ML20054H896

Forwards Response to NRC 820505 Request for Addl Info Re Inservice Insp Program

ML20054H896
Person / Time
Site:	Brunswick
Issue date:	06/18/1982
From:	Howe P CAROLINA POWER & LIGHT CO.
To:	Vassallo D Office of Nuclear Reactor Regulation
References
NUDOCS 8206250150
Download: ML20054H896 (7)

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Carolina Power & Light Company JUN 181982 Office of Nuclear Reactor Regulation ATTN: Mr. D. B. Vassallo, Chief Operating Reactors Branch No. 2 United States Nuclear Regulatory Commission Washington, D.C. 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 INSERVICE INSPECTION PROGRAM - SUPPLEMENTAL INFORMATION

Dear Mr. Vassallo:

Enclosed please find the Carolina Power & Light Company (CP&L) response to your May 5, 1982 request for additional information regarding the inservice inspection program for the Brunswick Steam Electric Plant Unit Nos. I and 2. As discussed previously with your staff, our response date to your request was extended to June 18, 1982.

Pursuant to your request, a copy of this submittal is being forwarded to your consultant, Science Applications, Incorporated.

Should you have any questions regarding the enclosed information, please contact my staff.

Yours very truly,

.W-P. W. Howe Vice President Technical Services MSG /cr (033C4T5)

Enclosure cc: Mr. J. J. Blake (NRC-RII)

Mr. R. C. De Young (NRC)

Mr. J. P. O'Reilly (NRC-RII)

Dr. D. A. Outlaw (SAI) j f g(

Mr. J. A. Van Vliet (NRC) 8206250150 820618 PDR ADOCK 05000324 0 PDR 411 Fayetteville Street . P. O. Box 1551. Rafeigh, N C. 27602

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CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT UNIT NOS. 1 AND 2 INSERVICE INSPECTION PROGRAM REQUEST FOR ADDITIONAL INFORMATION

1. Inspection Interval In Reference 1, you state "the updated In-Servicc Inspection and Test Program will be applicable for a new 120-month interval beginning July 1, 1981." However, 10CFR50.55a 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. In either case, please submit any additional relief requests or changes with supporting justification necessary to bring your 120-month inspection intervals into conformance with 10CFR50.55a. 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 10CFR50.55a(g)(4)(iv).

Response No. I An Inservice Inspection (ISI) program for the Brunswick Steam Electric Plant (BSEP) Unit Nos. I and 2 has been performed since March 17, 1977, and November 2, 1975, respectively.

The BSEP has adopted the 1977 through Summer 1978 Code, and updated the program to conform with 10CFR50.55a(g)(4) requirements. This program will continue with the referenced code for the remainder of the 120-month inspection interval, beginning with the dates of commercial operation (i.e.,

1977 through 1987 for Unit 1; and 1975 through 1985 for Unit 2).

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.

The following additional information is requested:

a. Identify the fraction of the lengths of welds J-31 and J-42 that are accessible to volumetric examination.

Response No. II.1.a The fraction of the lengths of welds J-31 and J-42 that are accessible to volumetric examination is 17 to 20 percent of each weld.

Question II.1.b

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

Response No. II.1.b l The estimated radiation doses that would result from such-examinations is 2.8 man-Rem.

Question II.1.c

c. Identify the fraction of the length of welds J-31 and J-42 that is accessible to surface examination. What is the estimated radiation dose from such examinations?

Response No. II.1.c See above responses II.1.a and II.1.b.

Question II.1.d

d. Will these welds be visually examined for 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?

Response No. II.1.d The welds are visually examined for leakage or deposits caused by leakage - both during the leak testing af ter each refueling outage and during the hydrostatic test to be performed near the end of the 120-month interval.

At this time, visual examination is scheduled during hydrostatic testing of BSEP Unit No. 2 during the current refueling outage.

Question II.1.e

e. Discuss the feasibility of increasing the extent of examination on accessible category B-B welds t4o compensate for the examinations which cannot be performed. This question was also asked in reference 3, but the response in reference 2 was l incomplete.

Response No. II.1.e The examination on accessible category B-B welds will be performed-in accordance with ASME Section XI, Addenda 77/78. The ISI procedures will be updated to meet the code requirements as specified in Response No. I, above.

II. 2. Relief Request 3, Category B-M-2, B12.40

, Relief is requested from the visual examination requirements for valve interior surfaces for Class I valves greater than four inches in diameter with functional and/or pressure tests substituted.

The following additional information is requested:

a. This relief request appears inconsistent with the B12.4 valve examination plans stated in Attachment D (Reference 1), pages

17, 19, 20, 21,122, 24, and 25 of the Component Nondestructive 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.

' Response No. II.2 The-comment is correct in noting an' inconsistency between relief request 3 (Reference 1) and the B12.40 valve examination plans stated in Attachment . D (Reference 1), pages 17,19,20,21,22,24, and 25 of the Component Nondestructive Examination tables. A clarification 'and justification for Relief. Request 3, Category B-M-2, B12.40, follows. This relief request is applicable to all Class I and II valves,' greater than 4 inches in diameter, in '

the ISI program.

As the subject valves are functional and/or successfully leakrate tested, the integrity and safe operability of the valves are assured.

Additionally, all. Class I and II valves have welded connections. Therefore, any degradation of the. valve body would be detected during the ISI weld inspection program. Disassembly and visual examination of the valves 'would not particularly contribute to such an assurance and would expose personnel to.

unnecessary levels of radiation.

Weld examination, functionalEtesting and/or leakrate testing should ensure valve operability. However, if the valve is. disassembled, the valve internals will undergo a visual examination.

The ISI procedures ' and program will be revised _ to reflect' the above, improved method of assuring the integrity and safe operation of the valves.

II. 3. Relief Request l4, Use of Ultrasonic Examination Calibration Blocks with drilled holes instead of notches.

Relief is requested from the 77 Code L (Summer 78 Addendum)

_ requirements for the use of ultrasonic examination calibration blocks with specified notches. Use of. calibration blocks with drilled holes in accordance with the 74 Code (Summer 75 Addendum) is requested.

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 calibration blocks? If not, please identify in program table by Section XI category number and by Section XI item number where relief is requested.

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Response No. II.3.a and II.3.b 1

i The calibration blocks are in compliance with ASME Section XI, l

Division 1, 77/78 and ASME Section V, Articles 4 and 5, _ therefore the relief request is withdrawn.

II. 4. Relief , Request 5, Categories B-J, C-B, and C-F.

(B9.1, B9.31, C2.2, C5.2) i~

Certain welds require volumetric examination over the inner 1/3 of the pipe volume and surface examination. The licensee proposes to use a full volumetric examination in lieu of the partial volumetric and surface examination on some of the welds in these categories.

I 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 l~ examination for the combination of surface and volumetric

-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 Figure IWB-2500-8 and IWC-2520-4.7. Please concur.

t Response No. II.4.a -

! The requirement in the 1977 Edition,x Summer 1978 Addendum of the i

Code for surface and lower 1/3T volumetric examination.will be applied where.

l practicable. Brunswick Steam Electric Plant Unit Nos. I and 2 were designed and constructed prior to the formalization of ASME Section XI. Therefore, in many cases, the surface examination is not practicable. Carolina Power & Light

Company will attempt to meet the Code requirements but when impracticable to i do so, we will substitute the more stringent, full volumetric examination. For this reason, any deviation from the Code will be reported on a case-by-case basis when

the inspection -is performed. This practice is consistent with 10CFR50.55a.

Response No. II.4.b i

Carolina' Power & Light Company concurs with volumes bounded as shown -

! in Figures IWB-2500-8 and IWC-2520-4,7.

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{ II. 5. Relief Request 6, Category B-A, Items Bl.11 and Bl.12 Relief is requested from the Summer 78 requirements to examine 100 percent of the RPV circumferential 'and longitudinal welds and the . vessel' beltline region welds due to space limitations. Summer 75 Code requirements

, will be met.

i The following additional information is requested:

i

a. Please provide additional justification for-your relief request.

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?

Response Nos. II.5.a and II.5.b Carolina Power & Light Company withdraws its relief request regarding this item.

II. 6. Attachment A of reference 1 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 to the extent practicable within the limitations of the component, or system portion, design and geometry."

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

Response No. 11.6, Code relief is not requested at this time. The ISI procedures are being revised in conformance with ASME Section XI 1977 Code (Summer 1978-Addendum). Pursuant to 10CFR50.55a, code relief will be considered on a case-by-case basis and will be requested as needed.

II. 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.

Response No.__ II.7 See response No.11.6.

II. 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 configuration of welds, surface performed in lieu of vol." This appears to be a case where relief from the code required examinations is needed. Please clarify and request relief, along with supporting drawings and justfication, if relief is needed.

Response No. 11.8 See response No.11.6.

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-s References ,

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1. E..E. Utley'(CP&L) to T. A. Ippolito (NRC), letter with attachments, March 2, 1981.

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

3. . T. A. Ippolito (NRC) to J. ' A. Jones (CP&L), letter, RAI, March 5, .1981.

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