ML20246B722
| ML20246B722 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/31/1988 |
| From: | Beth Brown, Mudlin J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20246B719 | List: |
| References | |
| CON-FIN-D-6022 EGG-ESM-7916, NUDOCS 8907100074 | |
| Download: ML20246B722 (25) | |
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January 1988 l g - ... I l , INFORMAL REPORT l
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/daho TECHNICAL EVALUATION REPORT ON THE FIRST 10-YEAR i National INTERVAL INSERVICE INSPECTION RELIEF REQUESTS:
Engineenny CAROLINA POWER AND LIGHT COMPANY. BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 Laboratory DOCKET NUMBERS 50-325 AND 50-324 i . Managed B. M. Brown - by the U.S. - J. D.. Mudlin Department
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EGG-ESM-79I6 1 I I 1 I i TECHNICAL EVALUATION REPORT DN THE l i FIRST 10-YEAR INTERVAL INSERVICE INSPECTION RELIEF REQUESTS: ) CAROLINA POWER AND LIGHT COMPANY, i BRUNSWICK STEAM ELECTRIC PLANT, UNITS I AND 2, DOCKET NUMBERS 50-325 AND 50-324 k I B. W. Brown J.-D. Mudlin Published January 1988 Idaho National Engineering Laboratory EG&G Idaho, Inc. Idaho Falls, Idaho 834I5 . Prepared for: U.S. Nuclear Regulatory Comission Washington, D.C. 20555
. under DOE contract No. DE-AC07-761 DOI 570 FIN No. D6022 (Project 5)
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ABSTRACT This report presents the results of the evaluation of the Brunswick Steam Electric Plant, Units I and 2, first 10-year interval inservice inspection (ISI) requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical. l I l 4
,This work was funded under:
l U.S. Nuclear Regulatory Commission l FIN No. D6022, Project 5 Operating Reactor Licensing Issues Program, Review of ISI for ASME Code Class I, 2, and 3 Components . l ii l j
SUMMARY
The Licensee, Carolina Power and Light Company, submitted on l November 10, 1986 requests for relief from the AsME Code Section XI requirements which the Licensee has determined to be impractical. The l available information in this submittal was reviewed. As a result of the review, a Request for Additional Information (RAI) was prepared describing the information and/or clarification required from the Licensee in order to complete the review. The requested information was provided by the licensee l in a letter dated June 4,1987. Based on the review ef the Licensee's relief requests, it is concluded that the Licensee has demonstrated that either the proposed alternatives would l provide an acceptable level. of quality and safety or that compliance with > the requirements would result..in hardships ar unusual difficulties without r, i compensating increase in the level of quality and safety and that the public i interest is not served by imposing certain provisions of Section XI of the ASME Code that have been determined to be impractical. i
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. CONTENTS A B S T RA C T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1
SUMMARY
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- 1. INTR 000CTION.......................................................... 1
- 2. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN....................... 3
- 3. EVALUATION OF RELIEF REQUESTS......................................... 4 i
3.1 Class 1 Components (No relief requests) ' l 3.2 Class 2 Components (No relief requests) , 3.3. Class 3 Components.(No relief requests) 3.4 Pressure Tests......... ........................................... 4 t . 3.4.1 Class 1-System Pressure Tests-{Me relief requests) l 3.4.2 Cl as s 2 Sys tem Pressure Tests. . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.4.2.1 Request for Relief No. PR-3, Pneumatic Test of Class 2 Control Rod Dri ve N itrogen Accumul ators. . . . . . . . . . . . . . . . . . . . 4 3.4.2.2 Request for Relief No. PR-4, Hydrostatic Test of the Cl ass 2 Portion of the Main Steam System... .. . .... .... .. . .. 6 3.4.2.3 Request for Relief No. PR-7, Hydrostatic Test of Unit No. 2 Class 2 Welds Upstream of HHR Heat Exc han g e rs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ; 3.4.2.4..- Request for Relief No. PR-9, Hydrostatic Test of ' Unit No. 2 Main Steam System Class 2 Piping and Components................................................. 9 3.4.3 Class 3 System Pressure Tests................................. 11 1 l 3.4.3.1 Request for Relief No. PR-1, Hydrostatic Test of the i Class 3 High Pressure Portion of the High Pressure Cool ant Injecti on Syst em. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 f, l 3.4.3.2 Request for Relief No. PR-8, Hydrostatic Test of Service Water Lube Water System Class 3 Piping............ 12 3.4.4 Genera'l (No relief requests) ; 3.S General........................................................... 14 l l 3.S.1 Ultrasonic Examination Techniques (No relief requests) iv
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=3.5.2 Exempted Components (No relief requests) l 3.s.3 0ther................................................. .. . . .. .. . . 14 3.s.3.1 ' Request for Relief No. VR-2, Component Supports on the Service Water Piping for the Four Diesel Fuel Storage Chambers..................................... 14
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- 4. CONCLUSION........................................................... 17-
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i' l- 9 L I TECHNICAL EVALUATION REPORT ON THE FIRST 10-YEAR INTERVAL INSERVICE INSPECTION RELIEF REQUESTS: 3 CAROLINA POWER AND LIGHT COMPANY, ' BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2, DOCKET NUMBERS 50-325 AND 50-324
- 1. INTRODUCTION l
The Brunswick Steam Electric Plant, Units I and 2, First 10-Year Interval Inservice Inspection (ISI) Program Plan was previously evaluated in the s Nuclear Regulatory Comission's (MRC's) Safety Evaluation Report (SER) dated f May 19 -1983-(Reference 1),-and was determined'to be ecceptable for implementation during the first inspection interval. This SER also granted, conditionally granted,'or denied the requests for relief. The Licensee, Carolina Power and Light Company, subsequently submitted additional requests for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI (Reference 2) reovirements which the Licensee has determined to be impractical for the fhit inspection interval. These additional relief requests for the first inspection interval were included in Attachment 2 of the November 10, 1986 (Reference 3) submittal of the second 10-year interval ISI program plan. The first 10-year inspection interval ended July 10, 1986. As required by 10 CFR 50.55a(g)(5) (Reference 4), if the licensee detemines that certain Code examination requirements are impractical and requests relief from them, the licensee shall submit infomation and justifications to the NRC to support that determination. Pursuant to 10 CFR 50.55a(g)(6), the NRC will evaluate the licensee's determinations under 10 CFR 50.55a(g)(5) that Code requirements are impractical. The NRC may grant relief and may impose alternative requirements that it determines are authorized by law, will not endanger life or property or the comon defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the I licensee that could result if the requirements were imposed on the facility. 1
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l.' The available information in the November 10, 1986 submittal was reviewed. In a letter dated April 3,1987 (Reference 5), the NRC requested additional information that was ' required in order to complete the review of these r relief requests. The requested information was provided by the Licensee in a letter dated June 4, 1987 (Reference 6). The additional requests for relief for the first inspection interval are evaluated in Section 3 of this report. Unless otherwise stated, references to the Code refer to the ASME Code, Section XI, 1977 Edition including Addenda through Summer 1978.
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a . 2.. EVALUATION OF INSERVICE INSPECTION PROGRAM PLAN
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The Brunswick Steam Electric Plant, Units 1 and 2,- First 10-Year Interval ISI Program Plan was previously evaluated in the NRC's SER, dated May 19, 1983, and was determined to be acceptable for implementation during the first inspection interval. This SER also granted, conditionally granted, or denied the requests for relief.
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- 3. EVALUATION OF RELIEF REQUESTS The additional requests for relief from the ASME Code requirements which the Licensee has determined to be impractical for the first 10-year inrpection interval are evaluated in the following sections. .All of these relief requests apply to both Units 1 and 2, with the exception of Requests for Relief Nos. PR-7 and PR-9 which are applicable to Unit 2 only.
3.1 Class 1 Comoonents (No relief requests) i 3.2 C1 ass 2 Ctmoonents- (No relief tequests) 1 3.3 ' Class 5'Combonents' (No relief requests) ' 3.4 Pressure Tests 3 4.1 Class 1 System Pressure Tests (No relief requests) i 3.4.2 Class 2 System Pressure Tests l 3.4.2.1 Reouest for Relief No. PR-3. Pneumatic Test of Class 2 Control
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Rod Drive Nitrooen Accumulators l Code Requirement: Section XI, paragraph IWC-521D(a)(2) requires that the pressure retaining components within each , system boundary shall be subjected to a system hydrostatic I pressure test [IWA-5211(d)) at the system test pressure specified in paragr4ph IWC-5222(a) and visually e mained by the d method specified in Table IWC-2500-1, Examination Category C-H. Paragraph IWA-5211(e) states that a system pneumatic test.may be conducted in lieu of a hydrostatic pressure test for components within the scope of IWC'and IWD. Licensee's Code Relief Recues_t: Relief is requested from performing the system pressure test required by IWC-5210(a)(2) at ".he pressure specified in IWC-5222(a) on the Class 2 Control ; Roo Drive (CRD) nitrogen accumulators. 4 1
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Licensee's Pronosed Alternative' Examination: The Licensee- j states that a visual examination (VT-2) was perfomed on the CRD nitrogen accumulators at operating pressure. Lineasee's Basis for Reauestina Relief: The Licensee states . that, to obtain test pressure, a nitrogen cylinder pressurized to a minimum of 2189 psi would have to be hard piped to the instrumentation block cartridge valve. The design pressure of j the CR0 nitrogen accumulators is 1750 psig. Pressurization of 1 this system to such pressures poses potential safety concerns. s Because the test would need to be i.iTM on each of the 137 Hydraulic Control Units (HCUs)'for both Brunswick Units I and
- " - 2, thereis the potential for personnel errorfas well as the
' safety. concern associated with the pressurization.
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, Water and nitrogen are separated in the mater atcumulater by an internal piston with 0-rings and seals. These seals nomally see a differential pressure of 450 psi applied in the reverse direction (1.e., applied on the nitrogen). The ir. creased pressure applied during a pressure test could cause nitrogen ,
I leakage into the water side of the piston, thereby resulting in 1 slower CRD insertion times and necessitating venting of the piping. k The purpose of ASME Section XI hydrostatic / pneumatic testing is l to identify degradation of the pressure boundary which is I reflected by through-wall leakage. As this portion of the CRD
' system remains in a static condition filled with nitrogen. I 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 j on-line monitoring system. Should nitrogen pressure drop to
. 940-970 psi, an automatic alarm is sounded in the Control 1 i
Room. This on-line system provides better assurance of the structural integrity than the pneumatic test performed once every 10 years.
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Evaluation: The Code-required system pneumatic test of the Class 2 CRD nitrogen accumulators is impractical because the possibility exists for nitrogen leakage into the water side of j i the internal piston that separates the water and nitrogen, I thereby resulting in slower CRD insertion times and necessitating venting of the piping. The visual examination of the CRD nitrogen accumulators performed at operating pressure, along with the on-line monitoring system for detection of a nitrogen pressure drop, provides a reasonable assurance of the integrity of the accumulators.
Conclusions:
Based on the above evaluation, it is concluded
.- that the Code requirement is impractical and that compliance with the specific requirements of Section 11 would result in f
hardship or unusual difficulties without a compensating 1 increase in the level of quality and safety. Therefore, it is reconcended that v 9 1ef be granted as requested. 3.4.2.2 Reauest for Relief No. PR-4. Hydrostatic Test of the Class ? Portion of the Main Steam System Code Requirement: Section XI, Subarticle IWC-5222(a) requires a hydrostatic pressure test of this Class 2 portion of the Main Steam System at a pressure of 1105 psig. , licensee's Code Relief Reevgb blief is requested from performing the Code-required hydrostatic pressure test of the Class 2 portion of the Main Stear System at the test pressure of 1105 psig. Licensee's Prooosed Alternative Examination: .The. Licensee states that a visual examinatiori (VT-2) was performed during a system hydrostatic test of the l'enctor Pressure Vessel and associated Reactor Coolant System piping at a pressure of i approximately 1088 psig by including the Class 2 Main Steam piping within the test boundary. l 6 1
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Licensee's Basis for Recuestino Relief: The Licensee states that the Main Steam Isolation Valves, which are the only i isolation valves between the Class 1 and Class 2 piping, are j unidirectional type valves designed to citise on flow from the Reactor Vessel. The hydrostatic test would require a pressure 1 of 1105 psig to be placed against the valve seat from the outboard side. These valves are designed to withstand j l approximately 25 psig from the opposite side. An imposed j pressure of 1105 psig on these valves when they are gagged l
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could cause damage to the stem and force the valves open,
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resulting .in. water entering.the reactor.vassel .at approximately 1305 psig.
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Evaluation: Because the system's design does not pemit j
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pressurizing the sect 16ns' of piping to the Code-required pressure from the Class 2 piping side,"the performance of the Code-required hydrostatic pressure test from the Class 2 piping side is impractical. The required visual examination of the l piping during the alternative pressure test as well as the 1 other required NDE of the welds in the system provide l reasonable assurance of the integrity of the piping. Tne f difference in the required test pressure and that proposed by the Licensee does not warrant imposition of the Code requirement. , j
Conclusions:
Based on the above evaluation, it is concluded { that the Code requirement is impractical and that the ' alternative test proposed by the Licensee, in conjunction with - the other NDE requirements, ensures an acceptable level of inservice structural integrity. Compliance with the specific - requirements of Section XI would result in hardship or unusual difficulties without a compensating in' crease in the' level of l quality,and safety. Therefore, it is recommended that relief I be granted as requested. I 7 l l I
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o . 3.4.2.3 Reauest for Relief No. PR-7. Hydrostatic Test of Unit No. 2 ,
-Class 2 Welds Uostream of RHR Heat Exchancers
} Code Requirement: Section XI, paragraph IWC 5210(a)(2) requires that the pressure retaining components within each system boundary shall be subjected to a system hydrostatic pressure test [IWA-5211(d)] at the system test pressure 7 specified in paragraph IWC-5222(a) and visually examined by the method specified in Table IWC-2500-1, Examination Category C-H. i Licensee's Code Relief Reauest: Relief is requested from i i . performing the system hydrostatic pressure test required by IMC-5210(a)(2) at the pressure specified is IWCd222(4) on weld ) - numbers 2-Ell-140 and 2*E11-FW1384 opstreen of RHR Heat , f E'x changer *2A and welds 2-Elt-FW82A and 2-E11 A00 spstreae of P)fR Heat Exchanger 28, installed under plant Modification 85-056 for Unit No. 2. Licensee's Prooosed Altemative Examination: The Licensee states that a visual (VT-2) examination was performed during a system functional test (IWC-5221) and the Code-required 100% surface examination was also performed. Licensee's Basis for Reauestina Relief: The U tenses states that, in order to pressure test the subject welds, the tube
- side of the AHR heat exchangers would be pressurized to 1400 psig, which could damage the heat exchangers. (RHR heat exchangers have a maximum design rating of 415 psig.)
Evaluation: -The system's design does not permit pressurizing the subject welds to the Code-reg'uired pressure without overpressurizing the RHR heat exchangars. Because of this, the i Code-required hydrostatic pressure test is impractical. The visual examination during the alternative test, along with the surface examinations, provides a reasonable assurance of the integrity of the welds. l 8 , I
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Conclusions:
Based on the above evaluation, it is concluded that the Code requirement is impractical and that compliance with the specific requirements of Section XI would result in j hardship or unusual difficulties without a compensating increase in the level of quality and safety. Therefore, it is recommended that relief be granted as requested. 3.4.2.4 Recuest for Relief No. PR-9. Hydrostatic Test of Unit No. 2 Main Steam System Class 2 Pioino and Comoonents Code Requirement: Section XI, paragraph IWC-5210(a)(2) requires that the pressure retaining components within each
._ system boundary shall be, subjected to. a. system hydrostatic .
, - pmssum test.(IWA-5211(d)] at the system test pressure
> + specified in paragraph IWC-5222(a) and shall be visually examined by the method specified in Table IWC-2500-1, Examination Category C-H. Licensee's Code Relief Reouest: Relief is requested from performing the system hydrostatic pressure test on the Unit No. 2 Main Steam System Class 2 piping and components as , required by IWC-5210(a)(2) at the pressure specified in l IWC-5222(a)- 1 Licensee's Procosed Alternative Examination: Th'e Licensee ] states .that a visual (VT-2) examination was performed during a j system functional test, as defined by IWC-5210(a)(1), utilizing a four-hour minimum hold time. This type of test was at a - pressure of 950 psig which is 140 psig lower than that which would be imposed during the hydrostatic test. ! Licensee's Basis for Reouestino Relief: The Licensee states that, in order to pressurize the subject piping system and j components, the turbine stop valves would need to be used as I test isolation valves. These valves (MS-SV-1, MS-SV-2, 1 MS-SV-3, MS-SV-4) are designed to reduce turbine speed (with no 1
1 load on the turbine) approximately one third. During l performance of the Unit No. 2 hydrostatic test, which was ) attempted on April 22, 1986, it was determined by temperature 3 indication on both sides of these stop valves, along with pressure indications for the turbine, that the stop valve seats j were leaking considerably. Cycling the valves during the test f to try and seat them was not practical due to the potential of ) inducing large volumes of water to the turbine. These valves l are non-safety related, they provide no containment isolation l function, and have no specific requirements for maximum leakage j , , (reference FSAR Section.15.6.3). . These valves are maintained j on.a five-year maintenance schedule controlled by a plant { maintenance instruction. (M1-la-526). They. are.ast . scheduled for maintenance until late 1987 (MS-SV-3 wid MS-SV-4) and 1990 (MS-SV-1 and MS-SV-2). Evaluation: The leaking valve seats do not permit pressurizing the sections of piping to the Code-required test pressure without inducing large volumes of water to the turbine. ] Because of this, pending maintenance of the valves, the
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Code-required hydrostatic pressure test is impractical. The
. visual examination during the alternative test provides a i reasonable assurance of the integrity of the subject Class 2 piping and components. ,
Conclusions:
' Based on the above evaluation, it is concluded i that, pending maintenance.cf the valves, the Code requirement is impractical and that compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality. and safety. Therefore, it is recommended that relief be granted as requested for' the first 10-year inspection interval. 10
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3.4.3 Class 3 System Pressure Tests ! 3.4.3.1 Reouest for Relief No. PR-1. ' Hydrostatic Test of the Class 3 3 Hiah Pressure Portion of the Hiah Pressure Coolant Iniection ! l i , System [ ode Requirement: Section XI, Subarticle IWD-5223(a) requires < I ) a hydrostatic pressure test of this Class 3 portion of the High L l Pressure Coolant Injection (HPCI) System at a test pressure of I ( at least 1.10 times the' system pressure for systems with Design ( ,, . . Temperature of_200*F,or _ lass,. and at least 1.25 times the j system pressure for systems with Design Temperature above j
- 4 ,200*F. ^The system pressure shell.be the lowest pressure
[ setting among the number of safety or relief valves provided i for overpressure protection within the boundary of the system ) to be tested. Licensee's Code Relief Reauest: Relief is requested from l performing the Code-required hydrostatic pressure test of the Class 3 portion of the HPCI System (approximately two-foot 1 section of pipe between E41-F059 and E41-PCV-F035 on line number 11-2-605) at the required test pressure. 1 Licensee's Proposed Alternative Examination: The Licensee i
. i states that a visual examination (VT-2) was performed during j the system hydrostatic pressure test of the low pressure side
' of the system and included line number 11-2-605 as part of the l iguarterly VT-2 amasinations performed on the system. j I
, ,, Licensee's Basis for Reouestino Relief: The Licensee states j that the piping between E41-F059.and E41-PCV-F035 (line number n 11-2-605) has a design rating of 460 psig, whereas the piping downstream of E41-PCV-F035 has a design pressure rating of 150 psig. The E41-PCV-F035 valve is a pressure control valve providing a pressure drop across the valve, preventing overpressurization of the low pressure portion of the system.
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Since this valve is designed with holes in the valve disc, it cann'ot be used as a boundary valve for the hydrostatic pressure test, thus making the hydrostatic test requirement impractical. Evaluation: The system's design does not permit pressurizing this section of piping to the Code-required pressure without either extensive temporary valve modifications or j overpressurizing the low pressure portion of the system. Because of this, the Code-required test pressure for this two-foot section of piping is impractical. The visual
< dnspection of. the two-foot section of piping during the
, alternative pressure tast-provides a. reasonable. assurance of
' the integrity of the piping.
Conclusions:
Based on the above evaluation, it is concluded that the Code requirement is impractical.and that the alternative test proposed by the Licensee ensures an acceptable level of inservice structural integrity. Compliance with the specific requirements of Section XI'would result in hardship or unusual difficulties without a compensating increase in the { 1evel of quality and safety. Therefore, it is recommended that I relief be granted as requested. . 3.4.3.2 Renuest for Relief No. PR-8. Hydrostatic Test of Service Water. ' Eube Water System Class 3 Pinino l Code Requirement: SectionXI,paragraphIWD-5210(a)(3) ! requires that the pressure retaining components within the boundary of each system specified in the Examination Categories of Table IWD-2500-1 shall be subjected to a system hydrostatic pressure test (IWA-5211(d)] at the system test pressure specified in paragraph IWD-5223(a) and examined in accordance with Table IWD-2500-1.. Listniee's Code Relief R qug11: Relief is requested from , performing the system hydrostatic pressure test required by ) 12 J
H. , r, , . IWD-5210(a)(3) at the pressure specified in IWD-5223(a) on Service Water Lube Water System Class 3 piping that supplies lubricating water to the bearings of all five Service Water Pumps. l Licensee's Proposed Alternative Examination: The Licensee states that a visual (VT-2) examination will be performed y during a system inservice test as defined by IWD-5210(a)(1) until the system is deactivated. )
, Licenska's Basis for paaa=stina Ralief: . , The Licensee. states l
, that the pfping: involved in this. test supplies. lubricating waters to the heariaps of all five service Water pumps. - This .
common piping p meludes runntag of these pumps during the hydrostatic pressure test as the pumps can only be run a very
-short period of time at the test pressure without damage to the bearings. Based on the four-hour hold time for the hydrostatic pressure test, it is the 1.icensee's position that this test is impractical.
I i NOTE: The Licensee reports that this piping system was scheduled to be deactivated in late 1987 by plant modification which includes a new bearing design. Evaluation: Because the bearing dc. sign does not permit j pressurizing the piping for the hold time aquired without k
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damage to the bearings,. the Code-required hydrostatic pressure f test is impract'ical. Relief will not be required after the new - { bearings are installed. The visual examination, until the j system is deactivated to install the new bearings, will provide # a reasonable assurance of the integrity of the piping.
Conclusions:
Based on the above evaluation? it is concluded that the Code requirement is imprcetical until the new bearings ) are installed and that compliance with the specific ) requirements of Section XI would result in hardship or unusual 13 I
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difficulties without a compensating increase in the level of quality and safety. Therefore, it is recommended that relief be granted as requested for the first 10-year inspection
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3.4.4 General (No relief requests) l 3.5 General 3.5.1 Ultrasonic Examination Technioues (No relief requests) 3.5.2 Exemoted Comnonents (No rel-lef requests) 3.5.3 Q1htt 3.5.3.1 Recuest for Relief No. VR-2. Comoonent Sunoorts on the Service Water Pipino for the Four Diesel Fuel Storace Chambers Code Requirement: Section XI, Table IWF-2500-1 requires a 100% visual examination (VT-3 and VT-4) of the component supports as defined by Figure IWF-1300-1. Licensee's Code Relief Recuest: Relief is requested from removing the fire retardant from the component supports on the Service Water Piping for the four Diesel Fuel Storage Chambers in order to perform the required VT-3 and VT-4 visual examinations. Licensee's proposed Alternative Examination: The Licensee states that these supports were v.isually inspected once during
, the interval with the fire retardant Pyrocrete 102 remaining on the supports. They were examined for any condition which might indicate that the support has been structurally degraded (i.e.,
severely cracked or missing pyrocrete, support entirely detached from the component). 14
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Licensee's Basis for Reauestino Relief: The Licensee states i that the component supports on these lines are covered by fire retardant Pyrocrete 102 as mandated per 10 CFR 50 Appendix R, Fire Protection Program for Nuclear Power Facilities Prior to l . January 1, 1979, and Branch Technical Position APCSB 9.5-1, Appendix A, Guidelines for Fire Prctection for Nuclear Power l Plants Docketed Prior to July 1, 1976. This material has been l applied to cover the entire support from the component to the i ceiling / wall for all component supports.
.(a) Pyrocrete 102 is.an extremely herd,Myid seterial. When l- . applied, it is considered to be a periaanent feature of the
, system andis expected to 1rndurehs.-the life span of I the facility. To remove this unterial fna these supports and components would require chipping the material from
! ,the support and/or component. This poses poteetial damage to the supports and/or components. (b) The subject supports represent approximately five percent of the total Service Water System component supports, and I thus do not encompass a large percentage of the supports on the Service Water System. 1 (c) With the exception of the two component supports at the south end of each header line (Lines 2-SW-235-18-157 and l 1-SW-217-18-157), all supports are basic U-bolt type supports. These supports have no saving parts, thereby ( eliminating problems associated with supports that have moving parts. The remaining two supports are rigid strut type supports. l 1 l [yaluation: Removal of the permanently installed fire retardant of the type described above in order to perform the l visual examination of the subject component supports is l impractical because the possibility exists for damage to the l supports and components. Because the Pyrocrete is a hard, I 15 i : 1
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rigid material, any movements of the supports should cause noticeably visible damage to the Pyrocrete. Therefore, the Licensee's proposed visual examination of these supports with the fire retardant in place is an acceptable alternative to the Code requirement. l l Ling.bsions: Based on the above evaluation, it is concluded j that compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
- Therefore, it is recommended that relief be granted as requested. .
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- 4. CONCLUSION Pursuant to 10 CFR 50.55a(g)(6), it has been determined that certain i Section XI required inservice examinations are impractical. In these cases, the Licensee has demonstrated that either the proposed alternatives would provide an acceptable level of quality and safety or that compliance with the requirements would result in hardships or unusual difficulties without a compensating increase in the level of quality and safety. l I
This technical evaluation has not identified any practical method by which the existing Brunswick Steam E16ctric Plant, Units 1 and 2, can meet all the
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, specific inservice inspection requirements of Sectica XI of. the ASME Code.
{ Requiring compliance with all the exact.Section XI required-inspections would require redesign of' a significant number of. plant systems, acquisition of sufficient replacement components, installation of the new components, - and a baseline examination of these components. A number of the piping and component support systems would require redesign to meet the specific inservice examination provisions. Even after the redesign efforts, complete compliance with the Section XI examination requirements probably could not be achieved. Therefore, it is concluded that the public interest is not served by imposing certain provisions of Section XI of the ASME Code that have been determined to be impractical. Pursuant to 10 CFR 50.55a(g)(6), relief is allowed from these requirements which are impractical to l implement. , I f'P 17 1
~
l . M 1
- 5. REFERENCES j
- 1. Letter, dated May 19, 1983, D.B. Vassallo (NRC) to E.E. Utley (Carolina Power and Light Company (CP&L)), ' Safety Evaluation Report Related to Requests for Relief from Inservice Inspection Requirements
- for Brunswick Steam Electric Plant, Units 1 and 2.
- 2. American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, Division 1:
1977 Edition through Sumer 1978 Addenda I )
- 3. Letter, dated November.10 198f, A.B. Cutter '(CP&L) to DcMuller (NRC),
l submittal of the' Brunswick Steam Electric Plant, Units 1 and 2, Second b '10-Year Interval Inservice inspection trogram Plan, Revision D, and I relief requests for the first. and second 10-year inspection intervals.
- 4. Code of Federal Regulations, Volume 10. Part 50.
- 5. Letter, dated April 3,1987, E.D. Sylvester (WRC) to E.E. Utley (CP&t),
request for additional information with regard to'the first 10-year inspection interval relief requests.
- 6. Letter, dated June *, 1987, S.R. Zimmersan (CP1L) to NRC, " Response to j Requests for Information.' {
/
e 18
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. 'u"'",d' i' SISUOGRAPHIC DATA SHEET EGG-SD-7916 n . ,.we, o.. . .. ..n
*TfcMiic'ai"EvaluationReportontheFirst10-Year ' " ' ' " " ' '
Interval Inservice Inspection Relief Requests: Carolina Power and Light Company, Brunswick Steam Electric Plant, . .. , . .. , c o.,,a , , , Units 1 and 2. Docket Numbers 50-325 and 50-324 . g ....
,,,,,,,,,, January . 1988
...,...,i.w.D I B.W. Brown, J.D. Mudlin ,,
January l 1988
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EG&G Idaho, Inc. ..,.w. P. O. Box 1625 . Idaho Falls ID 83415-2209 . FIN-D6022 (Project 5)
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Materials Engineering. Branch . Technical . Office of Nuclear Reactor Regulation "~" / U.S. ' Nuclear Regulatory Commission ~~ * ' ' " ' ' . - - ' ~ ~ Washington, D.C. 20555
'a mas,..C, J.P e.ou, er u ,
This report presents the results of the evaluation of the Brunswick Steam Electric Plant, Units I and 2, first 10-year interval inservice inspection (ISI) requests for. relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI requirements which the Licensee has determined to be impractical. I
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s . . .,.gg, . Unlimited
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Unclassified i, .sw . Os ..s..
- 1. .C. I
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