ML20138B878

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Responds to NRC 860218 Request for Addl Info Re 851025 Request for Exemption from 10CFR50,App J Type C Testing Requirements for Primary Containment Isolation Valves Associated w/H2/O2 Monitoring Sys
ML20138B878
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 03/20/1986
From: Zimmerman S
CAROLINA POWER & LIGHT CO.
To: Muller D
Office of Nuclear Reactor Regulation
References
NLS-86-072, NLS-86-72, NUDOCS 8603250209
Download: ML20138B878 (2)


Text

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s CP&L Carolina Power & Light Company SERIAL: NLS-86-072 MAR 2 01986 Director of Nuclear Reactor Regulation Attention: Mr. Dan Muller, Director BWR Project Directorate #2 Division of BWR Licensing United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 APPENDIX J EXEMPTION REQUEST

Dear Mr. Muller:

On October 25,1985, Carolina Power & Light Company requested an exemption to the testing requirements specified in Appendix J of 10 CFR 50 for certain primary

, containment isolation valves. In a letter dated February 18,1986, your staff requested I

additional information concerning our request for exemption from Type C testing requirements for valves associated with the 2H /02 m nitoring system. Enclosure I contains our responses to these questions.

Please refer any further questions regarding this matter to Mr. Stephen D. Floyd at (919) 836-6901.

Yours very truly, mw--

5. (. Zi rman Afanager Nuclear Licensing Section SRZ/ MAT /pgp (3463 MAT)

Enclosure cc: Mr. W. H. Rutand (NRC-BNP) W/A Dr. J. Nelson Grace (NRC-Ril) W/A Mr. E. Sylvester (NRC) W/A 0603250209 860320 0/

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l ENCLOSURE 1 I

TO SERIAL: NLS-86-072 NRC Request i

The information required to complete the review should include: 1) the verification that the piping is seismic Category 1; 2) a description of the quality group of the piping;

3) leak prevention characteristics and test history of the system; and 4) additional

, justification for the relief in terms of the difficulties of doing the Type C tests.

CP&L Response The piping used in the H2 /0 7monitoring system is seismic Category 1, Quality Group 1B.

As stated in the Brunswick Final Safety Analysis Report, Quality Group IB includes nuclear and engineered safety feature systems and containment extensions essential to

the control of the core and to the safe shutdown of the plant, the loss or failure of which

! could cause no hazard to the public.

1

The Hy/0 monitoring 2 system was designed to minimize leakage by specifying socket-

) weld rittings over the bulk of the sample line length. Threaded and compression type ,

fittings were used only where required for equipment connections or for maintenance. In addition, the sample tubing was down sized from I inch to 1/2 inch.

4 This system was installed on Brunswick-1 during the 1983 Reload 3 outage and during the 1984 Reload 5 outage on Brunswick-2. One leakage problem was encountered on j Brunswick-1 due to metal shavings lodged in the valve seats during installation. The lines 1 1 were cleaned and the valves repaired and retested satisfactorily. An integrated leak rate l j test of each unit verified that there was no tubing leakage.  !

l The requirement for Type C testing of this system results in 20 periodic tests per outage for each unit. These tests involve drywell entry in order to disconnect instrument tubing, j' thereby, providing test connections. Since these valves are not required for containment isolation purposes, failure of the H2/02monitoring system would result in no hazard to

! the public, and the system integrity is ensured during periodic Type A testing, the Company believes that any benefit gained in performance of the Type C testing is

l outweighted by the additional outage manpower and the man-rem. exposure incurred as a result.

i I l' l

l (3463 MAT /pgp) l,