ML20246D229

Reiterates Request for Technical Meeting W/Nrc Re Util 890523 Request for Exemption from Performing Required Integrated Leak Rate Testing During Upcoming Refueling Outage.Util Does Not Concur W/Nrc Assessment of Request

ML20246D229
Person / Time
Site:	Brunswick
Issue date:	08/21/1989
From:	Loflin L CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS-89-234, TAC-73271, NUDOCS 8908250297
Download: ML20246D229 (4)

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SER'IAL: NLS-89-234  !

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• (United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington,.DC 20555

-BRUNSWICK STEAM ELECTRIC PLANT, UNIT NO. 2-7 DOCKET NO.'.50-324/ LICENSE NO. DPR-62 JEXEMPTION REQUEST 10CFR50, APPENDIX J v, TYPE A TESTING FREQUENCY.

(NRC TAC NO.'~73271)-

Centlemen:

i. INTRODUCTION  ;

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~ On July 20, 1989, the NRC provided the results of a preliminary review (of.the., Company's May 23,.1989 request for an exemption from performing 1 the required' Brunswick-2~.ILRT during the upcoming refueling outage. ,j Carolina Power'& Light Company does not concur with the NRC's' assessment

, .of the' exemption request. .CP&L made the request in good faith,.in a effort to deal:with a significant issue for the Brunswick Plant.

, When the May 23,'1989 request was made, CP&L recognized that, as with any technicallissue, further dialogue would be necessary to resolve

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m technical questions. ' Several attempts were made with the Project j Manager.to schedule ~a technical meeting with'a staff reviewer so that ]

these questions could be raised and addressed expeditiously. ]

i.  : A tentative agenda: for a meeting was provided to the Project Manager. y The NRC would not' schedule such a meeting. The Company hereby. .

reiterates its request for a technical meeting with the Staff regarding )

-this issue. l I

e The following discussion provides a brief summary of CP&L's position on -j the specific concerns raised by the NRC's preliminary review. Further, j more detailed information can be provided should a technical meeting be  !

scheduled. l 1

DISCUSSION

-Issue li The NRC stated f. hat the discussion regarding

. Brunswick's overly conservative La leakage limit of 0.5%.was-not pert.inent to the request and that the I request must stand on its own merits. What is

,. acceptable at other facilities is not necessarily acceptable at Brunswick.

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Docum:nt Control Desk NLS-89-234 / Page 2

Response

The discussion regarding the La Primary containment leakage limit was not intended to be a basis for granting the exemption. Instead, it was additional information intended to demonstrate that recent containment integrity at Brunswick-2 has been good and to show the NRC that CP&L is pursuing enhancements to the overall containment integrity issue. This information was provided in a Summary section of the request, after the techni a1 discussion and 10 CFR 50.12 analysis, which made no mention of the Coipany's plans to request an increase of the La limit.

As stated in the Company's submittal, the requested exemption is based on the guidance provided in Information Notice 85-71 which indicated that the NRC would consider exemption to the accelerated Type A testing frequency incurred after the failure of two successive Type A tests when these failures were a result of leakage penalty additions made due to Type B and C testing. The technical information and history of the 1906 and 1988 ILRTs demonstrates that although the previous two Brunswick-2 ILRTs did not meet existing Technical Specification acceptance criteria, the failures were due to extenuating circumstances which are not indicative of overall containment integrity. As such, the primary reason for failing these ILRTs is leakage penalty additions from Type C testing, independent of the existing primary containment leakage limits.

Further strengthening this case is the fact that the NRC has concurred with Duke Power Company's position that requiring Type B and C penalties to be added to Type A testing results constitutes a backfit.

Issue 2: The problems with valves CAC-V16 and CAC-X20A were not identified by CP&L's " strong" Type B and C testing program. There is no justification in the request to demonstrate that the Type B and C testing program will correct these problems in the future.

Response

The May 23, 1989 exemption request demonstrated the problems with valves CAC-V16 and CAC-120A to be an isolated incident. Pressurizing the section of pipe between CAC-V16 and CAC-X20A for the LIRT caused CAC-X20A to seat, despite a rust bloom under the surface. As such, the CAC-X20A problem was not detected during the LLRT. This problem was discovered during the performance of the ILRT because some dirt or debris lodged in valve CAC-V16, allowing a small flow through the valve which was not enough to pressurize the area between the valves and re-seat CAC-X20A. No problems were encountered with this penetration during the March 1988 ILRT or subsequent LLRTs. Given the situation, it was impossible to detect the rust bloom via an LLRT. The failure to do so does not indicate a less than adequate Type B and C testing program.

In fact, the Region II Inspector has been very impressed with the Brunswick program in recent years and encouraged CP&L to pursue the Appendix J exemption request.

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'Documsnt Cantrol Desk NLS-89-234 / Page 3 Issue 3: The NRC stated that the operational difficulties in maintaining a constant containment temperature and pressure which caused the failure of the 1988 ILRT would not have been compensated for,by the Brunswick Type B and C testing program. .It was suggested'that perhaps the ILRT was initiated prematurely.

Response-The 1988'ILRT was not initiated prematurely. The' root cause of the temperature control. problem was the design of the residual heat removal

. (;RHR) system. The RHR system is not designed to control vessel temperature to the essentially constant value required-for the ILRT.

Mais problem is not unique to Brunswick or to this particular test.

Many hours of planning and scheduling precede an outage. The 1988 ILRT was conducted during its scheduled window. A typical ILRT adds 1approximately one week of critical path time to an outage. It is in-the

.best interest of the consumers, the Company and the NRC to see that outages are managed effectively and be of minimum duration. Extended ILRTs and unnecessary ILRTs do not support this goal.

Issue 4: The-July 20, 1989 NRC letter states: "Although your exemption request was dated May 23, 1989, your application was not considered complete until the staff received your June 14, 1989 request for an associated TS change. Your request to have the exemption by August 5, 1989 is considered unreasonable. You failed your second test in March 1988 and it.took you over 1 year to ask for relief.

You subsequently expected the staff to perform its evaluation over the course of a few weeks, which puts an unnecessary burden upon the staff."

Response-While the initial request could have been made prior to May 23, 1989, the delay in beginning the staff review until after submittal of the subsequent license amendment request was not warranted. The information required for the exemption request is contained in the request itself.

The Company considered the possible need for a license amendment during preparation of the request and determined that a change would not be

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necessary. It is CP&L's position, based on previous interactions with

. Region II, that granting of the exemption by the NRC would be L sufficient. The subsequent license amendment request was made at the NRR's incistence and does not reflect a change in the Company's l position.

Issue 5: 1he NRC stated that it would be beneficial to the staff to have testing result summaries for all Brunswick-2 Type A tests.

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.Docusint Control D2sk' NLS-89-234 / Page 4

Response

.Only the last two ILRTs were. addressed in'the Company's request because the passing of two successive ILRTs is sufficient to resume the normal retest schedule in accordance with Section III.D of 10CFR50 Appendix J.

Brunswick-2 ILRTs performed prior to 1986 are not directly related to the technical justification of this exemption request. Results of-previous Brunswick-2 ILRTs will be made available'to'the Staff at the

. requested. technical meeting.

CONCLUSION 1

lIn' conclusion, the May 23,:1989 Appendix J exemption request was a good-faith effort on the part of CP&L to deal with a significant issue at the

' Brunswick. Plant. The Company is proceeding with plans to perform an

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'ILRT during the upcoming refueling outage. While the optimum approval schedule of August 5, 1989 1 no longer possible, substantial benefits

-can still be achieved'through the reduction in outage. length if the

. requested exemption is_ approved. As such, Carolina. Power & Light

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. Company requests resolution of-this issue by November 10, 1989.

Please refer any questions regarding this submittal to Mr. William R.

Murray at (919) 546-4661.

Yours very truly, A

P Leonard'I. lin Manager Nuclear'Licensi g Section LIL/ MAT cc: Mr. S. D. Ebneter Mr. W. H. Ruland Mr. E. G. Tourigny

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