Text

Inservice Testing Program Plan for North Anna Unit 1
	ML20058C115
Person / Time
Site:	North Anna
Issue date:	10/17/1990
From:	; VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	;
Shared Package
ML20058C114	List: ML20058C112; ML20058C115;
References
	PROC-901017, NUDOCS 9010310276
	Download: ML20058C115 (38)
	v • d • e

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t New Revised Pages to the ASME Section XI Inservice Testing Program Plan for North Anna Unit 1 n

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9010310276 901017 PDR ADOCK 05000338 l

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4 2.2.5 PUMP INSERVICE TEST TABLE The Pump Inservice Test Table identifies the pumps to be tested in accordance with ASME Section XI.

The following information is provided for each pump; ASME Code Class, test quantities to be measured, test frequency, and relief requests if required.

The following is a brief explanation of the abbreviations used in the Pump Inservice Test Table.

NC

- Non-class Var.

- Variable Resistance System Fixed - Fixed Resistance System Q

- Quarterly Test Frequency CS

- Cold Shutdown Test Frequency (not more frequently than quarterly)

RR

- Reactor Refueling (18 months) 2Y

- 24 Months N/A

- Not applicable or impractical, relief requests-will explain in detail Under Speed, N/A applies to constant speed pumps which do not require the measurement of speed.

Therefore, no relief is necessary.

Under-Lube 011, N/A applies to pumps that have a lubrication system with no level.or pressure indication.

Therefore, no relief 1

is necessary.

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NPV-002al 2-9 Rev.-6 September 28, 1990

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RELIEF REQUEST P-2 Relief Request Withdrawn

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NPV-002b 2-17 Rev. 6 September 28, 1990

RELIEF REQUEST P-4 i

I.

IDENTIFICATION OF COMPONENTS System :

Emergency Diesel Generator Fuel Oil Pump (s):

1-EG-P-1HA 1-EG-P-1JA 1-EG-P-1HB 1-EG-P-1JB Class NC II. IMPRACTICAL CODE REQUIREMENTS Measure test quantities after the pump has been running Jif for five minutes.

III. BASIS FOR RELIEF The pump operating time is limited due to operational restraints.

While the diesels are running, these pumps start automatically when the fuel oil level in the day tank reaches the low level switch, and stop when the level reaches the high level switch.

The pump run time can vary depending upon the diesel load and the

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resulting fuel consumption rate.

If the pumps are allowed to run for five minutes prior to measuring the test quantities and the fuel consumption rate is low,

-3 not enough time is available to gather all of the required Section XI test data.

IV. ALTERNATE TESTING The measurement of Section XI quantities will begin when-

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the pump automatically starts on a low day tank level signal.

i I

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-NPV-002b 2-19 Rev. 6 September 28, 1990'

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RELIEF REQUEST P-6 I.

IDENTIFICATION OF COMPONENTS System :

Recirculation Spray Pump (s):

1-RS-P-1A 1-RS-P-1B Class 2

II. IMPRACTICAL CODE REQUIREMENTS Frequency of pump testing.

Measure inlet pressure and differential pressure.

III. BASIS FOR RELIEF Flow testing of these pumps requires containment entry, the connection of a temporary recirculation line and the erection of a temporary dike to contain recirculated water.

Approximately five to six days are needed to set up, perform the test, 1

and return the system to its normal configuration.

i Testing on a cold shutdown frequency would not allow enough time to plan for and perform a five to six day flow test.

Because these pumps are designed to take suction from a sump, measurement of inlet pressure is not practical.

Because of.the limitations in the test dike design, and the requirements for NPSH, the sump level cannot vary more than one foot during testing.

Therefore, inlet pressure can be calculated from sump level.

IV.-ALTERNATE TESTING

'These pumps will be run dry every quarter to verify-operability.

Each pump is equipped with a sensor to detect pump rotation.

Motor current.will be recorded for each pump test.

A flow test which includes vibration measurement will be performed every reactor refueling.

Differential pressure will be determined from the measured discharged pressure and the calculated inlet pressure.

NPV-002b 2-21 Rev. 6 September 28, 1990

RELIEF REQUEST P-7 l

I.

IDENTIFICATION OF COMPONENTS

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System :

Recirculation Spray Pump (s):

1-RS-P-2A 1-RS-P-2B Class 2

1 II. IMPRACTICAL CODE REQUIREMENTS

1. An inservice test shall be run on each pump nominally every 3 months during normal plant operation.

2. Each pump shall be run at least five minutes under conditions as stable as the system permits prior to measuring the test quantities.

3. Measure inlet pressure and differential pressure.

4 III. BASIS FOR RELIEF

1. The outside recirculation pumps take suction from the containment sump and discharge to the containment spray arrays.

To test these deep drelt-pumps, the pump pit and the recirculation test loop must be filled with primary grade water and vented.

The filling and venting process takes approximately 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

After the test is completed, the pump pit and recirculation piping must be carefully drained to avoid flooding the quench sptay basement.

Testing is the only source of operational based degradation for the pumps.

'They are also maintained dry and therefore are not subject to normal corrosion or 'ouling.

Considering the hardship of testing these pumps described above, the' exposure to degradation caused by frequent L

testing and the dry state in which the pumps are maintained, there is no compensating' increase in safety achieved by testing these pumps every three months.

NPV-002b-2-22 Rev. 6 September 28, 1990

RELIEF REQUEST P-7 (Cont.)

This position,is kJpported by ANSI /ASME OM (Part 6), An A.verican Standard In-Service Testing of Pumps, Paragraph 5.5, which states, " Pumps lacking re dry sumps) quired fluid inventory, (e.g.,

pumps in need not be tested in accordance with thin Part every 3 months.

These pumps shall be tested at least once every 2 years except as provided in para.

5.4.

The required fluid inventory shall be provided during this test."

Paragraph 5.4 discribes the testing frequency of pumps in systems which are declared inoperable or not required for service.

2. The test loop for these pumps contains a small volume of water.

A four inch test recirculation line branches off the ten inch pump discharge line a short distance from the pump.

The recirculation line discharges into the pump pit which is a cylinder aLproximately 50 feet deep and two feet in diameter.

Because of the small volume in the test loop, the hydraulic parameters stabilize quickly.

Therefore, a five minute stabilization period is not necessary to achieve repeatable test results.

In addition, if the pump is run for too long of a period, the water will heatup due to the limited water volume.

This heatup can lead to excessive pressures in the test loop.

3. Suitable suction pressure instrumentation is not installed.

The recirculation path will be filled with water to establish initial conditions for testing.

Therefore, inlet pressure can be calculated from the initial water level in the test loop.

IV. ALTERNATE TESTING These pumps will be flow tested on their recirculation paths at least once every two years.

After a two minute stabilization period, inlet pressure, differential pressure as determined from the calculated inlet pressure and measured discharge pressure, flow rate and vibration measurements will be taken.

NPV-002b 2-22a Rev. 6 September 28, 1990

RELIEF REQUEST P-15 I.

IDENTIFICATION OF COMPONENTS System :

Boric Acid Transfer Pump (s):

1-CH-P-2A 1-CH-P-2B Class 3

II. IMPRACTICAL CODE REQUIREMENTS Frequency of pump testing.

III. BASIS FOR RELIEF Permanent flow instrumentation is not installed on the recirculation piping, which is the only test loop e.vailable for quarterly testing.

To measure flow, flow must be established to the emergency and alternate boration paths and then to the charging pump suctions.

This flow would increase the reactor coolant system (RCS) boron inventory and cause a reactivity transient during normal operation.

During cold shutdown, the emerger.

and alternate boration path valves are tested wien flow.

However, this test is short in duration to minimize the amount of boric acid injected into the RCS.

The pump-test requires an extended period of boric acid injection, which would upset the RCS boron balance and possibly impact the ability of the plant to restart.

Therefore, this test should only be performed during cold shutdowns on the way to reactor refueling while the RCS is being borated or during reactor refuelings.

During RCS boration or during reactor refuelings, extended periods of pump operation on high speed can either interfere with the boration process or adversely affect the boron balance in the RCS.

Therefore, to limit the amount of boric acid injected into the RCS during the pump tests, the pumps will be run for more than three minutes on the recirculation flow path, and then only two minutes with flow to the RCS before the test quantities are measured.

NPV-002b 2-33a Rev. 6 September 28, 1990

RELIEF REQUEST P-15 (Cont.)

IV. ALTERNATE TESTING These pumps will be tested every quarter on the recirculation loop, and inlet pressure, differential pressure and vibration will be measured.

Every reactor refueling, inlet pressure, differential pressure, flow and vibration will be measured after the pumps have been run for three minutes on the recirculation flow path, and then for two minutes with flow to the RCS.

Note: The alternate testing complies with Generic Letter 89-04, Attachment 1, Position 9, except for the duration of the run period prior to measuring the test quantities.

l I

NPV-002b 2-33b Rev. 6 September 28, 1990

1 RELIEF REQUEST V-42 I.

IDENTIFICATION OF COMPONENTS System Safety Injection valve (s):

1-SI-125 1-SI-144 1-SI-127 1-SI-159 1-SI-142 1-SI-161 Class 1

II. IMPRACTICAL CODE REQUIREMENTS Exercise valves for operability every three months III. BASIS FOR RELIEF These valves cannot be partial or full flow tested during normal operation because the accumulator pressure (600 to 650 psig) is below Reactor Coolant System pressure and the injection of borated water would upset the reactor coolant chemistry.

During cold shutdown, the RCS pressure may still prevent full flow testing.

Also, discharging the accumulators would challenge the Low Temperature overpressure Protection System.

To veri;y valve closure using back flow for Valves 1 -S I 1.'4 5, 142 and 159, a containment entry must be made to manually manipulate the test configuration.

The accumulators must be isolated to verify closure using back flow for all six valves.

The small increase in safety gained by perf'>rming the back seat check valve tests every cold shutdown versus every reactor refueling does not justify the added burden of the increased test frequency.

IV. ALTERNATE TESTING These valves were placed into two groups.

Valves 1-SI-144, 161 are in one group and Valves 1-SI-125, 127, 142 and 159 are in the other group.

Because 1-SI-144 and 161 are downstream from RHR, they experience different service conditions than the other valves.

To verify that these valves will stroke to the open position, one valve from each group will be disassembled and inspected every other refueling outage.

Inspecting one valve every NPV-002d 2-66 Rev. 6 September 28, 1990

RELIEF REQUEST F-42 (Cont.)

other refueling outage is a deviation from the frequency of inspection described in Generic Letter 89-04, Position 2.

Justification for going to an extended inspection interval is provided below.

All six SI accumulator check valves in each unit were inspected after 8 years of service and were observed to be in "like new condition."

However, an inspection report was generated for only one of the six valves from each unit.

During the following outage for Unit 2 (1990 outage), the one documented valve from the previous outage was disassembled and inspected, along with one valve from the other group.

Both valves were found to be in "like new condition."

Because no degradation j

was detected, it can be concluded that the valves l

in each group for Units 1 and 2 are in good condition and that an extended interval is justified for both Units 1 and 2.

The "like new condition" of these valves is expected because during normal operation they remain closed and are subject to low flow conditions only during reactor refueling when a partial flow test is performed and when RHR is operating.

Given the lack of degradation observed in the SI accumulator discharge check valves, disassembling these valves presents a hardship with no compensating increase in safety.

The average dose received during the disassembly and inspection for the check valves farthest from the accumulator (Valves 1-SI-127, 144 and 161) was from 1500 to 2000 mrem per valve, and the average dose for the check valves nearest to the accumulator (valves 1-p SI-125, 142 and 159),was approximately 400 mrem per valve.

To open the valves, the vessel inventory l

must be reduced which can significantly increase the dose rate for areas near the vessel and increase the probability and consequences of a loss of decay heat removal.

Generic Letter 88-17 addlesses the problems associated with loss of decay heat removal.

Because of the increased dose rate, most work in the vessel area must be delayed j

until the vessel is refilled.

1 NPV-002d 2-67 Rev. 6 September 28, 1990

s RELIEF REQUEST V-42 (Cont.)

The use of nonintrusive monitoring techniques may still be evaluated.

If the evaluation is performed and if it shows that the full stroke of the check valve can be verified and documented, one SI accumulator discharge line will be flow tested every reactor refueling.

During every reactor refueling, a different line will be tested.

If the flow test is successful, these valves will not be subject to disassembly.

These valves will be individually confirmed closed by back seat testing every reactor refueling.

Note:

The basis for relief and alternate testing for confirmation of valve closure was revised after April 3, 1989.

The alternate testing to the open position was revised for Revision 6.

The alternat.ive of disassembly conforms to Generic Letter 89-04, Position 2 except for frequency.

The alternate testing for valve closure only deals with test frequency which is not specifically addressed in the NRC Generic Letter 89-04, Attachment 1.

NPV-002d 2-67a Rev. 6 L

september 28, 1990 L

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RELIEF REQUEST V-55 I.

IDENTIFICATION OF COMPONENTS System t

Emergency Diesel Air Services Valve (s):

1-EG-SOV-600HA 1-EG-SOV-600JA 1-EB-15 1-EG-SOV-601RA 1-EG-SOV-607JA 1-EB-34 1-EG-SOV-600HB 1-EG-SOV-600JB 1-EB-65 1-EB-84 Class NC II. IMPRACTICAL CODE REQUIREMENTS Section XI, IWV-3410 " Valve Exercising Test" III. BASIS FOR RELIEF l

The solenoid valves have actuation times considerably under a second and there is no visual reference on the solenoid valve to determine when it has stroked.

Therefore, the stroke time cannot be measured.

The solenoid vhlves are activated every month to start the die sels.

Both air banks are discharged when performing the monthly test.

After the test, the air bank pressure is recorded to verify a decrease in prensure, which confirms that the air banks dischargad properly.

Flow through check valves 1-EB-15, 34, 65 and 84 cannot be measured because instrumentation is not installed.

However, failure of these valves to full open promptly will affect the starting time of the diesel when the diesel is started from just one air bank.

A diesel alarm will activate if the starting time exceeds start failure requirements.

Verification that the diesel starts without an alarm constitutes a full stroke test for the check valves.

The test to start the diesels on one air bank is performed on a rotating basis once every six months.

Based on this rotation, each check valve will be full flow tested once every 18 months.

l l

1 NPV-002d 2-83 Rev. 6 September 28, 1990

RELIEF REQUEST V-55 (Cont.)

IV. ALTERNATE TESTING The solenoid valve will be full stroke exercised and check valves will be partial stroke exercised monthly by observing that the valves perform their intended function (if the diesel starts and the air bank pressures decrease, then the solenoid and check valves were stroked successfully).

Every 18 months, the check valves will be full stroke tested by discharging only one air bank to start the diesel.

The failure of either the solenoid or check valves to stroke properly will promptly give a diesel alarm.

Further investigation would identify problems with the operability of these valves.

The diesel start time will be recorded and compared to a maximum allowable start time during this test.

Note:

The basis for relief and alternate testing in this Relief Request was revised af ter April 3,

1989.

The acceptance criterion used for the alternate testing does not conform to NRC Generic Letter 89-04.

3 l

NPV-002d 2-84 Rev. 6 I

September 28, 1990

RELIEF REQUEST V-64

1. IDENTIFICATION OF COMPONENTS System Instrument Air valve (s):

1-IA-925 1-IA-926 1-IA-934 1-IA-935 Class NC II. IMPRACTICAL CODE REQUIREMENTS Exercise valves every three months.

III. BASIS FOR RELIEF To back seat these valves with flow to verify valve closure would require venting the lines upstream of the valves.

The 1-IA-925 and 926 valves are in series with no vent valves in between, as are 1-IA-934 and 935.

Therefore, there is no way to individually back seat these valves.

IV. ALTERNATE TESTING These valves will be back seat tested in groups.

The test volume will be pressurized upstream of the two valves in series and vented downstream of the valves.

If the group fails the back seat test, both valves in the group will be disassembled, inspected and repaired as necessary.

Note:

This Relief Request was not docketed before April 3, 1989.

The alternate testing l

presented in this Relief Request does not l

conform to NRC Generic Letter 89-04.

l NPV-002d 2-94 Rev. 6 September 28, 1990 1

RELIEF REQUEST V-67 I.

IDENTIFICATION OF COMPONENTS System Recirculation Spray Valve (s):

1-RS-18 1-QS-11 1-RS-27 1-QS-19 Class 2

II. IMPRACTICAL CODE REQUIREMENTS Exercise valves every three months.

III. BASIS FOR RELIEF These valves must seat to maintain containment integrity and open to allow flow to the containment spray headers.

Partial or full flow testing these valves would flow water to the spray arrays and saturate containment.

These valves can be mechanically exercised to the open and closed positions.

However, the valves are located inside containment and require the construction of scaffolding before they can be exercised.

The small increase in safety gained by exercising the valves during cold shutdown does not justify the burden of constructing the scaffolding.

These valves are l

containment isolation valves and are leak tested every l

reactor refueling.

l IV. ALTERNATE TESTING L

l These valves will be exercised to the open and closed positions every reactor refueling.

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l Note:

This Relief Request was not docketed before April 3,

1989.

The position in this Relief Request conforms to Section XI, IWV-3520, except for test f requency.

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1 I

NPV-002d 2-97 Rev. 6 September 28, 1990

s RELIEF REQUEST V-69 Relief Request Withdrawn 1

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l NPV-002d 2-99 Rev. 6 September 28, 1990 i

.. ~. _.

l New Revised Pages to the ASME Section XI Inservice Testing Program Flan for North Anna Unit 2 l

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l Virginia Electric and Power Company 1

2.2.5 PUMP INSERVICE TEST TABLE The Pump Inservice Test Table identifies the pumps to be tested in accordance with ASME Section XI.

The following information is provided for each pump; ASME Code Olass, test quantities to be measured, test frequency, and relief requests if required.

The following is a brief explanation of the abbreviations used in the Pump Inservice Test Table.

NC

- Non-class Var.

- Variable Resistance System Fixed - Fixed Resistance System Q

- Quarterly Test Frequency CS

- Cold Shutdown Test Frequency (not more frequently than quarterly)

RR

- Reactor Refueling (18 months) 2y

- 24 Months N/A

- Not applicable or impractical, relief requests will explain in detail Under Speed, N/A applies to constant speed pumps which do not require the measurement of speed.

Therefore, no relief is necessary.

Under Lube 011, N/A applies to pumps that have a lubrication system with no level or pressure indication.

Therefore, no relief is necessary.

N2-2AlR6 2-9 Rev. 6 September 28, 1990 i

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c RELIEP REQUEST P-2 Relief Request withdrawn i

1 N2-2BR6 2-17 Rev. 6 September 28, 1990

RELIEF REQUEST P-4 t

I.

IDENTIFICATION OF COMPONENTS System Emergency Diesel Generator Fuel Oil Pump (s):

2-EG-P-2HA 2-EG-P-2JA 2-EG-P-2HB 2-EG-P-2JB Class NC II. IMPRACTICAL CODE REQUIREMENTS Measure test quantities after the pump has been running for five minutes.

III. BASIS FOR RELIEF The pump operating time is limited due to operational restraints.

While the diesels are running, these pumps start automatically when the fuel oil level in the day tank reaches the low level switch, and stop when the level reaches.the high level switch.

The pump run time can vary depending upon the diesel load and the resulting fuel consumption rate.

If the pumps are allowed to run for five minutes prior to measuring the test quantities and the fuel consumption rate is low, not enough time is available to gather all of the required Section XI test data.

IV. ALTERNATE TESTING The measurement of Section XI quantities will begin when the pump automatically starts on a low day tank level signal.

N2-2BR6 2-19 Rev.

6.

September 28, 1990

M i

i RELIEF REQUEST P-6 I.

IDENTIFICATION OF COMPONENTS i

System :

Recirculation Spray Pump (s):

2-RS-P-1A 2-RS-P-1B Class 2

II. IMPRACTICAL CODE REQUIREMENTS Frequency of pump testing.

Measure inlet pressure and differential pressure.

III. BASIS FOR RELIEF Flow testing of these pumps requires containment entry, the connection of a temporary recirculation line and the erection of a temporary dike to contain recirculated water.

Approximately five to six days are needed to set up, perform the test, and return the system to its normal configuration.

Testing on a cold shutdown frequency would not allow enough time to plan for and perform a five to six day flow test.

Because these pumps are designed to take suction from a sunp, measurement of inlet pressure is not practical.

Because of the limitations in the test dike design, and the requirements for NPSH, the sump level cannot vary more than one foot during testing.

Therefore, inlet pressure can be calculated from sump level.

IV. ALTERNATE TESTING These pumps will be run dry every quarter to verify operability.

Each pump is equipped with a sensor to detect pump rotation.

Motor current will be recorded for each pump test.

A flow test which includes vibration measurement will be performed every reactor refueling.

Differential pressure will-be determined from the measured discharged l

pressure and the calculated inlet pressure.

N2-2BR6 2-21 Rev. 6 j

September 28, 1990

RELIEF REQUEST P-7 I.

IDENTIFICATION OF COMPONENTS I

System Recirculation Spray Pump (s):

2-RS-P-2A 2-RS-P-2B Class t

2 II. IMPRACTICAL CODE REQUIREMENTS

1. An inservice test shall be run on each pump nominally every 3 months during normal plant operation.

2. Each pump chall be run at least five minutes under conditions as stable as the system permits prior to measuring the test quantities.

3. Measure inlet pressure and differential pressure.

III. BASIS FOR RELIET

1. The outside recirculation pumps take suction from the containment sump and discharge to the containment spray arrays.

To test these deep draft pumps, the pump pit and the recirculation test loop must be filled with primary grade water and vented.

The filling and venting process takes approximately 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months .

After the test is completed, the pump pit and recirculation piping must be carefully drained to avoid flooding the quench sptay basement.

i Testing is the only source of operational based degradation for the pumps.

They are also maintained dry and therefore are not subject to normal corrosion or fouling.

Considering the I

hardship of testing these pumps described above, the exposure to degradation caused by frequent testing and the dry state in which the pumps are

. maintained, there is no compensating increase in safety achieved by testing these pumps every three months.

1 l

l N2-2BR6 2-22 Rev. 6 l

September 28, 1990

RELIEF REQUEST P-7 (Cont.)

This position is supported by ANSI /ASME OM (Part 6), An American Standard In-Service Testing of Pumps, Paragraph 5.5, which states, " Pumps lacking required fluid inventory, (e.g.,

pumps in dry sumps) need not be tested in accordance with this Part every 3 months.

These pumps shall be tested at least once every 2 years except as provided in para.

5.4.

The required fluid inventory shall be provided during this test."

Paragraph 5.4 discribes the testing frequency of pumps in systems which are declared inoperable or not required for service.

2. The test loop for these pumps contains a small volume of water.

A four inch test recirculation line branches off the ten inch pump discharge line a' short distance from the pump.

The recirculation line discharges into the pump pit which is a cylinder approximately 50 feet deep and two feet in diameter.