ML20133N701
| ML20133N701 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/25/1985 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| References | |
| NLS-85-374, NUDOCS 8510300014 | |
| Download: ML20133N701 (3) | |
Text
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gpgg Carolina Power & Ught Company SERIAL: NLS-35-374 OCT 2 51985 Director of Nuclear Reactor Regulation Attention:
Mr. D. B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO 50-324/ LICENSE NO. DPR-62 APPENDIX 3 EXEMPTION REQUEST
Dear Mr. Vassallo:
SUMMARY
Appendix 3 of 10CFR$0 requires leak testing of the primary reactor containment and related systems and components penetrating the primary containment pressure boundary.
Upon review of the Brunswick in-Service Inspection Program, we have determined that certain primary containment isolation valves currently receiving Type C testing do not require this testing. The purpose of this letter is to request an exemption from Type C testing requirements for these valves.
This will eliminate both the unnecessary outage manpower and the man-rem exposure associated with the Type C testing. The following provides a description of the af fected valves and justification for the exemptions:
Exemption I ~ Instrument Isolation Valves An exemption from Appendix 3 Type C testing requirements is requested for the instrument isolation valves associated with the following penetrations:
Pen No.
Function X-51D Drywell Pressure Sensing Line X-63D Drywell Pressure Sensing Line X-5IC Drywell Pressure Sensing Line X-6SA(C)
Drywell Pressure sensing Line X-$iB Drywell Pressure Sensing Line X 6SB Dr>well Pressure Sensing Line X-51A Drywell Pressure Sensing Line X 6SC(A)
Dr>well Pressure sensing Line X-76C Drywell Pressure Sensing Line X-57D Dr>well Pressure Sensing Line X-206B-B Torus Pressure Sensing Line X-206A-C Torus Level a
X-225B Torus Level
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X-206B-C rerus Level X-225A Torus Level
/
X-206A-D forus Level X-206C-D Torus Level t
0 X-206B-D Torus Level yg g0 X-206D-D Torus Level N,y N
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PDR ADOCK 0 324 P
A,tr. D. B. Vassallo NLS-35-374 / Page 2 Justification - These instrument lines are connected to sealed transducers and are designed to withstand the stresses of a loss-of-coolant accident. Since they are required to be operable during normal operation, shutdown, and accidents in order to monitor critical parameters, they are considered a part of the containment barrier. The integrity of this barrier is ensured by exposing the lines to periodic Type A test pressure.
Therefore, we believe these instrument lines do not require Type C testing.
Exemption 2 - Lines Terminating Elelow Minimum Torus Level An exemption from Appendix J Type C testing requirements is requested for the isolation valves in penetrations where the line terminates below the surface of the minimum torus level. These penetrations include the following:
Pen No.
Function X-210A/B HPCl/RCIC/RHR Pump Test and Minimum Flow Line X-225A/B RHR Pump Suction X-227A/B Core Spray Pump Suction X-223A/B Core Spray Pump Test Line X-224 RCIC Pump Suction X-212 RCIC Turbine Exhaust X-221 RCIC Barometric Condenser Drain X-214 HPCI Turbine Exhaust X-222 HPCI Turbine Drain Line X-226 HPCI Pump Suction X-231 Torus Drain Line Justification Appendix J requires local leakage rate testing of containment isolation valves in certa;n categories or systems identified in Sections II.H or III. A. I.(d).
Section ll.B defines containment isolation valves as those valves relied upon to perform a containment isolation function.
The above-listed penetrations terminate below the minimum water level of the torus and do not communicate with the containment atmosphere; therefore, they cannot become a source of gaseous leakage at any time during the post-accident period because they are ef fectively water sealed by the liquid inventory of the torus. Consequently, these valves are not relied upon to perform a containment isolation function, and we believe their testing is not a requirement of Appendix 3.
Exemption 3 - H / Og MonitorIsolation Valves g
An exemption from Appendix J Type C testing requirements is requested for the valves associated with the H /0 M nitors. The following penetrations provide the supply and 2
2 return for these monitors:
Pen No.
Func tion X-5/A CAC-AT-4409 Supply X-57B CAC-AT-4409 Supply X-60E CAC-AT-4409 Supply X -209B-A CAC-AT-4409 Supply X-24 5E CAC-AT-4409 Return X-7 3 A CAC-AT-44IO Supply X-73B CAC-AT-4410 Supply X-73C(E)
CAC-AT-4410 Supply X-206 A-A CAC-A T-4410 Supply X-244B CAC-AT-4410 Return
l i
Afr. D. B. Vassallo l
NLS-S$-374 / Page 3 e
Justification - These small diameter (1/2" OD) instrument lines are connected to H /02 I
2 monitors CAC-AT-4409 and CAC-AT-4410 which are seismically designed and essential i
for post-accident monitoring of the containment and, therefore, do not require automatic isolation. However, automatic isolation is provided on a Group 6 isolation signal only for j
the purpose of instrumentation protection. In addition, the integrity of these lines and instruments is ensured by exposing them to periodic Type A test pressure. Since these valves are not required for containment isolation purposes, we believe these lines do not require Type C testing.
ADMINISTRATIVE INFORMATION Carolina Pow er & Light Company has reviewed this request in accordance with 10CFR170.12 and determined that an application fee is required. A check for $150 is I
enclosed in payment of this fee. In order to support the upcoming Brunswick-2 outage, we request your approval by November 30, 1985.
Should you have any questions l
concerning this request, please contact Mr. Sherwood R. Zimmerman (919) 336-6242.
Yours very truly, O
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. Cutter - Vice President Nuclear Engineering & Licensing ABC/ MAT /mf (2035 MAT)
Enclosure cc:
Mr. W. H. Roland (NRC-BNP)
Dr. J. Nelson Grace (NRC-RII)
Mr. M. Grotenhuis (NRC)
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