View source for BSEP 18-0047, Supplement to Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) for End of Interval Leakage Test

{{Adams
| number = ML18095A026
| issue date = 04/05/2018
| title = Supplement to Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) for End of Interval Leakage Test
| author name = Wooten B
| author affiliation = Duke Energy Corp
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000324
| license number = DPR-062
| contact person = 
| case reference number = BSEP 18-0047
| document type = Letter type:BSEP
| page count = 12
}}

=Text=
{{#Wiki_filter:Brunswick Nuclear Plant P.O. Box 10429 Southport, NC 28461 April 5, 2018 Serial: BSEP 18-0047                                                          10 CFR 50.55a(z)(2)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
Brunswick Steam Electric Plant, Unit No. 2 Renewed Facility Operating License No. DPR-62 Docket No. 50-324 Supplement to Proposed Alternative In Accordance With 10 CFR 50.55a(z)(2) for End of Interval Leakage Test

==Reference:==
Letter from Bryan B. Wooten (Duke Energy) to NRC Document Control Desk, Proposed Alternative In Accordance with 10 CFR 50.55a(z)(1) for End of Interval Leakage Test, dated March 23, 2018, ADAMS Accession Number ML18082A037 Ladies and Gentlemen:
The referenced letter requested an alternative (i.e., ISI-11) to the requirements of paragraph IWB-5222(b) of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, 2001 Edition through 2003 Addenda for the Brunswick Steam Electric Plant (BSEP), Unit No. 2. The original basis for ISI-11 was 10 CFR 50.55a(z)(1), which corresponds to a "proposed alternative provides an acceptable level of quality and safety." This submittal updates the basis for ISI-11 to be 10 CFR 50.55a(z)(2), which corresponds to "compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety."
This submittal also provides supplemental information for supporting the proposed alternative to the requirements of ASME Code, Section XI, paragraph IWB-5222(b). The supplement to ISI-11 is included in the Enclosure to this submittal. The changes and additional information are marked with revision bars in the body of the document.
The ASME Code, Section XI, paragraph IWB-5222(b), requires that the pressure retaining boundary system leakage test, conducted at or near the end of each inspection interval, be extended to all Class 1 pressure retaining components within the system boundary. The enclosed relief request is to allow the required Unit 2, fourth 10-year, end of interval leakage testing on portions of the Core Spray, High Pressure Coolant Injection, and Standby Liquid Control Systems to be completed no later than the end of refueling outage B2R24 (i.e., currently scheduled for March 2019). Approval of the proposed alternative is requested prior to the end of the fourth 10-year ISI interval, which is currently scheduled to end on May 10, 2018.

U.S. Nuclear Regulatory Commission Page 2 of 2 Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.
S13.ly,         .PJ/;e Bryan Z      aaten Director - Organizational Effectiveness Brunswick Steam Electric Plant BBW/mkb

==Enclosure:==
Supplement to 10 CFR 50.55a Request Number ISl-11 cc (with Enclosure):
U.S. Nuclear Regulatory Commission, Region II ATIN: Ms. Catherine Haney, Regional Administrator 245 Peachtree Center Ave, NE, Suite 1200 Atlanta, GA 30303-1257 U.S. Nuclear Regulatory Commission ATTN: Mr. Gale Smith, NRC Senior Resident Inspector 8470 River Road Southport, NC 28461-8869 U.S. Nuclear Regulatory Commission ATTN: Mr. Andrew Hon (Mail Stop OWFN 8G9A) 11555 Rockville Pike Rockville, MD 20852-2738 Chair - North Carolina Utilities Commission (Electronic Copy Only) 4325 Mail Service Center Raleigh, NC 27699-4300 swatson@ncuc.net Mr. Cliff Dautrich, Bureau Chief North Carolina Department of Labor Boiler Safety Bureau 1101 Mail Service Center Raleigh, NC 27699-1101

BSEP 18-0047 Enclosure Page 1 of 10 Supplement to 10 CFR 50.55a Request Number ISI-11 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)
Unit 2 End of Fourth Interval Leakage Test
: 1.       ASME Code Components Affected Unit(s) Affected:               Brunswick Steam Electric Plant (BSEP), Unit 2 Code Class:                     ASME Code, Section XI, Class 1

==References:==
Subarticle IWB-5222(b)
Examination Categories:         B-P Item Number:                    15.10, Pressure Retaining Components Component Numbers:              Piping between 2-E21-F006A and 2-E21-F005A Piping between 2-E21-F006B and 2-E21-F005B Piping between 2-E41-V159 and 2-E41-F006 Piping between 2-C41-F007 and 2-C41-F006

==
Description:==
Pressure Testing
: 2.       Applicable Code Edition The Inservice Inspection Program for the fourth 10-year inservice inspection (ISI) interval is based on the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, 2001 Edition with 2003 Addenda. The fourth 10-year ISI interval began on May 11, 2008, and is currently scheduled to end on May 10, 2018.
: 3.       Applicable Code Requirement The ASME Code, Section XI, paragraph IWB-5222(b) requires the pressure retaining boundary during the system leakage test extend to all Class 1 components within the system boundary.
: 4.       Reason for Request An End of Interval Leakage Test (EOILT) is required during the fourth 10-year ISI interval to satisfy the requirement of ASME Section XI paragraph IWB-5222(b), which states:
The pressure retaining boundary during the system leakage test conducted at or near the end of each inspection interval shall extend to all Class 1 pressure retaining components within the system boundary.
During the B2R23 refueling outage in 2017 and B2R22 refueling outage in 2015, the EOILT was not performed during the Reactor Pressure Vessel (RPV) pressure test.
Compliance with the ASME Section XI paragraph IWB-5222(b) requirements would result in an unplanned Unit 2 shutdown prior to May 10, 2018 (i.e., the end of the fourth 10-year ISI interval) to complete the pressure test on the applicable portions of piping. In lieu of completing the pressure test and in accordance with 10 CFR 50.55a(z)(2), relief is requested on the basis that compliance with the specified requirements would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety.
To comply with the requirements of IWB-5222(b) for the applicable portions of piping by the end of the fourth 10-year ISI interval, Unit 2 would be required to be placed in cold shutdown conditions in order to perform the pressure test on the applicable portions of piping. Once in

BSEP 18-0047 Enclosure Page 2 of 10 cold shutdown conditions, the plant systems would have to be realigned for performance of the test. Additional stresses and fatigue associated with shutdown and startup would be imposed on systems and components, and would require personnel to enter radiation fields to configure and prepare the piping for the pressure test, align the plant for the test, and perform the required VT-2 examinations during the test. The resulting dose accrual and plant risk associated with cycling Unit 2 into cold shutdown conditions and alignments for the pressure test would result in hardship without a compensating increase of quality or safety of the plant.
: 5.       Proposed Alternative and Basis for Use In accordance with 10 CFR 50.55a(z)(2), the proposed alternative is to allow the required Unit 2, fourth 10-year, EOILT to be completed no later than the end of the refueling outage B2R24 (i.e.,
currently scheduled for March 2019) during the Reactor Pressure Vessel Pressure Test. This test would include the piping which meets the criteria of IWB-5222(b), and is not exempt per ASME Code Case N-798, Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Vent, Drain, and Test Isolation Devices, Section XI, Division 1, (i.e., Reference 1), and the existing approved BSEP relief request PT-01 for BSEPs fourth interval (i.e., Reference 2). The portions of piping that will be included in the test are listed below. Referenced Boundary Sketches, with valve and line information, are provided at the end of this enclosure.
First                                              Second Line Isolation       Affected Line        Line Size      Isolation Function Valve                                               Valve Core Spray      2-E21-F006A       2-E21-3-10-600          10       2-E21-F005A (CS) Injection (A Loop)
CS Injection    2-E21-F006B       2-E21-7-10-600          10       2-E21-F005B (B Loop)
High Pressure      2-E41-V159       2-E41-3-14-901          14        2-E41-F006 Coolant Injection (HPCI)
Injection Standby Liquid     2-C41-F007     2-C41-9-1 1/2-902         1.5       2-C41-F006 Control (SLC)
Injection The EOILT will be performed in the same manner as the regular 10-year test in accordance with the approved RPV pressure test procedure. The portions of piping that meet the IWB-5222(b) criteria and are not exempted by a code case will be pressurized to the RPV test pressure range of 1030 psig to 1070 psig. The test will be conducted using temporary hose connections to bypass the injection check valves of the CS, HPCI, and SLC systems. The remainder of piping that meets the criteria of IWB-5222(b) will be exempt per NRC approved code case N-798.
The pressure test will be evaluated by qualified VT-2 examiners completing visual examinations of the test boundaries in accordance with the approved RPV pressure test procedure.

BSEP 18-0047 Enclosure Page 3 of 10 Approval of the proposed alternative is requested prior to the end of the fourth 10-year ISI interval, which is currently scheduled to end on May 10, 2018.
Basis for Use BSEP is requesting an extension of the EOILT to be performed in the Unit 2 outage in 2019 (i.e., B2R24) for fourth interval credit. The request would not alter the May 11, 2018 start date for the fifth Interval and subsequent ISI intervals. With the approval, the EOILT would be performed twice during the fifth ISI interval, once during the first outage of the fifth interval for credit to the fourth interval and once at or near the end of the fifth Interval for credit to the fifth interval.
The most recent performance of the EOILT on Unit 2 was April 8, 2007. This test included the Class 1 injection lines for CS, HPCI, and SLC systems. The additional portion of Class 1 piping (i.e., vents, drains, and test lines) included in the IWB-5222(b) criteria was bounded by relief request PT-01 (i.e., Reference 2) and was not tested during the 2007 test, but was visually examined.
The subject piping is not susceptible to thermal fatigue due to the piping being upstream of the first isolation valve from the reactor vessel. Additionally, there are no known degradation mechanisms in each of the subject line systems which would cause degradation of the piping that would impact the structural integrity of the piping or piping welds.
The EOILT was last performed in 2007, however additional testing has been performed on the applicable portions of piping during each Unit 2 refueling outage since 2007. The testing of applicable portions of piping provides a reasonable level of assurance that the integrity of the piping is adequate to support performance of the EOILT during the next Unit 2 outage.
Operational and Pressure Testing The following table provides a summary of Operational, ASME Section XI, or Appendix J Local Leak Rate Testing that has been completed on the subject piping since the last performance of the EOILT in 2007.
Line Function                Test             Boundary         Test Pressure               Year Reactor Pressure      0PT-80.1 (RPV        RPV and Class 1     1033 -1052.9 psig            2007 Vessel and        Pressure Test)       Piping Class 1 Piping      (Code Case N-498, Reference 3)
CS Injection       0PT-07.1.1A (CS      Includes 2-E21-          371 psig                2007 (A Loop)        Injection Check      F006A to 2-E21-Valve Operability    F005A Test)
CS Injection       0PT-07.1.1A (CS      Includes 2-E21-          369 psig                2009 (A Loop)        Injection Check      F006A to 2-E21-Valve Operability    F005A Test)
CS Injection       0PT-07.1.1A (CS      Includes 2-E21-          383 psig                2011 (A Loop)        Injection Check      F006A to 2-E21-Valve Operability    F005A Test)

BSEP 18-0047 Enclosure Page 4 of 10 Line Function          Test          Boundary    Test Pressure   Year CS Injection 0PT-07.1.1A (CS   Includes 2-E21-    376 psig      2013 (A Loop)    Injection Check   F006A to 2-E21-Valve Operability F005A Test)
CS Injection 0PT-07.1.1A (CS   Includes 2-E21-    377 psig      2015 (A Loop)    Injection Check   F006A to 2-E21-Valve Operability F005A Test)
CS Injection 0PT-07.1.1A (CS   Includes 2-E21-    355 psig      2017 (A Loop)    Injection Check   F006A to 2-E21-Valve Operability F005A Test)
CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2007 (A Loop)    LRT) in           F006A to 2-E21- Test Pressure conjunction with  F005A              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2009 (A Loop)    LRT) in           F006A to 2-E21- Test Pressure conjunction with  F005A              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2011 (A Loop)    LRT) in           F006A to 2-E21- Test Pressure conjunction with  F005A              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2013 (A Loop)    LRT) in           F006A to 2-E21- Test Pressure conjunction with  F005A              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2015 (A Loop)    LRT) in           F006A to 2-E21- Test Pressure conjunction with  F005A              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2017 (A Loop)    LRT) in           F006A to 2-E21- Test Pressure conjunction with  F005A              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-07.1.1B (CS   Includes 2-E21-    402 psig      2007 (B Loop)    Injection Check   F006B to 2-E21-Valve Operability F005B Test)
CS Injection 0PT-07.1.1B (CS   Includes 2-E21-    391 psig      2009 Injection Check   F006B to 2-E21-

BSEP 18-0047 Enclosure Page 5 of 10 Line Function          Test          Boundary    Test Pressure   Year (B Loop)    Valve Operability F005B Test)
CS Injection 0PT-07.1.1B (CS   Includes 2-E21-    399 psig      2011 (B Loop)    Injection Check   F006B to 2-E21-Valve Operability F005B Test)
CS Injection 0PT-07.1.1B (CS   Includes 2-E21-    386 psig      2013 (B Loop)    Injection Check   F006B to 2-E21-Valve Operability F005B Test)
CS Injection 0PT-07.1.1B (CS   Includes 2-E21-    388 psig      2015 (B Loop)    Injection Check   F006B to 2-E21-Valve Operability F005B Test)
CS Injection 0PT-07.1.1B (CS   Includes 2-E21-    387 psig      2017 (B Loop)    Injection Check   F006B to 2-E21-Valve Operability F005B Test)
CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2007 (B Loop)    LRT) in           F006B to 2-E21- Test Pressure conjunction with  F005B              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2009 (B Loop)    LRT) in           F006B to 2-E21- Test Pressure conjunction with  F005B              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2011 (B Loop)    LRT) in           F006B to 2-E21- Test Pressure conjunction with  F005B              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2013 (B Loop)    LRT) in           F006B to 2-E21- Test Pressure conjunction with  F005B              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2015 (B Loop)    LRT) in           F006B to 2-E21- Test Pressure conjunction with  F005B              (Note 2) 0PT-80.1 RPV Pressure Test CS Injection 0PT-20.7B (PIV    Includes 2-E21- 0PT-80.1 RPV     2017 (B Loop)    LRT) in           F006B to 2-E21- Test Pressure conjunction with  F005B              (Note 2) 0PT-80.1 RPV Pressure Test

BSEP 18-0047 Enclosure Page 6 of 10 Line Function             Test            Boundary           Test Pressure             Year HPCI Injection    0PT-20.3-B21       Includes 2-E41-            50 psig               2007 (App. J LLRT)      F006 to 2-E41-V159 HPCI Injection    0PT-20.3-B21       Includes 2-E41-            50 psig               2009 (App. J LLRT)      F006 to 2-E41-V159 HPCI Injection    0PT-20.3-B21       Includes 2-E41-            50 psig               2011 (App. J LLRT)      F006 to 2-E41-V159 HPCI Injection    0PT-20.3-B21       Includes 2-E41-            50 psig               2013 (App. J LLRT)      F006 to 2-E41-V159 HPCI Injection    0PT-20.3-B21       Includes 2-E41-            50 psig               2015 (App. J LLRT)      F006 to 2-E41-V159 HPCI Injection    0PT-20.3-B21       Includes 2-E41-            50 psig               2017 (App. J LLRT)      F006 to 2-E41-V159 SLC Injection     0PT-20.14 (ASME    Includes 2-C41-           49.5 psig               2007 Section XI PT)     F006 to 2-C41-V5003 SLC Injection     0PT-20.14 (ASME    Includes 2-C41-           88.2 psig               2009 Section XI PT)     F006 to 2-C41-                                  (Note 1)
V5003 SLC Injection     0PT-20.14 (ASME    Includes 2-C41-           90.5 psig               2009 Section XI PT)     F006 to 2-C41-                               nd (2 Occurrence)
V5003                                           (Note 1)
SLC Injection     0PT-20.14 (ASME    Includes 2-C41-           91.5 psig               2011 Section XI PT)     F006 to 2-C41-                                  (Note 1)
V5003 SLC Injection     0PT-20.14 (ASME    Includes 2-C41-            92 psig                2013 Section XI PT)     F006 to 2-C41-                                  (Note 1)
V5003 SLC Injection     0PT-20.14 (ASME    Includes 2-C41-            93 psig                2015 Section XI PT)     F006 to 2-C41-                                  (Note 1)
V5003 SLC Injection     0PT-20.14 (ASME    Includes 2-C41-           93.5 psig               2017 Section XI PT)     F006 to 2-C41-                                  (Note 1)
V5003 Note 1    Indicates years that demineralized water was injected through the 1-C41-F007 Check Valve into the vessel however this portion of the test was not in the pressure boundary for the VT-2 Examination.

BSEP 18-0047 Enclosure Page 7 of 10 Note 2      0PT-20.7B is the Pressure Isolation Valve Leak Rate Test in Conjunction with the RPV Pressure Test. During this test the Core Spray Injection lines between the F006A/B and the F005A/B are pressurized at the RPV test pressure using mechanical jumpers through the F006 inboard and outboard drain lines.
Non Destructive Examinations There have been no non-destructive examinations completed on the piping addressed in this relief request.
: 6.       Duration of the Proposed Alternative This proposed alternative is requested until the end of the refueling outage B2R24, currently scheduled for March 2019.
: 7.       References
: 1.       ASME Code Case N-798, Alternative Pressure Testing Requirements for Class 1 Piping Between the First and Second Vent, Drain, and Test Isolation Devices, Section XI, Division 1
: 2.       Letter from Thomas H. Boyce (NRC) to Benjamin Waldrep (Carolina Power & Light Company), Relief Request PT-01 for the Fourth 10-Year Inservice Inspection Interval on System Pressure Test Boundary, dated November 6, 2008, ADAMS Accession No. ML082760533
: 3.       ASME Code Case N-498, Alternative Requirements for 10-Year System Hydrostatic Testing of Class 1, 2, and 3 Systems

BSEP 18-0047 Enclosure Page 8 of 10 0PT-80.1, Reactor Pressure Vessel ASME Section XI Pressure Test VT-2 Examination Boundary Drawing Core Spray A and B Loops Boundary

BSEP 18-0047 Enclosure Page 9 of 10 0PT-80.1, Reactor Pressure Vessel ASME Section XI Pressure Test VT-2 Examination Boundary Drawing Feedwater A Loop (High Pressure Coolant Injection)

BSEP 18-0047 Enclosure Page 10 of 10 0PT-80.1, Reactor Pressure Vessel ASME Section XI Pressure Test VT-2 Examination Boundary Drawing Standby Liquid Control}}