ML20246M157

Forwards Requests for Addl Info Re Util Response to Generic Ltr 88-01.Info Should Be Provided within 60 Days of Ltr Date

ML20246M157
Person / Time
Site:	Brunswick
Issue date:	05/11/1989
From:	Tourigny E Office of Nuclear Reactor Regulation
To:	Eury L CAROLINA POWER & LIGHT CO.
References
GL-88-01, GL-88-1, TAC-69128, TAC-69129, NUDOCS 8905190057
Download: ML20246M157 (20)

Text

. _ _ _

s ,

h  ;[l May 11, 1989 DISTRIBUTf0N Docket < File" NRC PDR ACRS(10)

LSpessard Docket Nos.- 50-325 and 50-324 Local PDR- MNBB 3701!

PDII-1 r/f

' Mr. Lynn W. Eury Brunswick r/f SVarga Executive Vice President

. Power Supply Glainas EAdensam l Carolina Power and Light Company ETourigny J

Post Office Box 1551 Raleigh, North Carolina 27602 PAnderson 0GC 15-B-18

Dear Mr. Eury:

EJordan MNBB 3302 BGrimes 9-A-2

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) PERTAINING TO CAROLINA- 1 POWER'8 LIGHT COMPANY'S RESPONSE TO GENERIC LETTER 88-01 FOR BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 (TAC NOS. 69128 AND 69129):

l Based on a preliminary review of your submittal in response to Generic '

Letter 88-01 for the Brunswick plant, the staff and its contractor, Viking Systems International, have determined that additional information is needed tc complete this review. The additional information needed is identified in '

the enclosure.

It is requested that this information be provided within 60 days of the date of this letter. If you have any questions regarding this request or schedule please call me at (301) 492-1474.

To expedite the review process,. it is requested that a copy of your RAI '

response be sent directly to the staff's contractor at the following address:

8 Dr. Armand A. Lakner "

Director, Safety and Reliability Viking Systems International 101 Chestnut Street {

Gaithersburg, ND 20877 '

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely, Original Signed By:

l E. G. Tourigny, Project Manger Project Directorate 11-1 l Division of Reactor Projects I/II

Enclosure:

l As stated cc: See next page

[R 'SWICK PLANT] M LA PP ,,

PA 04/J!//89 son 04W//69 iny/jd D:PD21h{

EAdensam g 04/g/89[

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8905190057 890511 PDR ADOCK 05000324 P PDC

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' Mr. L. W. Eury Brunswick Steam Electric Plant' Carolina Power & Light Company Units 1 and 2 l

cc:

Mr. Russell B. Starkey, Jr. Mr. J. L.' Harness Project Manager Plant General Manager I Brunswick Nuclear Project Brunswick Steam Electric Plant P. O. Box 10429 P. O. Box 10429 Southport, North Carolina 28461 Southport, North Carolina 28461 Mr. R.'E. Jones, General Counsel Mr. H. A. Cole 2 Carolina Power & Light Company Special Deputy Attorney General P. O. Box 1551 State of North Carolina Raleigh, North Carolina 27602 P. O. Box 629 Raleigh, North Carolina 27602 Mr. Mark S.'Calvert Associate General Coansel Mr. Robert P. Gruber Carolina Power & Light Company Executive Director P. O. Box 1551 Public Staff - NCUC Raleigh, North' Larolina 27602 P. O. Box 29520 Raleigh, North Carolina 27626-0520 Ms. Grace Beasley Board of Connissioners P. O. Box 249 Bolivia, North Carolina 28422 Mrs. Chrys Baggett State Clearinghouse Budget and Management 116 West Jones Street Raleigh, North Carolina 27603 Resident Inspector U. S. Nuclear Regulatory Commission Star Route 1 P. O. Box 208 Southport, North Carolina 28461 Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Mr. Dayne H. Brown, Chief Radiation Protection Branch Division of Facility Services N. C. Department of Human Resources 701 Barbour Drive Raleigh, North Carolina 27603-2008

(Unit 1)

ATTACHMENT A GENERAL QUESTIONS / REQUESTS Reviews of several licensee submittals has shown that most (although not all) of the submittals connonly lack certain information that is needed for evaluation  ;

of the submittals. 'hus, this general list of questions and requests has been 1

prepared for submission to each of the licensees. For those attachment for which the requested information was supplied in the(portions detail of this requested herein) in the original submittal, the utilities may reference the relevant pages or tables in the original submittal and supply only the requested information that was not provided. Please certify that you comply with the staff positions in GL-88-01 or identify and justify any deviations taken.

Item 1. Position on NRC Staff Positions Generic Letter 88-01 states on page 3:

" Pursuant to 10 CFR 50.54(f), you, as a BWR operating reactor licensee or construction permit holder, are requested to furnish, under oath or affirmation, your current plans relating to piping replacement, inspection, repair, and leakage detection. Your response should indicate whether you intend to follow the staff positions included in this letter, or propose alternative measures."

The staff positions outlined in Generic Letter 88-08 include positions on: (1) Materials. (2) Processes. (3 Water Chemistry. (4) Weld Overlay. (5) Partial Replacement. (6)) Stress Improvement of Cracked 4 Weldments. (7)ClampingDevices. (8) Crack Evaluation and Repair Criteria. (9) Inspection Method and Personnel. (10) Inspection Schedules. (11) Sample Expansion. (12) Leak Detection. (13)

Reporting Requirements.

Please supply information concerning whether the licensee: (1) endorses these positions, (2) proposes alternate positions, exceptions,orprovisions,and(3)isconsideringorplanningto apply them in the future. Please describe any alternate positions, exceptions, or provisions that are proposed.

Please supply this information using a table such as the illustrated in the example shown in Table 1.

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Table 1 Responses to NRC Staff Positions I Licensee Response

• Licensee Has/Will**

Accept Requests with Alternate Applied Consider for Staff Position _ Accept Provisions Position in Past Future Use

1. Materials

2. Processes

3. Water Chemistry

4. Weld Overlay

5. Partial Replacement

6. Stress Improvement of Cracked Weldsents

7. Clamping Devices

8. Crack Evaluation and Repair Criteria

9. Inspection Method and Personnel

10. Inspection Schedules

11. Sample Expansion

12. !aak Detection

13. Reporting Requirements

• Answer with "yes", " check mark" or "I" in appropriate column for each of the 13 NRC Staff Positions. List and explain each provision and/or alternate l position (or reference original submittal if it contains the listing and explanation). Use separate page(s) if needed.

• • Answer with "yes" or "no", as appropriate, in each column for each of 13 NRC ,

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Staff Positions. I A-2 1

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ATTACHMENT A (continued)

Item 2. Inservice Inspection Program Generic Letter 88-01 requests on page 3:

"Your current plans regarding pipe replacement and/or other measures taken or to be taken to mitigate ICSCC and provide assurance of continued long-term integrity and reliability."

"An Inservice Inspection Program to be implemented at the next refueling outage for austenitic stainless steel piping covered under the scope of this letter that conforms to the staff positions on inspection schedules methods and personnel, and sample expansion included in this letter."

The information pertaining to the pipe replacement and other mitigating actions as well as the Inservice Inspection Program provided in most of the licensee submittals were either incomplete or did not provide the background data that is needed to evaluate the ISI Program such as (1) reasons / justification for ICSOC classification of welds, (2) methods, personnel qualification, schedules and identities of welds inspected, and (3) results of previous inspections, and/or identities of welds to be inspected during future i'nspections.

Thus, the following information is requested:

1. A listing of all welds by system, pipe air.e. configuration (e.g., pipe to elbow, pipe to valve, etc.), drawing number (piping ISO with weld I.D.), location (i.e., inside or outside of containment, etc.), weld I.D. number, and ICSCC classification (i.e. IGSOC Category A, B, C, D, E F and C).

2. Reason / justification for the classification of each weld, using such information as (a) weld history such as heat sink welding (HSW), (b) pipe and weld metal compositions or material i identities to show either conforming material or non-conforming material (c) mitigating treatment (s) applied such as solution heat treating (SHT), stress improvement (IHSI or MSIP).

3. Identity of welds to be inspected during past and future refueling outage. Include (a) dates and results of previous inspections (b) flaw characteristics including orientation (axial or circumferential), maximum length, maximum depth, repairs and/or mitigating treatments applied.

Please supply this information in tabular form using formats such as that illustrated in Tables 2 and 3.

A-3

Table 2 History of Welds and Prior Mitigating Actions / Treatments

• Material **

IGSCC Weld Dia. Casting Treatment *M Qty System Wumber Configuration Inch Fornina Pipe Veld SHT R$W CRC SI 0.L.

Notes:

• List each weld separately, using ons or more lines as required.

• • For materials ioentify as non-conforming or conforming as appropriate concerning whether it conforms with the NRC Staff position on resistant materials. If conforming, identify the material type (e.g., Type 316 NG).

• • • For treatment list "I" under appropriate column (s) if weld was treated using indicated technique, i.e., solution heat. treated (SHT), heat sink welded (HSW), corrosion resistant clad (CRC),

stress improved (SI), or overlayed (0.L.). For SI, add explanation of method used, i.e., whether by induction heating or mechanical, whether pre and/or post treatment inspection was applied using methods and personnel qualified under NRC/EPRI/BWROG coordination plan, and whether treatment was applied within two years of sarvice date. Also add explanation and justification of any overlays that were not standard (per NRC Staff position).

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Table 3 Inspection Schedules Inspected /To Be Inspected / Flaws Found IGSCC Weld Dia. Past Future Caten System No. Inch. Configuration R.O.fX-2 R.O.fX-1 Flav R.O.fX R.O.fX+1 1

Instructions:

1. Under the heading, " Inspected /To BE Inspected," use as many columns as required to describe the following:

'(a) All previous inspections that were conducted (per NUREG 0313 Revision 2, page 5.2) using methods and personnel qualified under NRC/EPRI/BVROG coordination plan as upgraded in September, 1985.

plus (b) A sufficient number of future inspections to demonstrate that the schedules will follow the N.tc Staff positions as given in Table 1 in Generic latter 88-01.

2. Replace R.O.i (I-2 I-1. I, K+1) with setuni refueling outage numbers. Indicate dates iupections were/will be performed.

3. List each weld within the scope of Generic 14tter 88-01.

4. Place an "I" or other appropriate symbol under the appropriate column for each refueling outage for which that weld was inspected or will be inspected.

5. Indicate with "yes" under column marked " flaw" if a flaw indication was found. Attach a statement for erch flawed weld giving the orientation (axial or circumferential), the diner.sions (maximum length asd depth), and describing any repairs made.

A-5

ATTACHMEKT A (continued)

Item 3. Welds Covered ir Licensee Submittel Generic Intter 88-01 (on page 2) states:

"'!his Generic latter applies to all BWR piping made of sustenitic stainless steel that is four inches or larger in nominal diameter and contains reactor coolant at a temperature abova 200*F during power operation regardless of Code classification. It also applies ,

to reactor vessel attachments and appurtenances such as jet pump '

instrumentation penetration assemblies and head spray and vent components."

Were any welds that fall within this defined scope excluded from the licensee submittal (for example, welds in the RWCU outboard of the isolation valves)? If previously excluded, please list identity of such welds and plans for mitigation and inspections in Tables 2 and 3 or provide alternative proposal. If IGSCC susceptible welds were excluded from the licensee submittal based on temperature considerations please identify the welds and describe in detail the method of temperature esasurements.

Ites 4. Welds that Are Not W Inspectable Generic Latter 8841 (in Table 1) states: " Welds that are not W inspectable should be replaced. " sleeved", or local leak detection applied. RT examination or visual inspection for leakage may also be considered."

Does the licensee submittal include discussions and plans fort (a) All welds that are inaccessible for W inspections?

(b) All welds that are only partially accessible for W inspections?

I (c) Welds that cannot be W inspected because of geometrical constraints or other reasons.

If not, please list these welds and p!sna for mitigation / Inspection.

Item 5.14akane Detection Generic Imster 8841 states on page 3:

" Confirmation of you plans to ensure that the Technical A-6 i

,, . 1 ATT400ENT A (continued)

Specification related to leakage detection will be in conformance with the staff position on leak detection included in this letter."

The staff position is outlined on pages 5 and 6 of Generic letter 88-01 and include the following items:

1. Leakage detection should be in conformance with Position C of Regulatory Guide 1.45 " Reactor Coolant Pressure Boundary 14akage Detection Systems," or as otherwise approved by the NRC.

2. Plant shutdown should be initiated for corrective action whens (a) within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period any leakage detection system l indicates an increase of unidentified leakage in excess of 2 spa or its equivalent, or (b) the total unidentified leakage attains a rate of 5 sps or equivalent.

3. Imakage should be monitored (or determined from flow measurements if flow is continuously monitored) at approximately four hour intervals or less.

4. Unidentified leakage should include all leakage other than (a) leakage into closed systems, or (b) leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with operations of monitoring systems or not to be from a throughwall crack.

5. For plants operating with any IGSCC Category D E, F, or G welds, at least one of the leakage measurement instruments associated with each sump shall be operable, and the outage time for inoperable instruments shall be limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or immediately initiate an orderly shutdown.

Although most licensee submittals describe the intention of meeting some or all of these requirements or offer alternative measures, it is not always clear whether these requirements are contained in the Technical Specifications. Thus it is requested that this information should be provided by each licensee. For clarity and completeness, please use a checklist such as that illustrated in Table 4.

e .

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l Table 4 Licensee Positions on 14akage Detection j

'Already TS will be Alternate Contained Changed Position Position in TS to Include Proposed

1. Conforms with Position C of ,

Regulatory Guide 1.45 j

2. Plant shutdown should be initiated whens (a) within any period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, an increase is indicated in the rate of unidentified leakage in ('

excess of 2 spm, or (b) the total unidentified leakage attains a rate of 5 spe.

3. Leakage monitored a,t four hour intervals or less.

4. Unidentified leakage includes all except:

(a) leakage into closed systems, or (b) leakage into the containment atmosphere from sources that are located, do not interfere with monitoring systems, or not from throughwall crack.

5. Provisions for shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to inoperable measurement instruments in plants with Category D, E F, or G welds.

Instructions:

Place "I" or "yes" under appropriate column for each item. Provide description and justification for alternative positions if not already provided.

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ATTACHMENT B REQUEST MR ADDITIONAL INMRMATION PERTAINING TO BRUNSWICK STEAM ELECTRIC PLANT, UNIT 1 Item 1. Inservice Inspection Proaram Two IGSCC Category C welds (24A12, 24B13) and seven ICSCC Category D welds (12ARAS, 12ARB5, 12ARDS, 12BRFS, 12BRG5, 12BRHS, and 12 ARK 5) are listed in the licensee submittal as containing geometrical constraints that limit inspectability. Please supply descriptions of plans, if any, for alternate means of inspection of these welds.

In addition, please provide reasons / justification for the classifications of two IGSCC Category C welds and the six IGSCC Category D welds since the previous inspections have been incomplete.

page B - 1

(Unit 2)

ATTACHMENT A GENERAL QUESTIONS / REQUESTS Reviews of several licensee submittals has shown that most (although not all) of the submittals commonly lack certain information that is needed for evaluation of the submittals. Thus, this general list of questions and requests has been prepared for submission to each of the licensees. For those attachment for which the requested information was supplied (portions of this in the detail requested herein) in the original submittal, the utilities may reference the relevant pages or tables in the original submittal and supply only the requested information that was not provided. Please certify that you comply with the staff positions in GL-88-01 or identify and justify any deviations taken.

Item 1. Position on NRC Staff Positions Generic Letter 88-01 states on page 3:

" Pursuant to 10 CFR 50.54(f), you, as a BWR operating reactor licensee or construction permit holder, are requested to furnish, under oath or affirmation, your current plans relating to piping replacement, inspection, .

repair, and leakage detection. Your response should indicate whether you intend to follow the staff positions included in this letter, or propose alternative measures."

The staff positions outlined in Generic Letter 88-08 include p siticos on: (1) Materials. (2) Processes. (3) Water Chemistry. (4) Weld Overlay. (5) Partial Replacement. (6 Weldments. ( ) Clamping Devices. (8)) Crack Evaluation and RepairStress Im Criteria. (9 Inspection Method and Personnel. (10) Inspection Schedules. (1)SampleExpansion. (12) Leak Detection. (13)

Reporting Requirements.

Please supply information concerning whether the licensee: (1) endorses these positions, (2) proposes alternate positions, exceptions, or provisions, and (3) is considering or planning to apply them in the future. Please describe any alternate positions, ,

exceptions, or provisions that are proposed.  !

Please supply this information using a table such as the illustrated in the example shown in Table 1.

1 A-1

Table 1 ,

l Responses to NRC Staff Positions l

l Licensee Response

• Licensee Has/Will#* i Accept Requests l with Alternate Applied Consider for (

)

Staff Position Accept Provisions Position in Past Future Use

1. Materials .

2. Processes

3. Water Chemistry

4. Weld Overlay

5. Partial Replacement

6. Stress Improvement of Cracked Weldsents

7. Clamping Devices

8. Crack Evaluation and Repair Criteria

9. Inspection Method and Personnel

10. Inspection Schedules

11. Sample Expansion

12. Imak Detection

13. Reporting Requirements

• Answer with "yes", " check mark" or "X" in appropriate column for each of the 13 NRC Staff Positions. List and explain each provision and/or alternate position (or reference original submittal if it contains the listing and explanation). Use separate page(s) if needed.

• • Answer with "yes" or "no", as appropriate, in each column for each of 13 NRC Staff Positions.

' s A-2

1 l ATTAQMENT A (continued)

Item 2. Inservice Inspection Pronras Generic Letter 88-01 requests on page 3:

"Your current plans regarding pipe replacement and/or other i measures taken or to be taken to mitigate IGSOC and provide assurance of continued long-term integrity and reliability."

"An Inservice Inspection Program to be implemented at the next refueling outage for austenitic stainless steel piping covered under the scope of this letter that conforms to the staff positions on inspection schedules methods and personnel, and sample expansion included in this letter."

The information pertaining to the pipe replacement and other mitigating actions as well as the Inservice Inspectica Program provided in most of the licensee submittals were either incomplete or did not provide the background data that is needed to evaluate the ISI Program such as (1) reasons / justification for ICSOC classification of welds, (2) methods, personnel qualification, schedules and identities of welds inspected, and (3) results of previous inspections, and/or identities of welds to be inspected during future inspections.

Thus, the following information is requested:

1. A listing of all welds by system, pipe size, configuration (e.g., pipe to elbow, pipe to valve, etc.), drawing number (piping ISO with weld I.D.), location (i.e., inside or outside of containment, etc.), weld I.D. number, and ICSCC classification (i.e., ICSOC Category A, B, C, D, E, F and C).

2. Reason / justification for the classification of each weld, using such information as (a) weld history such as heat sink welding (HSW), (b) pipe and weld metal compositions or material identities to show either conforming material or non-conforming material (c) mitigating treatment (s) applied such as solution heat treating (SHT), stress improvement (INSI or MSIP).

3. Identity of welds to be inspected during past and future refueling outage. Include (a) dates and results of previous inspections, (b) flaw characteristics including orientation (axial or circuaferential), maximum length, maximum depth, repairs and/or mitigating treatments applied.

Please supply this information in tabular form using formats such as that illustrated in Tables 2 and 3.

A-3

Table 2 History of Welds and Prior Mitigating Actions / Treatments

• Material **

IGSCC Weld Dia. Casting Treatment ***

Caten System Number Configuration Inch Foraina. Pipe Weld SHT IgBf CRC JI,O.L.

Notes:

• List each weld apparate17, using one or more lines as required.

• • For material: identify as non-conforming or conforming as appropriate concerning whether it conforms with the NRC Staff position on resistant materials. If conforming, identify the material type (e.g., Type 316 NG).

• • • For treatment: list "I" under appropriate column (s) if weld was treated using indicated technique, i.e., solution heat. treated (SRT), heat sink welded (RSW), corrosion resistant clad (CRC),

stress improved (SI), or overlayed (0.L.). For SI, add explanation of method used, i.e., whether by induction heating or mechanical, whether pre and/or post treatment inspection was applied using methods and personnel qualified under NRC/EPRI/BWROG coordination plan, and whether treatment was applied within two years of service date. Also add explanation and justification of any overlays that were not standard (per NRC Staff position).

A-4

4 Table 3 Inspection Schedules l nspected/To Be Inspected /Fisws Found IGSCC Wald Dia. Past Future Caten System No. Inch. Configuration R.0.fX-2 R.0.fX-1 Flaw R.O.f1 R.0.fX+1 Instructions:

1. Under the heading, " Inspected /To BE Inspected," use as many columns as required to describe the followings (a) All previous inspections that were conducted (per NUREG 0313. Revision 2, page 5.2) using methods and personnel qualified under NRC/EPRI/BWROG coordination plan as upgraded in September, 1985.

plus (b) A sufficient number of future inspections to demonstrate that the schedules will follow the NRC Staff positions as given in Table 1 in Generic Imtter 88-01.

2. Replace R.O.# (I-2, I-1. I, I+1) with actual refueling outage numbers. Indicate dates inspections were/will be performed.

3. List each veld within the scope of Generic Letter 88-01.

4. Place an "I" or other appropriate symbol under the appropriate column for each refueling outage for which that veld was inspected or will be inspected.

5. Indicate with "yes" under column marked " flaw" if a flaw indication was found. Attach a statement for each flawed weld giving the orientation (axial or circumferential), the dimensions (maximum length and depth), and describing any repairs made.

1 l A-5 l

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ATTACl90!rt A (continued)

Ites 3. Welds Covered in Licensee Submittal Generic letter 88-01 (on page 2) states:

"This Generic IAtter applies to all BWR piping made of austenitic stainless steel that is four inches or larger in nominal diameter and contains reactor coolant at a temperature above 200*F during power operation regardless of Code classification. It also applies to reactor vessel attachments and appurtenances such as jet pump instrumentation penetration assemblies and head spray and vent  ;

components."

Were any welds that fall within this defined scope escluded from the licensee subsittal (for example, welds in the RWCU outboard of the isolation valves)? If previously excluded, please list identity of such welds and plans for sitigation and inspections in Tables 2 and 3 or provide alternative proposal. If IGSCC susceptible welds were excluded from the licensee submittal based on temperature considerations please identify the welds and describe in detail the method of temperature measurements.

Ites 4. Welds that Are Not UT Inspectable Generic latter 88 01 (in Table 1) states: " Welds that are not W inspectable should be replaced " sleeved", or local leak detection applied. RT examination or visual inspection for leakage may also be considered."

Does the licensee submittal include discussions and plans fors (a) All welds that are inaccessible for W inspections?

(b) All welds that are only partially accessible for W inspections?

(c) Welds that cannot be W inspected because of geometrical constraints or other reasons.

If not, please list these welds and plans for mitigation / inspection.

Ites 5.14akane Detection Generic !atter 88-01 states on page 3:

" Confirmation of you plans to ensure that the Technical A-6

]. "k

.r

• i AffAQMENT A (coatinued)

Specification reisted to leakage detection will be in conformance with the staff position on leak detection included la this letter."

The staff position is outlined on pages 5 and 6 of Generic Letter 88-01 and include the following items:

1. leakage detection should be in conformance with Position C of Regulatory Guide 1.45 " Reactor Coolant Pressure Boundary Imakage Detection Systems," or as otherwise approved by the NRC.

2. Plant shutdown should be initiated for corrective action when:

(a) within any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period any leakage detection system indicates an increase of unidentified leakage in excess of 2 spa or its equivalent, or (b) the total unidentified leakage attains a rate of 5 gym or equivalent.

3. Leakage should be monitored (or determined from flow measurements if flow is continuously monitored) at approximately.

four hour intervals or less.

4. Unidentified leakage should include all leakage other than (a) leakage into closed systems, or (b) leskage into the containment atmosphere from sources that are both specifically located and known either not to interfere with operations of monitoring systems or not to be from a throughwall crack. ,

l

5. For plants operating with any IGSCC Category D, E F, or G welds, at least one of the leakage measurement instruments associated with each sump shall be operable, and the outage time for inoperable instruments shall be limited tc 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> i or immediately initiate an orderly shutdown.

Although most licensee submittals describe the intention of meeting some or all of these requirements or offer alternative measures, it is not always clear whether these requirements are contained in the Technical Specifications. Thus it is requested that this information should be provided by each licensee. For clarity and completeness, please use a checklist such as that illustrated in Table 4 A-7

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Table 4 Licensee Positions on taakage Detection Already TS will be Alternate Contained Changed Position Position in TS to Include Proposed

1. Conforms with Position C of Regulatory Guide 1.45

2. Plant shutdown should be initiated whens (a) within any period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less, an increase is indicated in the rate of unidentified leakage in excess of 2 spa, or (b) the total unidentified leakage attains a rate of 5 spa.

3. Leakage monitored at four hour intervals or less.

4. Unidentified leakage includes all except:

(a) leakage into closed systems, or (b) leakage into the containment atmosphere from sources that are located, do not interfere with monitoring systems, or not from throughwall crack.

5. Provisions for shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to inoperable mea n rement instruments in plants with Category D, E F, or G welds.

Instructions:

Place "I" or "yes" under appropriate column for each ites. Provide description and justification for alternative positions if not already provided.

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ATTACHMENT B REQUEST M R ADDITIONAL IN MRMATION PERTAINING

'11) BRUNSWICK STEAM ELECTRIC PLANT, UNIT 2 Item 1. Inservice Inspection Program' Two IGSCC Category C welds (24A12, 24B13) and five IGSCC Category D welds (12 ARC 4A, 12ARE4A, 12BRF4A, 12BRG4A, and 12BRH4A) are listed in the licensee submittal as containing geometrical constraints that limit inspectability. Please supply descriptions of plans, if any, for alternate means of inspection of these welds. In addition, please provide reasons /justificati6n for the classifications of two IGSCC Category C welds and the five IGSCC Category D welds since the previous inspections have been incomplete.

page B - 1