ML20005E994

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Forwards Safety Evaluation Granting Relief from Certain ASME Code Section XI Requirements in Second 10-yr Interval Inservice Testing Program for Code Class 1,2 & 3 Pumps & Valves
ML20005E994
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 01/04/1990
From: Adensam E
Office of Nuclear Reactor Regulation
To: Eury L
CAROLINA POWER & LIGHT CO.
Shared Package
ML20005E995 List:
References
TAC-63523, TAC-63524, NUDOCS 9001120151
Download: ML20005E994 (4)


Text

L*.+[Ghl0%"4, UNITED STATES NUCLEAR REGULATORY COMMISSION 5'

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January 4, 1990 Docket Nos.

50-325 and 50-324 Mr. Lynn W. Eury Executive Vice President Power Supply Carolina Power & Light Company Post Office Box 1551 Raleigh, North Carolina 27602

Dear Mr. Eury:

SUBJECT:

SECOND TEN-YEAR INTERVAL INSERVICE TESTING PROGRAM - BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 (TAC NOS. 63523 AND 63524)

By letter dated October 23, 1986 Carolina Power & Light Cornany (CP&L) submitted the proposed Inservice Testing (IST) Program for tie second ten-year cycle of operation for the Brunswick Steam Electric Plant (BSEP), Units I and 2.

The second ten-year interval began on July 10, 1986 and ends July 9,1996. The staff, with assistance from its contractor.-

Idaho National Engineering Laboratory (EC&G), reviewed the program.

During.the course of the review, EG&G developed a list of comments and questions which were transmitted to CP&L as an attachment to the meeting notice dated July 15, 1987. CP&L provided a written response to the FG&G comments and questions, which was further discussed during a working meeting with your staff, and the hRC staff and NRC contractors.

This meeting was held on July 21-22, 1987 at the BSEP site.

Additional staff concerns and open items on the IST program were identified at the meeting.

To address staff concerns CP&L provided a revised program by letter dated Novenber 24, 1987, and provided additional changes by letters dated March 28,1988, November 2,1988, and Septenber 8,1989.

The BSEP, Units 1 and 2, second ten year IST program, as submitted and amended, was evaluated for compliance with the Code of Federal Regulations, 10 CFR 50.55a(g), which requires certain Class 1, 2 and 3 pumps and valves in water-cooled nuclear reactor facilities to meet the inservice testing requirements stated in the ASME Boiler and Pressure Vessel Code,Section XI; specifically, Subsection IWP, Inservice Testing of Pumps in Nuclear Power Plants, and Subsection IWV, Inservice Testing of Valves in Nuclear Power Plants.

Each facility is required to establish a program for the inservice testing of -

pumps and valves which is updated every ten years to meet the requirements in the latest approved edition and addenda to Section XI of the ASME Code.

The staff, with technical assistance from EG&G, has reviewed and evaluated the program originally submitted and the revised program and additional changes provided by CP&L letters, including the requests for relief from those require-ments that CP&L determined to be impractical to perform at DSEP, Units 1 and 2.

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Mr. W. L. Eury 2

January 4, 1990 The results of that review are sumnarized in the enclosed Technical Evaluation 1

Report (TER)(seeEnclosure1).

The staff agrees with the EG&G recorrendations contained in the TER and has reached the following conclusions.

i The staff has concluded that certain Section XI Code requirements are impractical to perfonn at BSEP, Units I and 2.

In those instances, we have granted relief from those requirements.

Certain relief requests were reviewed but deemed to be unnecessary as a result of a recent plant modification.

A request was granted for interim relief because the plant is scheduling changes to correct the F

situation on a permanent basis.

A summary of the pump and valve relief request determinations is presented in Table 1 of the staff Safety Evaluation (see ).

A sunsnary of these requirenents and the basis for granting the relief requests are also contained in the enclosed Safety Evaluation.

The r(

staf f has determined, wrsuant to 10 CFR 50.55(a)(3)(1) and 50.55a(g)(6)(i),

that the granting of tiese reliefs is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest.

In making this determination, the staff has given due consideration to the alternate testing being implemented and to the burden that could result if these requirements were imposed on the facility.

Accordingly, the staff concludes that the BSEP, Units 1 and 2 IST program is acceptable for implementation, provided the necessary corrections and inconsistencies identified in Appendix C of the TER are addressed by CP&L.

In accordance with Generic Letter 89 04, the licensee should review its implenenting procedures and amend them to address any deficiencies related to implementation of the positions in the generic letter.

Both of these actions should be completed within 180 days of the receipt of this letter.

CP&L is required to comply with the IST program as defined in the above references, CP&L submittal and supplemental letters; and in accordance with the reliefs granted in the enclosed Safety Evaluation.

Progrcm changes such as revisions or additional relief requests or deletion of any components from I

the BSEP's IST program should be submitted for staff review end should not be implemented prior to review and approval by the NRC.

This letter closes our action on TAC Nos. 63523 and 63524.

1 Sincerely, Original Signed By:

Elinor G. Adensam. Director Project Directorate 11-1 Division of Reactor Projects - I/11 Office of Huclear Reactor Regulation

Enclosures:

As stated cc w/encls:

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4 Mr. L. W. Eury Brunswick Steam Electric Plant Carolina Power & Light Company Units 1 and 2 2C:

Mr. Russell B. Starkey, Jr.

Mr. H. A. Cole Project Manager Special Deputy Attorney General Brunswick fluclear Pro'ect State of North Carolina P. O. Cox 10429 P. O. Box 629 Southport, North Carolina 28461 Raleigh, North Carolina 27602 Mr. R. E. Jones, General Counsel Mr. Robert P. Gruber Carolina Power & Light Company Executive Director P. O. Cox 1551 Public Staff - NCUC Raleigh, North Carolina 27602 P. O. Box 29520 Raleigh, North Carolina 27626-0520 Ms. Frankie Rabon Board of Comissioners P. O. Box 249 Bolivia, North Carolina 28422 Resident inspector U. S. Nuclear Regulatory Commission Star Route 1 P. O. Box 208 Southport, North Carolina 28461 Regional Administrator, Region II U. S. Nuclear Regulatory Comission 101 Marietta Street, Suite 2900 Atlar.ta, Georgia 30323 Mr. Dayne IL Drown, Chief Radiation Protection Branch Division of Facility Services H. C. Departrent of Human Resources 701 Berbour trive l

Raleigh, North Carolina 27603-?008 Mr. J. L. Hurness Plant General Manager Brunswick Steam Electric Plant P. O. Box 10429 Southport, North Carolina 28461 1

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