ML20126H317
| ML20126H317 | |
| Person / Time | |
|---|---|
| Site: | McGuire |
| Issue date: | 12/28/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20126H304 | List: |
| References | |
| NUDOCS 9301050140 | |
| Download: ML20126H317 (5) | |
Text
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UNITED STATES o,,
NUCLEAR REGULATORY COMMISSION y
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WASWNGioN. D. C. 20555 e
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,o SAFETY EVALVATION BY THE OFFICE OF N1! CLEAR REACTOR REGULATION RELATED TO THE INSERVICE INSPECTION PROGRAM RELIEF RE0 VEST DUKE POWER COMPANY tiCGulRE NUCLEAR STATION. UNIT 1 DOCKET NO. 50-369
1.0 INTRODUCTION
The Technical Specifications for McGuire Nuclear Station, Unit 1, state that the surveillance requirements for Inservice Inspection and lasting of the American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 compon-ents shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g),
except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).
Under 10 CFR 50.55a(a)(3)(1) alternatives to the requirements of paragraoh (g) may be used if the proposed alternatives would provide an acceptable level of quality or safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The regulations require that inservice examination of components'and system pressure tests conducted during the first ten-year interval comply with the requirements in-the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) on the date twelve months prior to the date of issuance of the operating license, subject to the limitations and modifications listed therein. The applicable edition of Section XI of the ASME Code for the McGuire Nuclear Station, Unit 1, first ten-year inservice inspection (ISI) interval is the 1980 Edition, through Winter 1980 Addenda.
The components (including supports) may meet the requirements set forth-in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein.
Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for his facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement.
After examination of the determination, pursuant to 10 CFR 50.55a(a)(3)(i), the Director of the Office of Nuclear Reactor Regulation may 9301050140 921229 PDR ADOCK 05000369 P
- authorize proposed alternatives to 10 CFR 50.55a(g)-when the proposed alternatives would provide an acceptable level of quality and safety.
Under-10 CFR 50.55a(g)(6)(ii), the Commission may require the licensee to follow an augmented inservice inspection program'for systems and components when the Commission deems that added assurance of structural reliability is necessary, in a letter dated August 19, 1992, the Duke Power Company _ submitted _ Relief Request No. 92-02, which requested relief from the limits on the one-year extension of the ten-year inservice inspection interval requirements of subparagraph IWA-2400(c).
This request was essentially anLamendment to a previous Relief Request (RR 90-02) that was evaluated by the NRC staff in a Safety Evaluation transmitted by letter dated January 30, 1992.
u 2.0 EVALVATION The staff has evaluated the information provided by the licensee in support of-Relief Request No. 92-02 as follows.
2.1 Reauest for Relief No. 92-02. Subarticle IWA-2400. Inspection Intervals Code Reauirement:
Subparagraph IWA-2400(c), states that:
"Each inspection. interval may be decreased or extended (but not cumulatively) by as much as l_ year.
For power units that are out of service continuously _ for 6 months or more, the inspection interval during which the outage occurred may be extended for_ a period equivalent to the outage."
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Licensee's Reauest for Relief:
The licensee requests-that the: ten-year inservice inspection interval, in addition to the twelve-month extension allowed by-the ASME Code, be extended to the end of the current fuel 1
cycle.
This relief would apply-to ASME Code Class 2 and Class 3 portions of systems and components-identified in the McGuireeUnit 1 inservice inspection program which have not_been hydrostatically-tested as required for the first interval.
Approximately 10% of the outage related class C hydrostatic tests and approximately 50% of.the class B-tests are required to be performed.
Licensee's Basis for Reauestina Relief: _In a _ letter dated. November 19, 1990, the-licensee requested that the first inspection interval be ex--
tended, from December 1, 1992 until December-1, 1993 in order to.com-plete the balance of Class 2 and 3 hydrostatic tests during a scheduled-refueling outage. Duke Power revised Relief Request 90-02 in letters dated _ July ll,1991 and October 2,1991. The NRC. staff _ evaluated the licensee's information in a SE transmitted in a-letter dated January 30,
'1992.
The NRC staff-gave approval'to " add four weeks to the ten-year ISI _ interval (plus the twelve month extension allowed by IWA-2400 (c))
to ensure that McGuire Unit I can operate until the end-of-cycle 8 refueling outage' currently scheduled to begin December 11,1992."
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- f Subsequent to NRC approving the relief request (90-02), McGuire Unit 1 experienced extended unplanned forced outages. As such, the-schedule for the Unit 1 end-of-cycle 8 refueling outage was revised to March 29, 1993.
As currently' scheduled, the end-of-cycle 8 refueling outage would begin after the extended ten-year inservice inspection interval expires.
To comply with the ASME Code would require Unit 1 to be shutdown by December 29, 1992, in order to ccmplete all of the remaining required hydrostatic tests.
This would result in another_ extended unplanned forced outage in order to complete a few remaining hydrostatic tests.
The licensee's position is that not performing the tests within _the prescribed schedule would not endanger the quality of operations nor affect the health and safety-of the public..Therefore, the burden of performing another -unplanned outage, and in the process causing plant equipment to experience an unnecessary shutdown /startup-cycle, in order to complete the remaining hydrostatic testing, outweighs the benefit of imposing the requirement during the current scheduled inservice inspection interval.
To avoid the need for additional relief requests to be submitted in the -
event there are additional extended unplanned forced outages, Duke requests that the extension be approved based on the start of the end-of-cycle 8 refueling outage instead of an explicit calendar.date.
If an explicit calendar date is necessary, then an extension of 120-days beyond the currently approved end date for the first interval is-requested.
Alternative Testina No alternative examinations are being-proposed. The required examinations will be performed.
The only change will be the time that the examinations-will be performed.
2.2 Staff Evaluation The technical issues associated with the subject Relief Request 92-02 were addressed by the NRC staff in the SE transmitted in a letter dated January 30, 1992, that approved an extension of the current inspection interval.
The staff's evaluation determined that the licensee's revised request does not involve new or different technical issues.
Scheduled 2.
inservice inspections are intended to be performed during outages of sufficient length to complete the ASME Code requirements.
The ASME Code is a national standard-that has.been incorporated by reference _by regulatory _and enforcement authorities. The ASME Council
.did not publish rules in ASME Section XI that require a plant Owner to enter a forced shutdown to complete Code requirements.
However, McGuire
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. Unit I would be required to shut down by December-29, 1992, in order to complete all of the remaining hydrostatic. tests unless the licensee-receives approval to extend the inspection: interval.
The' primary reason the refueling outage has been delayed 'is that McGuire Unit I has recently experienced extended unplanned forced outages.
Pursuant to the subject subparacraph IWA-2400(c), if McGuire thlit I had been out of service continuously for six months or more, the inspection interval during which the outage occurred may be extended for.a period equivalent to the outage. Therefore, the Code rules and the regulations already permit an extension of the interval.-for an unplanned outage over 6 months.- However, the existing approved inservice inspection plan requires a forced shutdown because McGuire Unit 1 experienced a-series of outages less than 6 months.
The NRC SE dated January 30, 1992, clearly intended to permit the
-licensee to complete the remaining hydrostatic tests during the upcoming refueling outage.
Subparagraph IWA-2400(c) encompasses the length of-time identified in the -licensee's submittal.
Therefore, the NRC staff determined that relief may be granted,-as requested by:the licensee, to complete the remaining-hydrostatic tests by the end of the upcoming refueling outage
3.0 CONCLUSION
Pursuant to 10 CFR 50.55a(g)(5)(iii), the-licensee determined that conformance.
with certain Code requirements is impractical for his facility-and submitted supporting information. The_ staff concludes pursuant to'10 CFR' 50.55a(g)(6)(i) that an extension of the inservice inspection; interval until the end-of-cycle 8 refueling outage to complete -the remaining hydrostatic -
tests is authorized by _ law -and will not endanger life, property, or the common defense and security, and is otherwise11n the public interest.
Date: __ December 28, 1992
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