ML16141A868
| ML16141A868 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 01/31/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML16141A867 | List: |
| References | |
| NUDOCS 9502070245 | |
| Download: ML16141A868 (3) | |
Text
,9REG 0j UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE SECOND TEN-YEAR INTERVAL INSERVICE INSPECTION REQUESTS FOR RELIEF 94-08 FOR DUKE POWER COMPANY OCONEE NUCLEAR STATION, UNIT 1 DOCKET NO. 50-269
1.0 INTRODUCTION
The Technical Specifications for Oconee Nuclear Station state that the inservice inspection and testing of the American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g), except where specific written relief has been granted by the Commission pursuant to Section 50.55a(g)(6)(i).
Section 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulties 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 the ASME Code,Section XI, "Rules for Inservice Inspection 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 inservice examination of components and system pressure tests conducted during the second 10-year interval 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) on the date 12 months prior to the start of the 120-month inspection interval, subject to the limitations and modifications listed therein. The applicable edition of Section XI of the ASME Code for the Oconee Nuclear Station, second 10-year inservice inspection (ISI) interval is the 1980 Edition through Winter 1980 Addenda. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.
9502070245 950131 PDR ADOCK 05000269 0
-2 Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(i), the Commission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed.
In its letter dated September 6, 1994, Duke Power Company (the licensee) submitted Request for Relief No. 94-08, asking authorization to use alternative examinations to the Code-required periodic pressure tests of the Standby Shutdown Facility (SSF) Fuel Oil system.
2.0 EVALUATION The staff has evaluated the information provided by the licensee in support of Request for Relief No. 94-08 as follows:
Code Requirement:
Table IWD-2500-1 of Section XI of the ASME Code requires pressure retaining components be visually examined, VT-2, during a system pressure test once each inspection period and during the hydrostatic test once each inspection interval.
Request for Relief No. 94-08:
The licensee requests relief from the requirements of the Code to perform a system pressure test during each inspection period and a hydrostatic test once each 10-year interval for the SSF fuel Oil System. In addition, the licensee proposes to use operations personnel in lieu of qualified inspectors to examine the system during the alternative examinations.
Licensee's Basis for Requesting Relief:
The licensee asserts that the proposed alternative tests provide an acceptable level of quality and safety in lieu of the ASME Code-required tests and examinations. The SSF diesels are run unloaded on a monthly basis and run under load for 60 minutes each quarter. During these evolutions, operations personnel verify the fuel oil inventory. If there is an unaccounted change in fuel oil inventory of more than 500 gallons, approximately one percent of the tank capacity, the change must be reported and evaluated. Also on a quarterly basis, the SSF Fuel Oil Transfer Pump is run, transferring oil from the Fuel Oil Storage Tank to the Fuel Oil Day Tank. The combination of those portions of the fuel oil system needed to run the diesels and those portions needed to transfer fuel oil to the day tank comprise the entire Fuel Oil System needed to perform its required safety function.
-3 In addition to monitoring of the fuel oil system while operating the diesel or fuel oil transfer pump, operations personnel tour the SSF at least once each shift. Part of the duties of the operator during this tour is to look for indications of fuel oil leaks.
Licensee's Proposed Alternative Examination:
The licensee proposes to examine the SSF Fuel Oil System as part of the routine operation and testing of the system by the Operation's department.
Staff Evaluation:
The Code requires that the Fuel Oil system be visually examined for leakage once each Inspection Period with the system at normal operating pressure, and once during each 10-year Inspection Interval during a hydrostatic pressure test of the system. Since the tanks are open to the atmosphere, the hydrostatic head with the storage tank filled to design capacity is used for the test pressure for the hydrostatic test. The visual examinations are required to be performed by qualified inspectors.
The normal conditions of the SSF Fuel Oil Storage Tank and the Fuel Oil Day Tank, required by the Oconee Technical Specifications, would ensure that the!
system was being examined under pressures which would meet the Code-required pressures. The operations personnel who would perform the monitoring are not qualified VT-2 inspectors; however, fuel oil leakage would be much more obvious than water leakage. Indication of leakage would remain until physically cleaned up.
Fuel oil also has a distinctive smell, color and feel, and therefore any leakage would be much more obvious. Because of the ease of detection of any leakage of fuel oil, the staff has determined that this alternative testing would provide an acceptable level of quality and safety in lieu.of the required ASME Section XI tests and visual examinations.
3.0 CONCLUSION
The staff has reviewed and evaluated the licensee's submittal, and has concluded that the alternative tests and examinations provide an acceptable level of quality and safety. Therefore, pursuant 10 CFR 50.55a(a)(3)(i), the licensee's proposed alternative testing contained in Request for Relief No.
94-08 is authorized.
Principal Contributor: L. Wiens Date: