,Section XI, paragraph IWB-5222(b) requires the pressure retaining boundary during the system leakage test extend to all Class 1 components within the system boundary.
- 4.
Reason for Request
An End of Interval Leakage Test (EOILT) is required during the fourth 10-year ISI interval to satisfy the requirement of ASME Section XI paragraph IWB-5222(b), which states:
The pressure retaining boundary during the system leakage test conducted at or near the end of each inspection interval shall extend to all Class 1 pressure retaining components within the system boundary.
During the B2R23 refueling outage in 2017 and B2R22 refueling outage in 2015, the EOILT was not performed during the Reactor Pressure Vessel (RPV) pressure test.
- 5.
Proposed Alternative and Basis for Use In accordance with 10 CFR 50.55a(z)(1), the proposed alternative is to allow the required Unit 2, fourth 10-year, EOILT to be completed no later than the end of refueling outage B2R24 (i.e.,
currently scheduled for March 2019) during the Reactor Pressure Vessel Pressure Test. This test would include the piping which meets the criteria of IWB-5222(b) which is not exempted per ASME Code Case N-798, Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Vent, Drain, and Test Isolation Devices,Section XI, Division 1, (i.e., Reference 1) and existing approved BSEP relief request RR-38 for BSEPs fourth interval (i.e., Reference 2). The portions of piping that will be included in the test are listed below.
BSEP 18-0040 Enclosure Page 2 of 10 Referenced Boundary Sketches, with valve and line information, are provided at the end of this enclosure.
Line Function First Isolation Valve Affected Line Line Size Second Isolation Valve Core Spray (CS) Injection (A Loop) 2-E21-F006A 2-E21-3-10-600 10 2-E21-F005A CS Injection (B Loop) 2-E21-F006B 2-E21-7-10-600 10 2-E21-F005B High Pressure Coolant Injection (HPCI)
Injection 2-E41-V159 2-E41-3-14-901 14 2-E41-F006 Standby Liquid Control (SLC)
Injection 2-C41-F007 2-C41-9-1 1/2-902 1.5 2-C41-F006 The EOILT will be performed in the same manner as the regular 10-year test in accordance with the approved RPV pressure test procedure. The portions of piping that meet the IWB-5222(b) criteria and are not exempted by a code case will be pressurized to the RPV test pressure range of 1030 psig to 1070 psig. The test will be conducted using temporary hose connections to bypass the injection check valves of the CS, HPCI, and SLC systems. The remainder of piping that meets the criteria of IWB-5222(b) will be exempt per NRC approved code case N-798.
The pressure test will be evaluated by qualified VT-2 examiners completing visual examinations of the test boundaries in accordance with the approved RPV pressure test procedure.
Approval of the proposed alternative is requested prior to the end of the fourth 10-year ISI interval, which is currently scheduled to end on May 10, 2018.
Basis for Use BSEP is requesting an extension of the EOILT to be performed in the Unit 2 outage in 2019 (i.e., B2R24) for fourth interval credit. The request would not alter the May 11, 2018 start date for the fifth Interval and subsequent ISI intervals. With the approval, the EOILT would be performed twice during the fifth ISI interval, once during the first outage of the fifth interval for credit to the fourth interval and once at or near the end of the fifth Interval for credit to the fifth interval.
The most recent performance of the EOILT on Unit 2 was April 8, 2007. This test included the Class 1 injection lines for CS, HPCI, and SLC systems. The additional portion of Class 1 piping (i.e., vents, drains, and test lines) included in the IWB-5222(b) criteria was bounded by Relief Request RR-38 (i.e., Reference 2) and was not tested during the 2007 test, but was visually examined.
The subject piping is not susceptible to thermal fatigue due to the piping being upstream of the first isolation valve from the reactor vessel. Additionally, there are no known degradation
BSEP 18-0040 Enclosure Page 3 of 10 mechanisms in each of the subject line systems which would cause degradation of the piping that would impact the structural integrity of the piping or piping welds.
The EOILT was last performed in 2007, however additional testing has been performed on the applicable portions of piping during each Unit 2 refueling outage since 2007. The testing of applicable portions of piping provides a reasonable level of assurance that the integrity of the piping is adequate to support performance of the EOILT during the next Unit 2 outage.
Operational and Pressure Testing The following table provides a summary of Operational, ASME Section XI, or Appendix J Local Leak Rate Testing that has been completed on the subject piping since the last performance of the EOILT in 2007.
Line Function Test Boundary Test Pressure Year Reactor Pressure Vessel and Class 1 Piping 0PT-80.1 (RPV Pressure Test)
(Code Case N-498, Reference 3)
RPV and Class 1 Piping 1033 -1052.9 psig 2007 CS Injection (A Loop) 0PT-07.1.1A (CS Injection Check Valve Operability Test)
Includes 2-E21-F006A to 2-E21-F005A 371 psig 2007 CS Injection (A Loop) 0PT-07.1.1A (CS Injection Check Valve Operability Test)
Includes 2-E21-F006A to 2-E21-F005A 369 psig 2009 CS Injection (A Loop) 0PT-07.1.1A (CS Injection Check Valve Operability Test)
Includes 2-E21-F006A to 2-E21-F005A 383 psig 2011 CS Injection (A Loop) 0PT-07.1.1A (CS Injection Check Valve Operability Test)
Includes 2-E21-F006A to 2-E21-F005A 376 psig 2013 CS Injection (A Loop) 0PT-07.1.1A (CS Injection Check Valve Operability Test)
Includes 2-E21-F006A to 2-E21-F005A 377 psig 2015 CS Injection (A Loop) 0PT-07.1.1A (CS Injection Check Valve Operability Test)
Includes 2-E21-F006A to 2-E21-F005A 355 psig 2017 CS Injection (A Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006A to 2-E21-F005A No Measured Pressure.
Leakage measured past F006A.
2007
BSEP 18-0040 Enclosure Page 4 of 10 Line Function Test Boundary Test Pressure Year CS Injection (A Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006A to 2-E21-F005A No Measured Pressure.
Leakage measured past F006A.
2009 CS Injection (A Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006A to 2-E21-F005A No Measured Pressure.
Leakage measured past F006A.
2011 CS Injection (A Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006A to 2-E21-F005A No Measured Pressure.
Leakage measured past F006A.
2013 CS Injection (A Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006A to 2-E21-F005A No Measured Pressure.
Leakage measured past F006A.
2015 CS Injection (A Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006A to 2-E21-F005A No Measured Pressure.
Leakage measured past F006A.
2017 CS Injection (B Loop) 0PT-07.1.1B (CS Injection Check Valve Operability Test)
Includes 2-E21-F006B to 2-E21-F005B 402 psig 2007 CS Injection (B Loop) 0PT-07.1.1B (CS Injection Check Valve Operability Test)
Includes 2-E21-F006B to 2-E21-F005B 391 psig 2009 CS Injection (B Loop) 0PT-07.1.1B (CS Injection Check Valve Operability Test)
Includes 2-E21-F006B to 2-E21-F005B 399 psig 2011 CS Injection (B Loop) 0PT-07.1.1B (CS Injection Check Valve Operability Test)
Includes 2-E21-F006B to 2-E21-F005B 386 psig 2013 CS Injection (B Loop) 0PT-07.1.1B (CS Injection Check Valve Operability Test)
Includes 2-E21-F006B to 2-E21-F005B 388 psig 2015
BSEP 18-0040 Enclosure Page 5 of 10 Line Function Test Boundary Test Pressure Year CS Injection (B Loop) 0PT-07.1.1B (CS Injection Check Valve Operability Test)
Includes 2-E21-F006B to 2-E21-F005B 387 psig 2017 CS Injection (B Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006B to 2-E21-F005B No Measured Pressure.
Leakage measured past F006B.
2007 CS Injection (B Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006B to 2-E21-F005B No Measured Pressure.
Leakage measured past F006B.
2009 CS Injection (B Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006B to 2-E21-F005B No Measured Pressure.
Leakage measured past F006B.
2011 CS Injection (B Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006B to 2-E21-F005B No Measured Pressure.
Leakage measured past F006B.
2013 CS Injection (B Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006B to 2-E21-F005B No Measured Pressure.
Leakage measured past F006B.
2015 CS Injection (B Loop) 0PT-20.7B (PIV LRT) in conjunction with 0PT-80.1 RPV Pressure Test Includes 2-E21-F006B to 2-E21-F005B No Measured Pressure.
Leakage measured past F006B.
2017 HPCI Injection 0PT-20.3-B21 (App. J LLRT)
Includes 2-E41-F006 to 2-E41-V159 50 psig 2007 HPCI Injection 0PT-20.3-B21 (App. J LLRT)
Includes 2-E41-F006 to 2-E41-V159 50 psig 2009 HPCI Injection 0PT-20.3-B21 (App. J LLRT)
Includes 2-E41-F006 to 2-E41-V159 50 psig 2011 HPCI Injection 0PT-20.3-B21 (App. J LLRT)
Includes 2-E41-F006 to 2-E41-V159 50 psig 2013
BSEP 18-0040 Enclosure Page 6 of 10 Line Function Test Boundary Test Pressure Year HPCI Injection 0PT-20.3-B21 (App. J LLRT)
Includes 2-E41-F006 to 2-E41-V159 50 psig 2015 HPCI Injection 0PT-20.3-B21 (App. J LLRT)
Includes 2-E41-F006 to 2-E41-V159 50 psig 2017 SLC Injection 0PT-20.14 (ASME Section XI PT)
Includes 2-C41-F006 to 2-C41-V5003 49.5 psig 2007 SLC Injection 0PT-20.14 (ASME Section XI PT)
Includes 2-C41-F006 to 2-C41-V5003 88.2 psig 2009 (Note 1)
SLC Injection 0PT-20.14 (ASME Section XI PT)
Includes 2-C41-F006 to 2-C41-V5003 90.5 psig 2009 (2nd Occurrence)
(Note 1)
SLC Injection 0PT-20.14 (ASME Section XI PT)
Includes 2-C41-F006 to 2-C41-V5003 91.5 psig 2011 (Note 1)
SLC Injection 0PT-20.14 (ASME Section XI PT)
Includes 2-C41-F006 to 2-C41-V5003 92 psig 2013 (Note 1)
SLC Injection 0PT-20.14 (ASME Section XI PT)
Includes 2-C41-F006 to 2-C41-V5003 93 psig 2015 (Note 1)
SLC Injection 0PT-20.14 (ASME Section XI PT)
Includes 2-C41-F006 to 2-C41-V5003 93.5 psig 2017 (Note 1)
Note 1 Indicates years that demineralized water was injected through the 1-C41-F007 Check Valve into the vessel however this portion of the test was not in the pressure boundary for the VT-2 Examination.
Non Destructive Examinations There have been no non-destructive examinations completed on the piping addressed in this relief request.
- 6.
Duration of the Proposed Alternative This proposed alternative is requested until the end of the refueling outage B2R24, currently scheduled for March 2019.
- 7.
References
- 1.
ASME Code Case N-798, Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Vent, Drain, and Test Isolation Devices,Section XI, Division 1
BSEP 18-0040 Enclosure Page 7 of 10
- 2.
Letter from Brenda Mozafari (NRC) to James Scarola (Carolina Power & Light Company), Request for Relief No. RR-38 Regarding Pressure Testing of Drain, Vent, Test, and Fill Lines Within the Reactor Coolant Pressure Boundary. ADAMS Accession No. ML070360418
- 3.
ASME Code Case N-498, Alternative Requirements for 10-Year System Hydrostatic Testing of Class 1, 2, and 3 Systems
BSEP 18-0040 Enclosure Page 8 of 10 0PT-80.1, Reactor Pressure Vessel ASME Section XI Pressure Test VT-2 Examination Boundary Drawing Core Spray A and B Loops Boundary
BSEP 18-0040 Enclosure Page 9 of 10 0PT-80.1, Reactor Pressure Vessel ASME Section XI Pressure Test VT-2 Examination Boundary Drawing High Pressure Coolant Injection Steam Line HPCI Injection 2-E41-F006 to 2-E41-V159
BSEP 18-0040 Enclosure Page 10 of 10 0PT-80.1, Reactor Pressure Vessel ASME Section XI Pressure Test VT-2 Examination Boundary Drawing Standby Liquid Control