ML20057F412
| ML20057F412 | |
| Person / Time | |
|---|---|
| Site: | McGuire  |
| Issue date: | 10/12/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20057F410 | List: |
| References | |
| NUDOCS 9310150255 | |
| Download: ML20057F412 (10) | |
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UNITED STATES i
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NUCLEAR REGULATORY COMMISSION g '.v 4,/
WASHINGTON, D.C. 2055M001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM RE0 VESTS FOR RELIEF DUKE POWER COMPANY MCGUIRE NUCLEAR STATION. UNIT 1 DOCKET NO. 50-369
1.0 INTRODUCTION
Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a, requires that inservice testing (IST) of certain ASME Code Class 1, 2 and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where alternatives are authorized or relief is granted by the Commission pursuant to paragraphs (a)(3)(1), (a)(3)(ii), or (f)(6)(1) of 10 CFR 50.55a.
In order to obtain authorization or relief, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety, (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) conformance is impractical because of limitations of geometry and design and considering the burden if the requirements were imposed. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provided alternatives to the Code requirements determined to be acceptable to the staff. When an alternative is proposed which is in accordance with GL 89-04 guidance and is documented in the IST program, no further evaluation is required; however, implementation of the alternative is subject to NRC inspection.
In rulemaking to 10 CFR 50.55a effective September 8,1992 (See 57 Federal Reaister 34666), the 1989 edition of ASME Section XI was incorporated in paragraph (b) of 10 CFR 50.55a.
The 1989 edition provides that the rules for IST of pumps and valves shall meet the requirements set forth in ASME Operations and Maintenance Standards Part 6 (OM-6), Inservice Testing of Pumps in Light-Water Reactor Power Plants, and Part 10 (OM-10), Inservice Testing of Valves in Light-Water Reactor Power Plants.
Pursuant to 10 CFR 50.55a(f)(4)(iv), portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met, and therefore, relief is not required for those inservice tests that are conducted in accordance with OM-6 and OM-10, or portions thereof. Whether all related requirements are met is subject to NRC inspection.
Section 50.55a authorizes the Commission to approve alternatives or grant relief from ASME Code requirements upon making the necessary findings. The NRC staff's findings, with respect to relief requested and alternatives proposed as part of the licensee's IST program, are contained in this Safety Evaluation (SE).
9310150255 931012 ADOCK0500g9-PDR P
By letter dated October 12, 1992, the Duke Power Company (the licensee) submitted Revision 18 of the McGuire Nuclear Station, Unit 1, second ten-year pump and valve IST program. The licensee, by letter dated February 17, 1993, also submitted a response to the April 8, 1992, SE regarding D">i' ion 17 of the IST program. The second ten-year interval began December 2, 1.92.
This program was developed utilizing the 1986 Edition, including the 1987 Addenda, of the ASME Section XI Code.
This SE provide the results of the staff review of the relief requests and alternatives contained in these submittals.
2.0 EVALUATION The licensee's IST program requests for relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, Brookhaven National Laboratory (BNL). The Technical Evaluation Report (TER), provided as Attachment 1, is BNL's evaluation of the licensee's IST program relief requests in the submittals dated October 12, 1992, and February 17, 1993. The staff has reviewed the TER and adopts the evaluations and conclusions contained therein, except as noted below in Section 2.1.
A t
summary of the relief request determinations is presented in Table 1.
The granting of relief or authorization of proposed alternatives is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed.
The implementation of the IST program is subject to inspection by NRC.
The licensee should refer to TER Section 5.0 and Section 2.1, below, for a discussion of IST program action items identified during the review. The licensee should resolve all items in accordance with the guidance therein.
2.1 Pump Relief Reauest 1.3.3 The requested relief from the requirements of Section XI, paragraph IWP-3210, regarding the allowable range of pump vibration is addressed in TER Section 2.1.3.
Although the licensee's proposal to delete the acceptance criteria based on relative change for smooth running pumps is a relaxation of Code requirements, the proposed absolute limits are based, in part, on the ASME/ ANSI OM-6 acceptance criteria and are more restrictive than the Code limits.
Furthermore, the ASME O&M Code committees are considering a change to the Code such that pump vibration below a minimum reference value would not be subject to limits based on relative change. The alternative to paragraph IWP-3210, rogarding the allowable range of pump vibration, is authorized as indicated in the TER provided that, if the vibration acceptance criteria for smooth running pumps are finalized by the ASME Code committees and approved by the staff, the IST program will be updated to meet the Code vibration requirements.
2.2 Pump Relief Reauest 1.4.7 Section 2.8.1 for the TER includes an evaluation for both premodification and postmodification relief associated with the diesel generator room sump pumps.
A status from the licensee indicates that as of August 10, 1993, the modifications for McGuire-Unit I are complete and for McGuire-Unit 2 are b
l
_3_
t-approximately one-half complete. The Unit 2 modifications will be continued during the current refueling outage, with a final action to complete during the diesel out-of service maintenance scheduled for October 1993.
Therefore, the interim relief granted for the premodification condition applied to Unit 2 until the modification are completed in October 1993.
-2.3 Valve Relief Reauest RR-3 i
Section 3.8.1 of the TER recommends that relief be granted to full-stroke
}
exercise the containment spray header check valves during refueling outage because exercising during power operations or during cold shutdown outages is impractical. However, the licensee indicated in the relief request that these i
valves were to be removed from the system. A status from the licensee indicates that as of August 10, 1993, the valves have been removed from McGuire-Unit I and are being removed from McGuire-Unit 2 during the current refueling outage. The licensee committed that the modifications for Unit 2 would be completed before the plant returns to power operations. Therefore, the valves and the relief request should be deleted form the IST program after the Unit 2 refueling outage.
2.4 Generic Valve Relief Reouest I r
Generic Valve Relief Request 1 indicates that the licensee intends to j
implement Portion 6 of Generic Letter (GL) 89-04 for valves that <troke in less than 2 seconds. The relief request has been established in.accordance with the guidance delineated in Position 6 and is, therefore, approved per GL 89-04 and is not further evaluated in the TER.
3.0 CONCLUSION
In evaluating the licensee's requests for reliaf from the requirements of Section XI, the staff considered (1) the acceptability of proposed alternative testing, (2) whether the hardship of compliance is without a compensating increase in safety, (3) the impracticality of performing the required testing i
due to the limitation of geometry and design and considering the burden if the requirements were imposed, and (4) whether the proposed alternative testing i
meets the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b)..The last column of Table 1 identifies the regulation or GL 89-04 guidance under which the requested relief is approved. The staff has determined that alternatives are authorized pursuant to 10 CFR 50.55a(a)(3) or relief is granted pursuant to 10 CFR 50.55a(f)(6)(1). Such relief is authorized by law and will not endanger life-or property, or the common defense and security and is otherwise in the public interest. The granting of relief or authorization of proposed alternatives is l
based upon the fulfillment of'any commitments made by the licensee in its basis for each relief request and the proposed alternate testing.
Date:
Attachment:
Technical Evaluation Report l
f
McGuire Nuctser Station - SE Tcbla 1 Summery of Relist Requsets-Relief Request TER Section XI Requirement
' Equipment Proposed Altemate NRC Action -
No.
Sect.
Identification Method of Testing Pump No.
2.1.1 IWP-3300, Inlet pressure All pumps Measure inlet pressure prior to Alternative approved per 1.3.1 measurement prior to pump startup of standby pumps only.
$50.55a 1(f)(4)(iv).
startuD Pump No.
2.1.2 IWP-2210, Allowance of reduced All pumps Acceptance criteria will be Relief not required.
1.3.2 range limits established to ensure that Section XI acceptance ranges and system recuirements are met.
Pump No.
2.1.3 IWP 3100, 3210, 4110, 4120, All Pumps
- 1. Measure vibration velocity at 1 and 2. Authorized in 4
1.3.3 4510, 4520(b), Measurement of more than one location.
accordance with $50.55a vibration displacement, vibration 1(a)(3)(i), with provisions.
neceptance criteria, Vibration
- 2. Use altemate vibration instrument accuracy, and range acceptance criteria.
3 and 4 Authorized in accordance with $50.55a
- 3. Use vibration instruments 1(a)(3)(ii), with provisions.
with an accuracy of 16.56%.
- 4. Use digital instruments that are auto-ranging.
i
- 5. Calibrate vibration
- 5. Relief denied.
instruments between 10-1000 Hr.
Pump No.
2.1.4 IWP-3100, 3300, Measurement All Pumps Measure vibration in accordance Altemative approved per 1.3.4 of oumo bearina temperature with Relief Reauest 1.3.3.
450.55a 1ff1f4)fiv).
s Pump No.
2.2.1 IWP-4120, Instrument range Auxiliary Feedwater Use installed instrumentation Autnorized in accordance 1.4.1 Pumps that has range 5 times the with $50.55a 1(a)(3)(i).
i reference value.
i Pump No.
2.3.1 IWP-3100, Measurement of EDG Fuel Oil Transfer Monitor tank level, measure Relief to not measure 1.4.2 suction pressure and AP and flow Pumps discharge pressure for discharge pressere denied.
> l, 7
acceptance criteria information only, use alternate Alternate flowrote acceptance l
flowrate acceptance criteria.
criteria and alternative to 8i l
suction pressure i
i measurement authorized in l
accordance with $50.55a 1(a)(3)(i).
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3 i
,, _.. _ _... _ _ _...., _.... _,... _ _ _, _. ~ _... - _
McGuiro Nuclzer Stction - SE Tabla 1 - Summsry of Rollef Rsqu sts (Continu:d)
Relief Request TER Section XI Requirement Equipment Proposed Attemate NRC Action -
No.
Sect.
Identification Method of Testing Pump No.
2.4.1 IWP-4120, instrument range Compenent Cochng Use installed instrumentation Authorized in accordance 1.4.3 Water Pumps that has range 4 times the with 950.55a 1(a)(3)(i).
reference value.
Pump No.
2.5.1 IWP-3110, 3300, 3400, 4120 RHR Pumps Quarteriv-Measure flow for Relief denied.
1.4.4 Instrument range, measurement information only, use pressure of flow quarterly, measurement instrumentation that meets Tech.
of parameters at single point.
Spec. accuracy requirements.
Refuelina-Use reference curve.
Pump No.
2.6.1 WP 3110, 3300, 3400, 4120, Safety injection Pumps Quarteriv-Measure flow for Relief denied.
1.4.5 Instrument range, measurement information only, use pressute of flow quarterly, measurement instrumentation that meets Tech.
of parameters at single point.
Spec. accuracy requirements.
Refuelina-Use reference curve.
Pump No.
2.7.1 WP 3110, 3300, 3400, 4120, Charging Pumps Quarteriv-Use pressure Relief to not measure flow 1.4.6 Instrument range, measurement instrumentation that meets Tech.
quarterly granted in of flow quarterly, measurement Spec. accuracy requirements.
accordance with Generic of parameters at single point.
Measure AP and vibration only.
Letter 89-04, Position 9.
Refuelina-Use reference curve.
Relief concerning pressure instrumentatiori and reference curves denied.
Pump No.
2.8.1 IWP-3100, Measurement of DG Room Sump Purip Premedification-Calculate Premedification-Interim 1.4.7 flowrate, suction and AP, average flowrate, record relief granted in accordance measurement of parameters at discharge pressure for with 950.55a (f)(6)(i).
single point.
information only.
Postmodification-Relief to Postmodification-Use reference use reference curves denied.
curve, test pump every two Alternate test frequency years.
approved pursuant to 950.55a 1(f)(4)(iv) for an interim period.
Generic Valve 1.0 IWV-3413(b), 3417, rapid acting Rapid-Acting Valves Assign a maximum limiting Relief granted in accordance No. I valve's acceptance criteria stroke time of 2 seconds to rapid-with Generic Letter 89-04, actino valves.
Position 6.
?
2
McGuiro Nuclear Station -. SE Table 1 - Summary of Rellef Requants (Continusd)
Relie! Request TER Section XI Requirement Equipment Propos*d Altemate NRC Action No.
Sect.
Identification Method of Testing Generic Valve 5.8 IWV-3427(b), valve acceptance Containment Isolation None.
Relief granted in accordance No. Il criteria Valves with Generic Letter 89 04, Position 10.
Generic Valve 3.1.1 IWV 3417(a), valve acceptance Power-Operated Valves Compare stroke times to Relief as requested denied.
No. lll criteria reference values.
Generic Valve 3.1.2 IWV-3417(a), increase test Power-Operated Valves increase test frequency to once Relief not required if licensee No. IV frequency to monthly when stroke every 6 weeks.
utilizes OM Part 10.
times increase more than 25 or 50% from orevious test.
Valve No. RR-5.11 IWV-3520, test frequency and 1 CA-165, 166, Service Disassemble and inspect.
Relief granted in accordance CA1 method Water to Aux. Feedwater with Generic Letter 89-04, System check valves Position 2.
Valve No. RR-5.11 IWV-3520, test frequency and 1CA-8, 10, 12, Aux.
Disassemble and inspect.
Relief granted in accordance CA2 method RV pump suc* ion check with Generic Letter 89-04, valves Position 2.
Valve No. RR-3.2.1 IWV-3520, test frequency 1KC-280, CCW return Verify valve closure capability Alternative approved KC1 to RCDT heat exchanger at refueling outages by $50 App.
pursuant to $50.55a check valve J leak test.
1(f)(4)(iv), provided all related recuirements are met.
Valve No. RR-3.2.2 IWV-3520, test frequency 1KC-322, CCW supply Verify va!ve closure capability Alternative approved KC2 to RCDT heat exchanger at refueling outages by $50 App.
pursuant to $50.55a check valve J leak test.
1(f)(4)(iv), provided all related reauirements are met.
Valve No. RR-3.2.3 IWV-3520, test frequency 1KC-279, CCW return Verify valve closure capability Alternative approved KC3 from RCP motor coolers at refueling outages by $50 App.
pursuant to $50.55a check valve J leak test.
1(f)(4)(iv), provided all related recuirements are met.
Valve No. RR-3.2.4 IWV-3520, test frequency 1KC-340, CCW supply Verify valve closure capability Alternative approved KC4 to RCP motor and at refueling outages by $50 App.
pursuant to $50.55a reactor vessel support J leak test.
1(f)(4)(iv), provided all coolers check valve related recuirements are met.
Valve No. RR-3.2.5 IWV 3520, test fri4quency 1KC-47, CCW relief and Verify valve closure capability Alternative approved KC5 drain return header at refueling outages by 50 App.
pursuant to $50.55a check valve J leak test.
1 f)(4)(iv), provided all Ire (lated recuirements are me 3
McGuiro Nucl::r St: tion - SE Tcbla 1 - Summ:ry of Rsil f R; quiets (C ntinu:d)
Relief Request TER Section XI Requirement Equipment Proposed Alternate NRC ' Action No.
Sect.
Identification Method of Testing Valve No. RR-3.3.1 IWV-3520, test frequency 1NB-262, Reactor Verify valve closure capability Alternative approved NB1 Makeup Storage Tank at refueling outages by $50 App.
pursuant to $50.55a supply check valve J leak test.
1(f)(4)(iv), provided all related reouirements are met.
Valve No. RR-3.4.1 IWV-3520, test frequency 1NC-259 and 261, RCP Verify valve closure capability Alternative approved NC1 oil system check valves at refueling outages by $50 App.
pursuant to $50.55a J leak test.
1(f)(4)(iv), provided all related recuirements are met.
Valve No. RR-3.5.1 IWV-3520, test frequency 1NF-229, Ice condenser Verify valve closure capability Alternative approved NF1 glycol supply check at refueling outages by $50 App.
pursuant to $50.55a valve J leak test.
1(f)(4)(iv), provided all related recuirements are met.
Valve No. RR-3.6.1 IWV-3520, test frequency INI-48, Containment Verify valve closure capability Alternative approved Nlt nitrogen supply check at refueling outages by 650 App.
pursuant to $50.55a valve J leak test.
1(f)(4)(iv), provided all related reauirements are met.
Valve No. RR-3.6.2 IWV-3520, test frequency and 1NI-59, 70, 81, 93. St Partial-stroke valves at cold Relief from full-stroke N12 method accumulator Piv check shutdowns, but not more frequent exercising the valve open valves than once per 9 months, and full-granted in accordance with stroke at refueling by Generic Letter 89-04, disassembly and inspection.
Position 2.
Verify valva closure capability by leak testing in accordance Relief from verifying the with PlV Tech. Spec.
closure capability granted in accordance with $50.558.
1(fif 6)fi).
Valve No. RR-3.6.3 IWV-3520, test frequency 1Ni-436, St Verify valve closure capability Alternative approved Nf3 accumulator fill and at refueling outages by $50 App.
pursuant to $50.55a check valve test header J leak test.
l 1(D(4)(iv), provided all check valve
.ated reauirements are met.
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4 L-. --.
McGuire Nuclear Station - SE Table 1 - Summary of Rellef Raquests (Continued)
Relief Request TER Section XI Requirement Equipment Proposed Alternate NRC Action No.
Sect.
Identification Method of Testing i
1 Valve No. RR-3.6.2 IWV-3520, test frequency and
- 1Ni,
~1 82, 94 Partial-stroke valves at cold Reket from full-stroke NI4 method accumulator PlV check shutdowns, but not more frequent exercising the valve open valves than once per 9 months, and full-granted in accordance with stroke at refueling by Generic Letter 89-04, disassembly and inspection.
Position 2.
Relief from Verify valve closure capability verifying the closure l
by leak testing in accordance capability granted in with PlV Tech. Spec.
accordance with $50.55a 1(f)f 6)fi).
Valve No. RR-3.7.1 IWV-3520, test frequency 1NM-420, 421, reactor Verify valve closure capability Alternative approved NM1 coolant sample check at refueling outages by 50 App.
pursuant to $50.55a valves J leak test.
1(f)(4)(iv), provided all related reautrements are met.
Valve No. RR-5.11 IWV-3520, test frequency and I N S-13, 16, 30, 33, Disassemble and inspect.
Relief granted in accordance NS1 method 41, 46, containment with Generic Letter 89-04, spray pump check valves Position 2.
Valve No. RR-5.11 IWV-3520, test frequency and INS-4, 21, RWST to Disassemble and inspect.
Relief granted in accordance NS2 method containment spray with Generic Letter 89-04, suction check valves Position 2.
Valve No. RR-3.8.1 IWV-3520, test frequency 1 NS-83, 84, 85, 86, Full-stroke exercise at rctueling Relief granted in accordance NS3 87, and 88, containment outages.
with 550.55a1(f)(6)(i).
spray header check valves Valve No. RR-3.9.1 IWV-3520, test frequency INV-1002, Standby Verify valve closure capability Alternative approved NV1 Makeup Pump to RCP at refueling outages by $5Mpp.
pursuant to $50.55a seals check valve J leak test.
(f)(4)(iv), provided all related recuirements are met.
Valve No. RR-3.10.1 IWV-3520, test frequency 1RF-823, Fire Verify valve closure capability Alternative approved RF1 protection header check at refueling outages by $50 App.
pursuant to $50.55a valve J leak test.
1(f)(4)(iv), provided all related reauirements are met.
Valve No. RR-5.11 IWV 3520, test frequency and 1RN-113, 214, SFP Disassemble and inspect at Relief granted in accordance RN1 method makeup header to SW refueling outages. Partial-with Generic Letter 89-04, check valves stroke exercise auarterly.
Position 2.
e 5
McGuiro Nucisar Station - SE Tabla 1 Summary of Rollsf Raquesta (Continuad)
Reliel Request TER Section XI Requirement Equipment Proposed Alternate NRC[ Action No.
Sect.
Identification Method of Testing Valve No. RR-5.11 IWV-3520, test frequency and ISA-5, 6, Steam to Disassenble and inspect to Relief granted in accordance SA1 method AFW pump turbine check verify closure.
with Generic Letter 89-04, valves Position 2.
Valve No. RR-3.11.1 IWV 3520, test frequency IVB-50, Breathing air Verify valve closure capability Alternative approved VD1 supply header check at refueling outages by 950 App.
pursuant to $50.55a valve J leak test.
1(f)(4)(iv), provided all related reauirements are met.
Valve No. RR.
3.12.1 IWV-3413(b), test method 1VGSV5160, 5161 Verify operational readiness Relief denied.
VG1 5162, 5163, 5170, during monthly diesel start tests.
5171, 5172, 5173, DG control air solenoid vivs.
Valve No. RR-3.13.1 IWV-3520, test frequency I VI-124, 149, Verify valve closure capability Alternative approved Vl1 Instrument air supply at refueling outages by 550 App.
pursuant to 650.55a check valves J leak test.
1(f)(4)(iv), provided all related reauirements are met.
Valve No. RR-3.13.1 IWV 3520, test frequency I VI-4 0, 161 Verify valve closure capability Alternative approved V12 Instrument air supply at refueling outages by 550 App.
pursuant to $50.55a check valves J leak test.
1(f)(4)(iv), provided all related reauirements are met.
Valve No. RR-3.14.1 IWV-3520, test frequency IVS-13, Station air Verify valve closure capability Alternative approved VS1 supply check val 7e at refueling outages by $50 App.
pursuant to $50.55a J leak test.
1(f)(4)(iv', provided all related reauirements are met.
Valve No. RR-3.15.1 IWV-3520, test frequency IVX-30, Containment Verify valve closure capability Alternative approved VX1 sample blower discharge at refueling outages by 550 App.
pursuant to 550.55a check valve J leak test.
1(f)(4)(iv), provided all related reauirements are met.
Valve No. RR-3.16.1 IWV-3520, test frequency 1WL-24, RCDT heat Verify valve closure capability Alternative approved WL1 exchanger to RWST at refueling outages by $50 App.
pursuant to $50.55a check valve J leak test.
1(f)(4)(iv), provided all related reauirements are met.
Valve No. RR-3.16.2 IWV-3520, test frequency 1WL-385, Containment Verify valve closure capability Alternative approved WL2 ventilation cooler at refueling outages by 550 App.
pursuant to $50.55a condensate check valve J leak test.
1(f)(4)(iv), provided all related recuirements are met.
6
McGuiro Nucl::r Ststlen - SE Tebla 1 - Summ:ry cf Railtf RsquIsta (Centinund)
Relief Request TER Section XI Requirement Equipment Proposed Alternate
' NRC Action No.
. Sec t. ~
Identification Method of Testing Valve No. RR-3.17.1 IWV-3520, test frequency 1WN-3, 5, 7, 11, 13, Exercise valves once every 2 Alternate test frequency WN1 and 15, DG room sump years.
approved pursuant to $50.55a pump discharge check 1(a)(3)(ii) for an interim valves ceriod.
Valve No. RR. 3.18.1 IWV-3520, test frequency 1YM-116, makeup Verify valve closure capability Alternative approved YM1 demineralized water at refueling outages by 950 App.
pursuant to 550.55a supply header check J leak test.
1(f)(4)(iv), provided all valve related reauirements are met.
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