ML20113F848

Forwards Revised Request for Relief from ASME Code,Section XI Snubber Testing Requirement to Be Performed as Part of Augmented Inservice Insp Program,Addressing Issue of Impracticality,Per 10CFR50.55a (g)(5)(iii) & (g)(6)(i)

ML20113F848
Person / Time
Site:	Mcguire, McGuire
Issue date:	01/17/1985
From:	Tucker H DUKE POWER CO.
To:	Adensam E, Harold Denton Office of Nuclear Reactor Regulation
References
TAC-54882, TAC-54883, NUDOCS 8501240151
Download: ML20113F848 (3)

Text

r o

Duxn POWElt GOMPANY P.O. n()x 33189 OIIARLOTTE, N.o. 28242 ILAL B. TUCKER TE R EPISOME m a rammannst (704) 373-4331 vom. ..o.mmo- January 17, 1985 Mr. Harold R. Denton, Director Office of Nucicar Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Ms. E. G. Adensam, Chief Licensing Branch No. 4

Subject:

McGuire Nuclear Station Docket Nos. 50-369, 50-370 Snubber Functional Tests /ASME Code Section XI Technical Specification Surveillance Requirement 4.7.8 states that each snubber required by T.S.3.7.8 shall be demonstrated operable by performance of an Augmented Inservice Inspection Program (as given in T.S.4.7.8a-1) and the requirements of Specification 4.0.5. Part of this Augmented Inspection Program (T.S.4.7.8e) is that during the first refueling shutdevn and at least once per refueling thereafter, a representative sample of snubbers shall be tested using one of the three sample plans given. The sample plan is to be selected and the NRC notified prior to the test period.

My letter to Mr. J. P. O'Reilly (NRC/01E) dated February 14, 1984 notified the NRC that Duke had selected sample plan No. 2 (T.S.4.7.8e(2)) for the functional testing which was performed during the McGuire Unit i first refueling. McGuire Technical Specifications require that inservice inspection and testing of various components be performed in accordance with Section XI of the ASME Code and applicable addenda. Snubber testing is included in the edition of the Code which McGuire is using. The Code testing requirement must be followed unless written relief has been granted by the NRC. Since the plan for snubber selection being used by Duke differed from that in Section XI of the ASME Code, it was subsequently determined that formal acknowledgement of the exemption to the Code would be appropriate. Consequently, my letter of April 12, 1984 requested written relief f rom the ASME Code requirement pursuant to 10 CFR 50.55a(g)(6)(1). (Fees pursuant to 10 CFR 170.22 were remitted via my July 12, 1984 letter to Mr. H. R. Denton in accordance with Ms. Reba M. Diggs' letter of May 1, 1984).

Please find attached a revised request for relief from the ASME code Section XI snubber testing requirement which more adequately addresses the issue of "Impractica-lity" in accordance with 10 CFR 50.55a (g)(5)(iii) and 50.55a (g)(6)(1). This matter has been previously discussed via telecons between Mr. Darl Hood et. al.

of your staff and Mr. P. B. Nardoci et. al (DPC) on October 30 and 31, 1984, during which the revision was requested by Mr. Hood.

O obf9 PDR 1

1 \

i

6-Mr. Harold R. Dinten, Dirsctor January 17, 1985 Page 2 It is requested that the relief request receive approval prior to the upcoming McGuire Unit 1 and 2 refueling outages as snubber inspections will be conducted at that time. It is our understanding that the NRC's technical review of the request has been completed with formal approval awaiting only the submittal of this revised information to support Duke's determination that comformance with the code requirements is impractical for the McGuire Nuclear Station. However, should there be any further questions regarding this matter, please advise.

.Very truly yours.

fI Hal B. Tucker PBN/mjf Attachment cc: (w/ attachment)

W. T. Orders Senior Resident Inspector McGuire Nuclear Station Mr. James P. O'Reilly, Regional Administrator U. S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323-i

.[-.

z anne @y

a. :.. j i

~

Duke Power Company McGuire Nuclear Station Request for Relief from ASME Code Section XI

1. Component for which Relief is Requested.

a.. Name and number:

All safety-related snubbers for Units 1 and 2

b. Function:

Snubbers are designed to prevent unrestrained pipe motion under dynamic loads.

c. ASt!E Section III Code Class:

Provide support for class 1, 2 and 3 systems.

d. Valve Cateaory:

N/A

2. Reference Code Requirement that has been determined to be impractical:

ASME Boiler and Pressure Vessel Code Section XI, 1980 Edition through winter 1980 Addenda, Article IWF-5400.

3. Basis for Requestina Relief:

The code requirement to perform functional testing on 10% of the total number of snubbers, with subsequent samples of.an additional 10% if any snubber fails the test, is impractical for stations with large numbers of snubbers. The consequences of using the 10% sample plan would lead to excessive radiation exposure, an increase in reinstallation errors, additional manpower requirements, and possibly extended outages due to the probability of being required to test 100% of the snubber N

- population. Alternate sampling pit.as, as outlined in the McGuire Technical Specifications, will provide a 95% confidence level that 90% of the snubbers are operable. The NRC has reviewed these alternate plans and has found-them acceptable. Due to the problems of dealing with such a large population of snubbers as required under the 10% plan, we would anticipate an actual decrease in the level of safety provided. McGuire Units-1 and 2 have a total population of approximately 2500 safety-related snubbers.

4. . Alternate E==iantions Safety-related snubbers will be functionally tested per one of the alternative plans in the McGuire Technical Specifications 3/4.7.8.e.

5. Implementation schedules McGuire safety-related snubbers will continue to be functionally tested per the requirensats of the Technical Specifications.