ML20057C040
| ML20057C040 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/17/1993 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20056C205 | List: |
| References | |
| NUDOCS 9309240322 | |
| Download: ML20057C040 (18) | |
Text
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data UNITED STATES j
j NUCLEAR REGULATORY COMMISSION t
W.- !HINGTON D.C. 20566-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM RE00ESTS FOR RELIEF VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION. UNITS 1 AND 2 DOCKET NUMBERS 50-338 AND 50-339
1.0 INTRODUCTION
The Code of Federal Regulations,10 CFR 50.55a, requires that inservice I
testing (IST) 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 i
l Code and applicable addenda, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Commission pursuant to Sections (a)(3)(i), (a)(3)(ii), or (f)(6)(1) of 10 CFR 50.55a.
In proposing alternatives or requesting relief, the licensee' must demonstrate
- Nt:
(1) the proposed alternatives provide an acceptable level of quality a:,d safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for its facility. NRC guidance contained in Generic Letter (GL) 89-04, Guidance on Developing Acceptable Inservice Testing Programs, provided alternatives to the Code requirements determined acceptable to the staff.
l Section 10 CFR 50.55a authorizes the Commission to approve alternatives and to i
I grant relief from ASME Code requirements upon making the necessary findings.
The NRC staff's findings with respect to authorizing alternatives and granting or not granting the relief requested as part of the licensee's IST program are contained in this Safety Evaluation (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 6 50.55a. 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 P. imps in Light-Water Reactor Power Plants, and Part 10 (OM-10)', Inservice Testing of Valves in Light-Water Reactor Power Plants. Pursuant to (f)(4)(iv), portions of subsequent 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 IST program evaluated in this SE covers the second ten-year IST interval for North Anna Power Station, Units 1 and 2.
The program indicates that the interval began December 14, 1990. The second ten-year interval IST program is 9309240322 930917 PDR ADOCK 05000338 l
P PDR u
- l
.-~
2 based on the requirements of the 1986 Edition of the ASME Section XI Code l
which was incorporated by reference in i 50.55a(b) by Volume 53 Federal l
Reoistir 16051~ effective May.5, 1988.
l l
2.0 BACKGROUND
f In their June 14, 1990, letter, Virginia Electic and Power Company (VEPCO) i submitted the second ten-year interval Inservice Testing (IST) Program for l
North Anna Power Station, Units 1 and 2.
In a letter dated October.3, 1989, YEPC0 had responded to NRC Generic Letter (GL) 89-04, Guidance on Developing i
Acceptable Inservice Testing Programs, based on the first ten-year interval program, which has been superseded by the revised program. Additionally, a j
revised IST submittal dated October 17, 1990, was provided following a meeting with NRC staff held September 6,1990, to discuss certain alternative test methods in the relief requests.
The NRC issued an interim relief for the second ten-year interval IST program
.l in a letter dated January 11, 1991. The interim approval for impleuentation of the revised program was based on a preliminary review performed by the.
NRC's contractor, EG&G Idaho. The interim approval was to remain in effect l
until a Safety Evaluation (SE) was issued.
i In VEPCO's 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, VEPC0 indicated that strap-on type ultrasonic flow instruments were being evaluated, which later i
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. The installation was to be completed by March 31, 1993.
[
In VEPCO's February 21, 1992, letter, interim relief to continue to utilize the stop check valve motor actuator to verify closure of the main steam line i
non-return stop check 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. Surry Power Station is a VEPC0 nuclear plant l
similar in design to North Anna and the results should be applicable to testing similar valves at North Anna.
2.1 Interval Start Date The second ten-year interval start date is based on the commercial operation date (December 14,1980) of North Anna Power Station, Unit 2, as required by.
i 10 CFR 50.55a(f)(5)(iv). The Unit I commercial operation date was July 6, 1978.
In a letter dated March 3, 1988, VEPC0 requested an exemption from the requirements of 10 CFR-50.55a(g)(4)(ii) to extend the start date for the second ten-year inservice inspection / inservice testing interval for North Anna, Unit 1, in order to establish concurrent intervals for the'two units.
The NRC granted the exemption in a letter dated April 26, 1988. The exemption remains in'effect for the life of the plant, unless otherwise modified.
i
3 2.2 Response To GL 89-04 i
As requested in GL 89-04, VEPC0 performed a review of the North Anna Power Station IST Program and provided a response to each of the positions included in Attachment 1 of GL 89-04. The results of the review and the' status of-1 conformance to the guidelines were described in Attachment 1 of the VEPC0 l
submittal dated October 3, 1989. A summary of the licensee's response to each
_ position follows:
Positions 1 and 2 - Check Valve Flow Testina For valves which cannot be full flow tested under any plant condition, a periodic disassembly program has been established which conforms to the guidance provided in Position 2.
Relief requests were developed where l
necessary.
Position 3 - Check Valve Backflow Testina j
Backflow testing methods were reviewed and were to be revised as necessary to conform with the guidance in Position 3.
Relief requests and cold shutdown justifications identified valves that could not be exercised to the closed position every quarter.
Position 4 - Pressure Isolation Valve Testina All the pressure isolation valves.in Technical Specifications are in the IST Program and are individually leakage tested.
Position 5 - Limitina Values of Full-Stroke Times for Power Operated Valves j
The maximum stroke times for valves was established in accordance with the guidance in Position 5.
Position 6 - Limitino Stroke Times for Rapid-Actino Valves The " rapid-acting" valves were assigned a maximum limiting value of full i
stroke time of 2 seconds in conformance with Position 6.
Additionally, the requirements of OM-10 were to be used as the basis for stroke time measurements of power-operated valves.
Position 7 - BWR Scram Valves - Not Applicable to PWRs j
Position 8 - Technical Specifications Action Statement Start Times The pump testing procedures were to be revised to conform to Position 8 guidance by December 31, 1989.
Position 9 - Pumo Testina Usina Mini-Flow' Return Ling 1 Pump testing relief requests were revised using the guidance in Position l
9.
I i
4 Position 10 - Containment Isolation Valve Testino Containment isolation valves from the Appendix J Program were included in the IST Program as Category A or A/C valves.
For containment isolation valves 6 inches or larger, the deviation from IWV-3427(b) was included in a relief request to the IST Program in accordance with the guidance in Position 10. Additionally, an exception was taken by VEPC0 in a relief request which requested that, in addition to repair or replacement of a leaking valve, corrective action can include an engineering evaluation to demonstrate that containment integrity will be maintained until the next Appendix J Type C test is performed.
(This relief request is evaluated in the SE.)
Position 11 - IST Procram Scope Based on the list of examples of components that could be included in the IST program, VEPC0 added the control room chilled water system and the accumulator isolation and vent valves to the North Anna IST Program.
3.0 EVALUATION 3.1 Relief Reauest V Pressurizer Power-0perated Relief Valve Relief Request V-27 is denied as discussed in TER Section 3.4.3.1.
The proposed alternate testing was to exercise the valves, 1-RC-PCV-1455C and 1-RC-PCV-1456 (pressurizer power-operated relief valves), during cold shutdowns when the reactor coolant system is depressurized, implying that this is not each cold shutdown, if not performed in the previous 3 months.
If the testing is performed each cold shutdown in accordance with the requirements of IWV-3412(a), the relief request should be changed to a cold shutdown justification.
The proposed frequency appears to be inconsistent with the VEPC0 response to GL 90-06, Resolution of Generic Issue 70, " Power-Operated Relief Valve and Block valve Reliability," and Generic Issue 94, " Additional Low-Temperature Overpressure Protection for Light-Water Reactors," Pursuant to 10 CFR 50.54(f), dated December 21, 1990.
For North Anna, the response states, in part, the following:
The PORVs and the block valves are included in the scope of the IST (Section XI) program. The block valves are included in the Generic Letter 89-10 HOV program. The solenoid valves and the check valves in the PORV control air system are checked indirectly when the PORVs are tested.
In accordance with our approved Section XI inservice testing program, the PORVs are not tested at power, but are stroke tested prior to each startup before establishing water-solid conditions. Therefore, the PORVs are tested prior to establishing conditions where the PORVs are used for low-temperature overpressure protection. The remainder of the Section XI requirements are completed in cold shutdown.
The NRC indicated the unacceptability of the VEPC0 response to GL 90-06 in a letter to W. L. Stewart dated March 16, 1993. The licensee should further review the testing of these valves and revise the response to GL 90-06 and/or
9 5
the IST program as necessary to ensure consistency in the statements concerning testing these valves. Additional valves may need to be added to the IST Program based on the VEPC0 review of the March 16, 1993, letter from NRC. These valves include the control air solenoid and check valves. The appropriate actions will be dependent upon the resolution of GL 90-06 for North Anna.
3.2 Relief Recuest V-42/V Accumulator Discharoe Check Valves In addition to the evaluation in Sections 3.2.3.5 and 3.2.3.6, and discussion in Appendix A, Anomalies 4 and 5, of the TER, the staff provides the following information for the licensee to consider in evaluating the extension of the disassembly and inspection (D&I) for the accumulator discharge check valves.
Disassembly and inspection of a check valve is not considered a true substitute for an operability test conducted under operating flow conditions, but is allowed when no other test means is available. Under operating conditions the valve internal parts are subject to dynamic flow loads, pressure gradients, differential temperature and gradients, and flow-induced and system-generated mechanical vibration.
Pipe loading on the valve body can affect the alignment of valve internal parts. Any of these conditions, or a combination of these conditions, can alter the valve performance and the effects could Le fiagnosed during operational testing. However, these operating conditions are not duplicated, and the results may not be apparent, in a disassembly and inspection effort. There have been instances where operational problems were discovered after disassembly / inspections. There are also examples of latent problems caused by the disassembly and inspection efforts, such as installing a bonnet-hung check valve is an incorrect orientation. Certain of these problems could be identified during a partial-flow test or a leakage test following disassembly / inspection, if performed.
In the past, conditions limiting testing of accumulator check valves justified the use of D&I since no other practical test method was available. With the 1
acceptance of non-intrusive methods and the development of other test methods, this justification requires a re-examination (reference NUREG/CP-0123,
" Proceedings of the Second NRC/ASME Symposium on Pump and Valve Testing").
GL 89-04, Position 2, was developed prior to widespread use of non-intrusive techniques.
It allowed D&I conditionally when other methods were impractical; however, in the public meetings, in response to questions on use of D&I, the staff indicated the use of other alternate techniques, including non-intrusives, were under investigation and were being encouraged by NRC.
Allowing D&I on a sampling basis was an extension of the Code-required time interval for valve testing. The D&I sample was small and valves in the group were identical in type, size, service conditions, exposure to operating environments, and age. The GL 89-04 sampling interval extension was justified on the basis that one valve in the group would be examined during each refueling outage and the performance of each valve in the group was representative of all the others.
GL 89-04, Position 2, allowed the use of a limited sampling plan to reduce the burden on the licensee to disassemble and inspect all valves in the group during each refueling. The sampling plan allowed that only one valve in each
6 group be disassembled and inspected at each refueling rather than disassembling and inspecting all valves in the group. The sampling plan further allowed a different valve in the group be disassembled and inspected at each refueling and the process be repeated until all valves were inspected.
With an 18-month operating fuel cycle, this would ensure that no valve D&I interval would be greater than 6 years.
Position 2 also suggested conditions of extreme hardship for consideration in extending the inspection interval beyond once every 6 years. In Position 2 the staff, in part, stated [i]n order to support extension of the valve disassembly and inspection interval to longer than once every 6 years, the licensee should develop the following information:
- a. Disassemble and inspect each valve in the grouping and document in detail and the condition of each valve and the valves's capability to be full stroked."
Although GL 89-04 suggested information to be considered by the licensee in developing justification for an interval extension it was not all inclusive.
The staff expected the licensee would conduct an in-depth review of all the safety effects as discussed during the public meetings.
The staff expectations for justification of an interval extensions were amplified in the responses to questions during the GL 89-04 public meetings.
Included in the staff justification expectations was a licensee's detailed evaluation of the effects on public safety, the maintenance history, service history, and other information relative to valve reliability and that the review and evaluation would rely on known and recorded valve condition of each valve from previous inspection data rather than subjective qualitative judgment.
3.3 Other Relief Reauests The licensee's IST program requests for relief from the requirements of Section XI have been reviewed by the staff with the assistance of its contractor, Idaho National Engineering Laboratory (INEL). The Technical Evaluation Report (TER) provided as Attachment 1 is INEL's evaluation of the licensee's IST program relief requests. The staff has reviewed the TER and concurs with the evaluations and conclusions contained therein. A summary of the relief request determinations is presented in Table 1.
The authorizing of alternatives or granting of relief is based upon the fulfillment of any commitments made by the licensee in its basis for each relief request and the alternatives proposed. The implementation of the IST program is subject to inspection by NRC.
Relief requests which relate to non-Code components are outside the scope of 10 CFR 50.55a and do not require NRC approval for implementation. These are indicated on Table 1.
Relief requests which are in accordance with the 1989 Edition of ASME Section XI (which incorporated OM-6 and OH-10) have been approved pursuant to 10 CFR 50.55a 1 (f)(4)(iv) as listed in Table 1.
Relief Requests V70/V71 were authorized for an interim period to provide the licensee a period of time to review the testing frequency for the open function of component cooling water check valves. Relief Requests P-9, P-10, and V-27 have been denied for reasons explained in the TER and in Section 3.1 above.
The licensee should refer to the TER, Appendix A, for a discussion of IST program anomalies identified during the review. The licensee should resolve
I i
7 all items in accordance with the guidance therein. The IST program relief requests that are not denied are acceptable for implementation provided the action items identified in Appendix A of the TER are addressed within one year of the date of this SE or by the end of the next refueling outage, whichever is later. The licensee should respond to the NRC within one year of the date of this SE describing actions taken, actions in progress, or actions to be taken, to address each of these items.
For the denied relief requests, testing should comply with the applicable Section XI requirements or GL 89-04 guidelines within 3 months of the receipt of this SE.
If the licensee has additional justification to address the reasons for denial, revised relief requests should be submitted within 3 months of the date of this SE.
4.0 CONCLUSION
The staff concludes that the relief requests as evaluated and modified by this SE will provide reasonable assurance of the operational readiness of the pumps and valves to perform their safety-related functions. The staff has determined that granting relief, pursuant to 10 CFR 50.55a (f)(6)(i) is authorized by law and will not endanger life or property, or the common defense and security and is otherwise in the public interest.
In making this determination the staff has considered the impracticality of performing the required testing considering the burden if the requirements were imposed.
Principal Contributor:
P. Campbell Date: September 17, 1993 i
m.
ENCLOSURE 1 Page No.
1 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD 0F BY NUMBER
& SUBJECT TESTING USNRC P-1 2.1.1.1 IWP-3IOD All pumps in Measure vibration Alternative
& -3300 the IST program velocity Authorized Bearing (a)(3)(i) temperature
& vibration measurement P-4 2.2.1.1 IWP-3500(a)
Emergency diesel Time pump from NRC approval not Test generator fuel automatic start required duration oil pumps signal Non-Code pumps l-EG-P-1HA,-1HB to shutoff
-lJA, & -lJB 2-EG-P-2HA,-2HB
-2JA,& -2JB P-5 2.3.1.1 IWP-3400(a)
Residual heat Test at cold Relief Granted Test removal pumps shutdown when RCS (f)(6)(i) frequency 1(2)-RH-P-1A &
<200 psig & RCPs
-1B secured. Not more than once every 3 months P-6 2.4.1.1 IWP-3400 Recirculation Dry run quarterly.
Approved pursuant Test spray pumps Flow tested at to (f)(4)(iv) frequency 1(2)-RS-P-IA refueling outages and -1B P-7 2.5.1.1 IWP-3400(a)
Outside Test once every Approved pursuant
& -3500(a) recirculation 2 years and to (f)(4)(iv)
Test spray pumps run pump for frequency &
1(2)-RS-P-2A 2 minutes duration
& -2B P-9 2.6.1.1 IWP-3100 Service water Measure pump Relief Denied Measure pumps dicharge pressure pump inlet & 1(2)-SW-P-1A differential
& -1B pressure P-10 2.6.1.2 IWP-3100 Service water Measure pump Relief Denied Measure pumps discharge pressure pump inlet 1(2)-SW-P-4 and differential pressure
I Page No.
2 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AND 2 SAFETY EVALUATION TABLE I
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC P-12 2.7.1.1 IWP-3100 Component Calculate pump Relief Granted
& -3110 cooling reference curve With Provisions Establish water pumps and compare to (f)(6)(i) fixed 1(2)-CC-P-1A in-situ values reference and -1B values Service water pumps 1(2)-SW-P-1A
-18 and -4 P-13 2.1.2.1 IWP-4110 Various pumps Use installed Alternative Instrument instrument with loop Authorized accuracy accuracy >2%
(a)(3)(ii)
P-14 2.8.1.1 IWP-3500 Feedwater pumps Recirculate pumps Approved pursuant Test 1(2)-FW-P-2 for >5 minutes to (f)(4)(iv) duration 1(2)-FW-P-3A prior to data 1(2)-FW-P-3B acquisition P-15 2.9.1.1 IWP-3400 Boric acid Quarterly test Relief Granted
& -3500 transfer pumps with partial data.
(f)(6)(i)
Test 1-CH-P-2A,-28 Refueling outage frequency
-2C,and -2D test with full
& duration data taken V-3 3.3.1.1 IWV-3521 Component Reverse flow closure Approved pursuant Test cooling water at refueling outages to (f)(4)(iv) frequency check valves 1-CC-84, -199
-154, 2-0C-78
-115, and -152 V-9 3.5.1.1 IWV-3411 Reactor coolant Exercise at cold Relief Granted Test seal water shutdown when RCS (f)(6)(i) frequency return isolation pressure is above valves 100 psig 1-CH-MOV-1380 and -1381 2-CH-MOV-2380 and -2381 V-10 3.5.2.1 IWV-3521 Charging system Exercise valves at Approved pursuant Test valves 1-CH-322 refueling outages, to (f)(4)(iv) frequency
-330,-336 not to exceed
-358,-380,& -402 24 months 2-CH-260,-284
Page No.
3 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V-14 3.14.1.1 IWV-3411 Inside Exercise at cold Relief Granted Test containment shutdowns when (f)(6)(i) frequency vacuum ejector vacuum is broken isolation valves 1-CV-TV-100 2-CV-TV-200 V-16 3.15.1.1 IWV-3521 Inside Exercise at Approved pursuant Test containment refueling outages to (f)(4)(iv) frequency fire protection not to exceed supply check 24 months valves 1-FP-272 and 2-FP-79 V-20 3.16.1.1 IWV-3521 Containment Exercise at Approved pursuant Test isolation refueling outages to (f)(4)(iv) frequency hydrogen not to exceed analyzers 24 months
& recombiner check valves 1-HC-14,-18 2-HC-15,and -20 V-21 3.6.1.1 IWV-3521 Instrument air
~ ll stroke Approved pursuant u
Test containment exercise at to (f)(4)(iv) frequency isolation refueling outages, check valves not to exceed 1-IA-55 & -149 24 months 2-IA-250 & -428 V-27 3.4.3.1 IWV-3411 Reactor coolant Exercise at cold Relief Denied Test valves shutdown when RCS frequency 1-RC-PCV-1455C is depressurized and 1456 2-RC-PCV-2455C and 1456 V-28 3.4.1.1 IWV-3521 Reactor coolant Exercise valves at Approved pursuant Test check valves refueling outages, to (f)(4)(iv) frequency 1-RC-149 not 2-RC-162 to exceed 24 months J
Page No.
4 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V-33 3.8.2.1 IWV-3522 Casing cooling Group valves and Relief Granted Test pump discharge disassemble and GL 89-04 method check valves inspect at 1-RS-123,& -138 refueling outages Position 2 2-RS-103,& -118 Unit Two 3.2.1.1 IWV-3411 Safety injection Full stroke Approved pursuant V-35 Test valves exercise & reverse to (f)(4)(iv) frequency 2-SI-MOV-2836 flow closure at
-2869A -2869B refueling outages,
-2890A &-2890B not to exceed 24 months V37/V38 App. A IWV-3521 Low head SI Valves grouped.
Relief Granted
& -3522 pump suction Performing GL 89-04 Test check valves disassembly and method and from containment inspection Position 2 frequency sump 1(2)-S1-1 1-SI-16 and 2-SI-21 Unit Two 3.2.1.2 IWV-3411 Safety injection Full stroke Approved pursuant V-37 Test valves exercise & reverse to (f)(4)(iv) 4 frequency 2-SI-MOV-2867C flow closure at
-2867D, -2890C refueling outages, and D not to exceed 24 months V38/V39 3.2.3.3 IWV-3521 Safety injection Partial stroke Approved pursuant Test check valves with mini-flow to (f)(4)(iv) frequency 1(2)-SI-9 quarterly and 1-S1-18 & -26 full-stroke exercise 2-SI-19 & -32 at refueling outages V39/V40 3.2.3.4 IWV-3521 Safety injection Partial stroke Approved pursuant Test check valves open & closed to (f)(4)(iv) frequency 1-51-47 and at cold shutdown.
2-51-18 Full stroke exercise open at refueling outages
Page No.
5 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V40/V41 3.2.2.1 IWV-3521 Safety injection Reverse flow closure Approved pursuant Test check valves every refueling to (f)(4)(iv) frequency 1-SI-106 & -110 outage, not to 2-SI-132 & -136 exceed 24 months V41/V42 3.2.2.2 IWV-3521 Various safety Exercise open and Approved pursuant Test injection closed at refueling to (f)(4)(iv) frequency check valves outages V42/V43 3.2.3.5 IWV-3521 Various safety Grouping valves.
Approved pursuant Test injection Performing sample to (f)(4)(iv) frequency check valves disassembly &
inspection with extension of disassembly interval V42/V43 3.2.3.6 IWV-3522 Various safety Performing sample Relief Granted Test injection disassembly and GL 89-04 method check valves inspection, with extension of Position 2 disassembly interval V43/V44 3.2.2.3 IWV-3521 Various safety Full stroke open Approved pursuant Test injection and reverse flow to (f)(4)(iv) frequency check valvas closure at refueling outages V44/V45 3.2.3.1 IWV-3521 Various safety Full stroke open Approved pursuant l
Test injection and reverse flow to (f)(4)(iv) frequency check valves closure at refueling outages V45/V46 3.7.1.2 IWV-3521 Service water Exercise at Approved pursuant Test check valves refueling outages to (f)(4)(iv) frequency 1-SW-Il4,-Il6 not to exceed
-120,-130,-140 24 months and -150 2-SW-68,-70
-74,-84,-94 and -104 V46/V47 3.10.1.1 IWV-3521 Condenser air Verify closed at Approved pursuant Test removal refueling outages to (f)(4)(iv) frequency containment isolation check valves
Page No.
6 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V47/V48 3.9.1.1 IWV-3521 Charging pump Partial stroke open Approved pursuant Test discharge checks and verify closure to (f)(4)(iv) 1 frequency 1-CH-254,-267 quarterly. Full
-279,2-CH-178 stroke
-193,and -208 exercise every refueling outage V49/V50 3.17.1.1 IWV-3522 Emergency diesel Verify valve NRC Approval not Test generator pump operability Required method discharge check during quarterly Non-Code valves valves,1-EG-254 pump testing
-266,-278,-295
-260,-272,-289
& -284 V50/V51 N/A IWV-3522 Containment Partial stroke NRC Approval not Test atmosphere exercise quarterly.
Required method cleanup check Perform sample Non-Code valves valves 1-HC-5 disassembly &
and 2-HC-7 inspection at refueling outages V52/V53 3.11.1.1 IWV-3521 Main steam to Exercise close at Approved pursuant Test Aux feed supply refueling outages to (f)(4)(iv) frequency check valves 1-MS-119,-122
-124,2-MS-117
-Il9,and -121 V53/V54 3.2.3.2 IWV-3521 Safety injection Partial stroke open Close Function GL 89-04 check valves quarterly, full Relief Granted Attach. I l-SI-4, -21 stroke GL 89-04 Item 2 2-SI-6,and -29 open at refueling Att.1 outages Pos.2 Reverse flow closure Open Function App.
disassembly and (f)(4)(iv) inspection V54/V55 3.1.1.1 IWV-3417(a)
Various valves Assign maximum Relief Granted Rapid stroke time GL 89-04 i
acting of 2 seconds Attach.1 1
valves Position 6
Page No.
7 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD 0F BY NUMBER
& SUBJECT TESTING USNRC V55/V56 3.12.1.1 IWV-3411 Emergency diesel Measure air bank NRC Approval not
-3413 generator air pressure drop and Required
& -3521 start solenoids diesel start times Non-Code valves Test and check frequency valves.
and stroke time V57/V58 3.4.2.1 IWV-3411 Reactor vessel Exercise at cold Relief Granted Test head and shutdown when RCS With Provisions frequency pressurizer is depressurized (f)(6)(i) vent valves V59/V59 3.1.2.1 IWV-3426 Various valves Assign maximum Approved pursuant Individual leakage rates to (f)(4)(iv) leakage to groups of rates valves V60/V61 N/A IWV-3427(b)
All valves None Relief Granted Corrective subject to GL 89-04 actions leakage tests Attach. 1-Position 10 V61/V62 N/A IWV-3521 Auxiliary Grouping Valves Relief Granted Test feedwater Performing GL 89-04 frequency check valves disassembly 1-FW-68,-100 and inspection Position 2
-132,2-FW-70
-102,and -134 V62/V63 3.3.1.2 IWV-3521 Component Verify reverse flow Approved pursuant Test cooling water closure at refueling to (f)(4)(iv) frequency check valves outages not to 1-CC-546,-559 exceed 24 months
-572, 2-00-276
-289,and -302 V63/V64 3.7.1.1 IWV-3521 Service water Partial stroke open Approved pursuant Test pump discharge quarterly. Full to (f)(4)(iv) j frequency checks 1(2)-SW-3 stroke open and 1(2)-SW-10 verify reverse flow 1-SW-22 closure at refueling and 2-SW-24 outages i
m
Page No.
8 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AN" SAFETY EVALUATION TABtE i
SUMMARY
OF G 1EF ktQUESTS RELIEF TER SECTION XI EQUIPMENT Al. TERNATE ACTION REQUEST SECTION REQUIREMENT IDLNTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V64/V65 3.6.2.1 IWV-3522 Instrument air Verify reverse flow NRC Approval not Test receiver closure in groups Required method isolation Non-Code valves check valves 1-IA-925,-926
-934,& -935 2-IA-396,-397
-405,and -406 V65/V66 3.3.2.1 IWV-3521 Component Verify reverse flow Approved pursuant Test cooling water closure at refueling to (f)(4)(iv) frequency check valves outages 1-CC-111,-146
-181, 2-CC-107
-144,and -181 V66/V67 3.1.3.1 IWV-3417(a)
All power Acceptance criteria Approved pursuant Corrective operated valves per ASME/ ANSI to (f)(4)(iv) actions OM part 10 V67/V68 3.8.1.1 IWV-3521 Outside Exercise at Approved pursuant Test recirculation refueling outages to (f)(4)(iv) frequency and quench spray check valves 1-RS-18,-27 2-RS-20,-30 1-05-11,-19 2-QS-II,-22 V70/V71 3.3.1.3 IWV-3521 Component Partial stroke open Opening:
Test cooling water quarterly, full Interim Relief frequency check valves stroke open when Authorized 1-CC-193 & -198 reactor vessel (a)(3)(ii) 2-CC-194 & -199 defueled, reverse Closing:
flow closure at Appvd.per refueling outages (f)(4)(iv)
V71/V72 3.13.1.1 IWV-3411 Control room air Exercise valves at NRC Approval not
& -3521 supply trip refueling outages Required Test and check valves Non-Code valves frequency 1(2)-CA-26 1-HV-TV-1306A
&-1306B 2-HV-TV-2306A
&-2306
Page No.
9 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V69/V70 3.1.2.2 IWV-3427(a)
All containment In addition to Alternative Corrective isolation valves repair or Authorized with action replacement, an Provisions engineering (a)(3)(ii) evaluation may be performed.
P-2 Withdrawn P-3 Withdrawn P-8 Withdrawn P-11 Withdrawn V-1 Withdrawn V-2 Withdrawn V-4 Withdrawn V-5 Withdrawn V-6 Withdrawn V-7 Withdrawn V-8 Withdrawn V-11 Withdrawn V-12 Withdrawn V-13 Withdrawn V-15 Withdrawn V-17 Withdrawn V-18 Withdrawn V-19 Withdrawn
Page No.
10 04/14/93 NORTH ANNA POWER STATION, UNITS 1 AND 2 SAFETY EVALUATION TABLE 1
SUMMARY
OF RELIEF REQUESTS RELIEF TER SECTION XI EQUIPMENT ALTERNATE ACTION REQUEST SECTION REQUIREMENT IDENTIFICATION METHOD OF BY NUMBER
& SUBJECT TESTING USNRC V-22 Withdrawn V-23 Withdrawn V-24 Withdrawn V-25 Withdrawn V-26 Withdrawn V-29 Withdrawn V-30 Withdrawn V-31 Withdrawn V-32 Withdrawn V-34 Withdrawn V-35 Withdrawn (Unit 1)
V-36/V-36 Withdrawn V48/V49 Withdrawn V51/V52 Withdrawn V56/V57 Withdrawn V58/V60 Withdrawn V68/V69 Withdrawn V72/V73 N/A IWV-3520 Non-return main Continue to use the Interim relief Tests for steam line stop motor operator to authorized Check Valves check valves drive the disc (a)(3)(1) closed until NRC SE dated nonintrusive methods 12/4/92 are developed
.-