ML20053C394

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Forwards Request for Addl Info Re Inservice Insp Program. Response Requested within 30 Days of Receipt of Ltr
ML20053C394
Person / Time
Site: Brunswick  
Issue date: 05/05/1982
From: Vassallo D
Office of Nuclear Reactor Regulation
To: Jackie Jones
CAROLINA POWER & LIGHT CO.
References
NUDOCS 8206020053
Download: ML20053C394 (6)


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ORB #2 Rdg Docket File DEisenhut MM 5 N NRC PDR SNorris

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L PDR JVan Vliet Docket tios. 50-325 OELD and 50-324 AE0D m

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g Gr'y File RECElVEO' fir. J. A. Jones Senior Executive Vice President 9;

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Dear !!r. Jones:

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Subject:

Inservice Inspection Program, Request for Additionil Information Re:

Drunswick Stean Electric Plant, Units 1 and 2 Our consultant Science Applications, Inc., has completed a prelir.inary review of the subject program for your facility. The documents reviewed.

are those referenced in the enclosure. Additional information is recuired to complete the review. Please pmvide the additional information icenti-fled in the enclosed Request for Additional Infomation within 30 days of receipt of this letter. To expedite this review, please provfde a copy of your submittal directly to:

l Dr. D. A. Outlaw Science Applications, Inc.

1710 Goodridge Drive McLean, Virginia 22102 We have attempted to discuss this mquest with the appropriate Carolina i

Power & Light Company (CP&L) personnel prior to issuing it so as to reach i

a nutual understanding of what an acceptable response would entail. Un-i fortunately, the appropriate CP&L personnel have met, over the past few l

ueeks, been available for such a discussion. Schedular constraints dictate that we now issue this request recognizing that additional clarification may be required. Therefore, should you have any questions on, or require additional clarification of, this request, contact your Project Manager.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OfB clearance is not required under P. L.96-511.

Sincerely, Original signed bi' C!0RB#2:DL 8206020053 820505 PDR ADOCK 05000324 D. D. Vassalla DVas llo G

PDR Domenic B. Vassallo, Chief 5/

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l NRC FORM 318 (10-80) NRCM 024o OFFICIAL RECORD COPY useo i.ei-mee.

Mr. J. A. Jones cc:

Richard E. Jones Esquire Carolina Pbser & Light Company 336 Fayetteville Street Raleigh, North Carolina 27602 George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N. W.

Washington, D. C.

20036 Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 1057 Southport, North Carolina 28461 Southport - Brunswick County Library 109 W. Moore Street Southpert, North Carolina 28461 Mr. Charles R. Dietz Plant Manager P. O. Box 4S8 Southport, North Carolina 28461 James P. O'Reilly Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 e

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Enclosure' REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION PROGRAM Brunswick 1 and 2

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I.

Inspection Interval In reference 1, you state "the updated In-Service Inspection and Test Program will be applicable for a new 120-month interval beginning July 1, 1981." However,10 CFR 50.55a requires that 120-month intervals be based on the dates of commercial operation. Therefore, your current ISI programs for units 1 and 2 should run through March 17,1987, and November 2,1985, respectively. Please revise your current program to run through those dates. You may either continue with the 77 through Summer 78 Code or revise your program back to the 74 through Summer 75-Code.

I.n either case, please submit any additional relief requests or changes with supporting justification necessary to bring your 120-month inspection intervals into conformance with 10 CFR 50.55a.

If you revise your basic program back to the 74 through Summer 75 Code, you may update related portions of your program to a later Code version per 10 CFR 50.55a(g)(4)(iv).

II. Relief Requests from the March 2, 1981, ISI Program (Reference 1, Attachments C and D) 1.

Relief Request 1, Category B-B, Bottom head welds J-31 and J-42.

Relief is requested from volumetric examination of two bottom head welds considered inaccessible due to physical space constraints and high radiation levels.

Radiation levels in the area average 100 to 200 mr/hr (reference 2).

The following additional information is requested:

a.

Identify the fraction of the lengths of welds J-31 and J-4 2 that are accessible to volumetric examination.

b.

What are the estimated radiation doses (in man-rem) that would result from such examinations?

c.

Identify the fraction of the length of welds J-31 and J-42 that is accessible to surf ace examination.

What is the estimated radiation dose from such examinations?

page 2 i

d.

Will these welds be visually examined for l

leakage or deposits caused by leakage both during the leak testing after each refueling outage and during the hydrostatic test to be performed near the end of the 120-month interval?

e.

Discuss the feasibility of increasing the extent of examination on accessible category B-B welds to compensate for the exam'inations which cannot be performed.

This question was also asked in rbference 3 but the response in reference 2 was incomplete.

2.

Relief Request 3, Category B-M-2, B12.40 Relief is requested from the visual examination require-mehts for valve interior surf aces for Class I valves greater than 4 inches in diameter with functional and/or pressure tests substituted.

The following additional infonnation is requested:

a.

This relief request appears inconsistent with the B12.4 valve examination plans stated ir.

Attachment D (reference 1), pages 17,19, 20, 21, 22, 24 and 25 of the Component Nondestruc-tive Examination tables. Those tables indicate that code requirements for these valves will be

' met. Please clarify your relief request and state for which valves relief is.being requested.

b.

Please provide more detailed justification for not performing the required examinations of the category B-M-2 valves.

3.

Relief Request 4, Use of Ultrasonic Examination Calibra-tion Blocks with drilled holes instead of notches.

Relief is requested from the 77 Code (Summer 78 Addendum) requirements for the use of ultrasonic examination cali-bration blocks with specified notches.

Use of calibra-tion blocks with drilled holes in accordance with the 74 Code (Summer 75 addendum) is requested.

page 3 The following additional information is requested:

a.

Please provide additional justification for not changing to the new calibration blocks required by the later code.

b.

Does this relief request apply to all calibra- -

tion blocks?

If. not, please identify in pro-gram table by Section XI category number and by Section XI item number, where relief is requested.

4.

Relief Request 5, Categories B-J, C-B, and C-F (B9.1,B9.31,C2.2,C5.2)

Certain welds require volumetric examination over the inner 1/3 of the pipe volume and surf ace examination.

The licensee proposes to use a full volumetric examina-tion in lieu of the partial volumetric and surface examination on some of the welds in these categories.

The following additional information is required:

a.

Please identify and describe the welds for which relief is being requested.

b.

We are willing to allow substitution of full volumetric examination for the combination of surface and alumetric examination if you are willing to commit to the volumetric examination of the volume bounded by A-C-F-E-D-B such as in Figures IWB-2500-8 and IWC-2520-4,7. Please Concur.-

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5.

Relief Request 6, Category B-A, Items Bl.11 and Bl.12 l

Relief is requested from the Summer 78 requirements to examine 100 percent of the RPV circumferential and i

longitudinal welds and the vessel beltline region welds l

due to space limitations. Summer 75 Code requirements will be met.

The following additional information is requested:

a.

Please provide additional justification for your relief request.

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'b.

Identify the welds that can and cannot be examined over 100% of the weld length due to physical limitations.

What fraction of the weld length can be examined?

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6.

Attachment A of reference l states: " Class 3 systems and supports will be inspected to the requirements of Table IWD-2500-1 of the Code. The examination will be conducted 4

to the extent practicable within the limitations of the component, or system portion, design and geometry."

Please provide relief requests and supporting justifica-tion documenting the Class 3 welds which will not be examined in accordance with Table IWD-2500-1.

7.

For several Class 2 welds listed in the " Weld and Support Inspection Program" tables of Attachment D, reference 1, the remark " Inspect all welds during full flow test in lieu of NDE" is given. Please clarify. Is code relief being requested?

If so, please provide. additional supporting justification and indicate why you consider the required examination to be impractical.

8.

For the Class 2 welds listed in the " Weld and Support Inspection Program" residual heat removal system, page 3 of 4, Item 8-2-1G, the remark states "Due to configura-tion of welds, surface performed in lieu of vel." This appears to be a case where relief from the code. required examinations is needed.

Please clarify and request relief, along with suporting drawings and justafication, if relief is needed.

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References 1.

E. E. ')tley (CP&L) to T. A. Ippolito (NRC), letter with attchments, March 2, 1981.

2.

E. E. Utley (CP&L) to T. A. Ippolito (NRC), letter, response to March 5, 1981, RAI, May 20, 1981.

3.

T. A. Ippolito (NRC) to Jones (CP&L), letter, RAI, March 5, 19S1.

A pril 14,1982 i

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