ML051720424
| ML051720424 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/09/2005 |
| From: | Gordon Peterson Duke Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MC5571, TAC MC5572, TAC MC5573, TAC MC5574, TAC MC5575, TAC MC5576, TAC MC5577, TAC MC5578 | |
| Download: ML051720424 (17) | |
Text
- _ Duke (W Powere A Duke Energy Company GARY R. PETERSON Vice President McGuire Nuclear Station Duke Power MG01 VP / 12700 Hagers Ferry Road Huntersville, NC 28078-9340 704 875 5333 704 875 4809 fax grpeters @duke-energy. corn June 9, 2005 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555-0001
Subject:
Reference:
McGuire Nuclear Station -
Units 1 & 2 Docket Nos. 50-369, 50-370 Inservice Testing Program Request for Additional Information (RAI)
Relief Request Nos. MC-GRP-01, MC-SRP-KC-01, MC-SRP-ND-01, and MC-SRV-NS-01 (TAC Nos. MC5571, MC5572, MC5573, MC5574, MC5575, MC5576, MC5577, and MC5578)
(1) Letter from Mr. G.R. Peterson of Duke Power to NRC, dated August 12, 2004, (2) Letter from Mr.
G.R. Peterson of Duke Power to NRC, dated November 18, 2004, and (3) Letter from Mr. James J. Shea of the NRC to Mr. G.R. Peterson of Duke Power, dated April 8, 2005.
Attached is the additional information that was requested by the NRC staff during a telephone conference conducted on March 17, 2005.
The NRC staff's requests for information and Duke's responses are stated in Attachment 1. Please note that includes the revised Relief Request No. MC-SRP-ND-01 as discussed in the Duke's responses.
Also note that Relief Request No. MC-SRV-NS-01 is being withdrawn.
Questions with respect to this matter should be directed to Norman T. Simms of Regulatory Compliance at 704-875-4685.
Since.6el (y 0 G.R. Peterson
\\
Attachments www. duke-energy. corn
U.S. Nuclear Regulatory Commission June 9, 2005 Page 2 xc:
W.D. Travers U.S. Nuclear Regulatory Commission, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23 T85 Atlanta, GA 30303 S.E. Peters (Addressee only)
NRC Project Manager (MNS)
U.S. Nuclear Regulatory Commission One White Flint North, MS 08 G9 11555 Rockville Pike Rockville, MD 20852-2738 J.B. Brady NRC Senior Resident Inspector McGuire Nuclear Station
ATTACHMENT 1 Duke's Response to NRC RAIs
Response to Nuclear Regulatory Commission Staff Request for Additional Information Relief Request Nos. MC-GRP-O1, MC-SRP-KC-O1.
MC-SRP-ND-O1, and MC-SRV-NS-O1 Duke Power Company McGuire Nuclear Station, Units 1 and 2 Generic Relief Request No. MC-GRP-01 Comment The licensee is requesting generic relief for all the pumps characterized as "smooth-running pumps." The staff has not authorized establishment of a minimum vibration reference value generically and has not authorized alert and required action range values for pumps classified in a licensee's inservice testing (IST) program as "smooth running." If a licensee intends to requests an alternative using a minimum reference value for each pump, the submittal should address the current vibration levels and the methodology for detecting pump degradation.
Question 1 In order for the NRC staff to complete its review of this relief request, please provide the pump specific information on vibration levels and the methodology for detecting pump degradation for all pumps for which relief is requested.
Response to Question 1 This generic relief request was granted for the licensee's previous IST Program 10 yr submittal. It is desired to re-approve the relief in order to maintain a standard generic lower threshold for acceptance criteria for any pump vibration measurement point reference value which falls below the threshold. Such generic relief has also been granted to Oconee Nuclear Station (ON-GRP-01) and similar specific relief was previously granted to Palo Verde Nuclear Generating Station (PRR-08).
The intent of the generic relief request above is to apply to any pump in the MNS IST program which has a vibration point reference value less than or equal to 0.075 in/sec. The desired acceptable range for such vibration points would be 0 to and including 0.19 in/sec (based on the code requirement 2.5 Vr value), alert range would be > 0.19 in/sec to and including 0.45 in/sec (based on the code requirement 2.5 Vr through 6 Vr), and required action would be >
0.45 in/sec. McGuire desires to continue applying these acceptance criteria for all pump vibration points on all pumps for all tests (Group A or B pump tests as well as Comprehensive pump tests).
1ST Program Relief Request RAIs June 9, 2005 Page 2 In addition to the code required testing, all of the pumps in the IST program are included in the Licensee's Predictive Maintenance Program. Additional monitoring includes advanced vibration monitoring techniques (bearing high frequency detection and spectral analysis for the pump as well as the driver), and lubricant analysis (for oil lubricated pumps) for wear debris, chemical composition and cleanliness. The Predictive Maintenance Program provides supplemental information to assure detection of pump degradation.
Following is a list of current IST pump vibration reference values less than 0.075 in/sec:
Vibration (in/sec)
Pump Name Vibration Point Boric Acid Transfer Pump 1A Boric Acid Transfer Pump 1B Boric Acid Transfer Pump 2A Boric Acid Transfer Pump 2B Centrifugal Charging Pump IA Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Vertical Outboard Axial Outboard Horizontal 0.02053 0.07349 0.02713 0.02368 0.03245 0.05688 0.04288 0.01703 0.03993 0.01277 0.01752 0.02148 0.01350 0.03349 0.01785 0.01616 0.01254 0.01904 0.01747 0.07203 0.05674 0.05607
IST Program Relief Request RAIs June 9, 2005 Page 3
, !'*a Centrifugal Charging Pump 1B Centrifugal Charging Pump 2A Centrifugal Charging Pump 2B Component Cooling Water Pump lAl Component Cooling Water Pump 1A2 Component Cooling Water Pump IBi Component Cooling Water Pump 1B2 Component Cooling Water Pump 2A1 Component Cooling Water Pump 2A2 Inboard Vertical Outboard Axial Inboard Horizontal Inboard Vertical Outboard Axial Outboard Vertical Outboard Axial Outboard Axial Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Horizontal Outboard Axial Outboard Vertical Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical 0.07411 0.06698 0.06698 0.06466 0.03303 0.05093 0.04941 0.05496 0.05063 0.05728 0.05807 0.04816 0.06442 0.04910 0.05093 0.03505 0.05123 0.06051 0.05963 0.04655 0.07096 0.06560 0.05033 0.06855 0.06766 0.05781 0.07084 0.05002 0.07391 0.05620
IST Program Relief Request RAIs June 9, 2005 Page 4 Component Cooling Water Pump 2B 1 Component Cooling Water Pump 2B2 Containment Spray Pump 1B Containment Spray Pump 2A Control Area Chilled Water Pump Train A Control Area Chilled Water Pump Train B Diesel Generator Sump Pump 1A2 Diesel Generator Sump Pump 1A3 Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Horizontal Inboard Vertical Outboard Axial Outboard Vertical Lower Bearing Axial Lower Bearing Axial Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Lower Bearing Lower Bearing + 90 Degrees Upper Bearing Upper Bearing + 90 Degrees Upper Bearing Axial Lower Bearing Lower Bearing + 90 Degrees Upper Bearing Axial 0.05226 0.04956 0.02857 0.05167 0.05048 0.06966 0.06250 0.04800 0.06395 0.07493 0.07224 0.03591 0.02486 0.02613 0.04243 0.03057 0.04987 0.05441 0.02294 0.02606 0.04358 0.00627 0.01040 0.03185 0.04555 0.05138 0.01342 0.01442 0.04655
IST Program Relief Request RAIs June 9, 2005 Page 5 Diesel Generator Sump Pump 1B2 Diesel Generator Sump Pump 1B3 Diesel Generator Sump Pump 2A2 Diesel Generator Sump Pump 2A3 Diesel Generator Sump Pump 2B2 Diesel Generator Sump Pump 2B3 Groundwater Drainage Sump A Pump A Lower Bearing Lower Bearing + 90 Degrees Upper Bearing Upper Bearing + 90 Degrees Upper Bearing Axial Lower Bearing Lower Bearing + 90 Degrees Upper Bearing Upper Bearing + 90 Degrees Upper Bearing Axial Lower Bearing Lower Bearing + 90 Degrees Upper Bearing Upper Bearing + 90 Degrees Upper Bearing Axial Lower Bearing Lower Bearing + 90 Degrees Upper Bearing Upper Bearing + 90 Degrees Upper Bearing Axial Lower Bearing Lower Bearing + 90 Degrees Upper Bearing Upper Bearing + 90 Degrees Upper Bearing Axial Lower Bearing Lower Bearing + 90 Degrees Upper Bearing Upper Bearing + 90 Degrees Upper Bearing Axial Upper Bearing Upper Bearing + 90 Degrees Upper Bearing Axial 0.00905 0.00951 0.04363 0.04202 0.03816 0.00933 0.00820 0.03898 0.04539 0.04979 0.00699 0.00863 0.03654 0.03257 0.03777 0.01160 0.01184 0.03877 0.04216 0.03137 0.01033 0.01083 0.04341 0.06039 0.03867 0.00760 0.00726 0.02796 0.03007 0.03654 0.04243 0.05123 0.07031
IST Program Relief Request RAIs June 9, 2005 Page 6 Groundwater Drainage Sump B Pump A Groundwater Drainage Sump B Pump B Groundwater Drainage Sump C Pump B Motor Driven Auxiliary Feedwater Pump IA Motor Driven Auxiliary Feedwater Pump 1B Motor Driven Auxiliary Feedwater Pump 2A Motor Driven Auxiliary Feedwater Pump 2B Nuclear Service Water Pump 2A Residual Heat Removal Pump 1B Residual Heat Removal Pump 2A Residual Heat Removal Pump 2B Safety Injection Pump IA Upper Bearing Upper Bearing Upper Bearing + 90 Degrees Upper Bearing Axial Upper Bearing + 90 Degrees Inboard Vertical Outboard Axial Outboard Vertical Inboard Vertical Outboard Axial Outboard Vertical Inboard Vertical Outboard Axial Outboard Vertical Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Vertical Lower Bearing Axial Lower Bearing Lower Bearing Axial Lower Bearing Axial Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical 0.06536 0.06064 0.06606 0.07117 0.07100 0.02988 0.05846 0.04720 0.04752 0.06089 0.04879 0.03935 0.06395 0.05384 0.05885 0.03185 0.04752 0.05975 0.03877 0.05674 0.07245 0.06900 0.07370 0.06900 0.03291 0.02408 0.04059 0.03935 0.02642
IST Program Relief Request RAIs June 9, 2005 Page 7 Safety Injection Pump lB Safety Injection Pump 2A Safety Injection Pump 2B Turbine Driven Auxiliary Feedwater Pump 1 Inboard Horizonial Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Horizontal Inboard Vertical Outboard Axial Outboard Horizontal Outboard Vertical Inboard Vertical 0.03945 0.03149 0.04436 0.03569 0.05370 0.02930 0.02439 0.04069 0.03057 0.04736 0.02720 0.02039 0.02956 0.02903 0.03125 0.04925 Specific Relief Request No. MC-SRP-KC-01 Question 2 The American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM)
Code Edition 1998 through the 2000 Addenda, requires that all pumps within the scope of an IST program need to be categorized either as Group A or Group B. Therefore, please specify the category of the component cooling water pumps (i.e., either Group A or Group B) and use the appropriate instrument accuracy, as required by the Table ISTB-3500-1 Response to Question 2 The submittal lists pump Group in the tables shown in Section 3.1 as follows:
Pump KC - Component Cooling Pumps Category Group A Only the instrument accuracy requirements for the Group A test (+/- 2%) are associated with this relief request.
IST Program Relief Request RAIs June 9, 2005 Page 8 Question 3 The licensee is requested to specify the paragraph of the OM Code from which relief is requested.
Response to Question 3 The specific OM code section for which relief is requested is Paragraph ISTB-3510(b)(1) which states "the full-scale range of each analog instrument shall be not greater than three times the reference value."
Question 4 Under the, "Basis for Relief " paragraph, the licensee specified a required pressure instrument accuracy of 2 percent based on Table ISTB-3500-1, This pressure instrument accuracy of 2 percent is only for Group A and Group B tests. The licensee did not provide accuracy information (i.e. +/- 0.5 percent) to be used for the comprehensive test of component cooling water pumps, as specified in Table ISTB-3500-1. Please clarify, and include the accuracy requirements for the comprehensive pump test.
Response to Question 4 The submittal table shown in Section 3.1 lists relief request MC-SRP-KC-01 as only applicable to the Group A quarterly flow/differential pressure test. Relief is not requested for instrument range requirements for the comprehensive test for which Code range and accuracy requirements are met.
Question 5 Under the, "Basis for Relief' paragraph, the licensee did not provide information related to the component cooling water pumps discharge pressure and pressure gauge accuracy requirements (for Group A or Group B and comprehensive pump tests). Please clarify and provide all the related information.
Response to Question 5 Relief is not requested for the comprehensive test for which instrumentation used meets Code range and accuracy requirements.
IST Program Relief Request RAIs June 9, 2005 Page 9 Specific Relief Request No. MC-SRP-ND-01 Question 6 ASME OM Code Edition 1998 through the 2000 Addenda, requires that all pumps within the scope of an IST program need to be categorized either as Group A or Group B. Therefore, please specify the category of the residual heat removal pumps (i.e., either Group A or Group B) and use the appropriate instrument accuracy, as required by the Table ISTB-3500-1 Response to Question 6 The submittal lists pump Group in the tables shown in Section 3.1 as follows:
Pump Categorv ND - Residual Heat Removal and Low Head Safety Injection Pumps Group A Only the instrument accuracy requirements for the Group A test (+/- 2%) are associated with this relief request.
Question 7 The licensee is requested to specify the paragraph of the OM Code from which relief is requested.
Response to Question 7 The specific OM code section for which relief is requested is Paragraph ISTB-3510(b)(1) which states "the full-scale range of each analog instrument shall be not greater than three times the reference value."
Question 8 Under the, "Basis for Relief" paragraph, the licensee states "Range requirements will be waived for the tests. The purpose of quarterly test is to verify Tech. Spec. requirements are met and to obtain vibration data for trending. The instrumentation used for the quarterly residual heat removal test will meet accuracy requirements for assuring RHR pump operability per Tech. Spec."
Please clarify and explain how quarterly inservice testing fulfills the Technical Specification Requirements.
IST Program Relief Request RAls June 9, 2005 Page 10 Response to Ouestion 8 The use of process analog instruments with 0.5% accuracy will more than compensate for instrument error in cases where installed instrument range is slightly greater than three times the reference value limitation required by the code in order to meet the 2% accuracy requirement for the Group A test. Instrumentation used for the comprehensive test meets instrument range and accuracy requirements.
Ouestion 9 The licensee is requested to rearrange and clarify the details provided under "Basis for Relief" and "Alternative Testing" so that the information is easily distinguished between the "Basis for Relief" and "alternative Testing" paragraphs.
Response to Ouestion 9 Please replace the relief request originally submitted with the one in Attachment 2. The discussion in both sections refers only to the Group A test. The relief request is not applicable to the comprehensive test.
Ouestion 10 Under the, "Alternative Testing" paragraph, the licensee specified a required pressure instrument accuracy of 2 percent based on Table ISTB-3500-1. This pressure instrument accuracy of +/- 2 percent is only for Group A and Group B tests. The licensee did not provide accuracy information (i.e. +/- 0.5 percent) related to the comprehensive test as specified in Table ISTB-3500-1. Please clarify, and include the accuracy requirements for the comprehensive pump test.
Response to Ouestion 10 Relief is not requested for the comprehensive test for which instrumentation used meets Code range and accuracy requirements. Although the submitted relief request contained the text "Group A/Comprehensive Test", the revised request from the previous question has deleted the reference to the Comprehensive test.
IST Program Relief Request RAIs '
June 9, 2005 Page 11 Specific Relief Request No. MC-SRV-NS-01 Question 11 In order for the staff to evaluate whether the proposed IST alternative is acceptable, the licensee must demonstrate that (1) the proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i) or (2) compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(ii),
or (3) the code requirements are impractical pursuant to 10 CFR 50.55a(f)(5)(iii). Please provide the information necessary to demonstrate the basis for the request consistent with these requirements.
Response to Question 11 The check valves covered by this relief request are included in the Appendix II Check Valve Condition Monitoring Program. This relief (which was approved for the previous 10 year IST submittal) was requested again but for the contingency where these valves might be removed from the condition monitoring program and resume exercise testing under ISTC-35 10, ISTC-3520 and ISTC5221. It is no longer desirable to submit a relief request for a contingency and this relief request is hereby retracted.
Question 12 The licensee is requested to specify the paragraph of the OM Code from which relief is requested.
Response to Question 12 This relief request is retracted as explained above.
Question 13 In the submitted relief request, it appears that the licensee intends to use grouping criteria for IST of the subject check valves, however, it is unclear which paragraph of the OM Code the licensee is requesting relief from. Please clearly identify the IST criteria and the specific paragraph of the OM Code for which relief is requested.
Please note that ISTC-5221 (c)(1) states, "Grouping of check valves for sample disassembly examination program shall be technically justified and shall consider, as a minimum, valve manufacturer, design, service, size, materials of construction, and orientation." Paragraph ISTC-5221(c)(3) states, "At least one valve from each group shall be disassembled and
IST Program Relief Request RAIs June 9, 2005 Page 12 examined at least once every 8 years." Provided the licensee meets all the requirements of grouping for these check valves as specified in ISTC-5221 (c), it is unclear why the licensee needs Relief from Code requirements.
Response to Ouestion 13 This relief request is retracted as explained above.
ATTACHMENT 2 REVISED RELIEF REQUEST MC-SRP-ND-O1
- t '- 11-"' i-:, ;'4
- s McGuire Unit 1 McGuire Unit 2 Specific Relief Request RELIEF REQUEST
PUMPS:
TEST REQUIREMENT:
MC-SRP-ND-01 1NDPU0001, IA Residual Heat Removal Pump INDPU0002, lB Residual Heat Removal Pump 2NDPUOOO1, 2A Residual Heat Removal Pump 2NDPU0002, 2B Residual Heat Removal Pump OMb-2000, ISTB-3510(b)(1) The full-scale range of each analog instrument shall be not greater than three times the reference value.
BASIS FOR RELIEF:
ALTERNATE TESTING:
The subject pumps have discharge process instrumentation installed.
The discharge pressure gauge has a range of 0-1000 PSIG and an accuracy of 0.5%. Typical reference values for pump discharge pressures are in the 230-260 PSIG range. Therefore, the process range does not meet the three times reference value criteria of the code. Installation and removal of special discharge test gauges for the purpose of quarterly Group A testing is a hardship. The minimum code requirement for instrument accuracy for these pressure gauges for Group A testing is 2% per Table ISTB-3500-1.
Since the accuracy of the installed process instrumentation is 0.5% it more than compensates for the use of the increased range of the process instrumentation. Therefore there is no compensating increase in level of quality or safety in performing the hardship of installation and removal of test instrumentation for quarterly testing for each these four pumps.
Perform the quarterly Group A Tests with the installed process instrumentation for the subject pumps. The accuracy of the process instrumentation (0.5%) is much greater than the requirements specified in Table ISTB-3500-1 for instrument accuracy (2%). The actual reading error at test pressure due to the process instrument is 2.2% (0.5%
- 1000/230) for discharge pressure at the low end of this range. If a 0-690 PSIG gauge was used with the code minimum 2%
accuracy, then the reading error would be 6% (2%
- 690/230).
Therefore the actual instrumentation error introduced into the test would be less (2.2% vs. 6%).
Using the installed process instrumentation data provides reasonable assurance that the component is operationally ready and meets the intent of the instrumentation requirements of the code. This relief was approved in the previous 120 month code update.