ML051010290
| ML051010290 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/11/2005 |
| From: | Grecheck E Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 05-192, TAC MB2221, TAC MB2222 | |
| Download: ML051010290 (12) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA23261 A p r i l 11, 2005 United States Nuclear Regulatory Commission Serial No.: 05-192 Attention: Document Control Desk NL&OS/ETS: Rev. 0 Washington, D. C. 20555 Docket Nos.: 50-338/339 License Nos.: NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)
NORTH ANNA POWER STATION UNITS 1 AND 2 ASME OPERATIONS AND MAINTENANCE (OM) CODE RELIEF REQUESTS P-3 AND P-4 North Anna is presently in the third ten-year inservice testing interval and testing is conducted in accordance with the requirements of the ASME OM Code, 1995 Edition, 1996 Addenda. The OM Code requires testing of the Service Water and Component Cooling Water pumps with the pumps operating at a specified reference point in accordance with existing code requirements ISTB 5.2.1 and ISTB 5.2.3. However, establishing flow at a specified reference point is very difficult due to system design and plant operating conditions. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), Dominion requests relief from the specific ISTB Code requirements as discussed in the attached relief requests. These relief requests were originally submitted to the NRC to request relief from the requirements of ISTB 5.2.1, and were approved by the NRC by letter dated January 28, 2002 (TAC Nos. MB2221 and MB2222). They have been revised to include relief from the requirements of ISTB 5.2.3 in addition to ISTB 5.2.1 and are attached for NRC review.
If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.
Very truly yours, n
Eugene S. Grecheck Vice President - Nuclear Support Services Attachments Commitments made in this letter: None
Serial No.05-192 Docket Nos. 50-338/339 cc: U.S. Nuclear Regulatory Commission Region II Sam Nunn Federal Atlanta Center 61 Forsyth Street, SW Suite 23T85 Atlanta, GA 30303 Mr. J. T. Reece NRC Senior Resident Inspector North Anna Power Station Mr. S. R. Monarque NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8-Hl2 Rockville, MD 20852 Mr. J. E. Reasor, Jr. (w/out attachments)
Old Dominion Electric Cooperative lnnsbrook Corporate Center Suite 300 4201 Dominion Blvd.
Glen Allen, VA 23060 Mr. M. Grace Authorized Nuclear Inspector North Anna Power Station
Attachment 1 Serial No.05-192 North Anna Unit 1 Interval 3 IST Program Plan Relief Requests P-3 and P-4 Virginia Electric and Power Company (Dominion)
North Anna Power Station Unit 1
Serial No.05-192 Docket Nos. 50-338/339 RELIEF REQUEST P-3 Systems: Service Water Pump(s): 1-SW-P-1A 1-SW-P-l B Group: A Class: 3 Function: The service water pumps supply cooling water to the component cooling and recirculation spray heat exchangers as well as other safety related components.
ISTB Code Requirements For Which Relief Is Requested ISTB 5.2.1 requires that Group A tests shall be conducted with the pump operating at a specified reference point.
ISTB 5.2.3 requires that Comprehensive tests shall be conducted with the pump operating at a specified reference point.
Basis For Request (ISTB 5.2.1 and ISTB 5.2.3)
Plant conditions may not be the same as when the reference values were established.
Many reference points must be established to anticipate future plant conditions. In the service water system, reproducing one of these reference flow points is not practical with the large butterfly valves installed, and it may not be desirable to alter cooling because of other plant operating parameters. Therefore, the pumps will be tested over a range of flows, and the results will be compared to acceptance criteria based on a portion of the pump curve and the hydraulic acceptance criteria given in ISTB.
The guidelines set forth in Code Case OMN-9, Use of a Pump Curve for Testing, and the conditions identified in Regulatory Guide 1.I 92, Operation and Maintenance Code Case Acceptability, ASME OM Code, will be followed. The conditions identified in Regulatory Guide 1 ,192 are:
(1) When a reference curve may have been affected by repair, replacement, or routine servicing of a pump, a new reference curve must be determined, or an existing reference curve must be reconfirmed, in accordance with Section 3 of this Code Case.
Serial No.05-192 Docket Nos. 50-338/339 RELIEF REQUEST P-3 (Cont.)
(2) If it is necessary or desirable, for some reason other than that stated in Section 4 of this Code Case, to establish an additional reference curve or set of curves, these new curves must be determined in accordance with Section 3.
Past vibration data for the subject pumps have been reviewed, and it has been determined that pump vibration does not vary significantly with flow rate over the range of the test flow rates. The alternative testing requirements of ISTB 5.2.1 and ISTB 5.2.3 provides an acceptable level of quality and safety.
Alternate Testina ProDosed Acceptance criteria will be based on a portion of the pump curve and not on discreet reference values. The testing guidelines set forth in Code Case OMN-9 and the conditions identified in Regulatory Guide 1.I 92 will be followed.
Using the provisions of this relief request as an alternative to the specific requirements of ISTB 5.2.1 and ISTB 5.2.3 identified above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), we request relief from the specific ISTB Code requirements identified in this relief request.
Serial No.05-192 Docket Nos. 50-338/339 RELIEF REQUEST P-4 Systems: Component Cooling Pump(s): 1-CC-P-1A 1-CC-P-1B Group: A Class: 3 Function: The component cooling pumps supply cooling water to the component cooling heat exchangers, which remove heat from systems containing radioactive fluids.
ISTB Code Requirements For Which Relief Is Requested ISTB 5.2.1 requires that Group A tests shall be conducted with the pump operating at a spec if ied refe rence point .
ISTB 5.2.3 requires that Comprehensive tests shall be conducted with the pump operating at a specified reference point.
Basis For Request (ISTB 5.2.1 and ISTB 5.2.3)
Plant conditions may not be the same as when the reference values were established.
Many reference points must be established to anticipate future plant conditions. In the component cooling system, reproducing one of these reference flow points is difficult with the large butterfly valves installed, and it may not be desirable to alter cooling because of other plant operating parameters. Therefore, the pumps will be tested over a range of flows, and the results will be compared to acceptance criteria based on a portion of the pump curve and the hydraulic acceptance criteria given in ISTB.
The guidelines set forth in Code Case OMN-9, Use of a Pump Curve for Testing, and the conditions identified in Regulatory Guide 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code will be followed. The conditions identified in Regulatory Guide 1.192 are:
(1) When a reference curve may have been affected by repair, replacement, or routine servicing of a pump, a new reference curve must be determined, or an existing reference curve must be reconfirmed, in accordance with Section 3 of this Code Case.
Serial No.05-192 Docket Nos. 50-3381339 RELIEF REQUEST P-4 (Cont.)
(2) If it is necessary or desirable, for some reason other than that stated in Section 4 of this Code Case, to establish an additional reference curve or set of curves, these new curves must be determined in accordance with Section 3.
Past vibration data for the subject pumps have been reviewed, and it has been determined that pump vibration does not vary significantly with flow rate over the range of the test flow rates. The alternative testing requirements of ISTB 5.2.1 and ISTB 5.2.3 provides an acceptable level of quality and safety.
Alternate Testina PrODosed Acceptance criteria will be based on a portion of the pump curve and not on discreet reference values. The testing guidelines set forth in Code Case OMN-9 and the conditions identified in Regulatory Guide 1.I 92 will be followed.
Using the provisions of this relief request as an alternative to the specific requirements of ISTB 5.2.1 and ISTB 5.2.3 identified above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), we request relief from the specific ISTB Code requirements identified in this relief request.
Attachment 2 Serial No.05-192 North Anna Unit 2 Interval 3 IST Program Plan Relief Requests P-3 and P-4 Virginia Electric and Power Company (Dominion)
North Anna Power Station Unit 2
Serial No.05-192 Docket Nos. 50-3381339 RELIEF REQUEST P-3 Systems: Service Water Pump(s): 2-SW-P-1A 2-SW-P-1B Group: A Class: 3 Function: The service water pumps supply cooling water to the component cooling and recirculation spray heat exchangers as well as other safety related components.
ISTB Code Requirements For Which Relief Is Requested ISTB 5.2.1 requires that Group A tests shall be conducted with the pump operating at a specified reference point.
ISTB 5.2.3 requires that Comprehensive tests shall be conducted with the pump operating at a specified reference point.
Basis For Request (ISTB 5.2.1 and ISTB 5.2.3)
Plant conditions may not be the same as when the reference values were established.
Many reference points must be established to anticipate future plant conditions. In the component cooling system, reproducing one of these reference flow points is difficult with the large butterfly valves installed, and it may not be desirable to alter cooling because of other plant operating parameters. Therefore, the pumps will be tested over a range of flows, and the results will be compared to acceptance criteria based on a portion of the pump curve and the hydraulic acceptance criteria given in ISTB.
The guidelines set forth in Code Case OMN-9, Use of a Pump Curve for Testing, and the conditions identified in Regulatory Guide 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code will be followed. The conditions identified in Regulatory Guide 1.192 are:
(1) When a reference curve may have been affected by repair, replacement, or routine servicing of a pump, a new reference curve must be determined, or an existing reference curve must be reconfirmed, in accordance with Section 3 of this Code Case.
Serial No.05-192 Docket Nos. 50-338/339 RELIEF REQUEST P-3 (Cont.)
(2) If it is necessary or desirable] for some reason other than that stated in Section 4 of this Code Case, to establish an additional reference curve or set of curves, these new curves must be determined in accordance with Section 3.
Past vibration data for the subject pumps have been reviewed] and it has been determined that pump vibration does not vary significantly with flow rate over the range of the test flow rates. The alternative testing requirements of ISTB 5.2.1 and ISTB 5.2.3 provides an acceptable level of quality and safety.
Alternate Testina ProDosed Acceptance criteria will be based on a portion of the pump curve and not on discreet reference values. The testing guidelines set forth in Code Case OMN-9 and the conditions identified in Regulatory Guide 1.192 will be followed.
Using the provisions of this relief request as an alternative to the specific requirements of ISTB 5.2.1 and ISTB 5.2.3 identified above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), we request relief from the specific ISTB Code requirements identified in this relief request.
Serial No.05-192 Docket Nos. 50-338/339 RELIEF REQUEST P-4 Systems: Component Cooling Pump(s): 2-CC-P-1A 2-CC-P-1 B Group: A Class: 3 Function: The component cooling pumps supply cooling water to the component cooling heat exchangers, which remove heat from systems containing radioactive fluids.
ISTB Code Requirements for Which Relief is Requested ISTB 5.2.1 requires that Group A tests shall be conducted with the pump operating at a specified reference point.
ISTB 5.2.3 requires that Comprehensive tests shall be conducted with the pump operating at a specified reference point.
Basis For Request (ISTB 5.2.1 and ISTB 5.2.3)
Plant conditions may not be the same as when the reference values were established.
Many reference points must be established to anticipate future plant conditions. In the component cooling system, reproducing one of these reference flow points is difficult with the large butterfly valves installed, and it may not be desirable to alter cooling because of other plant operating parameters. Therefore, the pumps will be tested over a range of flows, and the results will be compared to acceptance criteria based on a portion of the pump curve and the hydraulic acceptance criteria given in ISTB.
The guidelines set forth in Code Case OMN-9, Use of a Pump Curve for Testing, and the conditions identified in Regulatory Guide 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code will be followed. The conditions identified in Regulatory Guide 1.192 are:
(1) When a reference curve may have been affected by repair, replacement, or routine servicing of a pump, a new reference curve must be determined, or an existing reference curve must be reconfirmed, in accordance with Section 3 of this Code Case.
Serial No.05-192 Docket Nos. 50-338/339 RELIEF REQUEST P-4 (Cont.)
(2) If it is necessary or desirable, for some reason other than that stated in Section 4 of this Code Case, to establish an additional reference curve or set of curves, these new curves must be determined in accordance with Section 3.
Past vibration data for the subject pumps have been reviewed, and it has been determined that pump vibration does not vary significantly with flow rate over the range of the test flow rates. The alternative testing requirements of ISTB 5.2.1 and ISTB 5.2.3 provides an acceptable level of quality and safety.
Alternate Testina ProDosed Acceptance criteria will be based on a portion of the pump curve and not on discreet reference values. The testing guidelines set forth in Code Case OMN-9 and the conditions identified in Regulatory Guide 1.192 will be followed.
Using the provisions of this relief request as an alternative to the specific requirements of ISTB 5.2.1 and ISTB 5.2.3 identified above will provide adequate indication of pump performance and continue to provide an acceptable level of quality and safety.
Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), we request relief from the specific ISTB Code requirements identified in this relief request.