ML20080H583
| ML20080H583 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 02/13/1995 |
| From: | Freeman D DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20080H586 | List: |
| References | |
| GL-90-09, GL-90-9, NUDOCS 9502220381 | |
| Download: ML20080H583 (6) | |
Text
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11-I
..DukeIbuerCornpany T C McMaxa McGuire Nuclear Generation Deparanent.
Vice President 12700Hagers fenyRoad(MG0lVP)
(7M)8754800
\\
Hurdenvulle, NC28078M5 (TN)8754809 Fax
\\
i February 13, 1995 1
Document Control Desk l
U.S.' Nuclear Regulatory Commission f
Washington, D.C.
20555
Subject:
McGuire Nuclear Station Docket Nos:
50-369 and 370 Relief Request 94-012: Snubber Inspection Intervals for Unit 2 l
Dear Sir:
Pursuant to 10 CFR
- 50. 55a (g) (5) (iii),
I am submitting the i
attached relief request for NRC review and approval.
Per NRC Generic Letter 90-09 dated December 11, 1990 on
' Alternative Requirements fcr Snubber Visual Inspection Intervals and Corrective Actions
i
...the staff has developed an alternate schedule for visual i
inspections that maintains the same confidence level as the existing schedule and generally will' allow the licensee to perform visual inspections and corrective actions during l
plant outages.
Because this line item TS improvement will reduce future occupational radiation exposure and is. highly cost effective, the alternate inspection schedule is l
consistent with the Commission's policy statement on TS improvements.
The attached relief request seeks relief from impractical snubber inspection frequencies and till invoke the snubber testing l
frequency as reflected in the current McGuire Nuclear Station Technical Specifications 3.7.8, Table 4.7-2 which are the same as those reflected in the referenced GL 90-09.
I Should there be any questions regarding' this matter, please 1
contact James E.
Snyder at (704) 875-4447.
Very truly yours,
/P/A T. C. McMeekin 1
1 9502220381 950213 PDR ADDCK 05000369 I
l P
PDR j
I wome
U. S,. Nuclear Regulatory Commission February 13, 1995 Page 2/3 xc:
Mr.
S.
D.
Ebneter Administrator, Region II U.S. Nuclear Regulatory Commission l
101 Marietta St.,
NW, Suite 2900 Atlanta, Ga.
30323 i
Mr. Victor Nerses j
U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Mail Stop 14H25 Washington, D.C.
20555 Mr. Robert E. Martin j
U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C.
20555 Mr. George F. Maxwell NRC Resident Inspector McGuire Nuclear Station Dayne Brown, Chief i
Sivision of Radiation Protection 1
O.
Box 27687 Ra2*tgh, N. C.
27611-7687 i
i l
I February 13, 1995 U.S,. Nuclear Regulatory Commission Page 3/3 bxc:
Jesse O. Barbour (EC07J)
Jerry Goodman (EC07J)
G. A. Copp (EC050)
Z.
L.
Taylor (CN01RC)
E.
Burchfield (ON01RC)
W.
R. Cross Kay L. Crane Dwin E.
Caldwell s
P.
T. Vu John M. Washam i
l
I DUKE POWER COMPANY MCGUIRE NUCLEAR STATION Request for Relief From ASME Code Section XI Requirements I.
Component for Which Relief is Requested A. Name and Identification Number j
All Unit 2 safety-related snubbers.
B.
Function Snubbers are designed to prevent pipe motion under dynamic loads.
C. ASME Section XI Code Class Provides support for Class 1,2,3 systems.
D. Valve Category i
Not applicable.
II.
ASME Code Section Requirement that has been determined to be impractical.
ASME Boiler and Pressure Vessel Code Section XI, Article IWF-5000.
+
III.
Basis for Requesting Relief The 1989 ASME Boiler and Pressure Vessel Code Section XI, Article IWF-5300 (a) states: " Inservice examinations shall be performed in accordance with the first Addenda to ASME/ ANSI OM-1987, Part 4 (published 1988), using the VT-3 visual examination method described in IWA-2213." Paragraph 2.3.2.2 of the first Addenda to ASME/ ANSI OM-1987, Part 4 states that examinations shall be conducted at 18 month intervals +25%.
I
~-
If" unacceptable snubbers are revealed, the interval for.
)
subsequent inspections shall be reduced in accordance with the following table:
)
i Number of Unacceptable Months to Subsequent i
Snubbers Examination
{
f 0
18 1
12 l
2 6
3,4 4
[
5,7 2
i
>8 1
s McGuire Unit 2 Technical Specifications 3/4.7.8, SNUBBERS has a surveillance frequency not to exceed 48. months which is altered i
based on the number of unacceptable snubbers found during the previous inspection in proportion to the sizes of the various i
snubber populations or categories.
See the attached copy of the subject TS Table 4.7-2, SNUBBER VISUAL INSPECTION INTERVAL.
The examination interval requirements in the McGuire Unit 2 TS Table 4.7-2 are based on NRC Generic Letter 90-09, ' Alternative Requirements for Snubber Visual Inspection Intervals and l
Corrective Actions.'
Prior'to the incorporation of GL 90-09 into the TS, the examination inspection interval in the TS was identical to that in the first Addenda to ASME/ ANSI OM-1987, Part t
4.
NRC GL 90-09 acknowledged that licensees having a large l
number of snubbers find that the 18 month visual inspection i
schedule in the first addenda to ASME/ ANSI OM-1987, part 4 is excessively restrictive and that some licensees have spent a i
significant amount of resources and have subjected plant personnel to unnecessary radiological exposure to comply with the visual examination requirements without increasing the confidence level in snubber operability.
i McGuire Unit 2 has 335 snubbers subject to the inservice inspection per IWA-5000. McGuire Unit 2 is currently on a fuel cycle length of approximately 18 months.
In order to comply with the current ASME requirements of IWF-5000, Duke Power would be l
required to perform VT-3, visual examinations on all 359 snubbers-within the inservice inspection program at every refueling j
outage.
This examination frequency is twice that presently required by the approved TS 3/4.7.8 and significantly greater l
than that required under Section XI codes through the 1986 t
edition.
As indicated in NRC GL 90-09, this increased inspection per ASME requirements does not increase the confidence level in snubber operability above that obtained by the requirements of l
i j
l O
l 1
IVs Alternate Testing As an alternative to the requirements of ASME Section XI, IWF-5000, paragraph IWA-5053 (e) which invokes the inspection frequency in paragraph 2.3.2.2 of the first Addenda to ASME/ ANSI i
OM-1987, Part 4 (published in 1988), VT-3, visual inspection of snubbers within the Section XI inservice inspection boundaries shall be examined on a schedule as provided by McGuire Nuclear l
Station TS 3/4.7.8, Table 4.7-2.
For the purposes of determining inspection frequency, the snubbers within the inservice boundaries shall be considered part of the total population of snubbers inspected under TS 3/4.7.8.
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