ML20214U012
| ML20214U012 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 06/04/1987 |
| From: | Zimmerman S CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NLS-87-118, NUDOCS 8706110005 | |
| Download: ML20214U012 (15) | |
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i CD&L Carolina Power & Light Company SERIAL: NLS-87-Il8 g 4 gg 10CFR50.55afg) -
i United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 l
DOCKET NOS. 50-325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 l
IN-SERVICE INSPECTION - RESPONSE TO REQUESTS FOR INFORMATION Gentlemen:
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Carolina Power & Light Company (CP&L) submitted a description of the in-service i
inspection program for the second 10-year interval of operation for the Brunswick Steam Electric Plant (BSEP), Unit Nos. I and 2 on November 10,1986. Included in this submittal were requests for relief from both the first and second 10-year intervals. On April 3,1987, the NRC requested additional information via two separate letters; one concerning the first interval relief requests, and the other concerning the second interval program and relief requests.
The response to the request for information concerning the first 10-year interval is provided in Attachment 1. Responses related to the second 10-year interval are included in Attachments 2,3, and 4. The Company is unable to respond fully to the requests relating to the second 10-year interval due to the magnitude of information requested.
This information is expected to be compiled for Unit I by July 31,1987, and by November 30,1987 for Unit 2 and will be submitted for each unit shortly af ter its completion date.
Please refer any questions regarding this submittal to Mr. Stephen D. Floyd at (919) 836-6901.
Yours,very truly, www S.
. Zi erman anager Nuclear Licensing Section BAT /lah (5212 BAT)
Attachments cc:
Dr. J. Nelson Grace (NRC-RII)
Mr. W. H. Rutand (NRC-BNP)
Mr. E. Sylvester (NRC) 8706110005 870604 PDR ADOCK 05000324 G
PDR 411 Fayette Its street e P. O Box 1551
- Raleigh, N. C 27602
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In-Service Inspection Response to Request for Information First 10-Year Interval Program For Relief Request PR-3, justify why it is impractical to replace the rupture disk with a nonfailing plate in order to perform the pressure test at the required pressure.
Response: The particular portion of the control rod drive (CRD) systern covered under
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Relief Request PR-3 is indicated on Figure 1. To obtain test y essure, a nitrogen cylinder pressurized to a minimum of 2189 psi would have to 1.? hard piped to the instrumentation block cartridge valve, which is shown on Figure 2. The design pressure of the CRD nitrogen accumulators is 1750 psig. Pressurizatica of this system to such pressures poses potential safety concerns. In addition, the tes.t would need to be performed on each of the 137 Hydraulic Control Units (HCUs) on each unit, thereby introducing the potential for personnel error as well as the safety concern associated with the pressurization.
Water and nitrogen are separated in th+ water accumulator by an internal piston with O-rings and seats. These seals normally see a differential pressure of 450 psi applied in i
the reverse direction (i.e., applied on the nitrogen). The increased pressure applied during a pressure test could cause nitrogen leakage into the water side of the piston, thereby resulting in slower CRD inserticri times and thus necessitating venting of the piping.
l The purpose of ASME Section XI bydiostatic/ pneumatic testing is to identify degradation of the pressure boundary which is ref;ected by through-wall leakage. As this portion of the CRD system remains in a static condition filled with nitrogen, degradation of the pressure boundary is unlikely. As part of the instrumentation block, a nitrogen pressure gauge reflects actual pressure for each accumulator. In addition, there is an on-line i
monitoring system. Should nitrogen pressure drop to 940-970 psi, an automatic alarm is I
sounded in the Control Room. This on-line system provides better assurance of the l
structural integrity than the pneumatic test performed once every 10 years.
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FIGURE 2-cex-9s824 ISOLATION VALVE (EP 116) %
CHARGING WATER RISER SCRAM VALVE PILOT AIR ISOLATION VALVE (EP 102)
H UST WATE RISE
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WI HORAWAL RISER ISOLATION VALVE (EP 101)
ISOLATION VALVE (EP 103) d DRIVE WATER RISER INSERT RISER
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SCRAM PILOT VALVE ASSEMBLY 3
(EP 117,118)
ISOLATION VALVE (EP 104) -
- pf COOLING WATER RISER f
yl (EP 127)
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ISOLATION VALVE (EP 112)
SCRAM DISCHARGE RISER INLET SCRAM VALVE
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126) k I
-DIRECTIONAL CONTROL VALVE b
(EP 122)(WITHDRAW)
DIRECTIONAL CONTROL VALVE
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[0 IRE. TION C NTROL VALVE E
MANIFOLD y
yWIRING TROUGH ASSEMBLY OIRECTIONAL CONTROL VALVE (EP 120)(WITHDRAW AND SETTLE)
SHUTOFF VALVE (EP 107)
WATER ACCUMULATOR DRAIN SCRAM ACCUMULATOR N 2 p
CYLINDER (EP 128)
SCRAM WATER ACCUMULATOR (EP 125) e l
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ACCUMULATOR N PRESSURE 2
FRAME f lNDICATOR (EP 131) f/
G CARTRIDGE VALVE (EP 111)
ACCUMULATOR N2 CHARGING
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A ACCUMULATOR INSTRUMENTATIOP j
ASSEMBLY
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Figure 2-1.
Hydraulic Control Unit, Part No. 729E950 2-2
In-Service Inspection Response to Request for Additional Information Second 10-Year Interval Program A.
Provide the staff with an itemized listing of the components, by system, subject to examination during the second 10-year interval. The requested listing will permit the staff to determine if the extent of ISI examinations meets the applicable Code requirements.
Response:. Due to the magnitude of this request (approximately 6000 components per unit), such a listing cannot be provided at this time. All ISI components are currently being loaded into a computerized tracking / data base program which will be capable of providing the requested listing sorted by system. Loading of data is scheduled for completion by July 31,1987 on Unit 1 and by November 30,1987 on Unit 2. The requested information will be provided for each unit after loading is complete.
B.
Provide the staff with isometric and/or component drawings showing the welds, components, and supports which are required to be examined by Section XI of the ASME Code.
Response: In conjunction with the data loading effort, new sets of ISI weld and support isometrics are being generated. These new isometrics incorporate changes in ISI identification numbers and boundary changes for the new interval. These will be submitted along with the component listing af ter data loading is complete.
C.
Provide the staff with a list (by Code Class) of specific exemptions applied to the systems being examined during the second 10-year inspection interval.
Response: Attachment 3 provides a list of specific exemptions applied to systems being examined during the second 10-year interval.
D.
Provide the staff with a reference list of calibration blocks including identifications, mnerial specifications, and sizes.
Response: Attachment 4 provides the current list of calibration standards.
E.
Review of the Augmented Examination Section of the ISI Program Plan shows that i
welds in the Control Rod Drive (CRD) scram discharge volume (SDV) piping may not be included for examination. The staff finds that because the SDV piping is designed and fabricated according to the requirements of ASME Section III Class 2, and because of its importance in achieving the scram function it should, as a minimum, be subjected to the ISI requirements for Class 2 piping in the ASME Code Section XI. Have the requirements of ASME Code Section XI and the recommendations of NUREG-0803 been incorporated in the CRD section of the BSEP, Units 1 and 2 second 10-year interval ISI plan?
Response: The CRD scram discharge volume piping has been incorporated into the ISI Class 2 program. The ASME Section XI and NUREG-0803 recommendations have been incorporated for this piping.
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F.
Plans for in-service examination of the Reactor Pressure Vessel welds should address the degree of compliance with Regulatory Guide 1.150," Ultrasonic Testing of Reactor Vessel Welds During Pre-Service and In-Service Examinations." Discuss the near-surface induced flaws and the use of electronic gating as related to the volume of material near the surface that is not being examined.
Response: Carolina Power & Light Company has not committed to Regulatory Guide 1.150. The requested information must be obtained from the vendor. This information will be submitted along with the component list and isometric drawings after that data is compiled.
G.
In Request for Relief No. RR-2, what percentage of the circumferential beltline region weld is examinable? For the proposed alternative examination, the licensee should consider substituting examinations of accessible portions of other beltline region welds for an inaccessible portion of Weld Number DC.
Response: Approximately 30% (299" of 751") of the circumferential beltline region weld is examinable. Based on estimated accessibilities, an additional 373" of other beltline region circumferential and longitudinal weld lengths could be examined.
Request for Relief Number RR-2 will be revised to reflect this and resubmitted with the component list and isometric drawings.
H.
From the valve listing in Request for Relief No. RR-3, it is not clear which unit the valves are located in. The licensee should list the valves for each unit. Do the valves for Unit I and 2 have the same identification numbers? If so, the licensee should submit a revised relief request which makes that statement.
Response: The valve listing in Request for Relief Number RR-3 is applicable for both units and will be revised to reflect this and resubmitted with the component list and isometric drawings.
I.
Requests for relief are not automatically granted for the second 10-year inspection interval. A complete submittal of the requests for relief must be submitted for each 10-year inspection interval for the staff to review the relief requests against the updated Code requirements. Furthermore, the staff monitors the development of new or improved examination techniques. As improvements in these areas are achieved and implemented in the industry, the staff requires that these techniques be incorporated in subsequent inspection interval ISI program plan examination requirements. Attachment 2 to the licensee's November 10,1986 submittal contains relief requests (VR-2, PR-1, PR-3, PR-4, PR-7, PR-8, and PR-9) for the first 10-year inspection interval which ended July 10,1986. These relief requests will be evaluated separately from the relief requests for the second 10-year interval.
Should these relief requests also be included in the ISI Program Plan for the second 10-year inspection interval? If so, the licensee should provide a complete submittal of relief requests for the second 10-year inspection interval.
Response: Of the seven requests for relief listed, VR-2, PR-1, and PR-4 will be applicable for the second 10-year inspection interval. A complete submittal of relief requests applicable to the second 10-year interval will be submitted with the component listing and isometric drawings.
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List of Specific Exemptions - Class 1 t
Reference Key Description 81W-0281W-B0 Components that are connected to the reactor coolant system j
and part of the reactor coolant pressure boundary and that are of such a size and shape that upon postulated rupture, the resulting flow of coolant from the reactor coolant system under normal plant operating conditions is within the capacity of makeup systems which are operable from on-site emergency power per
!WB-1220 (A), 80W81.
81W-0281W-BI Piping of one-inch nominal pipe size and smaller, except for steam generator tubing. Components and their connections in -
piping of one-inch nominal pipe size and smaller per 1
IWB-1220 (B)(1) and (2), 80W81.
31W-0281W-B2 Reactor vessel head connections and associated piping two-inch l
nominal pipe size and smaller, made inaccessible by control rod l
drive penetrations per IWB-1220 (C),80W81.
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Page 2 of 5 List of Specific Exemptions - Class 2 Reference Key Description 81W-0281W-C0 Components of systems or portions of systems that during normal plant operating conditions are not required to operate or perform a system function but remain flooded under static conditions at a pressure of at least 80% of the pressure that the component or system will be subjected to when required to operate per IWC-1220 (A),80W81 (normal conditions exclude only testing and maintenance).
81W-0281W-Cl Components of systems or portions of systems, other than residual heat removal systems and emergency core cooling systems, that are not required to operate above a pressure of 275 psig (1900 KPa) or above a temperature of 200'F (93*C) per IWC-1220 (B), 80W81.
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Page 3 of 5 List of Specific Exemptions - Class 2 (Pg ng Only)
Reference Key Description 81W-02N408Al Code Case N-408 Exemption! Components (or parts of components) of residual heat removal (RHR), emergency core cooling (ECC), and containment heat removal (CHR) systems for vessels, piping, pumps, valves, and other components nominal pipe size four inches and smaller are exempt from volumetric and surface examination requirements of IWC-2500.
Code Case N-408 Exemption: Components (or components) of RHR, ECC, and CHR systems (parts of 81W-02N408A6 or portions of systems) for piping and other components of any size beyond the last shutoff valve in open-ended portions of systems that do not contain water during normal plant operating conditions are exempt from volumetric and surface requirements of IWC-2500.
81W-02N408B1 Code Case N-408 Exemption: Components (or parts of components) of systems (or portions of systems) other than RHR, ECC, and CHR systems for vessels, piping, pumps, valves, and other components of nominal pipe size four inches and smaller are exempt from the volumetric and surface requirements of IWC-2500, Code Case N-408 Exemp(tion: Components (or parts of 81W-02N408B2 components) of systems or portions of systems) other than RHR, ECC, and CHR systems for component connections of nominal pipe size four inches and smaller (including nozzles, socket fittings, and other connections) in vessels, piping, pumps, valves, and other comoonents of any size are exempt from the volumetric and surface requirements of IWC-2500.
81W-02N408B3 Code Case N-408 Exemption: Components of systems other than RHR, ECC, and CHR systems for vessels, piping, pumps, valves, other components, and component connections of any size of systems that operate (when the system function is required) at a pressure equal to or less than 275 psig and at a temperature equal to or less than 200'F are exempt from the volumetric and surftce requirements of IWC-2500.
Cod Case N-408 Exemp(tion: Components (or parts of 81W-02N408B4 con ponents) of systems or portions of systems) other than RHR, ECC, and CHR systems for piping and other components of any size bt. yond the last shutoff valve in open-ended portions of systems that do not contain water during normal plant operating conditions are exempt from the volumetric and surface requirements of IWC-2500, j
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5 Page 4 of 5 List of Specific Exemptions - Class 2 (Piping Only)
(continued) 81W-02N408NW Code Case N-408 Exemption: Nominal wall thickness below the required nominal wall thickness to be examined (less than 3/8 inches). For Examination Categories C-F-1 and C-F-2, Footnote 2 requires that some welds exempted from nondestructive 1
examination be included in the weld count to which the 7.5%
sampling rate'is applied for those welds requiring examination.
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Page5of5 List of Specific Exemptions - Class 3 Reference Key Description 81W-0281W-C2 Component connections (including nozzles in vessels and pumps),
piping and their associated valves and vessels and their attachments that are four-inch nominal pipe size and smaller per j
IWC-1220 (C), 80W81.
81W-0281W-C3 Piping support members and piping support components that are encased in concrete shall be exempt from examination requirements of IWC-2500 per IWC-1230,80W81.
81W-0281W-D0 Integral attachments of supports and restraints to components that are four-inch nominal pipe size and smaller within the system boundaries of Examination Categories D-A, D-B, and D-C of Table IWD-2500-1 shall be exempt from the Visual Examination VT-3.
81W-0281W-D 1 Integral attachments of supports and restraints to components j
that are four-inch nominal pipe size may be exempt from Visual Examination VT-3 of Table IWD-2500-1 provided components are 4
'l located in a system (or portions of a system) whose function is not required in support of reactor residual heat removal, containment heat removal, and emergency core cooling per IWD-1220.2 (A), 80W81.
81W-0281W-D2 Integral attachments of supports and restraints to components that are four-inch nominal pipe size may be exempt from Vistal Examination VT-3 of Table IWD-2500-1 provided the components operate at a pressure of 275 psig or less and a temperature of 200*F (93*C) or less per IWD-1220.2 (B),80W81.
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List of Calibration Standards Calibration Material Block No.
Specification
- Size, Schedules / Thickness CRD-1 SB-166 4" 0.845" T IB SA312 TP304 3" SCH 80 2B-A312 TP304 4"' SCH 80 3B A312 TP304 6" SCH 80 4B SA312 TP304 10" SCH 80 5BR SA358 12" SCH 80 6BR SA358 GR304 20" SCH 80 7BR SA240 GR340 22" SCH 80 8BR SA240 GR304 24" SCH 100 9BR SA240 GR304 28" SCH 80 10B SA333 GR6 3" SCH 160 llB A106 GRB 4" SCH 80 12B A106 GRB 4" SCH 120 13B A106 GRB 10" SCH 80 14B SA333 GR6 10" SCH 100 16B A333 GR6 14" SCH 120 17B A333 GR6 18" SCH 120 18B A333 GR6 20" SCH 80 19B A106 24" SCH 80 21B A106 GRB 6" SCH 160 22B SA285B
.746" T PLATE 24B SA312 12" SCH 160 (52128AT/bec) t
F Page 2 of 4 List of Calibration Standards (continued)
Calibration Material Block No.
Specification Size, Schedules / Thickness 25B A106 GRB 12" SCH 160 26B A540 B23 3.00" DIA X 22.00" STUD 27B C/S 5.5" DIA X 24" STUD 29B A106 GRB 6" SCH 40 30E3 A106 GRB 14" SCH 30 3tB A106 16" SCH 30 32B A106 24" SCH 20 33B 18" 2.50" T 34B SA106 GRB 9" OD X 1.65" T 35B SA181 6" OD X 1.50" T 36B SA106 GRB 6" OD X 0.950" T 37B SA182 F304 4" OD X 0.950" T 38B SA181 3" OD X 0.750" T 39B SA312 GR304H 6" OD X 0.930" T 40B SA3l2 GR304H 8" OD X 0.830" T 41B SA106 GRB 6" SCH 120 42B TP304 10" SCH 160 43B SA312 GR304 10" SCH 80 45B A333 GRB 3.00" T PLATE 46B SA312 TYP 316 3.00" T PLATE 47B SA333 GRC 27.0" L X 5.875" T
- Equivalent chemical properties to SA333 GR6.
(5212 BAT /bme) i
F Page 3 of 4 List of Calibration Standards (continued)
Calibration Material Block No.
Specification Size, Schedules / Thickness 48B SB168 13.75" OD X 0.875" T 50B S/5304 6.78" OD 51B S/S304 4" SCH 80 52B C/S 10" SCH 80 53B A-105-73 GR7/
14" OD X 0.7" T A508-69 CL1 54B A182 GR74 F316 16" OD X 0.950" T 55B A350 GRLF2
~ 10" SCH 100 56B B166 INCO 600 14" SCH 100 57B SA508 CLil 16" L X 8" T 58B SA508 CLil 28" X 2.00" T 59B SA333 GR6 12" SCH 100 60B SA508 CL2 20" L X 12" W 61B A106 GRB 10" SCH 120 62B A106 GRB 16" SCH 80 63B A106 GRB 24" SCH 30 64B A106 GRB 16" SCH 120 65B A106 GRB 20" SCH 120 66B A106 GRC 24" SCH 100 67B A106 GRC 30" X 1.50" T 71B A516 GR70 0.875" T PLATE 72B A516 GR70 1.125" T PLATE (52126AT/bac) 4 m
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r Page 4 of 4 List of Calibration Standards (continued)
Calibration Material Block No.
Specification Size, Schedules / Thickness 73B A106 GRB 8" OD 0.594" T 74B A106 GRB 8" OD 0.718" T 75B A106 GRB 14" OD 0.937"T 76B A106 GRB 12" SCH 80 77B A106 GRB 14" SCH 80 78B SA508 CL2 12.50" L X 8.00" W 79B SA105 CL2 7.25" T 80B A193 GRB-7 3" X 15 3/8" STUD 81B A193 GRB 3" X 14.50" STUD 82B A106 GRB 20" DIA SCH 20 83B A105 SB166 12" OD SAFE END THERMAL SLEEVE 84B SB168 13.25" OD X 1.45"T 100 ROL 304SS/308L OVERLAY 12" SCH 80 101 ROL 304SS/308L OVERLAY 28" SCH 80 102 ROL 304SS/308L OVERLAY 32" DIA 103 ROL 304SS/308L OVERLAY 6" SCH 80 110 ROL A&B 304SS/308L OVERLAY 4" SCH 80 CP&L-21-1 304SS/308L OVERLAY 4" SCH 80 200-111 ROL CP&L-21-1 304SS/308L 22" OD X 1.00"T 200-112 ROL (52128AT/bac)
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