Text

Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) for End of Interval Leakage Test
	ML18082A037
Person / Time
Site:	Brunswick
Issue date:	03/23/2018
From:	Wooten B; Duke Energy Progress
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BSEP 18-0040
	Download: ML18082A037 (12)
	v • d • e

( -, DUKE Brunswick Nuclear Plant P.O. Box 10429 ENERGYe Southport, NC 28461 MAR 2 3 2018 Serial: BSEP 18-0040 10 CFR 50.55a(z)(1)

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 Proposed Alternative In Accordance With 10 CFR 50.55a(z)(1) for End of Interval Leakage Test Ladies and Gentlemen:

In accordance with 10 CFR 50.55a(z)(1 ), Duke Energy Progress, LLC (Duke Energy), hereby requests approval of an alternative to the requirements 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 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.

Please refer any questions regarding this submittal to Mr. Lee Grzeck, Manager - Regulatory Affairs, at (910) 832-2487.

Sincerely, 157 _ c.1/~

Bryan B. Wooten Director - Organizational Effectiveness Brunswick Steam Electric Plant MAT/mat

Enclosure:

10 CFR 50.55a Request Number ISl-11

U.S. Nuclear Regulatory Commission Page 2 of 2 cc (with enclosure):

U.S. Nuclear Regulatory Commission, Region II ATTN: 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 18-0040 Enclosure Page 1 of 10 10 CFR 50.55a Request Number ISI-11 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)

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.

5. Proposed Alternative and Basis for Use In accordance with 10 CFR 50.55a(z)(1), the proposed alternative is to allow the required Unit 2, fourth 10-year, EOILT to be completed no later than the end of 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) which is not exempted 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 existing approved BSEP relief request RR-38 for BSEPs fourth interval (i.e., Reference 2). The portions of piping that will be included in the test are listed below.

BSEP 18-0040 Enclosure Page 2 of 10 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.

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 RR-38 (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

BSEP 18-0040 Enclosure Page 3 of 10 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)

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- No Measured 2007 (A Loop) LRT) in F006A to 2-E21- Pressure.