ML091330236

Response to NRC Comments on the Fourth Interval ISI Program

ML091330236
Person / Time
Site:	North Anna
Issue date:	05/12/2009
From:	Hartz L Dominion, Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
08-595D
Download: ML091330236 (8)

Text

10 CFR 50.55a VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 12, 2009 u.s. Nuclear Regulatory Commission Serial No. 08-595D Attention: Document Control Desk NL&OS/ETS RO Washington, D.C. 20555 Docket No. 50-338 License No. NPF-4 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNIT 1 RESPONSE TO NRC COMMENTS ON THE FOURTH INTERVAL lSI PROGRAM In letters dated October 17, 2008 (Serial No. 08-0595) and February 18, 2009 (Serial No, 09-595B), Dominion submitted the North Anna Power Station Unit 1 Inservice Inspection (lSI) Program for the fourth lSI interval applicable to Class 1, 2, and 3 components, component supports, and a revision to Relief Request CS-001. Included with the program were requests for alternatives or relief from specific code requirements in accordance with 10 CFR 50.55a (a)(3)(i) and/or (ii) or 10 CFR 50.55a(g)(5)(iii). In an April 30, 2009 phone call with Dominion, the NRC staff commented on the lSI program submittal. In response to those NRC staff comments, revised lSI program pages are included in the attachment to this letter. Please replace the original pages with the attached pages.

If you have any questions or require additional information, please contact Mr. Thomas Shaub at (804) 273-2763.

Sincerely,

(~n~~

Leslie Hartz Vice President - Nuclear Support Services Attachments:

1 Response Comments on the Fourth Interval lSI Program and CS-001

2. Revised Pages Commitments made in this letter: None

Serial No. 08-5950 Docket No. 50-338 Response to NRC Comments on lSI Program Page 2 of 2 cc: U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW Suite 23T85 Atlanta, Georgia 30303 Mr. J. E. Reasor, Jr.

Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd.

Suite 300 Glen Allen, Virginia 23060 NRC Senior Resident Inspector North Anna Power Station Ms. D. N. Wright NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North MaiI Stop 0-8 H4A 11555 Rockville Pike Rockville, Maryland 20852 Mr. J. F. Stang, Jr.

NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North MaiI Stop 0-8 G9A 11555 Rockville Pike Rockville, Maryland 20852

Serial No. 08-5950 Docket No. 50-338 ATTACHMENT 1 FOURTH INTERVAL lSI PLAN RESPONSE TO COMMENTS ON THE FOURTH INTERVAL lSI PROGRAM VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT 1

Serial No. 08-5950 Docket No. 50-338 Response to NRC Comments on lSI Program FOURTH INTERVAL lSI PLAN RESPONSE TO REQUEST FOR INFORMATION FOR FOURTH INTERVAL lSI PROGRAM AND RELIEF REQUEST CS-001 NRC Comments The NRC staff has the following comments related to North Anna Unit 1 lSI Fourth 10-year Interval Program submittal and Relief Request CS-001, Revision 1:

1. The original lSI fourth 10-year interval program submittal dated October 7, 2008, Abstract, Page ii, Third paragraph states that IWP (inservice testing of pumps) and IWV (Inservice Testing of Valves) Program are separate programs and are not included as part of lSI Program. Please note that the Articles IWP and IWV are not part of the applicable ASME Section XI, 2004 Edition.

2. The original lSI fourth 10-year program submittal dated October 7, 2008, Abstract, Page viii, Table states that Relief Request CS-001- Surveillance of snubbers will be in accordance with TRM and preservice testing in accordance with ISTD. Please note that ISTD is not part of ASME Section XI, nor the Relief Request CS-001, Revision 1 dated February 18, 2009. ISTD needs to be deleted from the lSI program.

3. Revised Relief Request CS-001, Revision 1, Page, 2 of 8, Visual Examination, third paragraph, fourth line states that historically, the number of unacceptable visual snubber inspections at NAPS Unit 1 is one or less and based on the snubber population, the current inspection interval is 48 months (every other refueling outage). Please note that 48 months are not a guarantee, it depends upon future visual examination.

Dominion Response NRC Comments 1 and 2 Revised lSI Program pages are attached to address the specific NRC comments.

NRC Comment 3 The phrase "the current inspection interval is 48 months (every other refueling outage)"

was included to identify the current inspection interval for Unit 1. Dominion agrees that if additional failures are identified during future inspections the inspection frequency will change accordingly. A revised page is attached with the phrase removed to avoid confusion.

Page 1 of 1

Serial No. 08-5950 Docket No. 50-338 ATTACHMENT 2 FOURTH INTERVAL lSI PLAN RESPONSE TO COMMENTS ON THE FOURTH INTERVAL lSI PROGRAM CORRECTED PAGES VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT 1

ABSTRACT VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNIT 1 INSERVICE INSPECTION PLAN FOURTH INSPECTION INTERVAL MAY 1, 2009 THROUGH APRIL 30, 2019 As required by the Code of Federal Regulations, Title 10, Part 50, Section 50.55a (10 CFR 50.55a), the NAPS 1 Inservice Inspection (ISn Program should have been updated to the 2001 Edition of ASME Section XI with addenda through the 2003 Addenda.. This was the latest edition and addenda of Section XI incorporated into 10 CFR 50.55a as of April 30, 2008. However, as allowed by 10 CFR 50.55a(g)(4)(iv), the fourth inservice inspection plan was prepared to the requirements of the 2004 Edition of ASME Section XI. This updated program is for the NAPS 1 fourth ten year inspection interval scheduled to commence May 1, 2009 and be completed April 30, 2019. These dates reflect extension of the first interval by 201 days documented in our letter to the NRC dated 8/25/88, Serial No.88-486, and extension of the second interval by 127 days approved per NRC Letter No.98-167, dated 3/6/98. In cases where the requirements of Section XI have been determined to be impractical, requests for relief have been developed per 10 CPR 50.55a(g)(5). Alternatives, as allowed by 10 CFR 50.55a(a)(3), to specific requirements of ASME Section XI or 10 CPR 50.55a, that provide an acceptable level of quality and safety and provide a methodology more conducive to the performance of an examinations have been proposed. Similarly, alternatives have been proposed when compliance with specified requirements would result in hardship or unusual difficulty without a compensation increase in the level of quality and safety.

This document provides an overview and summary of the NAPS-1 lSI Program for Subsections IWA, IWB, IWC, IWD and IWF. The boundaries of the lSI Program, component classifications, and the employment of exemptions in IWB-1220, IWC-1220, IWD-1220, and IWF-1230 are shown on the lSI Classification Boundary Drawings (CBMs). The graphic codes, symbols and text used on the CBMs are detailed on 11715-CBM-L&S-4, Legends and Symbols Drawing.

The Inservice Inspection Schedule for Components and Component Supports and the Inservice Inspection Plan for System Pressure Tests are provided in separate volumes to the lSI Program. System Pressure Tests are performed in accordance with the System Pressure Test Implementing Schedule.

The lWE (Requirements for Class MC and CC Components) and IWL (Requirements for Class CC Concrete Components) Programs are separate and are not included as part of the lSI Program. Steam generator inspections will continue to be performed under Plant Technical Specifications NAPS VI I4-ISI Plan 11 Revision QA

North Anna Power Station Unit 1, Interval 4 lSI Correspondence (Continued)

Component Support Relief Requests CS-OO 1 - Surveillance of snubbers will be in accordance Pending with Technical Requirements Manual and preservice testing in accordance with ASME OM Part 4.

Miscellaneous Documents (Reserved for Later Use.)

Partial Coverage Relief Requests (Reserved for Later Use.)

Risk Informed Application (Reserved for Later Use.)

NAPS VI I4-ISI Plan viii Revision 0

There are 326 small bore snubbers and 12 large bore snubbers (greater than 50 KIPS) installed in North Anna Unit 1. All the snubbers at NAPS Unit 1 are hydraulic snubbers.

Snubber maintenance and repair are controlled at NAPS by written maintenance procedures that are based on manufacturers' recommendations and industry good practices. These procedural requirements are similar to the requirements of OM Part 4, paragraph 1.5.6. 'Changing snubber maintenance procedures requires review and approval of the snubber engineer. Design engineering approval is required for any changes that could affect the snubbers ability to meet the functional (operability) test acceptance criteria or affect the snubbers ability to support the design load. Following maintenance and repair, snubbers are required to be functionally tested to demonstrate that they meet the acceptance criteria. Snubbers that are modified or replaced due to visual or functional testing deficiencies are subject to the requirements of IWA-4000 and must be evaluated for suitability as required by OM Part 4, paragraph 1.5.7. Replacement snubbers are functionally tested prior to installation and visually inspected following installation in accordance with the snubber visual inspection criteria.

VISUAL INSPECTIONS For visual inspections, the TRM states that snubbers are categorized as accessible or inaccessible during reactor operation and may be examined independently. This is the same requirement as OM Part 4, paragraph 1.6.

The TRM does not address snubber preservice examinations. However, snubbers are rotated from service in accordance with Code Case N-508-3 (approved by Reg. Guide 1.147) and following replacement a visual examination is required to be performed in accordance with maintenance procedures and the post maintenance testing program. This visual examination is similar to the preservice examination requirements described in OM Part 4, paragraph 2.1.1. Additional preservice operability testing proposed by Virginia Electric and Power Company (Dominion) is described later in this section. Repair/Replacements activities will be performed as required by Code Case N-508-3 and IWA-4000. Replacement snubbers are functionally tested prior to installation to demonstrate that they meet engineering acceptance criteria.

The intervals for snubber visual inspections are conducted in accordance with the TRM visual examination table which meets Generic Letter 90-09.

The inspection interval is based on the snubber population and the number of unacceptable snubbers. Historically, the number of unacceptable visual snubbers inspections at NAPS Unit 1 is one or less. The OM Part 4, paragraph 2.3.2.2 bases the inspection frequency on the number of unacceptable snubbers but does not take into consideration the snubber Page 2 of 8