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MONTHYEARML0925200322009-08-27027 August 2009 Response to Relief Request 09-GO-001 Request for Additional Information Regarding Requirements for Certain Buried Components of the Condenser Circulating Water System Project stage: Request ML1004703592010-02-18018 February 2010 Relief Request 09-GO-001, Regarding Alternatives from Pressure Test Requirements for Buried Piping Project stage: Other ML1004700452010-02-18018 February 2010 Relief Request 09-GO-001, Regarding Alternatives from Pressure Test Requirements for Buried Piping Project stage: Other 2009-08-27
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Category:Letter
MONTHYEARIR 05000369/20230042024-01-31031 January 2024 Integrated Inspection Report 05000369/2023004 and 05000370/2023004 ML24019A1392024-01-25025 January 2024 TSTF 505 and 50.69 Audit Summary ML24019A2002024-01-24024 January 2024 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection IR 05000369/20234022023-12-14014 December 2023 Material Control and Accounting Program Inspection Report 05000369/2023402 and 05000370/2023402 ML23317A2272023-11-17017 November 2023 William B. McGuire Nuclear Station, Units 1 and 2 - Transmittal of Dam Inspection Report - Non-Proprietary ML23317A3462023-11-14014 November 2023 Duke Fleet - Correction Letter to License Amendment Nos. 312 & 340 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000369/20230032023-10-24024 October 2023 Integrated Inspection Report 05000369/2023003 and 05000370/2023003; and Inspection Report 07200038/2023001 IR 05000369/20240102023-10-13013 October 2023 Notification of McGuire Nuclear Station Comprehensive Engineering Team Inspection U.S. Nuclear Regulatory Commission Inspection Report 05000369, 370/2024010 IR 05000369/20230102023-10-13013 October 2023 Age Related Degradation Inspection Report 05000369/2023010 and 05000370/2023010 ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds IR 05000369/20233012023-09-20020 September 2023 William B. McGuire Nuclear Station - NRC Examination Report 05000369/2023301 and 05000370/2023301 ML23230A0652023-08-31031 August 2023 William B. McGuire Nuclear Station, Units 1 and 2 - Relief Request Use of Later Edition of ASME Code ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000369/20230052023-08-25025 August 2023 Updated Inspection Plan for McGuire Nuclear Station Units 1 and 2 (Report 05000369/2023005 and 05000370/2023005) IR 05000369/20230022023-07-28028 July 2023 Integrated Inspection Report 05000369/2023002 and 05000370/2023002 IR 05000369/20234202023-07-24024 July 2023 Security Baseline Inspection Report 050003692023420 and 050003702023420 ML23206A0092023-07-24024 July 2023 William B. McGuire Nuclear Station Operator Licensing Written Examination Approval 05000369/2023301 and 05000370/2023301 ML23207A0762023-07-14014 July 2023 EN 56557 - Update to Part 21 Report Re Potential Defect with Trane External Auto/Stop Emergency Stop Relay Card Pn: XI2650728-06 ML23159A2712023-06-20020 June 2023 William B. McGuire Nuclear Station, Unit 1 - Relief Request Impractical Reactor System Welds ML23237A2672023-06-13013 June 2023 June 13, 2002 - Meeting Announcement - McGuire and Catawba Nuclear Stations 50-369, 50-370 and 50-413, 50-414 ML23159A0052023-06-0505 June 2023 56557-EN 56557 - Paragon - Redlined ML23115A2122023-05-0101 May 2023 Review of the Spring 2022 Steam Generator Tube Inspection Report ML23118A0762023-05-0101 May 2023 Approval for Use of Specific Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI IR 05000369/20230012023-05-0101 May 2023 Integrated Inspection Report 05000369/2023001 and 05000370/2023001 ML23094A1832023-04-18018 April 2023 Audit Plan TSTF-505, Rev. 2, RITSTF Initiative 4B & 10 CFR 50.69, Risk-Informed Categorization & Treatment of Structures, Systems & Components for Nuclear Power Reactors (EPIDs L-2023-LLA-0021 & L-2023-LLA-0022) ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility IR 05000369/20220062023-03-0101 March 2023 Annual Assessment Letter for McGuire Nuclear Station Units 1 and 2 (NRC Inspection Report 05000369/2022006 and 05000370 2022006) IR 05000369/20220042023-01-30030 January 2023 Mcguire Nuclear Station - Integrated Inspection Report 05000369/2022004 and 05000370/2022004 IR 05000369/20224202023-01-11011 January 2023 Security Baseline Inspection Report 05000369/2022420 and 05000370/2022420 ML22356A0512022-12-14014 December 2022 Curtiss-Wright Nuclear Division, Letter Regarding Potential Efect in a Configuration of the 11/2 Inch Quick Disconnect Connector Cable Assemblies Supplied to Duke Energy (See Attached Spreadsheet) for a Total of 460 of Connectors Only Suppl ML22347A1512022-12-13013 December 2022 William B. Mcguire Nuclear Station Notification of Licensed Operator Initial Examination 05000369/2023301 and 05000370/2023301 ML22340A6662022-12-0808 December 2022 Summary of November 30, 2022, Public Meeting with Duke Energy Carolinas, LLC for McGuire Nuclear Station, Units 1 & 2 Proposed LAR to Adopt TSTF-505, Rev. 2 and 10 CFR 50.69 Risk-Informed Categorization and Treatment of Structures, Systems ML22290A1012022-11-29029 November 2022 Issuance of Amendment Nos. 326 and 305, Regarding Changes to Technical Specification 3.4.3, Reactor Coolant System Pressure Temperature Limits ML22096A0032022-11-18018 November 2022 McGuire Nuclear Station and Shearon Harris Nuclear Power Plant Authorization of RA-19-0352 Regarding Use of Alternative for RPV Head Closure Stud Examinations ML22256A2532022-11-14014 November 2022 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-541, Rev. 2 IR 05000369/20220032022-10-27027 October 2022 Integrated Inspection Report 05000369/2022003 and 05000370/2022003 IR 05000369/20220112022-09-29029 September 2022 Biennial Problem Identification and Resolution Inspection Report 05000369/2022011 and 05000370/2022011 ML22266A0782022-09-26026 September 2022 William B. Mcguire Nuclear Station, Unit 2 Pressurizer Power Operated Relief Valve Relief Request ML22258A0302022-09-15015 September 2022 Evacuation Time Estimate Reports ML22242A0022022-09-12012 September 2022 Issuance of Amendments to Adopt TSTF 569, Revision 2, Revise Response Time Testing Definition IR 07200038/20220012022-09-12012 September 2022 Operation of an Independent Spent Fuel Storage Installation Report 07200038/2022001 ML22230B6132022-09-0101 September 2022 Review of the Draft Environmental Assessment and Finding of No Significant Impact for Brunswick Steam Electric Plant and McGuire Nuclear Station Independent Spent Fuel Storage Installations Decommissioning Funding Plans IR 05000369/20220052022-08-29029 August 2022 Updated Inspection Plan for McGuire Nuclear Station Units 1 and 2 NRC Inspection Report 05000369/2022005 and 05000370/2022005 IR 05000369/20220022022-07-26026 July 2022 Integrated Inspection Report 05000369/2022002 and 05000370/2022002 ML22215A2502022-07-25025 July 2022 EN 55960 - Update - Curtiss Wright ML22164A0362022-07-19019 July 2022 Mcguire Nuclear Station, Units 1 and 2; Issuance of Amendments to Revise the Conditional Exemption of the End-Of-Cycle Moderator Temperature Coefficient Measurement Methodology (EPID L-2021-LLA-0198) Public ML22175A0162022-06-24024 June 2022 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML22046A0222022-06-14014 June 2022 Issuance of Amendments to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO ML22111A3112022-05-16016 May 2022 Letter Issuing Exemption to McGuire IR 05000369/20224012022-05-12012 May 2022 Cyber Security Inspection Report 05000369/2022401 and 05000370/2022401 2024-01-31
[Table view] Category:Safety Evaluation
MONTHYEARML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23230A0652023-08-31031 August 2023 William B. McGuire Nuclear Station, Units 1 and 2 - Relief Request Use of Later Edition of ASME Code ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 ML23159A2712023-06-20020 June 2023 William B. McGuire Nuclear Station, Unit 1 - Relief Request Impractical Reactor System Welds ML23118A0762023-05-0101 May 2023 Approval for Use of Specific Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility ML22290A1012022-11-29029 November 2022 Issuance of Amendment Nos. 326 and 305, Regarding Changes to Technical Specification 3.4.3, Reactor Coolant System Pressure Temperature Limits ML22096A0032022-11-18018 November 2022 McGuire Nuclear Station and Shearon Harris Nuclear Power Plant Authorization of RA-19-0352 Regarding Use of Alternative for RPV Head Closure Stud Examinations ML22256A2532022-11-14014 November 2022 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-541, Rev. 2 ML22266A0782022-09-26026 September 2022 William B. Mcguire Nuclear Station, Unit 2 Pressurizer Power Operated Relief Valve Relief Request ML22242A0022022-09-12012 September 2022 Issuance of Amendments to Adopt TSTF 569, Revision 2, Revise Response Time Testing Definition ML22164A0362022-07-19019 July 2022 Mcguire Nuclear Station, Units 1 and 2; Issuance of Amendments to Revise the Conditional Exemption of the End-Of-Cycle Moderator Temperature Coefficient Measurement Methodology (EPID L-2021-LLA-0198) Public ML22046A0222022-06-14014 June 2022 Issuance of Amendments to Adopt TSTF-439, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO ML22010A2812022-03-0404 March 2022 Issuance of Amendments to Adopt TSTF-577, Rev. 1 Revised Frequencies for Steam Generator Tube Inspections (EPID L-2021-LLA-0161 ML21306A1592021-11-16016 November 2021 Request to Use Provisions of Later Edition and Addenda of the ASME Code, Section XI (EPID; L-2021-LLR-0048) ML21155A2132021-08-26026 August 2021 Plant ML21131A0262021-06-23023 June 2021 Issuance of Amendments to Change Technical Specification 3.8.1, to Reduce Emergency Diesel Generator Maximum Voltage ML21113A0132021-05-0606 May 2021 Request for Use of a Later Edition of ASME Boiler and Pressure Vessel Code, Section XI for Repair and Replacement Activities ML21029A3352021-02-16016 February 2021 Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML20300A2062020-11-0909 November 2020 Duke Fleet - Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI ML20258A2712020-09-21021 September 2020 Correction Letter to Amendment Nos. 301, 329, 307, 303, 178, 317, 296, 416, 418, 417, and 268 ML20230A2052020-08-21021 August 2020 Relief Request RA-20-0031, Delay to Update the Code of Record for Inservice Inspection ML20083F9272020-08-12012 August 2020 Issuance of Amendments to Relocate the Unit/Facility/Plant Staff Qualification Requirements to the Duke Energy Quality Assurance Program Description ML19254A6202019-09-17017 September 2019 Duke Energy Fleet (Brunswick, Catawba, Robinson, McGuire, Oconee, and Shearon Harris) - Alternative to Use Encoded Phased Array Ultrasonic Examination in Lieu of Radiography ML19217A3242019-08-14014 August 2019 Relief Request MC-SRV-NC-03, Alternate Testing for Pressurizer Power Operated Relief Valve Block Valve 2NC-35B ML19184A5852019-08-0808 August 2019 Issuance of Amendment Nos. 316 and 295 to Correct Editorial Error in Technical Specification 3.0 and Remove Expired Footnotes from TS 3.5.2, 3.6.6, 3.7.5, 3.7.6, 3.7.7, 3.7.9, 3.7.11, 3.8.1, and 3.8.4 ML19058A6322019-07-0101 July 2019 Issuance of Amendments to Revise Emergency Action Level Schemes to Incorporate Clarifications Provided by Emergency Preparedness FAQs ML19126A0302019-06-28028 June 2019 Issuance of Amendments to Technical Specification 3.8.1, AC Sources-Operating ML19128A3262019-06-20020 June 2019 Alternative to Depth Sizing Qualification Examination of Welds ML19050A2972019-04-18018 April 2019 McGuire Nuclear Station, Units 1 and 2, Shearon Harris Nuclear Power Plant, Unit 1, H B. Robinson Steam Electric Plant, Unit 2 - Issuance of Amendments Regarding Removal ML19091A1942019-04-17017 April 2019 Safety Evaluation Input for License Amendment Request to Revise the Technical Specifications 3.8.1, AC Sources - Operating. ML18355A6102019-01-25025 January 2019 Issuance of Amendments to Revise the Licensing Basis for Protection from Tornado Generated Missiles ML18318A3582019-01-16016 January 2019 Issuance of Amendment Nos. 311 and 290 to Correct Non-Conservative Technical Specification 3.4.11, Pressurizer Power Operated Relief Valves Porvs) ML18277A3222018-11-19019 November 2018 Issuance of Amendments 310 and 289 to Technical Specifications to Adopt TSTF-234-A, Revision 1, Add Action for More than One (D)Rpi Inoperable ML18172A1722018-08-15015 August 2018 Issuance of Amendments to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application ML18009A8422018-01-31031 January 2018 Issuance of Amendments to Extend the Containment Type a Leak Rate Test Frequency to 15 Years and Type C Leak Rate Test Frequency to 75 Months (CAC Nos. MF9020 and MF9021; EPID L-2016-LLA-0032) ML17297A9172018-01-0505 January 2018 Issuance of Amendments Adopting Technical Specifications Task Force Traveler TSTF-197-A, Revision 2 (CAC Nos. MF9110 and MF9111; EPID L-2017-LLA-0161) ML17331A0862017-12-26026 December 2017 Alternative to Inservice Inspection Regarding Reactor Pressure Vessel Threads ML17277A3132017-10-31031 October 2017 Issuance of Amendments Adopting Technical Specifications Task Force Traveler TSTF-340-A, Revision 3 (CAC Nos. MF9117 and MF9118; EPID L-2017-LLA-0169) ML17269A1982017-10-31031 October 2017 Issuance of Amendments Adopting Technical Specifications Task Force Traveler TSTF-352-A, Revision 1 ML17271A0342017-10-31031 October 2017 Issuance of Amendments Adopting Technical Specifications Task Force Traveler TSTF-349-A, Revision 1, TSTF-361-A, Revision 2, and TSTF-438-A, Revision 0 (CAC Nos. MF9101 - MF9107) ML17261B2182017-10-25025 October 2017 Issuance of Amendments Adopting Technical Specifications Task Force Traveler TSTF-315-A Revision 0 (CAC Nos. MF9112 and MF9113; EPID L-2017-LLA-0171) ML17269A0552017-10-25025 October 2017 McGuire, Units 1 and 2 - Issuance of Amendments Adopting Technical Specification Task Force Traveler TSTF-283-A, Revision 3 (CAC NOS. MF9098 and MF9099) ML17244A1022017-09-25025 September 2017 Issuance of Amendments Adopting Technical Specifications Task Force Traveler TSTF 285-A, Revision 1 ML17240A3542017-09-18018 September 2017 Issuance of Amendments Adopting Technical Specifications Task Force Traveler TSTF-269-A, Revision 2 ML17188A3872017-08-21021 August 2017 Issuance of Amendments Regarding Application to Consolidate Emergency Operations Facilities and Associated Emergency Plan Changes (CAC Nos. MF7650 Through MF7660) ML17055A6472017-05-0808 May 2017 Brunswick, Catawba, McGuire, Shearon Harris, and H. B. Robinson - Issuance of Amendments to Revise Technical Specifications to Adopt TSTF-522, Revision 0 (CAC Nos. MF8422, MF8423, MF8424, MF8425, MF8426, MF8427, MF8428, and MF8429) ML17066A3742017-04-26026 April 2017 Issuance of Amendments Re. Application to Revise TSs to Adopt TSTF-427, Rev. 2, Using the Consolidated Line Item Improvement Process (CAC Nos. MF8039 Through MF8049) ML17060A4812017-03-27027 March 2017 Issuance of Amendments Regarding Change to Technical Specification 3.6.14, & Divider Barrier Integrity; ML17003A0192017-03-0808 March 2017 Issuance of Amendments Regarding Change to Technical Specifications (Ts), Removal of Superseded TS Requirements 2023-09-25
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 18, 2010 Mr. Regis T. Repko Vice President McGuire Nuclear Station Duke Energy Carolinas, LLC 12700 Hagers Ferry Road Huntersville, NC 28078
SUBJECT:
MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, RELIEF REQUEST 09-GO-001, REGARDING ALTERNATIVES FROM PRESSURE TEST REQUIREMENTS FOR BURIED PIPING (TAC NOS. ME0958 AND ME0959)
Dear Mr. Repko:
By letter dated February 24,2009, as supplemented by letter dated August 27,2009, Duke Energy Carolinas, LLC (Duke, the licensee), submitted relief request (RR) 09-GO-001 for McGuire Nuclear Station, Units 1 and 2 (McGuire 1 and 2), related to the Inservice Inspection (lSI)
Program for the third 10-year interval pertaining to system pressure tests. The licensee requested approval of a proposed alternative to the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code) from performing required pressure tests of the buried components of the nuclear service water system. The Code requires measuring the rate of pressure loss or change in flow between the ends of the buried components. The licensee proposed an alternative test that will confirm that flow of the nuclear service water system is not impaired during normal plant operation. The Code of Record for McGuire 1 and 2 is the 1998 Edition through the 2000 Addenda of the ASME Code.
Based on the information provided by the licensee, the Nuclear Regulatory Commission (NRC) staff has determined that the licensee's compliance to the Code of record would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to Title 10 of the Code of Federal Regulations, Part 50, Section 50.55a(a)(3)(ii), the NRC authorizes the proposed alternative in RR 09-GO-001 for the third 10-year lSI interval for McGuire 1 and 2, which is scheduled to end on November 30, 2011, for McGuire 1 and February 18, 2014, for McGuire 2. Enclosed is the NRC's Safety Evaluation.
R. Repko -2 If you have any questions concerning this action, please contact John Stang of my staff at 301-415-1345 Sincerely, Gloria Kulesa, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-369 and 50-370
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR APPROVAL OF RELIEF 09-GO-001 REGARDING ALTERNATIVES FROM PRESSURE TEST REQUIREMENTS FOR BURIED PIPING MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 DUKE ENERGY CAROLINAS, LLC DOCKET NOS. 50-369 AND 50-370
1.0 INTRODUCTION
By letter dated February 24, 2009, Agencywide Documents Access and Management System (ADAMS) Accession No. ML090890782), as supplemented by letters dated August 27,2009 (ADAMS Accession No. ML092520032), Duke Energy Carolinas, LLC (the licensee), submitted relief request (RR) 09-GO-001 for the McGuire Nuclear Station, Units 1 and 2 (McGuire 1 and 2) related to the Inservice Inspection (lSI) Program for the third 1O-year interval for McGuire 1 and 2.
The licensee requested approval of a proposed alternative to the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code (Code) for required pressure test of the buried components of the nuclear service water system. The Code requires measuring the rate of pressure loss or change in flow between the ends of the buried components. The licensee proposed an alternative test that will confirm that flow is not impaired during normal operation.
The integrity of the buried piping will be ensured during unimpaired flow testing for each train of the nuclear service water system by balancing the flow from the output of the nuclear service water pumps against the total measured flow through various nuclear safety-related loads. All of the individual component flows are recorded and verified against the owner-established flow acceptance criteria. In addition to the unimpaired flow test, the licensee will perform a visual examination of the ground surface areas above components buried to detect evidence of through-wall leakage in buried components. The Nuclear Regulatory Commission (NRC) staff has reviewed the licensee's proposed alternative pursuant to Title 10 to Code of Federal Regulations (10 CFR), Part 50, Section 50.55a(a)(3)(ii) on the basis that compliance to the Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
2.0 REGULATORY REQUIREMENTS Section 50.55a(g) requires that lSI of ASME Code Class 1, 2, and 3 components be performed in accordance with Section XI of the ASME Code and applicable addenda, except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). According Enclosure
-2 to 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraph 50.55a(g) may be used, when authorized by the NRC, if an applicant demonstrates that the proposed alternatives would provide an acceptable level of quality and safety or if the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in ASME Code,Section XI, Rules for lSI of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that lSI of components and system pressure tests conducted during the first 1O-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The lSI Code of Record for the third 1O-year inspection interval at McGuire 1 and 2 is the 1998 Edition, through the 2000 Addenda of the ASME Code,Section XI.
3.0 TECHNICAL EVALUATION
System/Component(s) for Which Relief is Requested ASME Code Class 3 nuclear service water system buried piping at McGuire 1 and 2.
ASME Code Requirements As applicable to the McGuire 1 and 2, the 1998 Edition through the 2000 Addenda of the ASME Code,Section XI, Table IWO-2500-1, Examination Category O-B, Item Number 02.10 requires a system pressure test and a VT-2 visual examination. Subsection IWA-5244(b) requires buried components that are isolable by means of valves be tested to determine the rate of pressure loss in the buried components. Alternatively, the test may determine the change in flow between the ends of the buried components. The system pressure test for nonisolable buried components shall consist of a test to confirm that flow during operation is not impaired.
Licensee's Request for Relief Approval of a proposed alternative is requested from performing the system pressure test for buried portions of Class 3 piping that are isolable by means of valves by determining the rate of pressure loss or the change in flow between the ends of buried piping.
Licensee's Basis for Requesting Relief The buried piping segments of the Class 3 nuclear service water piping at McGuire 1 and 2 are bounded by butterfly valves that are not designed or expected to provide an adequate leak tight boundary that is necessary for an accurate pressure decay test. To perform an accurate rate of pressure loss test, extensive maintenance or system modifications would be required. Also, the buried piping is not instrumented to measure change of flow at the ends. The licensee has proposed an alternative to perform the unimpaired flow test. Neither the change in flow test
[IWA-5244(b)(1)] nor the unimpaired flow test [IWA-5244(b)(2)] is sufficiently sensitive to detect
-3 small through-wall leakage in these buried components, due to relatively high system flow rates and accuracy of flow measurement instrumentation. As such, there is no appreciable difference between the level of quality and safety achieved by performing either of these tests.
Visual examinations of ground surface areas are capable of detecting potentially small through-wall leakage in the buried component. These visual examinations and unimpaired flow tests will provide reasonable assurance of the structural and leak-tight integrity of the buried components.
For McGuire 1 and 2, the unimpaired flow tests for the buried piping identified in the relief request are conducted in accordance with "RN [Nuclear Service Water] Flow Balance" for each train of nuclear service water system. In accordance with Generic Letter (GL) 89-13 "Service Water System Problems Affecting Safety-Related Equipment," the flow balancing is performed as part of licensee's test program at the design basis flow rates to ensure that all components are not fouled or clogged and that they will be able to receive their design basis flow rates simultaneously. Flow rates measured during flow balance testing are verified to meet the licensee's flow acceptance criteria for each cooled components. If the measured nuclear service water system flow is less than the specified acceptance criteria, the nuclear service water train is declared inoperable and the appropriate Limiting Condition for Operating of the Technical Specifications is entered into. In addition, the condition is entered into the licensee's corrective action program for resolution.
Licensee's Proposed Alternative The licensee proposes to use as an alternative to the requirements of IWA-5244(a) or IWA-5244(b), a verification that flow during operation is not impaired in non-isolable buried piping.
For each segment of the buried pipe, periodic flow testing will be performed in accordance with flow balance test procedure for each train. These surveillance procedures require flow to be measured, recorded and compared to established acceptance criteria to provide assurance that flow is not impaired during operation. In addition to the unimpaired flow test, the licensee will perform a visual examination of the ground surface areas above components buried to detect evidence of through-wall leakage in buried components.
4.0 NRC STAFF'S EVALUATION The Code of Record for McGuire 1 and 2 requires a system pressure test for the buried portion of the nuclear service water piping and the condenser circulating water that will determine either a rate of pressure loss or a change in flow at the ends of the buried piping. The buried piping at McGuire 1 and 2 uses butterfly valves at the ends which were not designed for pressure isolation and therefore, are unsuitable to determine meaningful rate of pressure loss. One end of the buried piping is not instrumented for flow measurement which does not permit measurement of change in flow at the ends of the buried pipe. Therefore, the ASME Code-required test cannot be performed. In order to comply with the ASME Code requirement, extensive maintenance or system modification would be required or additional instrumentation need to be installed in the buried piping which would result in hardship to the licensee. The ASME Code, however, allows for nonisolable testing for buried components to confirm that flow during operation is not impaired.
The NRC staff agrees with the licensee's approach that unimpaired flow in the buried piping can be qualitatively assessed during the flow balance test routinely performed in accordance with GL 89-13. The procedure for the flow balance testing will confirm that the nuclear service water
- 4 GL 89-13. The procedure for the flow balance testing will confirm that the nuclear service water system of each unit is capable of supplying the design basis cooling water to various nuclear safety-related loads. During this test alignment, all of the individual component flows are recorded, including the total system flow and the opposite unit system flow. The recorded test flows are verified against the licensee's established flow acceptance criteria. The NRC staff finds that the licensee's proposed test performed in accordance with the GL 89-13 program will ensure unimpaired flow in the buried piping given that the specified flow from each of the pumps is available, assuming no major breach in the piping pressure boundary. The licensee has stated, however, that if during the flow balance test, the required flow could not be achieved, the nuclear service water system train under the test would be declared inoperable and the appropriate Limiting Condition for Operating of the Technical Specifications is entered into. In addition, the condition is entered into the licensee's corrective action program for resolution. The licensee will also perform a visual examination of the ground surface areas above buried components to detect any evidence of through-wall leakage. Therefore, the licensee's proposed alternatives in RR 09-GO-001 will provide reasonable assurance of structural and leak-tight integrity. The NRC staff has determined that compliance with the ASME Code requirement would require extensive maintenance and/or system modifications requiring the installation of additional flow measuring devices at the inlet and outlet ends of buried piping. This would result in hardship to the licensee without a compensating increase in the level of quality and safety.
5.0 CONCLUSION
The NRC staff concludes that for the buried portion of the nuclear service water system at McGuire 1 and 2, compliance with the ASME Code,Section XI requirement to perform a system pressure test that determines the rate of pressure loss or the change in flow would result in hardship to the licensee without a compensating increase in the level of quality and safety. The licensee's proposed alternative does provide reasonable assurance of structural and leak-tight integrity of the buried piping. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the proposed alternatives in RR 09-GO-001 are authorized for the third 1O-year lSI interval for McGuire 1 and 2.
All other requirements of ASME Code,Section XI for which relief has not been specifically requested remain applicable, including a third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: P. Patnaik, NRR Date: February 18, 2010
R. Repko -2 If you have any questions concerning this action, please contact John Stang of my staff at 301-415-1345 Sincerely, IRA!
Gloria Kulesa, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-369 and 50-370
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC RidsRgn2MailCenter Resource LPLlI-1 RtF RidsNrrPMMcGuire Resource (hard copy)
RidsAcrsAcnw_MailCtr Resource RidsNrrDciCpnb Resource RidsNrrDorlLp2-1 Resource PPatnaik, NRR RidsNrrLAMOBrien Resource (hard copy) DDiaz-Toro, EDO R-II ADAMS Accession No. ML100470359 *via memo OFFICE NRRlLPL2-1/PM NRRlLPL2-1/PM NRRtLPL2-1/LA NRRlCPNB/BC NRRtLPL2-1/BC NRRtLPL2-1/PM NAME JStang JThompson MO'Brien TChan* GKulelsa JStang DATE 2/17/10 2/17/10 2/17/10 12/24/09 2/18/10 2/18/10 OFFICIAL RECORD COpy