ML20057C039
| ML20057C039 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/17/1993 |
| From: | Berkow H Office of Nuclear Reactor Regulation |
| To: | Stewart K VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML20056C205 | List: |
| References | |
| GL-89-04, GL-89-4, TAC-M8646, TAC-M86645, NUDOCS 9309240320 | |
| Download: ML20057C039 (3) | |
Text
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- .o September 17, 1993 Docket Hos. 50-338 and 50-339 Mr. W. L. Stewart Senior Vice President - Nuclear Virginia Electric and Power Company 5000 Dominion Blvd.
Glen Allen, Virginia 23060
Dear Mr. Stewart:
SUBJECT:
SAFETY EVALUATION FOR THE INSERVICE TESTING PROGRAM RELIEF REQUEST FOR PUMPS AND VALVES, NORTH ANNA POWER STATION, UNITS N0. 1 & NO. 2 (TAC NOS. M86645'& M86646)
By letter dated June 14, 1990, you submitted the second ten-year interval l
Inservice Testing (IST) program for NA-l&2.
By letter dated October 3, 1989, you responded to NRC Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," based on the first NA-l&2 ten-year interval program, which was superseded by the revised program.
Additionally, you provided a revised IST submittal dated October-17, 1990, following a meeting with the NRC staff held on September 6,1990, to discuss certain alternative test methods described in the relief requests.
The NRC issued interim approval for the NA-l&2 second ten-year interval IST program relief requests in a letter dated January 11, 1991. The interim approval for implementation of the revised program was based on a preliminary review performed by the NRC contractor, EG&G, Idaho. The interim approval was to remain in effect until a Safety Evaluation (SE) was issued.
In your letter of September 18, 1991, a schedule for installation of permanent flow instruments for the emergency diesel generator fuel oil transfer pumps was provided.
In previous submittals, you indicated that strap-on type ultrasonic flow instruments were being evaluated, which later proved to be unsuitable for use on these pumps due to the low flow / low volume pumping conditions which impacted the accuracy and repeatability of the strap-on instrumentation.
In your February 21, 1992, letter, interim relief to continue to utilize the stop check valve motor actuator to verify closure of the main steam line non-return stop check valve was requested.
The NRC issued an SE dated December 4,1992, which granted interim relief to remain effective until various non-intrusive test methods could be evaluated during the Surry Power Station, Unit 2, 1993 refueling outage. The Surry Power Station is similar in design to NA-l&2 and the results should be applicable to testing similar valves at NA-l&2.
The interim relief was contingent upon your implementing a non-intrusive test method for the subject valves following the Surry 2 refueling outage.
The NRC extended the interim relief until September 1, 1993, by letter to you dated June 8, 1993.
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2 The enclosed SE was prepared by the NRC staff to provide the results of the staff review of the relief requests contained in the NA-1&2 second ten-year interval program.
This effort also closes any outstanding action related to your response to GL 89-04.
The Code of Federal Regulations, 10 CFR 50.55a, requires that inservice testing of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific written relief has been requested by the licensee and alternatives authorized or relief granted by the Commission pursuant to Sections (a)(3)(1), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a.
Guidance on acceptable alternatives to Section XI requirements was provided by NRC in GL 89-04 for certain aspects of IST.
Certain 11censees, including Virginia Electric and Power Company (VEPC0) for NA-1&2, were required to review their IST program against the positions in Attachment 1 of GL 89-04 and provide a response to address the results in their review. You provided this response in your letter dated October 3,1989, as stated above; however, the response has been superseded by the revised second ten-year interval program which is evaluated in the enclosed SE.
Furthermore, in rulemaking to 10 CFR 50.55a effective September 8, 1992, (see 57 Federal Reaister 34666), the 1989 edition of ASME Section XI was incorporated in 1 (b) of 650.55a. The 1989 edition provides that the rules for IST of pumps and valves may meet the requirements set forth in ASME Operations and Maintenance Standards Part 6 (OM-6), " Inservice Testing of Pumps in Light-Water Reactor Power Plants," and Part 10 (0M-10), " Inservice Testing of Valves in Light-Water Reactor Power Plants." Pursuant to (f)(4)(iv), portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met, and therefore, relief is not required for those inservice tests that are conducted in accordance with OM-6 and OM-10, or portions thereof. Whether all related requirements are met is subject to NRC inspection.
The NRC staff, with technical assistance from Idaho National Engineering Laboratory (INEL), has reviewed the information concerning IST program requests for relief submitted for NA-l&2.
The staff adopts the evaluations and conclusions contained in the attached Technical Evaluation Report (TER) prepared by INEL.
Relief is being granted from the testing requirements which we have determined would be impractical to perform. Alternatives to ASME Code requirements are being authorized where compliance would result in a hardship without a compensating increase in safety, or where the proposed alternative testing provides an acceptable level of quality and safety. A summary of the NRC actions is provided in Table 1 of the SE.
For relief requests that have been denied, your testing should comply with the applicable Section XI requirements or GL 89-04 guidelines within 3 months of the receipt of this SE.
If you have additional justification to address the reasons for a denial, a revised relief request should be submitted within 3 months of the date of this SE, as appropriate.
4 The IST program relief requests which are granted are acceptable for implementation provided the action items identified in Appeidix A of the TER are addressed within I year of the date of the SE or by the end of the next refueling outage, whichever is later, or by the schedule specified in an individual action item.
The granting of relief is based upon the fulfillment j
of any commitments made by you in your basis for each relief request and the alternatives proposed.
The licensee should respond to the NRC within 1 year I
of the date of this SE describing actions taken, actions in progress, or actions to be taken, to address each of these items. The licensee should also provide the status of flow instrument installation for the emergency diesel generator fuel oil transfer pumps.
Program changes involving new or revised relief requests should not be implemented prior to approval by the NRC. New or revised relief requests that meet the positions in GL 89-04, Attachment 1, should be submitted to the NRC but can be implemented provided the guidance in GL 89-04, Section D, is followed.
Program chances that add or delete components from the IST program should also be periodically provided to the NRC.
Sincerely, (Original Signed B7)
Herbert N. Berkow, Director Project Directorate 11-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosures:
I. Safety Evaluation
- 2. Technical Evaluation Report cc w/ enclosures:
See next page Distribution Docket File T. Murley/F. Miraglia NRC & Local PDRs J. Partlow PDII-2 RF E. Rossi S. Varga J. Lieberman G. Lainas E. Jordan H. Berkow G. Hill (2)
E. Tana OC/LFDCB L. Engle L. Plisco, EDO RII OGC ACRS (IO)
M. Sinkule. RII Document Name - A:NA866645.RE OFC LA:PDII-2 PM: PDil-L D:P_DII-2 OGC jy NAME ETana ((I LEngi k HBhk DATE f / 7/93 9 / 9. [93 9/N93 3/h/93
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Mr. W. L. Stewart North Anna Power Station Virginia-Electric & Power Company Units 1 and 2 cc:
Mr. William C. Porter, Jr.
Robert B. Strobe, M.D., M.P.H.
County Administrator State Health Commissioner Louisa County Office of the Commissioner P.O. Box 160 Virginia Department of Health Louisa, Virginia 23093 P.O. Box 2448 Michael W. Maupin, Esq.
Hunton and Williams Regional Administrator, RII Riverfront Plaza, East Tower U.S. Nuclear Regulatory Commission 951 E. Byrd Street 101 Marietta Street, N.W., Suite 2900 Richmond, Virginia 23219 Atlanta, Georgia 30323 Dr. W. T. Lough Virginia State Corporation Commission Mr. G. E. Kane, Manager Division of Energy Regulation North Anna Power Station P.O. Box 1197 P.O. Box 402 Richmond, Virginia 23209 Mineral, Virginia 23117 Old Dominion Electric Cooperative 4201 Dominion Blvd.
Glen Allen, Virginia 23060 Mr. M. L. Bowling, Manager Nuclear Licensing & Programs Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, Virginia 23060 Office of the Attorney General Supreme Court Building 101 North 8th Street Richmond, Virginia 23219 Senior Resident Inspector North Anna Power Station U.S. Nuclear Regulatory Commission Route 2, Box 78 Mineral, Virginia 231172 n