ML20034E754

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Forwards Request for Relief from Requirements of Section XI of ASME Code Involving Extension of Interim Relief Granted on 911116,to Allow for Completion of Mods to Wn Sys
ML20034E754
Person / Time
Site: McGuire, Mcguire  Duke Energy icon.png
Issue date: 02/17/1993
From: Mcmeekin T
DUKE POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9303010307
Download: ML20034E754 (6)


Text

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ll DukeIbuer Company l

AlcGuire Kuclear Generation Department 12700 Hagers Teny Road (AfG01A)

T C Afan w u Huntermlle, NC28073 898S Vice President (TO.f)STS4800 (70(18754809 ftx DUKEPOWER February 17, 1993 U.

S.

Attention: Nuclear Regulatory Commission Washington, Document Control Desk D. C.

20555

Subject:

McGuire Nuclear Station, Units 1 and 2 Docket Nos. 50-369 and 50-370 Inservice Testing (IST) Requirements Relief Request 93-01 Dear Sir; Pursuant to 10 CFR 50.55(g)(5)(111) attached relief request for NRC review and approvalI am submitting the request for relief from the requirements of Section X1 This the ASME Code involves the extension of the i t of that was granted by the NRC on January 16 n erim relief the completion of modifications to the WH syst1991 to allow for modification to the WN system is scheduled to be co em.

The during the next refueling outage for each unit mpleted extension of the interim relief period until the e d As such, an cycle 8 refueling outages for both units is request d n -of-e

Briefly, Station was submitted by a letter dated April 20the IST progra which superseded all previous IST program submittal
1990, IST program plan '.. hat was submitted by the A s.

The letter covered the first ten year interval fro pril 20, 1990 1981, to December 1, 1391, 1994 for unit 2.

for Unit 1 and March 1,m December 1, March 1, 1984 to program plan for unit 1 was submitted by an October 12The second ten y letter.

1992 The IST program plan submitted by the April 20 identified several requests for re 1990 letter request was for the WN sump pumps. lief.

One of the relief letter By a January 16 1991 the nex,t refueling outages, whichever was gre tthe NRC gra believed to be, until for the completion of modifications to the WNat that time, of sufficient leng a er. This was direct measurement of certain parameters could b system so that e done.

9303010307 930217 DR ADOCK 05000369 p

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S. Nuclear Regulatory Commission February 17, 1993 page 2 i

A revised request for relief for the WN pumps was submitted 1

l by a letter dated December 2, 1991.

The relief request was revised to state that the modifications to the WN system would be completed by the end of 1992.

In response, the NRC l

stated in an April 8, 1992 letter that the interim relief l

could not be extended since the basis for extending the interim relief was not specified.

Further, that a modification schedule with the basis for extending the interim relief period be submitted.

To this end, please find attached for both units a revised relief request for the WN sump pumps, which includes a new modification schedule and the basis for extending the interim relief period.

l Please contact Paul Guill at (704) 875-4002 if you have any questions regarding this matter.

Very truly yours, hYhblufN' Ted C. McMeekin i

1 xc:

Mr.

S. D. Ebneter Regional Administrator, Region II U.

S.

Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta Georgia 30323 Mr.

P.

K. Van Doorn i

Senior NRC Resident Inspector, McGuire McGuire Nuclear Station Mr. T.

A. Reed, Project Manager Office of Nuclear Reactor Regalation U.

S.

Nuclear Regulatory Commission One White Flint North, Mail Stop 9H3 Washington, D.C.

20555

U. S. Nuclear Regulatory Commission February 17, 1993 page 3 xcc: With attachment R.

O. Sharpe L. J. Kunka P.

F.

Guill

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I ATTACHMENT

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DUKE POWER COMPANY MCGUIRE NUCLEAR STATION Request for Relief From ASME Code Section XI Requirements I.

Component for Which Relief is Requested i

A.

Name and Identification Number Diesel Generator room sump pumps, WN-1,2A2; WN-1,2A3; WN-1,2B2; and WN-1,2B3 B.

Function l

l The removal of water from the Diesel Generator I

rooms.

C.

ASME Section XI Code Class Class 3 D.

Valve Category Not Applicable II.

ASME Code Section XI Requirement'That Has Been Determined To Be Impractical For Unit 1, ASME Code Section XI,-1986 Editica, Subsection IWP, Subarticle 3100, Table IWP-3100-1.

In particular, The discharge pressure, and the flow rate inservice. test

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quantities of Table IWP-3100-1.

I For Unit 2, ASME Code Section XI, 1980 Edition through Winter 1980 addenda, Subsection IWP, Subarticle 3100, Table IWP-3100-1.

In particular, the. discharge pressure, and'the flow rate inservice test quantities of Table IWP-3100-1.

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.III. Basis for Requesting Relief 1

l The original basis for requesting relief was that the diesel generator room sump pumps are vertical pumps that are tested by filling the diesel generator room sump and pumping the sump down.

A stable system condition can not be obtained due to the continuous decrease in the sump water-level.

In addition, there is no instrumentation to measure suction pressure, discharge pressure or' flow rate.

A modification to the WN system is required to install the piping, valves, and instrumentation needed to perform the Code required testing.

Until the modification to the WN system is completed, an alternate means of calculating the above parameters was proposed.

The request for relief for this situation was submitted April'20, 1990.

Approval by the NRC was granted on an interim basis, as documented in a NRC letter dated January 16, 1991.

The initial interim relief that was granted by l

the NRC was only valid for one year (up to January 16, 1992) l or until the next refueling outage (the end-of-cycle 7 l

refueling outages'for both units), whichever was greatest.

l As such the modifications to the WN system should have been implemented by January 16, 1992 for Unit 1 and prior to the startup of cycle 8 for Unit 2.

The initial relief request that was submitted for this situation was amended.

A revised relief request was submitted to the NRC by a December 2, 1991 letter.

The l

revised relief request stated that the modifications to the WN system would be completed by the end of 1992.

A response by the NRC to this change was provided within an April 8, 1992 letter.

The NRC did not extend the period for the interim relief that was granted January 16, 1991.

The reason for not extending the interim relief was because the basis for extending the period was not specified.

The NRC suggested that a schedule for the modification, with-the basis for extending the period be submitted.

Accordingly, the subsequent paragraphs addresses the modification schedule and the basis for this schedule.

Implementation will require tie-in to the common discharge header for the diesel generator room sump pumps.

In order to accomplish these tie-ins, the diesel generators are required to be removed from service and are thus render inoperable.

For this reason, the tie-ins are scheduled to be installed during a routine diesel generator preventive maintenance outage while the unit is operating.

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If implementation is not completed prior to the next refueling outage for each unit, the tie-ins will be installed during the outage.

The next. Unit l_ refueling j

outage (end-of-cycle 8) is scheduled to start March 13, 1993 l

and completed by June 4, 1993.

The next Unit 2 refueling

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outage (end-of-cycle 8) is scheduled to start July 1, 1993 and be completed by September 14, 1993.

The following discussion is some background information

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explaining why the modifications to the WN system have not l

already been completed as committed to within the request for reliefs that have been submitted.

The modifications were approved for both units in-April, 1990 with implementation planned for late 1991.

A survey of the proposed piping and hanger layout for the modifications was performed in August, 1991.

During the walkdown, it was discovered that the piping and hangers as designed could l

potentially interfere _with other modifications that were j

planned to be installed later, and could interfere with i

maintenance activities for the diesel generators.

In i

September,.1991, the decision was made to redesign the piping and hanger layout to avoid the potential interference 4

problems.

During a meeting-held in October, 1992 to review l

l post-modification testing,_ changes to the design of the l

modifications were suggested to reduce long-term maintenance-costs, reduce the timeframe required to install the tie-ins, and simplify hydrostatic testing.

These requested changes have been incorporated into the design of the modifications.

IV.

Alternate Testinq The alternate testing method that was discussed in the initial relief request that was submitted April 20, 1990 will. continue to'be performed..Briefly,'the' average discharge pressure and_ flow rate will be calculated and than compared to the acceptance criteria per. Table IWP-3100-2.

This alternate method will. continue to provide a measure of pump degradation and will continue to provide-a reasonable assurance of operational readiness in the interim.

V.

Implementation Schedule i

The alternate method of testing continues to be performed.

This alternate method of testing will continue until the necessary modifications to the WN system are completed.

Implementation of the modifications to the WN system will be completed prior to or during the end-of-cycle 8 refueling.

outages for both~ units.. The current schedule for the start of these refueling outages are March 13, 1993 for Unit 1 and July.1, 1993 for Unit 2.

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