ML051720424

Units 1 & 2, Inservice Testing Program Request for Additional Information (RAI)

ML051720424
Person / Time
Site:	Mcguire, McGuire
Issue date:	06/09/2005
From:	Gordon Peterson Duke Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MC5571, TAC MC5572, TAC MC5573, TAC MC5574, TAC MC5575, TAC MC5576, TAC MC5577, TAC MC5578
Download: ML051720424 (17)

Text

_ Duke GARY R. PETERSON (W Powere Vice President McGuire Nuclear Station A Duke Energy Company Duke Power MG01 VP / 12700 Hagers Ferry Road Huntersville, NC 28078-9340 704 875 5333 704 875 4809 fax grpeters @duke-energy. corn June 9, 2005 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555-0001

Subject:

McGuire Nuclear Station - Units 1 & 2 Docket Nos. 50-369, 50-370 Inservice Testing Program Request for Additional Information (RAI)

Relief Request Nos. MC-GRP-01, MC-SRP-KC-01, MC-SRP-ND-01, and MC-SRV-NS-01 (TAC Nos. MC5571, MC5572, MC5573, MC5574, MC5575, MC5576, MC5577, and MC5578)

Reference:

(1) Letter from Mr. G.R. Peterson of Duke Power to NRC, dated August 12, 2004, (2) Letter from Mr.

G.R. Peterson of Duke Power to NRC, dated November 18, 2004, and (3) Letter from Mr. James J. Shea of the NRC to Mr. G.R. Peterson of Duke Power, dated April 8, 2005.

Attached is the additional information that was requested by the NRC staff during a telephone conference conducted on March 17, 2005. The NRC staff's requests for information and Duke's responses are stated in Attachment 1. Please note that Attachment 2 includes the revised Relief Request No. MC-SRP-ND-01 as discussed in the Duke's responses. Also note that Relief Request No. MC-SRV-NS-01 is being withdrawn.

Questions with respect to this matter should be directed to Norman T. Simms of Regulatory Compliance at 704-875-4685.

Since.6el (y 0 G.R. Peterson \

Attachments www. duke-energy. corn

U.S. Nuclear Regulatory Commission June 9, 2005 Page 2 xc:

W.D. Travers U.S. Nuclear Regulatory Commission, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23 T85 Atlanta, GA 30303 S.E. Peters (Addressee only)

NRC Project Manager (MNS)

U.S. Nuclear Regulatory Commission One White Flint North, MS 08 G9 11555 Rockville Pike Rockville, MD 20852-2738 J.B. Brady NRC Senior Resident Inspector McGuire Nuclear Station

ATTACHMENT 1 Duke's Response to NRC RAIs

Response to Nuclear Regulatory Commission Staff Request for Additional Information Relief Request Nos. MC-GRP-O1, MC-SRP-KC-O1.

MC-SRP-ND-O1, and MC-SRV-NS-O1 Duke Power Company McGuire Nuclear Station, Units 1 and 2 Generic Relief Request No. MC-GRP-01 Comment The licensee is requesting generic relief for all the pumps characterized as "smooth-running pumps." The staff has not authorized establishment of a minimum vibration reference value generically and has not authorized alert and required action range values for pumps classified in a licensee's inservice testing (IST) program as "smooth running." If a licensee intends to requests an alternative using a minimum reference value for each pump, the submittal should address the current vibration levels and the methodology for detecting pump degradation.

Question 1 In order for the NRC staff to complete its review of this relief request, please provide the pump specific information on vibration levels and the methodology for detecting pump degradation for all pumps for which relief is requested.

Response to Question 1 This generic relief request was granted for the licensee's previous IST Program 10 yr submittal. It is desired to re-approve the relief in order to maintain a standard generic lower threshold for acceptance criteria for any pump vibration measurement point reference value which falls below the threshold. Such generic relief has also been granted to Oconee Nuclear Station (ON-GRP-01) and similar specific relief was previously granted to Palo Verde Nuclear Generating Station (PRR-08).

The intent of the generic relief request above is to apply to any pump in the MNS IST program which has a vibration point reference value less than or equal to 0.075 in/sec. The desired acceptable range for such vibration points would be 0 to and including 0.19 in/sec (based on the code requirement 2.5 Vr value), alert range would be > 0.19 in/sec to and including 0.45 in/sec (based on the code requirement 2.5 Vr through 6 Vr), and required action would be >

0.45 in/sec. McGuire desires to continue applying these acceptance criteria for all pump vibration points on all pumps for all tests (Group A or B pump tests as well as Comprehensive pump tests).

1ST Program Relief Request RAIs June 9, 2005 Page 2 In addition to the code required testing, all of the pumps in the IST program are included in the Licensee's Predictive Maintenance Program. Additional monitoring includes advanced vibration monitoring techniques (bearing high frequency detection and spectral analysis for the pump as well as the driver), and lubricant analysis (for oil lubricated pumps) for wear debris, chemical composition and cleanliness. The Predictive Maintenance Program provides supplemental information to assure detection of pump degradation.

Following is a list of current IST pump vibration reference values less than 0.075 in/sec:

Vibration Pump Name Vibration Point (in/sec)

Boric Acid Transfer Pump 1A Inboard Horizontal 0.02053 Inboard Vertical 0.07349 Outboard Axial 0.02713 Outboard Horizontal 0.02368 Boric Acid Transfer Pump 1B Inboard Horizontal 0.03245 Inboard Vertical 0.05688 Outboard Axial 0.04288 Outboard Horizontal 0.01703 Outboard Vertical 0.03993 Boric Acid Transfer Pump 2A Inboard Horizontal 0.01277 Inboard Vertical 0.01752 Outboard Axial 0.02148 Outboard Horizontal 0.01350 Outboard Vertical 0.03349 Boric Acid Transfer Pump 2B Inboard Horizontal 0.01785 Inboard Vertical 0.01616 Outboard Axial 0.01254 Outboard Horizontal 0.01904 Outboard Vertical 0.01747 Centrifugal Charging Pump IA Inboard Vertical 0.07203 Outboard Axial 0.05674 Outboard Horizontal 0.05607

IST Program Relief Request RAIs June 9, 2005 , !'*a Page 3 Centrifugal Charging Pump 1B Inboard Vertical 0.07411 Outboard Axial 0.06698 Centrifugal Charging Pump 2A Inboard Horizontal 0.06698 Inboard Vertical 0.06466 Outboard Axial 0.03303 Outboard Vertical 0.05093 Centrifugal Charging Pump 2B Outboard Axial 0.04941 Component Cooling Water Pump lAl Outboard Axial 0.05496 Component Cooling Water Pump 1A2 Inboard Horizontal 0.05063 Inboard Vertical 0.05728 Outboard Axial 0.05807 Outboard Horizontal 0.04816 Outboard Vertical 0.06442 Component Cooling Water Pump IBi Inboard Horizontal 0.04910 Inboard Vertical 0.05093 Outboard Axial 0.03505 Outboard Horizontal 0.05123 Outboard Vertical 0.06051 Component Cooling Water Pump 1B2 Inboard Horizontal 0.05963 Outboard Axial 0.04655 Outboard Vertical 0.07096 Component Cooling Water Pump 2A1 Inboard Vertical 0.06560 Outboard Axial 0.05033 Outboard Horizontal 0.06855 Outboard Vertical 0.06766 Component Cooling Water Pump 2A2 Inboard Horizontal 0.05781 Inboard Vertical 0.07084 Outboard Axial 0.05002 Outboard Horizontal 0.07391 Outboard Vertical 0.05620

IST Program Relief Request RAIs June 9, 2005 Page 4 Component Cooling Water Pump 2B 1 Inboard Horizontal 0.05226 Inboard Vertical 0.04956 Outboard Axial 0.02857 Outboard Horizontal 0.05167 Outboard Vertical 0.05048 Component Cooling Water Pump 2B2 Inboard Horizontal 0.06966 Inboard Vertical 0.06250 Outboard Axial 0.04800 Outboard Vertical 0.06395 Containment Spray Pump 1B Lower Bearing Axial 0.07493 Containment Spray Pump 2A Lower Bearing Axial 0.07224 Control Area Chilled Water Pump Train A Inboard Horizontal 0.03591 Inboard Vertical 0.02486 Outboard Axial 0.02613 Outboard Horizontal 0.04243 Outboard Vertical 0.03057 Control Area Chilled Water Pump Train B Inboard Horizontal 0.04987 Inboard Vertical 0.05441 Outboard Axial 0.02294 Outboard Horizontal 0.02606 Outboard Vertical 0.04358 Diesel Generator Sump Pump 1A2 Lower Bearing 0.00627 Lower Bearing + 90 Degrees 0.01040 Upper Bearing 0.03185 Upper Bearing + 90 Degrees 0.04555 Upper Bearing Axial 0.05138 Diesel Generator Sump Pump 1A3 Lower Bearing 0.01342 Lower Bearing + 90 Degrees 0.01442 Upper Bearing Axial 0.04655

IST Program Relief Request RAIs June 9, 2005 Page 5 Diesel Generator Sump Pump 1B2 Lower Bearing 0.00905 Lower Bearing + 90 Degrees 0.00951 Upper Bearing 0.04363 Upper Bearing + 90 Degrees 0.04202 Upper Bearing Axial 0.03816 Diesel Generator Sump Pump 1B3 Lower Bearing 0.00933 Lower Bearing + 90 Degrees 0.00820 Upper Bearing 0.03898 Upper Bearing + 90 Degrees 0.04539 Upper Bearing Axial 0.04979 Diesel Generator Sump Pump 2A2 Lower Bearing 0.00699 Lower Bearing + 90 Degrees 0.00863 Upper Bearing 0.03654 Upper Bearing + 90 Degrees 0.03257 Upper Bearing Axial 0.03777 Diesel Generator Sump Pump 2A3 Lower Bearing 0.01160 Lower Bearing + 90 Degrees 0.01184 Upper Bearing 0.03877 Upper Bearing + 90 Degrees 0.04216 Upper Bearing Axial 0.03137 Diesel Generator Sump Pump 2B2 Lower Bearing 0.01033 Lower Bearing + 90 Degrees 0.01083 Upper Bearing 0.04341 Upper Bearing + 90 Degrees 0.06039 Upper Bearing Axial 0.03867 Diesel Generator Sump Pump 2B3 Lower Bearing 0.00760 Lower Bearing + 90 Degrees 0.00726 Upper Bearing 0.02796 Upper Bearing + 90 Degrees 0.03007 Upper Bearing Axial 0.03654 Groundwater Drainage Sump A Pump A Upper Bearing 0.04243 Upper Bearing + 90 Degrees 0.05123 Upper Bearing Axial 0.07031

IST Program Relief Request RAIs June 9, 2005

.: .

Page 6 Groundwater Drainage Sump B Pump A Upper Bearing 0.06536 Groundwater Drainage Sump B Pump B Upper Bearing 0.06064 Upper Bearing + 90 Degrees 0.06606 Upper Bearing Axial 0.07117 Groundwater Drainage Sump C Pump B Upper Bearing + 90 Degrees 0.07100 Motor Driven Auxiliary Feedwater Pump IA Inboard Vertical 0.02988 Outboard Axial 0.05846 Outboard Vertical 0.04720 Motor Driven Auxiliary Feedwater Pump 1B Inboard Vertical 0.04752 Outboard Axial 0.06089 Outboard Vertical 0.04879 Motor Driven Auxiliary Feedwater Pump 2A Inboard Vertical 0.03935 Outboard Axial 0.06395 Outboard Vertical 0.05384 Motor Driven Auxiliary Feedwater Pump 2B Inboard Horizontal 0.05885 Inboard Vertical 0.03185 Outboard Axial 0.04752 Outboard Horizontal 0.05975 Outboard Vertical 0.03877 Nuclear Service Water Pump 2A Inboard Vertical 0.05674 Residual Heat Removal Pump 1B Lower Bearing Axial 0.07245 Residual Heat Removal Pump 2A Lower Bearing 0.06900 Lower Bearing Axial 0.07370 Residual Heat Removal Pump 2B Lower Bearing Axial 0.06900 Safety Injection Pump IA Inboard Horizontal 0.03291 Inboard Vertical 0.02408 Outboard Axial 0.04059 Outboard Horizontal 0.03935 Outboard Vertical 0.02642

IST Program Relief Request RAIs June 9, 2005 Page 7 Safety Injection Pump lB Inboard Horizonial 0.03945 Inboard Vertical 0.03149 Outboard Axial 0.04436 Outboard Horizontal 0.03569 Outboard Vertical 0.05370 Safety Injection Pump 2A Inboard Horizontal 0.02930 Inboard Vertical 0.02439 Outboard Axial 0.04069 Outboard Horizontal 0.03057 Outboard Vertical 0.04736 Safety Injection Pump 2B Inboard Horizontal 0.02720 Inboard Vertical 0.02039 Outboard Axial 0.02956 Outboard Horizontal 0.02903 Outboard Vertical 0.03125 Turbine Driven Auxiliary Feedwater Pump 1 Inboard Vertical 0.04925 Specific Relief Request No. MC-SRP-KC-01 Question 2 The American Society of Mechanical Engineers (ASME) Operations and Maintenance (OM)

Code Edition 1998 through the 2000 Addenda, requires that all pumps within the scope of an IST program need to be categorized either as Group A or Group B. Therefore, please specify the category of the component cooling water pumps (i.e., either Group A or Group B) and use the appropriate instrument accuracy, as required by the Table ISTB-3500-1 Response to Question 2 The submittal lists pump Group in the tables shown in Section 3.1 as follows:

Pump Category KC - Component Cooling Pumps Group A Only the instrument accuracy requirements for the Group A test (+/- 2%) are associated with this relief request.

IST Program Relief Request RAIs June 9, 2005 Page 8 Question 3 The licensee is requested to specify the paragraph of the OM Code from which relief is requested.

Response to Question 3 The specific OM code section for which relief is requested is Paragraph ISTB-3510(b)(1) which states "the full-scale range of each analog instrument shall be not greater than three times the reference value."

Question 4 Under the, "Basis for Relief " paragraph, the licensee specified a required pressure instrument accuracy of 2 percent based on Table ISTB-3500-1, This pressure instrument accuracy of 2 percent is only for Group A and Group B tests. The licensee did not provide accuracy information (i.e. +/- 0.5 percent) to be used for the comprehensive test of component cooling water pumps, as specified in Table ISTB-3500-1. Please clarify, and include the accuracy requirements for the comprehensive pump test.

Response to Question 4 The submittal table shown in Section 3.1 lists relief request MC-SRP-KC-01 as only applicable to the Group A quarterly flow/differential pressure test. Relief is not requested for instrument range requirements for the comprehensive test for which Code range and accuracy requirements are met.

Question 5 Under the, "Basis for Relief' paragraph, the licensee did not provide information related to the component cooling water pumps discharge pressure and pressure gauge accuracy requirements (for Group A or Group B and comprehensive pump tests). Please clarify and provide all the related information.

Response to Question 5 Relief is not requested for the comprehensive test for which instrumentation used meets Code range and accuracy requirements.

IST Program Relief Request RAIs June 9, 2005 Page 9 Specific Relief Request No. MC-SRP-ND-01 Question 6 ASME OM Code Edition 1998 through the 2000 Addenda, requires that all pumps within the scope of an IST program need to be categorized either as Group A or Group B. Therefore, please specify the category of the residual heat removal pumps (i.e., either Group A or Group B) and use the appropriate instrument accuracy, as required by the Table ISTB-3500-1 Response to Question 6 The submittal lists pump Group in the tables shown in Section 3.1 as follows:

Pump Categorv ND - Residual Heat Removal and Low Head Safety Injection Pumps Group A Only the instrument accuracy requirements for the Group A test (+/- 2%) are associated with this relief request.

Question 7 The licensee is requested to specify the paragraph of the OM Code from which relief is requested.

Response to Question 7 The specific OM code section for which relief is requested is Paragraph ISTB-3510(b)(1) which states "the full-scale range of each analog instrument shall be not greater than three times the reference value."

Question 8 Under the, "Basis for Relief" paragraph, the licensee states "Range requirements will be waived for the tests. The purpose of quarterly test is to verify Tech. Spec. requirements are met and to obtain vibration data for trending. The instrumentation used for the quarterly residual heat removal test will meet accuracy requirements for assuring RHR pump operability per Tech. Spec."

Please clarify and explain how quarterly inservice testing fulfills the Technical Specification Requirements.

IST Program Relief Request RAls June 9, 2005 Page 10 Response to Ouestion 8 The use of process analog instruments with 0.5% accuracy will more than compensate for instrument error in cases where installed instrument range is slightly greater than three times the reference value limitation required by the code in order to meet the 2% accuracy requirement for the Group A test. Instrumentation used for the comprehensive test meets instrument range and accuracy requirements.

Ouestion 9 The licensee is requested to rearrange and clarify the details provided under "Basis for Relief" and "Alternative Testing" so that the information is easily distinguished between the "Basis for Relief" and "alternative Testing" paragraphs.

Response to Ouestion 9 Please replace the relief request originally submitted with the one in Attachment 2. The discussion in both sections refers only to the Group A test. The relief request is not applicable to the comprehensive test.

Ouestion 10 Under the, "Alternative Testing" paragraph, the licensee specified a required pressure instrument accuracy of 2 percent based on Table ISTB-3500-1. This pressure instrument accuracy of +/- 2 percent is only for Group A and Group B tests. The licensee did not provide accuracy information (i.e. +/- 0.5 percent) related to the comprehensive test as specified in Table ISTB-3500-1. Please clarify, and include the accuracy requirements for the comprehensive pump test.

Response to Ouestion 10 Relief is not requested for the comprehensive test for which instrumentation used meets Code range and accuracy requirements. Although the submitted relief request contained the text "Group A/Comprehensive Test", the revised request from the previous question has deleted the reference to the Comprehensive test.

IST Program Relief Request RAIs '

June 9, 2005 Page 11 Specific Relief Request No. MC-SRV-NS-01 Question 11 In order for the staff to evaluate whether the proposed IST alternative is acceptable, the licensee must demonstrate that (1) the proposed alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i) or (2) compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(ii),

or (3) the code requirements are impractical pursuant to 10 CFR 50.55a(f)(5)(iii). Please provide the information necessary to demonstrate the basis for the request consistent with these requirements.

Response to Question 11 The check valves covered by this relief request are included in the Appendix II Check Valve Condition Monitoring Program. This relief (which was approved for the previous 10 year IST submittal) was requested again but for the contingency where these valves might be removed from the condition monitoring program and resume exercise testing under ISTC-35 10, ISTC-3520 and ISTC5221. It is no longer desirable to submit a relief request for a contingency and this relief request is hereby retracted.

Question 12 The licensee is requested to specify the paragraph of the OM Code from which relief is requested.

Response to Question 12 This relief request is retracted as explained above.

Question 13 In the submitted relief request, it appears that the licensee intends to use grouping criteria for IST of the subject check valves, however, it is unclear which paragraph of the OM Code the licensee is requesting relief from. Please clearly identify the IST criteria and the specific paragraph of the OM Code for which relief is requested.

Please note that ISTC-5221 (c)(1) states, "Grouping of check valves for sample disassembly examination program shall be technically justified and shall consider, as a minimum, valve manufacturer, design, service, size, materials of construction, and orientation." Paragraph ISTC-5221(c)(3) states, "At least one valve from each group shall be disassembled and

IST Program Relief Request RAIs June 9, 2005 Page 12 examined at least once every 8 years." Provided the licensee meets all the requirements of grouping for these check valves as specified in ISTC-5221 (c), it is unclear why the licensee needs Relief from Code requirements.

Response to Ouestion 13 This relief request is retracted as explained above.

ATTACHMENT 2 REVISED RELIEF REQUEST MC-SRP-ND-O1

t '- 11-"' i-: , ;'4 :

s McGuire Unit 1 McGuire Unit 2 Specific Relief Request RELIEF REQUEST

MC-SRP-ND-01 PUMPS: 1NDPU0001, IA Residual Heat Removal Pump INDPU0002, lB Residual Heat Removal Pump 2NDPUOOO1, 2A Residual Heat Removal Pump 2NDPU0002, 2B Residual Heat Removal Pump TEST REQUIREMENT: OMb-2000, ISTB-3510(b)(1) The full-scale range of each analog instrument shall be not greater than three times the reference value.

BASIS FOR RELIEF: The subject pumps have discharge process instrumentation installed.

The discharge pressure gauge has a range of 0-1000 PSIG and an accuracy of 0.5%. Typical reference values for pump discharge pressures are in the 230-260 PSIG range. Therefore, the process range does not meet the three times reference value criteria of the code. Installation and removal of special discharge test gauges for the purpose of quarterly Group A testing is a hardship. The minimum code requirement for instrument accuracy for these pressure gauges for Group A testing is 2% per Table ISTB-3500-1. Since the accuracy of the installed process instrumentation is 0.5% it more than compensates for the use of the increased range of the process instrumentation. Therefore there is no compensating increase in level of quality or safety in performing the hardship of installation and removal of test instrumentation for quarterly testing for each these four pumps.

ALTERNATE TESTING: Perform the quarterly Group A Tests with the installed process instrumentation for the subject pumps. The accuracy of the process instrumentation (0.5%) is much greater than the requirements specified in Table ISTB-3500-1 for instrument accuracy (2%). The actual reading error at test pressure due to the process instrument is 2.2% (0.5%

• 1000/230) for discharge pressure at the low end of this range. If a 0-690 PSIG gauge was used with the code minimum 2%

accuracy, then the reading error would be 6% (2%

• 690/230).

Therefore the actual instrumentation error introduced into the test would be less (2.2% vs. 6%). Using the installed process instrumentation data provides reasonable assurance that the component is operationally ready and meets the intent of the instrumentation requirements of the code. This relief was approved in the previous 120 month code update.