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MONTHYEARML1004711122010-02-17017 February 2010 Relief Request 09-GO-001, Regarding Alternatives from Pressure Test Requirements for Buried Piping Project stage: Other ML12030A0892012-01-23023 January 2012 Duke Energy Carolinas - Relief Request Serial #09-GO-001 Request for NRC Clarification Project stage: Request ML12289A8892012-10-23023 October 2012 Clarification of Relief Granted for Relief Request 09-GO-001 Project stage: Other 2012-01-23
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Category:Letter
MONTHYEARML23304A1422024-02-0101 February 2024 Issuance of Environmental Scoping Summary Report Associated with the U.S. Nuclear Regulatory Commission Staffs Review of the Oconee Nuclear Station, Units 1, 2, & 3, Subsequent License Renewal Application ML24005A2492024-01-24024 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting) IR 05000269/20243012024-01-11011 January 2024 Notification of Licensed Operator Initial Examination 05000269/2024301, 05000270/2024301, and 05000287/2024301 ML23331A7982023-12-14014 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report (01R32) ML23262A9672023-12-13013 December 2023 Alternative to Use RR-22-0174, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems Section XI, Division 1 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 05000269/20230032023-11-14014 November 2023 Integrated Inspection Report 05000269/2023003, 05000270/2023003, and 05000287/2023003; and IR 07200040/2023001; and Exercise of Enforcement Discretion ML23219A1402023-10-10010 October 2023 Audit Report Proposed Alternative to Use ASME Code Case N-752, Risk Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems XI, Division 1 ML23269A1102023-10-0606 October 2023 Letter to Steven Snider-Revised Schedule for the Environmental Review of the Oconee Nuclear Station, Unit 1, 2, and 3, Subsequent License Renewal Application ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 IR 05000269/20230112023-08-25025 August 2023 Comprehensive Engineering Team Inspection Report 05000269/2023011 and 05000270/2023011 and 05000287/2023011 IR 05000269/20230052023-08-25025 August 2023 Updated Inspection Plan for Oconee Nuclear Station Units 1, 2 and 3 (Report 05000269/2023005, 05000270/2023005, and 05000287/2023005) IR 05000269/20230022023-07-28028 July 2023 Integrated Inspection Report 05000269/2023002, 05000270/2023002 and 05000287/2023002 ML23208A0972023-07-27027 July 2023 Subsequent License Renewal List of Threatened and Endangered Species That May Occur in Your Proposed Project Location or May Be Affected IR 05000269/20230102023-07-19019 July 2023 Biennial Problem Identification and Resolution Inspection Report 05000269/2023010 and 05000270/2023010 and 05000287/2023010 and Notice of Violation ML23178A0682023-07-0303 July 2023 Audit Plan Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 & 3 Systems Section XI, Division 1 ML23132A2392023-06-0101 June 2023 Summary of the April 2023 Remote Environmental Audit Related to the Review of the Subsequent License Renewal Application ML23144A0192023-05-25025 May 2023 Review of the Spring 2022 Steam Generator Tube Inspection Report (O3R31) IR 05000269/20230012023-05-12012 May 2023 Integrated Inspection Report 05000269/2023001 and 05000270/2023001 and 05000287/2023001 ML23121A0552023-05-0303 May 2023 Acknowledgement of Withdrawal Request to Revise TS 5.5.2 Containment Leakage Rate Testing Program 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 ML23117A0432023-04-20020 April 2023 Framatome, Inc., Part 21 Notification of Existence of a Defect ML23075A0732023-04-0505 April 2023 License Renewal Regulatory Audit Regarding the Environmental Review of the Subsequent License Renewal Application Supplement (EPID Number L-2021-SLE-0002) ML23045A1332023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - Achp Letter ML23045A1402023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - Shpo Letter ML23045A1432023-03-15015 March 2023 Request for Scoping Comments Concerning the Supplemental Environmental Review of Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application - State Tribe Letter ML22332A4932023-03-10010 March 2023 William States Lee III 1 and 2 - Issuance of Amendments Regarding the Relocation of the Emergency Operations Facility ML23069A1102023-03-10010 March 2023 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML23061A1772023-03-0303 March 2023 Notification of Oconee Nuclear Station Comprehensive Engineering Team Inspection - NRC Inspection Report 05000269/2023011, 05000270/2023011 and 05000287/2023011 IR 05000269/20220062023-03-0101 March 2023 Annual Assessment Letter for Oconee Nuclear Nuclear Station, Units 1, 2 and 3 (NRC Inspection Report 05000269/2022006, 05000270/2022006, and 05000287/2022006) ML23039A1632023-02-0808 February 2023 Requalification Program Inspection ML23037A0772023-02-0606 February 2023 402 Cyber Notification and RFI Letter Final IR 05000269/20220042023-02-0202 February 2023 Integrated Inspection Report 05000269 2022004 and 05000270/2022004 and 05000287/2022004 ML22363A3942023-01-12012 January 2023 Subsequent License Renewal Environmental Report Supplement - Proposed Review Schedule 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 ML22321A0492022-12-0808 December 2022 Issuance of Amendment Nos. 426, 428 and 427, Additional Mode Change Limitations Applicable to the Adoption of TSTF- 359, Revision 9, Increase Flexibility in Mode Restraints ML22329A1042022-11-29029 November 2022 Review of the Fall 2021 Steam Generator Tube Inspection Report ML22321A1582022-11-22022 November 2022 Summary of Conference Call Regarding the Fall 2022 Steam Generator Tube Inspections 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 05000269/20220032022-11-0707 November 2022 Integrated Inspection Station 05000269/2022003 and 05000270/2022003 and 05000287/2022003 ML22301A0112022-11-0303 November 2022 Request for Withholding Information from Public Disclosure Regarding the SLR Application - September 2, 2022 ML22298A0752022-10-27027 October 2022 Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application Duke Energy Letter Dated July 25, 2022 ML22264A0322022-10-20020 October 2022 _Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application - Duke Energy Letter Dated July 8, 2022 IR 05000269/20220112022-09-26026 September 2022 NRC Inspection Report 05000269/2022011 and 05000270/2022011 and 05000287/2022011 ML22258A0302022-09-15015 September 2022 Evacuation Time Estimate Reports ML22222A0072022-09-14014 September 2022 Request for Withholding Information from Public Disclosure Regarding the Subsequent License Renewal Application ML22231B1362022-09-0101 September 2022 Review of the Draft Environmental Assessment and Findings of No Significant Impact for Catawba Nuclear Station, H.B. Robinson Steam Electric Plant, and Oconee Nuclear Station Independent Spent Fuel Storage Installation Decommissioning Fundi ML22234A0062022-08-30030 August 2022 SLRA - Closed Public Meeting Summary - August 18, 2022 2024-02-01
[Table view] Category:Safety Evaluation
MONTHYEARML23262A9672023-12-13013 December 2023 Alternative to Use RR-22-0174, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems Section XI, Division 1 ML23256A0882023-09-25025 September 2023 Issuance of Alternative to Steam Generator Welds ML23195A0782023-08-29029 August 2023 Issuance of Amendments Regarding the Adoption of Technical Specifications Task Force Traveler TSTF-554, Revision 1 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 ML22349A1452022-12-19019 December 2022 Non-Proprietary Safety Evaluation Related to the SLRA of Oconee Nuclear Station, Units 1, 2, and 3 ML22321A0492022-12-0808 December 2022 Issuance of Amendment Nos. 426, 428 and 427, Additional Mode Change Limitations Applicable to the Adoption of TSTF- 359, Revision 9, Increase Flexibility in Mode Restraints 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 ML22096A1872022-07-15015 July 2022 Issuance of Amendment Nos. 424, 426, and 425 Revise TS 3.7.7, Low Pressure Service Water (LPSW) System to Extend the Completion Time for One Required Inoperable LPSW Pump 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 ML22068A0252022-03-15015 March 2022 Code Case OMN-28 - Alternative Valve Position Verification Approach to Satisfy ISTC-3700 for Valves Not Susceptible to Stem-Disk Separation ML22046A2802022-02-23023 February 2022 Relief from ASME Code Paragraph ISTP-3540(b) Related to High Pressure Injection Pumps Vibration Measurements ML22046A2452022-02-18018 February 2022 Regarding Alternative to Implement Code Case OMN-22, Smooth Running Pumps ML22019A1352022-01-21021 January 2022 Proposed Alternative to Implement ASME Code Case OMN-24 ML21347A0102021-12-20020 December 2021 Proposed Alternative to Implement ASME Code Case OMN-26 ML21335A1062021-12-0707 December 2021 Proposed Alternative to ASME Code W, Section XI, Subsection Iwl Regarding Containment Post-Tensioning System Inservice Inspection Requirements ML21281A1412021-11-19019 November 2021 Authorization and Safety Evaluation for Alternative Reactor Pressure Vessel Inservice Inspection Intervals ML21155A2132021-08-26026 August 2021 Plant 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 ML21006A0982021-03-15015 March 2021 Issuance of Amendment Nos. 421, 423, and 422 Revision of Licensing Basis for High Energy Line Breaks Outside of Containment (EPID L-2019-LLA-0184) (Public Version) 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 ML20335A0012021-01-26026 January 2021 Issuance of Amendment Nos. 420, 422, and 421 Measurement Uncertainty Recapture Power Uprate ML20303A0242020-12-0909 December 2020 Issuance of Amendments 419, 421, 420 TSTF-272, Refueling Boron Concentration Clarification ML20296A2812020-11-25025 November 2020 Issuance of Amendment Nos. 418, 420 and 419 TSTF-421, Revision to RCP Flywheel Inspection Program 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 ML20237F4352020-09-0404 September 2020 Issuance of Amendments Regarding the Technical Specification Requirements Pertaining to Mode Change Limitations 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 ML20055F5712020-02-26026 February 2020 Proposed Alternative Request 19-ON-001 to Use Modified American Society of Mechanical Engineer'S Boiler and Pressure Vessel Code Case N-853 ML20042D7142020-02-13013 February 2020 Relief Request 19-ON-002 for Proposed Alternative to Reactor Vessel Nozzle Weld Examination Frequency Requirements in ASME Code Case N-770-2 ML19260E0842019-10-31031 October 2019 Issuance of Amendments 415, 417, and 416, Regarding the Updated Final Safety Analysis Report Description of Tornado Mitigation ML19056A0862019-09-30030 September 2019 Issuance of Amendments Nos. 414, 416 and 415 Regarding the Physical Security Plan 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 ML19183A3172019-07-17017 July 2019 Issuance of Amendments Regarding the Updated Final Safety Analysis Report Section for Fission Gas Gap Release Rates ML19058A6322019-07-0101 July 2019 Issuance of Amendments to Revise Emergency Action Level Schemes to Incorporate Clarifications Provided by Emergency Preparedness FAQs ML19128A3262019-06-20020 June 2019 Alternative to Depth Sizing Qualification Examination of Welds ML18311A1342018-12-17017 December 2018 Non Proprietary - Issuance of Amendments Regarding the Updated Final Safety Analysis Report Section for the Standby Shutdown Facility ML18172A1722018-08-15015 August 2018 Issuance of Amendments to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application ML18040A1942018-04-12012 April 2018 Issuance of Amendments Regarding the Technical Specifications for Control Room Habitability (CAC Nos. MF9555, MF9556, and MF9557; EPID L-2017-LLA-0219) ML18051B2572018-02-28028 February 2018 Safety Evaluation for Alternative to Codes and Standards Requirements Associated with Bronze Tape Wrapped Emergency Power Cables (CAC Nos. MF7365, MF7366, and MF7367; EPID L-2016-LLR-0001) ML17331A0862017-12-26026 December 2017 Alternative to Inservice Inspection Regarding Reactor Pressure Vessel Threads ML17335A0252017-12-0505 December 2017 Correction to Safety Evaluation for Amendment Nos. 406, 408, and 407 (CAC Nos. MF7417, MF7418, and MF7419; EPID L-2016-LLA-0002) ML17124A6082017-11-20020 November 2017 Issuance of Amendments Regarding the Technical Specifications for Electrical Power Systems (CAC Nos. MF7417, MF7418, and MF7419; EPID L-2016-LLA-0002) ML17202U7912017-08-30030 August 2017 Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 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) ML17167A2652017-07-12012 July 2017 Issuance of Amendments Regarding the Technical Specifications for Dry Spent Fuel Storage Cask Loading and Unloading (CAC Nos. MF8161, MF8162, and MF8163) ML17103A5092017-05-11011 May 2017 Issuance of Amendments Allowing the Use of the Copernic Fuel Performance Code 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) ML16197A0112016-07-22022 July 2016 Relief Request Nos. 15-ON-002 and 15-ON-003, Fourth 10-Year Inservice Inspection Interval 2023-09-25
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 17, 2010 Mr. Dave Baxter Vice President, Oconee Site Duke Energy Carolinas, LLC 7800 Rochester Highway Seneca, SC 29672
SUBJECT:
OCONEE NUCLEAR STATION, UNITS 1,2, AND 3, RELIEF REQUEST 09-GO-001, REGARDING ALTERNATIVES FROM PRESSURE TEST REQUIREMENTS FOR BURIED PIPING (TAC NOS. ME0962, ME0963, AND ME0964)
Dear Mr. Baxter:
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 the fourth 1O-year interval of Oconee Nuclear Station Units 1, 2, and 3 (Oconee 1, 2, and 3) related to the Inservice Inspection (lSI) Program pertaining to system pressure tests. The licensee requested approval of a proposed alternative to the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code from performing required pressure tests of the buried components of the condenser circulating water system by measuring the rate of pressure loss or change in flow between the ends of the buried components. Alternatively, the licensee proposed a test that will confirm that flow during operation is not impaired.
Based on the information provided by the licensee, the Nuclear Regulatory Commission (NRC) staff has determined that the licensee's compliance to the lSI 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 lSI program alternative proposed in RR 09-GO-001 for the fourth 10-year lSI intervals of Oconee 1, 2, and 3 which are scheduled to end on July 14, 2013, for Oconee 1, September 8, 2014, for Oconee 2 and December 15, 2014, for Oconee 3. Enclosed is the NRC's Safety Evaluation.
D. Baxter -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. 50-269, 50-270, and 50-287
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 OCONEE NUCLEAR STATION, UNITS 1,2, AND 3 DUKE ENERGY CAROLINAS, LLC DOCKET NOS. 50 269, 50-270 AND 50-287
1.0 INTRODUCTION
By letter dated February 24, 2009, Agencywide Documents Access and Management System (ADAMS) Accession No. ML090890782), as supplemented by letter dated August 27, 2009 (ADAMS Accession No. ML092520032), Duke Energy Carolinas, LLC (Duke, the licensee),
submitted relief request (RR) 09-GO-001 for the Oconee Nuclear Station Units 1, 2 and 3 (Oconee 1, 2 and 3) for the fourth 10-year interval of Oconee 1, 2, and 3 related to the Inservice Inspection (lSI) Program 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) required pressure test for buried components of the condenser circulating water (CCW) system, by measuring the rate of pressure loss or change in flow between the ends of the buried components. Alternatively, the licensee proposed a test that will confirm that flow during operation is not impaired.
The integrity of the buried piping will be ensured during unimpaired flow testing of the CCW system by comparing the flow from the output of the CCW pumps against the total measured flow through various 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 to 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraph 50.55a(g) may be used, Enclosure
-2 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 10-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 fourth 1O-year inspection interval of Oconee 1, 2 and 3 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 CCW system buried piping at Oconee 1, 2, and 3.
ASME Code Requirements As applicable to the Oconee 1, 2 and 3, 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 the 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 CCW piping at Oconee 1, 2 and 3 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 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 small through-wall leakage in these buried components, due to relatively high system flow rates and accuracy of flow
-3 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 components. These visual examinations and unimpaired flow tests will provide reasonable assurance of the structural and leak-tight integrity of the buried components.
For Oconee 1,2 and 3, the unimpaired flow tests are conducted in accordance with the procedure "LPSW [Low Pressure Service Water] System Flow Data Verification" which confirms that the CCW system for Oconee 1, 2 and 3 is capable of supplying cooling water to the LPSW pumps. 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 tests are verified to meet Iicensee'sl1ow acceptance criteria for each cooled component. If the measured CCW system flow is less than the specified acceptance criteria, the LPSW system is declared inoperable, and 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 the CCW system. 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 requires a system pressure test for the buried portion of the CCW system that will determine either a rate of pressure loss or a change in flow at the ends of the buried piping. The buried CCW piping at Oconee 1,2 and 3, 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 system modifications would be required and additional instrumentation would need to be installed in the buried piping which would result in hardship to the licensee. The ASME Code, however, allows for nonisolable buried components to confirm that flow during operation is not impaired. The NRC staff finds acceptable the licensee's 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 test will confirm that the CCW system is capable of supplying the design basis cooling water to various safety-related loads.
During this test alignment. all of the individual component flows are recorded. The recorded test
-4 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 GL 89-13 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 LPSW system would be declared inoperable and the condition entered into the licensee's corrective action program for resolution. In addition to the test for unimpaired flow, 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 of the buried piping and components. The NRC staff has determined that compliance with the ASME Code requirement would require extensive system modifications which would cause 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 CCW system at Oconee 1, 2, and 3, 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 provides 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 fourth 10-year lSI interval for Oconee 1, 2 and 3. 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 Date: February 17,2010
ML100471112 *via memo NRR-028 OFFICE NRRlLPL2-1/PM NRRlLPL2-1/LA NRRlCPNB/BC NRRlLPL2-1/BC NRRlLPL2-1/PM NAME JStang MO'Brien TChan" GKulelsa JStang DATE 2/17/10 2117/10 12/24/09 2/17/10 2/17/10