ML20114B507
| ML20114B507 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/24/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, John Miller Office of Nuclear Reactor Regulation |
| References | |
| 85-062, 85-62, NUDOCS 8501290255 | |
| Download: ML20114B507 (51) | |
Text
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VIHOINIA ELECTHIC AND l'OWER COMPANY RIcuxoxn,VIHOINTA 23261 W.L. STEWART Vacs Panasonst weet=== o,ma.non.
January 24, 1985 Mr. Harold R. Denton, Director Serial No.85-062 Office of Nuclear Reactor Regulation N0/LNH:acm Attn:
Mr. James R. Miller, Chief Docket Nos. 50-338 Operating Reactors Branch No. 3 License Nos. NPF-4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT NO. 1 INSERVICE TESTING OF PUMPS AND VALVES A meeting was held on November 29 and 30, 1984 with representatives of Vepco, NRR and EG&G Idaho, Inc. to discuss the North Anna Unit No. 1 Inservice Testing Program for Pumps and Valves.
As a result of this meeting there were four specific open items which required utility action.
The first item wcs to determine if the atmospheric dump valves should be included in the IWV Program.
These valves will be included in the IWV Program and will be tested during cold shutdown outages. A relief request is attached.
The second item was to determine a method and frequency to full-stroke exercise the casing ' cooling discharge check valves.
After reviewing the system configuration it has been determined that the only method for verifying freedom of movement of the valves is by disassembly. This will be done during refueling outages. A relief request for these valves is attached.
Item three was to determine a method and frequency for testing the accumulator discharge check valves.
Methods of testing these valves are currently under review. This item will be addressed at a later date.
The fourth item is to determine if the outside recirculation spray pumps can be tested quarterly. These pumps can be run quarterly using the recirculation path.
The IWP Program will be revised to reflect this change.
A relief request for these pumps is attached.
In addition to the specific open items identified, there were a number of other changes discussed during this meeting. Attached are proposed revisions to the IST Programs to reflect these discussions. Also attached are a list of valve maximum stroke times and a copy of earlier correspondence requested by Mr. Joel Page of NRR.
8501290255 850124 PDR ADOCK 05000338 P
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visoinsA Ex.actuse awn Powsm Courawy to Harold R. Denton The April 17, 1984 letter granting interim approval of the North Anna Units 1 and 2 Inservice Testing Program states that the utility should request an extension to this relief if the detailed review by NRR is not complete by December 31, 1984.
In our letter dated December 31, 1984 (Serial No. 258), we requested that you extend the interim relief, as provided for in your letter, until such time that the North Anna Inservice Testing Program for Pumps and Valves is. approved.
Vse y truly yours, k
s W. L. Stewart Enclosures cc:
Mr. James P.,O'Reilly Regional Administrator Region II Mr. M. W. Branch NRC Resident Inspector North Anna Power Station
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- e ITEM 1 RELIEF REQUEST FOR ATMOSPHERIC DUMP VALVE TESTING t
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d MS-Nots-06 IW RELIEF REQUEST System:
Main Steam Valve (s): PCV-MS-101A, B, C Relief Justification:
These valves are the atmospheric dump valves on the Main Steam header.
These valves'cannot be tested during power operation because it could cause excessive cooldown of the Steam Generator and possibly cause an overpower condition.
Alternate Testing: Full stroke exercise when returning to power after a cold shutdown outage (but not more frequently than every three months).
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ITEM 2 RELIEF REQUEST FOR CASING COOLING DISCHARGE CHECK VALVE TESTING w
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RS-Nots-02 IWV RELIEF REQUEST System:
Recirculation Spray Valve (s): 1-RS-123 1-RS-138 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
These check valves must open and close in order to perform their safety function. Due to system design, they are not in the Casing Cooling Pump test flowpath and can only be fully exercised by disassembly.
Valves 1-RS-123 and 1-RS-138 are located in the safeguards valve pit which is a limited access area.
Safety lanterns, harnesses, an air sample and a fresh air supply must be obtained before entering the valve pit.
The valves will be exercised only during refueling outages because the logistics of valve disassembly do not justify the small increase in safety gained by testing during cold shutdown.
Alternate Testing: Exercise for operability by disassembly each refueling.
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,a ITEM 3 ACCUMULATOR DISCHARGE CHECK VALVE TESTING
.i TO BE ADDRESSED AT A LATER DATE.
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ITEM 4 RELIEF REQUEST FOR RECIRCULATION SPRAY PUMP TESTING
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Pcg2 1 of 2, PUMP TESTING TABLE ASME System Inlet Differential Flow Lube Bearing Relief Pump Class Resistance Speed Pressure Pressure Rate Vibration Oil Temp Request 1-CC-P-1A.
3 Var.
N/A Q
Q Q
Q Q
A 1
1-CC-P-1B 3
. Var.
N/A Q
Q Q
Q Q
A 1
1-CH-P-1A 2
Fixed N/A N/A Q
N/A Q
Q A
1,2 1-CH-P-1B 2
Fixed N/A N/A Q
N/A Q
Q A
1,2 1-CH-P-lC 2
Fixed N/A N/A Q
N/A Q
Q A
1,2 1-CH-P-2A 3
Fixed.
N/A N/A CS CS N/A N/A N/A 3
1-CH-P-2B 3
Fixed N/A N/A CS CS N/A N/A N/A 3
1-EG-P-lHA Fixed N/A N/A N/A
.N/A Q
N/A N/A 4
1-EG-P-lHB Fixed N/A N/A N/A N/A Q
N/A N/A 4
1-EG-P-lJA Fixed
-N/A N/A N/A N/A Q
N/A N/A 4
1-EG-P-1JB Fixed N/A N/A N/A N/A Q
N/A N/A 4
1-FW-P-2 3
Fixed Q
Q Q.
Q Q
Q A
1 1-FW-P-3A 3
Fixed N/A Q
Q Q
Q Q
A 1
1-FW-P-3B 3
Fixed N/A Q
Q Q
Q Q
A 1
1-QS-P-1A 3
Fixed N/A
-Q Q
Q Q
Q A
1 1-QS-P-1B 3
Fixed N/A Q
Q Q
Q Q
A 1
1-RH-P-1A 2
Var.
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P;ga 2 of 2 PUMP TESTING TABLE ASME System Inlet Differential Flow Lube Bearing Relief Pump Class
-Resistance Speed Pressure Pressure Rate Vibration Oil Temp Request 1
1-RH-P-1B 2
Var.
1,5 1-RS-P-1A 2
N/A N/A N/A N/A N/A N/A N/A 6
1-RS-P-1B 2
N/A N/A N/A N/A N/A N/A N/A 6-1-RS-P-2A 2
Var.
N/A N/A N/A Q
Q N/A N/A 1,7 1-RS-P-2B 2
Var.
N/A N/A N/A Q
Q N/A N/A 1,7 1-RS-P-3A 3
Fixed N/A Q
Q Q
Q Q
A 1
1-RS-P-3B 3
Fixed N/A Q
Q Q
Q Q
A 1
1-SI-P-1A 2
Fixed N/A N/A Q
Q Q
N/A N/A 1,8 1-SI-P-1B 2
Fixed N/A N/A Q
Q Q
N/A N/A 1,8 1-SW-P-1A 3
Var.
N/A N/A N/A Q
Q N/A N/A 1,9 l-SW-P-1B 3
Var.
N/A N/A N/A Q
Q N/A N/A 1,9 l-SW-P-4 3.
Var.
N/A N/A N/A Q
Q N/A N/A 1,10 e Sperd is measured for variable speed pumps.
1-FW-P-2 is the only variable speed pump in this program.
1 See IWP Relief Request #5.
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IST PROGRAM REVISIONS i-r
e RELIEF REQUEST #3 PUMPS 1-CH-P-2A 1-CH-P-2B SECTION XI REQUIREMENTS FOR WHICH RELIEF IS REQUESTED 1.
Quarterly pump testing.
2.
Measure inlet pressure.
3.
Measure vibrations, lube oil level or pressure and bearing temperature.
BASIS FOR RELIEF REQUEST 1.
These pumps are used during normal operation to recirculate the boric acid storage tanks and to makeup to the Chemical and Volume Control System. Flow indication is available when the pumps are used for makeup, however this flow is limited to 10 gpm.' The only other indication available is discharge pressure. Inlet pressure can be calculated. Full flow indication is available when the pumps are flowing to the emergency boration path. This can only be done during cold shutdowns because the introduction of concentrated boric acid to the Reactor Coolant System would cause system transients.
2.
Inlet pressure instrumentation is not installed.
3.
These pumps are totally encased in insulation which makes vibration, lube oil level or pressure and bearing temperatures impossible to measure or observe.
ALTERNATE TESTING 1.
Test while going to cold shutdown by flowing through the emergency boration path.
.This will allow for flow measurement in addition to calculating differential pressure.
2.
Inlet pressure will be calculated from Boric Acid storage tank level.
3.
NONE.
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J RELIEF REQUEST #4 PUMPS 1-FG-P-lHA 1-EG-P-lHB l-EG-P-lJA 1-EG-P-lJB SECTION XI RFQUIREMENTS FOR WHICH RELIEF IS REQUESTED
- 1. Measure inlet pressure and differential pressure.
- 2. Measure flow rate.
- 3. Measure lube oil level or pressure and bearing temperatures.
BASIS FOR RELIEF REQUEST
- 1. Inlet pressure instrumentation is not installed.
- 2. Flow instrumentation is not installed.
- 3. These. pumps cannot be run long enough to take accurate data without overflowing the Emergency Diesel Generator Fuel Oil Day Tanks.
ALTERNATE TESTING
- 1. These pumps take suction from the Fuel Oil Storage Tank. The level of this tank will be observed to establish initial conditions for testing. Discharge pressure will be obser~ed.
- 2. Operability of these pumps will be verified by their ability co fill the Emergency Diesel Generator Fuel Oil Day Tanks with an Emergency Diesel Generator running.
3..NONE
o RELIEF REQUEST #5 PUMPS 1-RH-P-1A 1-RH-P-1B SECTION XI REQUIREMENTS FOR WHICH RELIEF IS REQUESTED Quarterly pump testing.
BASIS FOR RELIEF REQUEST These pumps take suction from the Reactor Coolant System.
Because the Residual Heat Removal System is required to be isolated from the Reactor Coolant System during power operation, these pumps cannot be exercised during power operation.
ALTERNATE TESTING These pumps will be tested each cold shutdown.
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RELIEF REQUEST #6
' PUMPS'
'l-RS-P-1A
'l-RS-P-1B SECTION XI REQUIREMENTS FOR WHICH RELIEF IS REQUESTED
- 1. Measure inlet pressure, differential pressure, flow rate and vibrations.
- 2. Measure lube oil level or pressure and bearing temperatures.
BASIS FOR RELIEF REQUEST 1.
Full flow testing of these pumps would spray water inside the containment building.
Theso pumps were designed to be periodically run dry for a short period of time to verify operability.
2.
Proper lube oil level or pressure cannot be observed because pump bearings are in the main flow path.
IWP-4310 provides exemption from measuring bearing temper-atures for bearings in the main flow path.
ALTERNATE TESTING 1.
These pumps will be run dry to verify operability. Each pump is equipped with a sensor to detect pump rotation which alarms in the contrbl room. This alarm will be observed during each pump test. Motor current will-be' recorded for each pump test. Each pump is equipped with a vibration detector and a high vibration alarm in the control room set at 0.004 inches. This alarm will be observed during each pump test.
2.
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RELIEF REQUEST #7 PUMPS 1-RS-P-2A 1-RS-P-2B SECTION XI-REQUIREMENTS FOR WHICH RELIEF IS REQUESTED 1.
-Measure inlet pressure, differential pressure.
2.
Measure lube oil level or pressure and bearing temperatures.
' BASIS FOR' RELIEF REQUEST 1..
No inlet pressure instrumentation is installed.
2.
Proper lube oil level or pressure cannot be observed because pump bearings are in the main flow path.
IWP-4310 provides exemption from measuring bearing temperatures for bearings in the main flow path.
ALTERNATE TESTING 1.
Because these pumps are run on recirculation, inlet pressure can be considered constant. Discharge pressure is therefore directly related to pump performance.
Discharge pressure will be measured in place of differential pressure.
~ 2.
NONE.
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ALL-Nota-01 IWV RELIEF REQUEST System (s): All Relief Requested:
Exemption from 3 month Full / Partial Stroke Exercising Category E Valves Relief Justification:
All Category E valves are maintained locked or sealed in the required safety position in accordance with Station Administrative Procedures.
Because they are administratively controlled in the required position exercising to a non-safety position is not necessary.
Alternate Testing: NONE o
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CC-Nots-02 IWV RELIEF REQUEST System:
Component Cooling Valve (s):-TV-CC-101A, B TV-CC-102A, B, C, D, E, F TV-CC-104A, B, C Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
Failure of these valves in the closed position.would result in a loss of Component Cooling flow to Reactor Coolant Pump thermal barriers, lube oil stator and/or shroud coolers. The increased level of safety gained from exercising these valves during power operation does not justify the operational consequences should they fail in the closed position.
l Alternato Testing:
Exercise for operability during Cold Shutdown (but not more frequently than once per three months)..
-NOTE:
These valves will not be exercised during cold shutdown where any Reactor Coolant Pump is left in operation.
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m CC-Nots-03 IWV RELIEF REQUEST System:
-Qomponent Cooling
. Valve (s): 1-CC-84 1-CC-193 1-CC-546 1-CC-119 1-CC-198 1-CC-559 1-CC-154 1-CC-572 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
These check valves must seat upon reversal of flow in order to fulfill their safety functions. The only method to verify this actuation is to perform a leak rate /back pressure test. Since the valves are located inside containment and/or their systems are. required during power operation, they cannot be tested every three months.
1-CC-193 and CC-198 are in the Component Cooling lines to the Residual Heat Removal heat exchangers. These valves will be full stroked open each cold shutdown; however, closure cannot be verified since the Residual. Heat Removal system is needed_during cold shutdown to control the Reactor Coolant System temperature.
1-CC-546, 559, and 572 are check valves in the component Cooling lines to the cooling coils inside containment.
These lines can not be drained during short cold shutdowns because the cooling coils are needed to control containment' temperature. They will-be exercised only during refueling outages.
Alternate Testing: All check valves listed will-be exercised to the closed position ~each refueling outage. Check. valves 1-CC-193 and 1-CC-198 will be full stroked open each cold shutdown. All other valves listed (Component Cooling to Recirculation Air Cooling Coils) do not perform safety related opening functions.
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7-CC-Note-04 IWV RELIEF REQUEST System:
Component Cooling Valve (s): 1-CC-024 1-CC-047 Relief. Requested:
Exemption from 3 month Full Stroke Requirements Relief Justification:
Exercising these ch'ck valves to the full open position every three e
months would require major Component Cooling water throttling changes.
These transients are especially difficult during winter months when there are few heat rejection requirements. The logistics of rebalancing the Component Cooling System does not justify the small increase in safety gained by performing full rather than partial stroke tests every 3 months or cold shutdown.
Alternate Testing: All check. valves listed will be partially stroked open every three months and fully stroked open each refueling outage. These check valves will be verified closed each 3 months.
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e CV-Nots-01 IWV RELIEF REQUEST System: Containment Vacuum Valve (s): TV-CV-100 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
This containment isolation valve must remain closed during Modes 1, 2, 3 and 4 per Technical Specifications (T.S. 3.6.5.1).
Exercising during power operation would require entering the action statement of Technical Specifications. Exercising will be performed during shutdowns when containment vacuum is broken and use of the containment air ejector is required.
Alternate Testing: Exercise for operability during Cold Shutdown (but not more frequently than once per three months)
NOTE:
This valve will not be exercised during Cold Shutdowns where containment vacuum is maintained.
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IWV REIIEF REQUEST System:
Chemical & Volume Control System Valve (s): HCV-1200 A,B,C TV-1204 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
Varying letdown flow through the Regenerative Heat Exchanger will cause variations in charging flow temperatures. This is not desirable since changing charging temperatures could result in thermal shock to the system.
Exercising will be performed during cold shutdowns when thermal shock is not a considstation.
Alternate Testing: Exercise for operability during Cold Shutdown (but not more frequently than once per three months) k L
CVCS-Nots-03 IWV RELIEF REQUEST System:
Chemical & Volume Control System Valve (s): MOV-1289A, B Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements
- Relief Justification:
Exercising these valves during power operation would isolate the normal charging flow path from the charging pumps to the Reactor Coolant System. -The operational consequences of providing an alternate charging flow path during power operation do not justify the small increase in safety gained by exercising these valves every three months.
Alternate Testing: Exercise for operability during Cold Shutdown (but not more frequently than once per three months).
NOTE:
These valves will not be exercised during Cold Shutdowns where charging is maintained.
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CVCS-Nota-06 IWV RELIEF REQUEST System:
Chemical & Volume Control System Valve (s): MOV-1380 MOV-1381 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements
- Relief Justification:
Charging flow to the Reactor Coolant Pump seals is required at cil times the pumps are in operation. Failure of one of these valves in the closed-position could result in damage to a Reactor Coolant Pump seal, thus placing the plant in an unsafe condition. Reactor Coolant Pumps will be secured during shutdown testing.
Alternate Testing:
Exercise for operability during Cold Shutdown (but not more frequently than once per three months).
NOTE:
These valves will not be exercised during cold shutdowns where Reactor Coolant Pump seal injection is maintained.
r" CVCS-Note-11 IW RELIEF REQUEST System: Chemical and Volume Control System Valve (s): 1-CH-254 1-CH-279 1-CH-267 Relief Requested:
Exemption from 3 month Full Stroke Exercising Relief Justification:
These valves are partial-stroke exercised quarterly when the charging pump tests are performed.
They cannot be full-stroke exercised during poser operation because this would require full Safety Injection flow.
The full Safety Injection flow test cannot be performed during cold shutdown because there is insufficient volume in the Reactor Coolant System. These valves will be full-stroke exerci sed during refueling outage then the Reactor Coolant System can accommodate Safety Injection flow.
Alternate Testing: Fartial-stroke exercise quarterly.
Full-stroke exercise each refueling outage.
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CVCS-Nota-12 IWV RELIEF REQUEST System:
Chemical And Volume Control System Valve (s): HCV-1311 1-CH-328 Relief Requested:
Exemption from 3 month Full Stroke Exercising Relief Justification:
These valves are in the Auxiliary Spray Line to the pressurizer from the Charging System. These valves cannot be exercised during power operation because of the thermal shock to the auxiliary spray nozzle.
They cannot be tested during cold shutdown because a bubble is usually maintained in the pressurizer during cold shutdowns. These valves will be full stroke exercised during refueling outages.
Alternate Testing:
Full stroke exercise during refueling outages.
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CVCS-Nots-13 IWV RELIEF REQUEST System:
Chemical and Volume Control System Valve (s): 1-CH-084 1-CH-102
-Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
These check valves are located at the Boric Acid Transfer Pump discharge. There is no flow indication on the pump recirculation flow path; therefore, full flow through the check valve cannot be verified.
Flow instrumentation is available in the emergency boration path, but this cannot be used during power operation due to boron introduction to the Reactor Coolant System. These check valves will be exercised to the full open position each cold shutdown in conjunction with Boric Acid Transfer Pump testing.
Alternate Testing:
Exercised to the open position each cold shutdown (not to exceed 9 months).
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EG-Nott-01 IW RELIEF REQUEST System:
Emergency Diesel Generator (Air Start System)
Valves:
S0V-EG-600HA SOV-EG-600JA S0V-EG-600HB S0V-EG-600JB SOV-EG-60lH SOV-EG-60lJ Relief Requested:
' Exemption from stroke timing.
Relief Justification:
The Emergency Diesel Generator Air Start System solenoid valves cannot be stroke timed due to instrumentation limitations. As an alternate, the following will verify acceptable operation:
1.
Diesel will accelerate to at least 900 rpm in under 10 seconds.
2.
An established pressure drop in each air receiver for diesel start.
NOTE:
Since diesel testing is performed more frequently than required valve testing, this verification may not be performed each diesel start.
Alternate Testing:
Exercise for operability at least once every 3 months as stated above.
FW-Note-04 IWV RELIEF REQUEST System:
Feedwater Valve (s): 1-FW-068 1-FW-093 1-FF-100 1-FW-127 1-FW-132 1-FW-279 1-FW-148 1-FW-165 1-FW-183 Relief Requested:
Exemption frcm 3 month Full Stroke Requirements Relief Justification:
4 These check valves are in the Auxiliary Feedwater flowpath. During power operation, it is desirable to limit auxiliary feedwater flow to the: Steam Generators due to main feedwater flowrate and temperature Concerns.
Alternate Testing: Each check valve listed will be partially opened at 1,
least once every 3 months during Aux Feed Pump test-ing and fully opened following each cold shutdown in accordance with Technical Specification 4.7.1.2.c.
Valves 1-FW-068, 1-FW-100 and 1-FW-132 will be ls ?
verified closed based on pipe surface temperature at least once every three months. Valves 1-FW-093, 1-FW-127, 1-FW-279, 1-FW-148, 1-FW-165, and 1-FW-183 do not perform safety related closure functions.
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Main Steam Valve (s): 1-MS-286 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
This valve is normally in the open position and automatically closes on turbine overspeed.
Exercising during power operation would disable the
. Turbine Driven Auxiliary Feedwater pump which would require entering the action statement of Technical Specifications (T.S. 3.7.1.2) which is not desirable.
Alternate Testing:
Exercise for operability during Cold Shutdown (but not more frequently than once per three months)
MS-Nota-05 IWV RELIEF REQUEST System:
Main Steam Valve (s):
1-MS-19 1-MS-96 1-MS-58 Relief Requested:
Exemption from 3 month Full Stroke Exercising Relief. Justification:
These valves are located on the top floor of the Main Steam Valve House.
The valves are exercised using a manual handwheel. Because of the valve location there is a personnel hazard involved in manually exercising these valves during power operation.
Alternate Testing: Full-stroke exercise each cold shutdown.
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QS-Note-01 IWV RELIEF REQUEST System:
Quench Spray Valve (s): 1-QS-11 1-QS-19 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
These check valves must seat upon reversal of flow and open to pe.rform their safety function. These weight loaded check valves are located inside containmeat and are therefore not accessible for exercising during power operation. These valves will be exercised to the open and closed position manually during cold shutdown but not more frequently than once per nine months.
Alternate Testing: These valves will be manually exercised during cold shutdown (but not more frequently than once per nine months)*.
- Weight loaded check valve setpoint check will be performed every 18 months in accordance with Technical Specifications (T.S. 4.6.3.2.2c).
NOTE:
These valves will not be exercised during cold shutdowns where containment vacuum is maintained. This is necessary to minimize personnel hazards association with subatmospheric containment entries.
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RC-Nots-01 IWV RELIEF REQUEST System:
Reactor Coolant Valve (s): PORV-1455C PORV-1456 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
Exercising these valves during power operation would cause high differential pressure across the PORV Block Valves. Although these valves are designed to accommodate this differential pressure, cycling would eventually degrade the block valves seating capability thus decreasing plant safety. These valves will be exercised during shutdowns when the Reactor Coolant System is depressurized.
Alternate Testing: Exercise for operability during Cold Shutdown (but not more frequently than once per three months).
NOTE:
These valves will not be exercised during cold shutdowns where a pressurizer bubble is maintained.
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RS-Nots-01 IWV RELIEF REQUEST System:
Recirculation Spray Valve (s): 1-RS-18 1-RS-27 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
These check valves must seat upon reversal of flow and open to perform their safety function. These weight loaded check valves are located inside containment and are therefore not accessible for exercising during power operation. These valves will be exercised manually to the open and closed position during cold shutdown but not more frequently than once per 9 months.
Alternate Testing: These valves will be manually exercised during cold shutdown (but not more frequently than once per nine months)*.
- Weight loaded check valve setpoint check will be performed every 18 months in accordance with Technical Specifications (T.S. 4.
3.1.2d).
NOTE:
These valves will not be exercised during cold shutdowns where containment vacuum is maintained. This is necessary to minimize personnel hazards associated with subatmospheric containment entries.
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System:
Safety Injection Valve (s): HCV-1936
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Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
This valve is normally closed during power operation in fulfillment of its containment isolation function and is rarely opened. This valve has no remote position indication which makes it difficult to verify that the valve returns to the closed position.
This valve will be exercised during cold shutdown except when containment vacuum is maintained during i
the cold shutdown outage.
Alternate Testing: Exercise for operability during Cold Shutdown (but not more frequently than once per three months)
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SI-Nots-06 s
IWV RELIEF REQUEST
- System: Safety Injection Valve (s): 1-SI-9 1-SI-26 Relief Requested:
Exemption-from 3 month Full / Partial Stroke Requirements a
Relief Justification:
1 1-SI-9 and 1-SI-26 are the Low Head Safety Injection Pump discharge check valves. Due.to system design, these discharge check valves are not in the Low Head Safety Injection Pump test flowpaths. They cannot be tested during power operation because the LHSI pumps cannot overcome Reactor Coolant System pressure. These valves cannot be exercised during cold shutdown because this could create an overpressure condition in the Reactor Coolant System. These valves will.be full stroke exercised during refueling outages when the Low Head Safety Injection
- Pumps are used to fill the reactor cavity.
Alternate Testing: Full stroke exercise during refueling outages.
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SI-Nots-07 IWV RELIEF REQUEST System:
Safety Injection Valve (s): 1-SI-47 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
This is the Refueling Water Storage Tank supply check valve to the charging header.
Exercising this valve during power operation would reqcire charging pump suction be aligned with the Refueling Water Storage Tank. This alignment would cause a sudden increase in Reactor Coolant System boron inventory. A full Safety Injection flow path is not available except during refueling outages when the vessel head is removed. This valve can be partial stroke exercised during cold shut-down by running one charging pump taking suction from the Refueling Water Storage Tan'*.
Alternate Testing: Partial stroke exercise for operability during Cold Shutdown (but not more frequently than'once per three months). Full stroke exercise each refueling.
rm; SI-Noto-09 IWV RELIEF REQUEST I
System:
System Injection Valves (s):
1-SI-83 1-SI-195 1-SI-86 1-SI-197 1-SI-89 1-SI-199 Relief Requested: Exemption from 3 month Full / Partial Stroke
-Requirements Relief Justification:
These-Safety Injection check valves must open and close to fulfill their safety function. They cannot be exercised to the oper, position during power operation because this would cause Safety Injection flow into the Reactor Coolant System which would disrupt normal plant operation.
These valves cannot be exercised to the closed position during power operation because they are inside containment. These valves cannot be exercised open during cold shutdown because this could create an over-pressure condition in the Reactor Coolant System.
Full Safety Injection tests are performed at refueling outages when there is sufficient volume in the Reactor Coolant System to accomodate Safety Injection flow rates.
Alternate Testing: Full stroke. exercise open during refueling outages.
Closed testing performed in accordance with T.S.
4.4.6.2.2 which identifies these valves as high/ low pressure boundary valves to be leak tested during cold shutdown (but not more frequently than once per 9 months).
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SI-Noto-11 IWV RELIEF REQUEST System:
Safety Injection Valves (s):
1-SI-79 1-SI-185 1-SI-211 1-S1-90 1-SI-201 1-SI-213 1-SI-95 1-51-206 1-SI-99 1-SI-207 1-SI-103 1-31-209 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
These are Safety Injection hot and cold leg injection check valves. They cannot be exercised during power operation because this would cause Safety Injection flow into the Reactor Coolant System which would disrupt normal plant operation. These valves cannot be tested during cold shutdown because of insufficient volume in the Reactor Coolant System and therefore will be exercised to the open position during refueling outages when there is sufficient volume in the Reactor Coolant System to accommodate Safety Injection flow rates.
Alternate Testing:
Exercise during refueling outages.
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SI-Nots-12 IW RELIEF REQUEST System:
Safety Injection Valve (s): 1-SI-190 1-SI-192 1-SI-194 Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
These Safety Injection check valves must be open to fulfill their safety function. They can not be exercised to the open position during power operation because this would cause Safety Injection flow to the Reactor Coolant System which would disrupt normal plant operation. These valves will be exercised during refueling outages when there is sufficient volume in the Reactor Coolant System to accommodate Safety Injection flow rates.
Alternate Testing:
Exercise to the open position during refueling outages.
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SI-Nats-13 IWV RELIEF REQUEST System:
Safety Injection Valve (s): 1-SI-018 Relief Requested:
Exemption from 3 month Full Stroke Requirements Relief Justification:
The Refueling Water Storage Tank supply to the "B" Low Head Safety Injection pump is only fully opened on Safety Injection flow. The quarterly pump test is performed on recirculation flow rather than full Safety Injection flow since the Low Head Pumps cannot overcome Reactor Coolant System pressure during power operation.
Full Safety Injection tests are performed at refueling outages when there is sufficient volume in the Reactor Coolant System to accommodate Safety Injection flow rates.
Alternate Testing: Check valve 1-SI-018 will be partially stroked open each 3 months and fully stroked open each refueling outage.
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SI-N:ts-14 IWV RELIEF REQUEST System:
Safety Injection Valve (s): MOV-1867C, D Relief Requested:
Exemption from 3 month Full / Partial Stroke Requirements Relief Justification:
These are the Boron Injection Tank outlet valves to the Reactor Coolant System cold leg. Exercising these valves introduces concentrated boric acid into the injection line which is not heat traced down stream of the first check valve in containment. This requires the injection line to be flushed to remove the boric acid. This cannot be done during power operation because it would require boron injection to the Reactor Coolant System.
Alternate Testing:
Exercise during cold shutdown (but not more often than every 3 months).
SW-Nsta-02 IWV RELIEF REQUEST System:
Service Water Valve (s): 1-SW-003 1-SW-010 1-SW-022 1-SW-309 1-SW-311 Relief Requested:
Exemption from 3 month Full Stroke Requirements Relief Justification:
1 Exercising these check valves to the full open position every three months would require major Service Water and Component Cooling Water throttling changes. These transients are especially difficult during winter months when there are few heat rejection requirements. The logistics of rebalancing these systems do not justify the small increase in safety gained by performing full rather than partial stroke tests every 3 months or cold shutdown.
Alternate Testing: All check valves listed will be partially stroked open every three months and fully stroked open each refueling outage check valves 1-SW-003, 1-SW-010, and 1-SW-022 will be verified closed each 3 months.
Valves 1-SW-309 and 1-SW-311 do not perform safety related closure functions.
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VALVE MAXIMUM STROKE TIMES
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MAXIMUM VALVE MARK NUMBER STROKE TIME FCV-AS-100 A, B 60 seconds FCV-AS-200 A, B TV-BD-100 A-F 60 seconds TV-BD-200 A-F MOV-CC-100 A, B 40 seconds
-M0V-CC-200 A B TV-CC-100 A-C 60 seconds TV-CC-200 A-C TV-CC-101 A, B 60 seconds TV-CC-202 A, B TV-CC-102 A-F 60 seconds TV-CC-202 A-F TV-CC-103 A B 60 seconds TV-CC-203 A, B TV-CC-104 A, B, C 60 seconds TV-CC-204 A B, C TV-CC-105 A, B, C 60 seconds TV-CC-205 A, B, C HCV-1200 A, B, C 10 seconds HCV-1200 A, B, C MOV-1115 B, C, D, E 10 seconds MOV-2115 B, C, D, E MOV-1267 A, B 12 seconds M0V-2267 A B MOV-1269 A, B MOV-2269 A, B MOV-1270 A, B MOV-2270 A B HOV-1275 A, B, C 12 seconds MOV-2275 A, B, C MOV-1286 A B, C 12 seconds MOV-2286 A B, C MOV-1287 A, B C MOV-2287 A, B, C MOV-1289 A, B 10 seconds HOV-2289 A, B MOV-1350 20 seconds i
MOV-2350
r-o MAXIMUM VALVE MARK NUMBER STROKE TIME MOV-1373 12 seconds MOV-2373 MOV-1380 10 seconds MOV-2380' MOV-1381 MOV-2381 TV-1204 10 seconds TV-2204 TV-CV-100 60 seconds TV-CV-200 TV-CV-150 A, B, C, D 60 seconds TV-CV-250 A, B C, D TV-DA-100 A, B 60 seconds TV-DA-200 A. B TV-DA-103 A, B 60 seconds TV-DA-203 A B TV-DG-100 A, B 60 seconds TV-DG-200 A, B FCV-FW-1478, 88, 98 5 seconds FCV-FW-2478, 88, 98 FCV-FW-1479, 89, 99 5 seconds FCV-FW-2479, 89, 99 MOV-FW-100 B D 60 seconds HOV-FW-200 B D MOV-FW-154 A, B, C 5 seconds MOV-FW-254 A, B C TV-HC-100A-109 A 5 seconds TV-HC-100B-109B TV-HC-200A-209A TV-HC-200B-209B MOV-HV-100 A, 3. C, D 40 seconds MOV-HV-200 A, B, C, D MOV-HV-101, 102 MOV-HV-201, 202 TV-IA-201 A, B 60 seconds TV-IA-102 A, B 60 seconds TV-IA-202 A B
o MAXIMUM VALVE MARK NUMBER STROKE TIME TV-LM-100 A-H 60 seconds
-TV-LM-200 A-H TV-LM-101 A-D TV-LM-201 A-D NRV-MS-101 A-C 140 seconds NRV-MS-201 A-C TV-MS-101 A B, C 5 seconds TV-MS-201 A, B, C TV-MS-109 60 seconds TV-MS-209 TV-MS-110 60 seconds TV-MS-210 TV-MS-111 A, B 60 seconds TV-MS-211 A B MOV-QS-100 A, B 40 seconds MOV-QS-200 A, B MOV-QS-101 A, B 40 seconds MOV-QS-201 A, B MOV-QS-102 A B 40 seconds MOV-QS-202 A, B MOV-1535, 1536 20 seconds MOV-2535, 2536 PORV-14550, 1456 Air SOV 1, 2, 3 Open 10 sec.
Close 2 sec.
PORV-2455C, 2456 N
SOV 1, 2, 3 Open 10 sec.
Close 2 sec.
2 N
SOV 3 Open 2.14 sec. Close 2 sec.
2 SOV-RC-101 A-1, A-2, B-1, B-2 10 seconds SOV-RC-201 A-1, A-2, B-1, B-2 SOV-RC-102 A-1. A-2, B-1, B-2 SOV-RC-202 A-1, A-2, B-1, B-2 TV-1519 A 10 seconds TV-2519.A MOV-1700, 1701 120 seconds MOV-2700, 2701 MOV-1720 A, B 20 seconds MOV-2720 A, B TV-RM-100 A B, C, D 60 seconds TV-RM-200 A, B C, D MOV-RS-100 A, B 120 seconds MOV-RS-200 A, B
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- h MAXIMUM VALVE MARK NUMBER STROKE TIME MOV-RS-101 A, B 120 seconds MOV-RS-201'A, B MOV-RS-155 A, B 180 seconds MOV-RS-255 A, B MOV-RS-156 A, B MOV-RS-256 A, B HCV-1936 10 seconds HCV-2936 MOV-1836 12 seconda MOV-2836 MOV-1860 A, B 120 seconds MOV-2860 A, B MOV-1862 A, B 120 seconds MOV-2862 A, B MOV-1863 A, B 40 seconds MOV-2863 A, B MOV-1864 A, B 120 seconds MOV-2864 A, B MOV-1865 A, B, C 20 seconds MOV-2865 A, B, C MOV-1867 A, B, C D 10 seconds MOV-2867 A, B, C, D MOV-1869 A B 20 seconds MOV-2869 A, B MOV-1885 A, B, C, D 12 seconds MOV-2885 A, B, C, D MOV-1890 A, B 20 seconds MOV-2890 A, B NOV-1890 C, D 20 seconds MOV-2890 C, D TV-SI-100 60 seconds TV-SI-200 TV-SI-101 60 seconds TV-SI-201 TV-1842, 2842 60 seconds TV-1859, 2859 TV-1884 A, B, C 10 seconds TV-2884 A, B, C
. o MAXLMUM VALVE MARK NUMBER STROKE TIME TV-SS-100 A, B, 200.A, B 60 seconds TV-SS-101 A, B, 201 A, B TV-SS-102 A, B, 202 A, B TV-SS-103 A, B, 203 A, B TV-SS-104 A, B, 204 A, B TV-SS-106 A, B, 206 A, B TV-SS-107 A B, 207 A, B TV-SS-108 A, B, 208 A B TV-SS-109 A-C 209 A-C TV-SS-111 A-C 211 A-C TV-SS-112 A, B, 212 A, B TV-SV-102.2 60 seconds TV-SV-202.2
'TV-SV-102.1, 202.1 TV-SV-103, 203 MOV-SW-100 A, B 40 seconds MOV-SW-200 A, B MOV-SW-101 A-D 40 seconds MOV-SW-201 A-D MOV-SW-105 A-D MOV-SW-205 A-D MOV-SW-102 A, B 40 seconds MOV-SW-202 A, B MOV-SW-106 A, B MOV-SW-206 A, B MOV-SW-103 A-D 40 seconds MOV-SW-203 A-D MOV-SW-104 A-D MOV-SW-204 A-D MOV-SW-108 x, P 40 seconds MOV-SU-208 ti, B MOV-SW-113 '.. B 40 seconds MOV-SW-213 A, 8 MOV-SW-115 A, B 40 seconds MOV-SW-215 A, B HOV-SW-117 MOV-SW-217 i
TV-VG-100 A, B 60 seconds TV-VG-200 A, B i
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8 PREVIOUS CORRESPONDENCE REQUESTED BY NRC REVIEWERS
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s J. c. EASTWooD Docket Nos. 50-338 g4a rzcu.tanAa7 (oarctuu.)
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4dW1 Mr. W. L. Stewart Vice Pmsident - Nuclear Operations Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261
Dear Mr. Stewart:
Re: North Anna Units 1 and 2 By letters dated October 5,1983 (Serial No. 4878) and February 2 and 28, 1984 (Serial Nos. 487D and 487E), you submitted a proposed pump and valve inservice testing (IST) program description including requests for relief from selected ASME Code requirements pursuant to 10 CFR 50.55a(g).
In addition, by letter dated February 28, 1984 (Serial No. 487F) you requested in-terim approval of the relief requests as they relate to the inservice inspec-tion and testing for pumps and valves for North Anna Unit Nos 1 and 2.
Althrugh we have not completed our detailed review of your submittals, our preliminary review makes it clear to us that your proposed program to implement those ASME Code requirements that you have found to be practical would increase the scope of inservice testing for your facility beyond that currently recuired by your Technical Specifications. We have concluded that this upgrading of your inservice testing program will further enhance safety.
Based on our preliminary review, we agree with your determination that it is impractical within the limitations of design, geometry and materials of con-struction of components, for you to meet certain of the specified ASME Code requirements and that imposition of those requirements wnuld result in hard-ships or unusual difficulties without a compensating increase in the level or quality of safety. Therefore, pursuant to 10 CFR 50.55a(g)(6)(1), we l
hereby grant relief, on an interim basis until December 31, 1984, pending completion of our detailed review, from those inservice testing requirements j,
of the ASME Code that you have requested. However, you should request an extension to this interim relief if, by December 31, 1084, we have not com-pleted our detailed review of your submittals. Moreover, since the scope of i
the inservice testing will be increased by your proposed program, and the granting of this relief is based only on the impracticality of selected ASME Code requirements, we have determined that the relief granted neither in-creases the probability or consequences of accidents previously considered nor i
decreases safety margins and that, therefore, it does not involve a signifi-cant hazards consideration. Therefore, you are authorized to, and should proceed to, inplement your proposed program (except where your current Tech-nical Specifications are more restrictive).
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2-i Mr. W. L. Stewart During the period between now and the date we complete our detailed review of your submittal, you must comply with both your existing Technical Specifications and your proposed inservice testing program.
In the event conflicting requirements arise for some components, you must comply with the more restrictive requirements (e. g., shorter inspection intervals, increased number of parameters measured).
In other words, the granting of this relief from ASME Code requirements should not be interpreted to give you relief from any of the require-ments in your existing Technical Specifications.
When our detailed review of your October 5,1983 and February 2 and 28, 1984 submittals is complete, we will: (1) issue final approval of your p(2) gram (which may contain modifications resulting from the staff's review),
ro grant relief from any ASME Code requirements that are detemined to be impractical for your facility for the duration of the inspection interval, and (3) issue appropriate changes to your Technical Specifications.
f4[9 Si g ly, Jame[R. Miller, Chief Operating Reactors Branch f3 Division of Licensing cc: See next page t
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