Letter Sequence Request |
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EPID:L-2019-LLR-0067, Relief Request MC-SRV-NC-03, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) for Pressurizer Power Operated Relief Valve (PORV) Block Valve 2NC-35B Inservice Testing (Open) |
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Category:Letter type:RA
MONTHYEARRA-24-0137, Relief Requests for Inservice Testing Plan – Fifth Interval2024-07-0101 July 2024 Relief Requests for Inservice Testing Plan – Fifth Interval RA-24-0030, Duke Energy - Annual Radioactive Effluent Release Report - 20232024-04-29029 April 2024 Duke Energy - Annual Radioactive Effluent Release Report - 2023 RA-24-0083, Annual Report of Changes Pursuant to 10 CFR 50.462024-04-25025 April 2024 Annual Report of Changes Pursuant to 10 CFR 50.46 RA-24-0031, Annual Radiological Environmental Operating Report - 20232024-04-23023 April 2024 Annual Radiological Environmental Operating Report - 2023 RA-24-0094, Request for Approval of Duke Energy Corporation Transition to ANSI/ANS3.1-2014, American National Standard for Selection and Training of Nuclear Power Plant Personnel and Revision 4 of Regulatory Guide 1.8, Rev. 4 Qualification and Traini2024-04-17017 April 2024 Request for Approval of Duke Energy Corporation Transition to ANSI/ANS3.1-2014, American National Standard for Selection and Training of Nuclear Power Plant Personnel and Revision 4 of Regulatory Guide 1.8, Rev. 4 Qualification and Training RA-24-0101, (Mns), Units 1 and 2, Notification of Deviation from MRP-227, Revision 1-A Baffle-to-Former Bolt Inspection Frequency2024-04-16016 April 2024 (Mns), Units 1 and 2, Notification of Deviation from MRP-227, Revision 1-A Baffle-to-Former Bolt Inspection Frequency RA-24-0093, Response to NRC Regulatory Issue Summary 2024-01 Preparation and Scheduling of Operator Licensing Examinations2024-04-0202 April 2024 Response to NRC Regulatory Issue Summary 2024-01 Preparation and Scheduling of Operator Licensing Examinations RA-24-0085, Onsite Property Insurance Coverage2024-04-0101 April 2024 Onsite Property Insurance Coverage RA-24-0086, 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums2024-04-0101 April 2024 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums RA-24-0067, Independent Spent Fuel Storage Installation (ISFSI)2024-02-29029 February 2024 Independent Spent Fuel Storage Installation (ISFSI) RA-24-0004, End of Cycle 29 (M1R29) Inservice Inspection Summary Report2024-02-21021 February 2024 End of Cycle 29 (M1R29) Inservice Inspection Summary Report RA-23-0242, Proposed Alternative for the Inspection of Reactor Vessel Closure Head Penetrations in Accordance with 10 CFR 50.55a(z)(2)2024-01-10010 January 2024 Proposed Alternative for the Inspection of Reactor Vessel Closure Head Penetrations in Accordance with 10 CFR 50.55a(z)(2) RA-23-0325, Submittal of Procedures CSD-EP-HNP-0101-01, 02, CSD-EP-ONS-0101-01, CSD-EP-RNP-0101-01, and EP-RNP-EPLAN-ANNEX2024-01-0808 January 2024 Submittal of Procedures CSD-EP-HNP-0101-01, 02, CSD-EP-ONS-0101-01, CSD-EP-RNP-0101-01, and EP-RNP-EPLAN-ANNEX RA-23-0295, Delay of Planned End Date for Fourth 10-Year Inservice Testing (1ST) Program Interval2024-01-0404 January 2024 Delay of Planned End Date for Fourth 10-Year Inservice Testing (1ST) Program Interval RA-23-0318, Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-0404 December 2023 Supplement to Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RA-23-0284, RA-23-0284 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-16016 November 2023 RA-23-0284 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation RA-23-0279, Supplement to Application to Adopt Risk-Informed Completion Times TSTF-505, Revision 2 and Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power2023-11-0202 November 2023 Supplement to Application to Adopt Risk-Informed Completion Times TSTF-505, Revision 2 and Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power RA-23-0281, Procedure EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Summary of Changes2023-11-0101 November 2023 Procedure EP-ALL-EPLAN, Duke Energy Common Emergency Plan, Revision 5, Summary of Changes RA-23-0225, Procedure AD-EP-ALL-0109, Offsite Protective Action Recommendations, Revision 9, and the Joint Information Center (JIC) Relocation, Summary of Changes2023-09-20020 September 2023 Procedure AD-EP-ALL-0109, Offsite Protective Action Recommendations, Revision 9, and the Joint Information Center (JIC) Relocation, Summary of Changes RA-23-0154, Duke Energy - Response to Request for Additional Information Regarding Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2023-07-20020 July 2023 Duke Energy - Response to Request for Additional Information Regarding Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) RA-23-0136, Duke Energy Response to Request for Additional Information Regarding Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2023-07-20020 July 2023 Duke Energy Response to Request for Additional Information Regarding Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) RA-23-0142, Mcguire, Units 1 and 2, Oconee, Units 1, 2, and 3, H. 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Robinson, Unit 2, Response to Request for Additional Information Regarding the License Amendment Request to Revise Restrictive Technical Specification Surveillance Require RA-23-0127, 10 CFR 50.55a(g)(4)(iv) Request to Use a Subsequent Edition of ASME Section XI Referenced in 10 CFR 50.SSa(a) for ISI Code of Record2023-06-28028 June 2023 10 CFR 50.55a(g)(4)(iv) Request to Use a Subsequent Edition of ASME Section XI Referenced in 10 CFR 50.SSa(a) for ISI Code of Record RA-23-0135, Submittal of 30 Day Report Per 10 CFR 26.719(c), Unsatisfactory Performance of Health and Human Services Certified Laboratory2023-06-0707 June 2023 Submittal of 30 Day Report Per 10 CFR 26.719(c), Unsatisfactory Performance of Health and Human Services Certified Laboratory RA-23-0041, Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations2023-05-30030 May 2023 Response to NRC Regulatory Issue Summary 2023-01 Preparation and Scheduling of Operator Licensing Examinations RA-23-0118, Cycle 29, Revision 1, Core Operating Limits Report (COLR)2023-05-0303 May 2023 Cycle 29, Revision 1, Core Operating Limits Report (COLR) RA-23-0117, Report of Changes to Duke Energy McGuire Emergency Plan Annex2023-05-0101 May 2023 Report of Changes to Duke Energy McGuire Emergency Plan Annex RA-23-0044, Aduke Energy Annual Report of Changes Pursuant to 10 CFR 50.462023-04-26026 April 2023 Aduke Energy Annual Report of Changes Pursuant to 10 CFR 50.46 RA-23-0047, Duke Energy Annual Radiological Environmental Operating Report - 20222023-04-26026 April 2023 Duke Energy Annual Radiological Environmental Operating Report - 2022 RA-23-0046, Annual Radioactive Effluent Release Report - 20222023-04-24024 April 2023 Annual Radioactive Effluent Release Report - 2022 RA-23-0037, Duke Energy - Decommissioning Funding Plan for Independent Spent Fuel Storage Installations (Isfsis)2023-03-30030 March 2023 Duke Energy - Decommissioning Funding Plan for Independent Spent Fuel Storage Installations (Isfsis) RA-23-0039, 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums2023-03-30030 March 2023 10 CFR 140.21 Licensee Guarantees of Payment of Deferred Premiums RA-23-0040, Onsite Property Insurance Coverage2023-03-30030 March 2023 Onsite Property Insurance Coverage RA-23-0036, Biennial Decommissioning Financial Assurance Reports2023-03-30030 March 2023 Biennial Decommissioning Financial Assurance Reports RA-23-0076, Supplement to Response to Request for Additional Information (RAI) Regarding McGuire Nuclear Station Unit 1 Spring, 2022 Outage Steam Generator Tube Inspection Report2023-03-16016 March 2023 Supplement to Response to Request for Additional Information (RAI) Regarding McGuire Nuclear Station Unit 1 Spring, 2022 Outage Steam Generator Tube Inspection Report RA-23-0024, Response to Request for Additional Information (RAI) for Relief Request for RPV Reactor Coolant System Welds2023-02-28028 February 2023 Response to Request for Additional Information (RAI) for Relief Request for RPV Reactor Coolant System Welds RA-23-0065, Report of Changes to McGuire EAL Technical Basis Document2023-02-23023 February 2023 Report of Changes to McGuire EAL Technical Basis Document RA-18-0090, Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors2023-02-17017 February 2023 Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors RA-22-0257, Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2023-02-17017 February 2023 Proposed Alternative for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) RA-22-0091, Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements2023-02-16016 February 2023 Application to Revise Technical Specifications to Adopt TSTF-554, Revision 1, Revise Reactor Coolant Leakage Requirements RA-18-0190, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2023-02-16016 February 2023 License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b RA-23-0025, End of Cycle 28 (M1R28) Steam Generator Tube Inspection Report Response to Request for Additional Information (RAI)2023-02-15015 February 2023 End of Cycle 28 (M1R28) Steam Generator Tube Inspection Report Response to Request for Additional Information (RAI) RA-23-0001, Request to Use a Provision of a Later Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section XI2023-02-0202 February 2023 Request to Use a Provision of a Later Edition and Addenda of the ASME Boiler and Pressure Vessel Code, Section XI RA-22-0118, License Amendment Request to Revise Restrictive Technical Specification Surveillance Requirement Frequencies2023-02-0101 February 2023 License Amendment Request to Revise Restrictive Technical Specification Surveillance Requirement Frequencies RA-22-0256, Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2023-01-23023 January 2023 Proposed Alternative for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) RA-22-0335, Submittal of 30-Day Report Per 10CFR26.719(c)(1) - Unsatisfactory Performance of a Health & Human Services Certified Lab2022-12-0505 December 2022 Submittal of 30-Day Report Per 10CFR26.719(c)(1) - Unsatisfactory Performance of a Health & Human Services Certified Lab RA-22-0312, Report of Changes to McGuire Emergency Plan Annex2022-10-26026 October 2022 Report of Changes to McGuire Emergency Plan Annex RA-22-0303, End of Cycle 28 (M1 R28) Steam Generator Tube Inspection Report2022-10-25025 October 2022 End of Cycle 28 (M1 R28) Steam Generator Tube Inspection Report RA-22-0291, Report of Changes to Emergency Plan Implementing Procedures2022-10-17017 October 2022 Report of Changes to Emergency Plan Implementing Procedures RA-22-0024, Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii) for Volumetric Examination of Class 1 Components2022-09-21021 September 2022 Relief Requested in Accordance with 10 CFR 50.55a(g)(5)(iii) for Volumetric Examination of Class 1 Components 2024-07-01
[Table view] |
Text
Thomas*o. Ray, P.E.
Site ViceJ*resident
. M9Guire Nuclear Station
~*.ENERGY Duke Energy : : *
. MG01VP I 12700 Hager's Ferry Road
. Huntersvilie, Ne 28078 o: 980.875,4?0~. . . .
- f: 980.875.4809 Tom.Ray@duke*energy.com ..
RA-19-0310 July 17, 2()19. 10 CFR 50:55a
- ATTN: Document Control Desk U.S. NuclearRegulatory Commission Washington, *Dc 20555-0001
Subject:
. . Duke Energy Carolinas, LLC (Duke Energy)
McGuire Nuclear Station, Unit No. 2
- Renewed Facility Operating License NPF-17. :*
Docket No. 50-370 * * *
. Relief Request MC-SRV-NC-03 Proposed Alternative in Accordance with 1o*CFR 50.55a(z)(2) for Pressurizer Power:C)perated Relief Valve (PORV) Block Valve 2NC-35B lnservice Testing
- Pursuant to 10 CFR50.55a(z)(2), Duke Energy hereby requests U.S. Nuclear Regulatory Commission's approval of alternative testing for Pressurizer PORV Block Valve 2NC-35B. This*
valve has packing leakage, and stroking the valve quarterly creates a hardship witho'ut a
.. compensatfng hicrease in quality and safety, as described in the attached relief request.
The next quarterly testing for 2N.C:-35B is due September 10, 2019. The last date for the .
surveillance, including the 23-day grace period inaccordance with ASME Code Case OMN-20,
. lnservice Test Frequency; is October 3, 2019. Duke Energy .requests NRC's approval of this relief request no later'than September 30, 2019.
If you .have any questions or require additional information; please contact Mr. James Smith,
. Manager - Nuclear Support Services, at(98.0) 875-5477. .. . .
Thomas D. Ray, P.E.
- McGuire Nuclear Station www.dl.Jke0en\lrgy .com
U.S. Nuciear Re*gulatory Commission Document Confrol Desk .
. Serial: RA-19-0310 Page 2.
LJG/ljg ..
Enclosure:
- Specific Valve Relief Request MC-SRV~NC-D3 cc: .
Laura Dudes, Regional Administrator U.S. Nuclear Regulatory Commission Marquis One Tower
- 245 Pe~cht.ree Center Avem.1e, NE Suite 1200 .
Atlanta,-Georgia 30303-1257.
Andy Hutto, Senior. Resident Inspector .*
U.S. NuciearRegulatory Commission
.McGuire Nuclear Station Michael . Mahoney,*
Project Manager U.S. Nuclear Regulatory Commission
. 11555. Rockville Pike.
Mailstop 0-881 A
- Rockville, MD 20852 www.dµke 0 l:)nergy .com
Enclosure File: MC-1234.01 McGuire Nuclear Station Unit 2 "'" Specific Valve Relief Request MC-SRV-NC-03 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)
-- Hardship without a compensating increase in quality and safety --
- 1. ASME Code Component(s) Affected:
Pressurizer Power Operated Relief Valve (PORV) Block Valve 2NC-35B.
- 2. Component Function:
The pressurizer PORV Block Valves are normally open motor:.operated gate valves located on the pressurizer steam space. To perform their design safety functions, the subject valves must provide isolation in the case of a leaking or stuck open PORV and must open to vent the pressurizer during a steam generator tube rupture event. Manual operator action is credited for valve actuation in both the closed and open directions. There is a total of three PORV block valves (single A train and two B train) directly upstream of their respective PORVs. These valves do not receive an automatic actuation signal. These valves are interlocked to prevent more than one valve from closing at a time.
3. Applicable Code Edition and Addenda
ASME OM Code 2004 through 2006 Addenda.
4. Applicable Code Requirement
Quarterly exercise testing [ASME OMb-2006, section ISTC-3510]; Quarterly valve stroke time testing open and closed directions [ASME OMb-2006, section ISTC-5121l Two-year position verification testing [ASME OMb-2006, section ISTC-3700]. Note the two-year position indication verification testing does not apply to this relief request.
5. Reason for Request
Nuclear Condition Report (NCR) 02275540 was initiated by Engineering on June 4, 2019 due to an increasing trend in identified reactor coolant system (RCS) leakage between May 27, 2019 and June 9, 2019 .. The May 27, 2019 corrected identified RCS. leakage value was 0.055 GPM and gradually increased to 0.23 GPM by June 9, 2019. Technical Specification (TS) 3.4.13 limits RCS identified leakage to a maximum of 10 GPM. A containment entry was made on June 8, 2019 to investigate the source of identified RCS leakage. The investigation determined the leakage source to be from the common PORV block valve stem leak off line. A troubleshooting plan was developed and 2NC-35B was stroked closed on June 10, 2019 resulting in a significant decrease in RCS identified leakage. From June 10, 2019 to June 18, 2019, RCS identified leakage remained low with 2NC-35B in the closed position as shown in Figure 1.
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Enclo s ure File : MC - 1234 . 01 McGuire Unit 2 RCS Identified Leakage 0.25
~
a.. 0.2
~
j 0.15
.3
~ 0.1 C
a, J:!
~ 0.05 a:
Figure 1: McGuire Unit 2 RCS Identified Leakage Stroking 2NC-35B can create a hardship as further packing degradation may result, reducing operational RCS leakage margin. Current RCS leakage values are stable with 2NC-35B closed and the remaining two PORV block valves 2NC-31 Band 2NC-33A open.
2NC-35B remains operable with emergency power available. Based on current plant conditions and as described in the proposed alternative basis, Duke Energy is requesting relief from ASME Code quarterly valve surveillances to prevent quarterly valve cycles until valve repair can be made during the next Unit 2 refueling outage, which is currently scheduled to begin on March 21, 2020.
Repair of 2NC-35B would require entry into containment and RCS depressurization for isolation purposes. Personnel safety and ALARA practices are maximized during a scheduled refueling outage. Additionally, maneuvering the reactor to a mode outside of TS applicability and depressurizing the RCS involves inherent risk and increases nuclear safety risk due to cycling plant equipment.
- 6. Proposed Alternative and Basis for Use:
As an alternative to performing quarterly surveillance testing on 2NC-35B, Duke Energy is requesting to defer exercise and valve stroke timing testing for the remainder of the current Unit *2 fuel cycle . In the event of PORV block valve packing leakage, stroking the respective valve creates a hardship because of the increased potential for packing leakage. Increased leakage reduces the margin for acceptable reactor coolant system identified leakage (Reference TS 3.4.13, Operational Leakage). If RCS identified leakage exceeds its allowable limit, the required action is plant shutdown. All other PORV block valves will continue to be stroked quarterly per applicable ASME code requirements.
As stated in Section 5, to control stem packing leakage on 2NC-35B, the valve was manually closed , with emergency power available. Operational valve stroke timing testing was conducted on June 10, 2019 in both the closed and open directions with satisfactory results. This testing demonstrates the valve is fully operationally ready to open in the current configuration.
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Enclosure File: MC-1 2 34.01 When the valve is closed due to valve packing leakage, the valve is administratively maintained closed with emergency power available. If required to be opened to perform its intended safety function, the valve is opened by the control room operator. Opening the valve with a packing leak during normal plant operation may cause further stem packing damage, resulting in increased RCS leakage.
PORV block valves have established preventative maintenance activities. The valves have maintained consistent performance with no adverse trends or abnormalities noted during Motor Operated Valve diagnostic testing. The valve actuator general and lubrication condition is of sufficient quality to support continued reliability with the relief of quarterly exercise and stroke timing activities until scheduled repairs.
lnservice Testing (1ST) performance history of McGuire Unit 1 and Unit 2 PORV block valves has been excellent with no valve stroke timing or position indication testing failures from reviewed data January 1, 2009 to present. 2NC-35B valve stroke timing performance (open and closed directions) has been consistently between 5.5 and 6.0 seconds, demonstrating acceptable margin to the maximum limit of 10 seconds.
This relief request is similar to relief request MC-SRV-NC-02 for PORV block valve 2NC-31 B that was approved by the NRC on January 17, 2017 (i.e., Reference 8.k).
- 7. Duration of Proposed Alternative:
This condition is only intended to permit McGuire Unit 2 operation for a limited period of time not to exceed restart from the next refueling outage. 2NC-35B repair is planned for the next McGuire Unit 2 refueling outage M2R26 scheduled to begin on March 21 , 2020. Following the refueling outage, Duke Energy will resume quarterly testing of 2NC-35B per applicable ASME Code requirements .
- 8.
References:
a) Duke Energy, McGuire Nuclear Station ASME lnservice Testing Program Revision 28, dated March 1, 2013 b) NEI white paper "Standard Format for Requests from Commercial Reactor Licensees Pursuant to 10 CFR 50.55a" Revision 1 dated June 7, 2004.
c) Duke Energy fleet procedure AD-EG-ALL-1720 "lnservice Testing (1ST) Program Implementation" Revision 04 dated October 17, 2018.
d) Technical Specification Surveillance Requirement 3.4.11 .1 e) Technical Specification 3.4.13 RCS Operational LEAKAGE f) NCR 02275540 Elevated Unit 2 Reactor Coolant System Identified Leakage g) McGuire Flow Diagram MCFD-2553-2.0 NC (Reactor Coolant) System h) MCTC-1553-NC.V002-01 Revision 01 Test Acceptance Criteria for Pressurizer PORV Block Valves 1/2NC-31 B, -33A and -358.
i) MCS-1553.NC-00-0001 Revision 35 Design Basis Specification for the NC System j) WO 20332860: Investigate/Repair Elevated Stem Leakoff from 2NC-35B k) McGuire Relief Request MC-SRV-NC-02, dated December 1, 2016 (ADAMS ML16349A620), and NRC SE, dated January 17, 2017 (ADAMS ML16358A696).
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