ML20082E124
| ML20082E124 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/18/1983 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, John Miller Office of Nuclear Reactor Regulation |
| References | |
| 487C, NUDOCS 8311280053 | |
| Download: ML20082E124 (2) | |
Text
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VIRGINIA ELECTRIC AND power COMPANY Ricnwoxo,VrROINIA 20261 W.L.Srawaar Vars Psaminant November 18, 1983 wuct.
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Mr. Harold R. Denton, Director Serial No. 487C Office of Nuclear Reactor Regulation N0/JHL:acm Attn:
Mr. James R. Miller, Chief Docket Nos. 50-338 Operating Reactors Branch No. 3 50-339 Division of Licensing License Nos. NPF-4 U. S. Nuclear Regulatory Commission NPF-7 Washington, D. C. 20555 Centlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT NOS. 1 AND 2 STATUS OF INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES This letter is provided as a statement of the present status of the North Anna Power Station inservice testing program for pumps and valves as required by the ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWP and IWV.
The revised pump and valve testing programs were transmitted to you by way of letter dated October 5, 1983 (Serial No. 487B).
These revised programs were prepared due to discrepancies discovered by an engineering review of the then present programs. Discrepancies with the valve testing program were discussed in LER 83-022/03L-0, dated May 13, 1983.
.We have since transmitted an amendment to the above, LER 83-022/03L-1, in order to clarify our implementation date for the revised IWP and IWV testing programs.
Specifically, in the original issue of the LER it was stated the revised programs would be implemented by September 30, 1983.
However, during the preparation of the revised programs, it was determined that in order to have a smooth and orderly transition into the revised programs, it would be necessary to move the implementation date to March 1,
1984.
This revised implementation date was also stated in the letter transmitting the revised testing programs.
At present, and until March 1, 1984, our pump and valve testing programs will be in transition.
Until final implementation of the revised programs, the station IWP and IWV programs will be documented by Station Administrative Procedures.
It should be noted that the present pump and valve programs are not in strict compliance with the requirements of the 1974 Edition, Summer 1975 Addenda of ASME Code Section XI, Subsections IWP and IWV.
Relief has been requested for these deviations in the programs submitted in our Octotet 5,
1983 letter.
The requested relief from strict compliance of the Coda is required in part due to system design and/or configuration which does riot make it feasible or practical to test in strict compliance with the Code. As an example, many of our pumps do not have instrumentation installed to record inlet pressure.
8311280053 831118 QA9 PDR ADOCK 05000 0
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visoix:A Es.scranc Axo Powra COMPANY TO Harcld R. Denton In reference to valve testing, it is our understanding that it is not the intent of IWV to prevent unit return to power if cold shutdown valve testing (the testing of those valves that cannot be tested during power operation) is not complete.
Therefore, the cold shutdown valve testing philosophy at North Anna and as discussed in our IWV submittal is that valve testing will commence no later than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after reaching cold shutdown and continue until complete or until the unit is ready to return to power, whichever occurs first.
When plant conditions cannot accomodate a particular cold shutdown test (i.e.
maintaining containment vacuum, unable to secure a pump or unable to remove a system from service), this test will be performed during the next cold shutdown that permits access to the component or system.
Completion of all valve testing is not a prerequisite for plant start-up.
Any testing not completed at one cold shutdown should be performed during the subsequent scheduled cold shutdowns to meet the Code specified testing frequency.
In case of frequent cold shutdowns, valves will not be exercised more often than the frequency specified by the Code.
In applying this philosophy, those tests that require extensive work in containment ( i.e. draining lines to back seat check valves) are not initiated unless it is anticipated that the unit will be in cold shutdown for an extended period of time beyond the normal 10 - 14 day scheduled maintenance outage.
These tests, if not performed during other cold shutdowns, will be performed during but no greater than each refueling outage.
As stated previously, we will be working toward implementation of the revised IWP and IWV programs for North Anna Units 1 and 2 by March 1, 1984.
These revised programs will be based on the submittal of October 5, 1983 and will incorporate the relief requ1sts.
Very truly yours, n
a Ate W. L.
tewart I
cc:
Mr. James P. O'Reilly Regional Administrator Region II Mr. M. B. Shymlock NRC Resident Inspector North Anna Power Station l
Mr. C. k. Swope Quality Assurance North Anna Power Station 1
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