ML20116A883
| ML20116A883 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/22/1996 |
| From: | Kansler M VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 96-290, TAC-M94303, TAC-M94304, NUDOCS 9607290010 | |
| Download: ML20116A883 (102) | |
Text
VIRGINIA Etecrule Axu Powen COMPANY IIICIIMOND,VIHOINIA 202 61 July 22, 1996 United States Nuclear Regulatory Commission Serial No.96-290 Attention: Document Control Desk NL&OS/EJW Washington, D.C. 20555 Docket No.
50-338 50-339 License No.
NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 RESPONSES TO INSERVICE TES_IltLG PROGRAM ANOMALIES in a Safety Evaluation Report dated October 18,1994, the NRC identified ten anomalies with the North Anna Power Station ASME Section XI Inservice Testing (IST) Program (TAC Nos. M94303 and M94304) and requested Virginia Electric and Power Company's (Virginia Power's) response to those anomalies. Our response was sent to the NRC in a letter dated October 18, 1995.
By letter dated February 15, 1996, the NRC staff documented acceptance of our response to the ten anomalies. However after reviewing the letter dated February 15,1996, we believe that additional clarification is necessary to ensure a common understanding between our position and that of the NRC staff. These clarifications are discussed in Attachment 1.
Changes have also been made to the North Anna IST Program which affect Anomalies Nos. 5 and 8. The major change is a commitment to the 1989 Edition of ASME Section XI which invokes the requirements of OM Part 10, " Inservice Testing of Valves in Light-Water Reactor Plants," OMa-1988. North Anna was previously committed to the 1986 Edition of ASME Section XI. Descriptions of the IST Program changes are also included in Attachment 1.
Additionally, several relief requests are being revised to apply the 10 CFR 50, Appendix J, Option B leak testing frequency to the closure test interval for certain check valves that serve as containment isolation valves. The relief requests and other minor changes for North Anna Units 1 and 2 are described in Attachments 2 and 3, respectively. Pursuant to 10 CFR 50.55a(f)(5), the revised relief requests are included for NRC review in Attachments 4 (Unit 1) and 5 (Unit 2) of this letter. Accordingly, we request written concurrence with the revised relief requests.
Attachments 4 and 5 also provide replacement pages for each unit's IST Program.
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9607290010 960722 ADOCK0500g8 DR
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These IST Program changes and revised relief requests have been approved by the North Anna Station Nuclear Safety and Operating Committee.
If you have any i
questions or require additior'al information, please contact us.
Very truly yours,
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M. R, ansler
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fesident - Nuclear Engineering and Services Vi Attachments l
ec:
United States Nuclear Regulatory Commission Region 11 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. R. D. McWhorter NRC Senior Resident inspector North Anna Power Station l
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i ATTACHMENT 1 NORTH ANNA POWER STATION CLARIFICATION OFIST ANOMAllES AND DESCRIPTION OF PROGRAM CHANGES Clarifications and program change descriptions are provided below for Anomalies 1,3, 4, 5 and 8.
The NRC discussions in the safety evaluation report for the remaining anomalies are consistent with our intended positions.
Anomalies 1 and 3 l
The NRC discussion in their letter dated February 15,1996, states that "the results of the assessment for the combination of Pump Relief Requests P-9 and P-12 were not addressed" in our response. However, our response dated October 18,1995, did address the results of the assessment performed to determine the impact of the combination of pump Relief Requests P-9 and P-12 on our ability to assess the operational readiness of the pumps. The pertinent discussion of that assessment is j
reiterated below:
The assessment for determining operational readiness included a review of normalized test data for each pump. North Anna has the ability to normalize the test data and trend the data from test to test. By knowing the polynomial equation that describes the reference pump curve discussed in P-12, a reference value can be calculated for the dependent variable using the value of the independent variable. The actual test result is divided by the reference value to yield a normalized test result which can then be used to trend the performance of the pump. This review showed that the test results were trendable and provide the ability to assess the operational readiness of these pumps.
Also, the NRC discussion refers to a conference call held with Virginia Power on January 29,1996, and that "during this conference call the licensee indicated that it is further assessing the effect and that it will use instruments that meet the accuracy requirement of the Code for the instruments identified in Pump Relief Request P-13."
During that call we discussed the possibility of using instruments which comply with Code accuracy requirements, if and when we choose to convert to such instrumentation, we will withdraw Relief Request P-13. However, it is necessary to clarify that our evaluation to convert to instrumentation with accuracies commensurate with Code requirements is in its preliminary stages, and a decision has not yet been made on this subject. Virginia Power has not committed to modifying the existing instrumentation at this time.
Meanwhile, our complete assessment and results for determining the operational readiness of the pumps have been documented and will continue to be available onsite for NRC inspection and review while North Anna uses the instrumentation currently described in Relief Request P-13.
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l Anomalv 4 The NRC letter dated February 15,1996, states that our October 18,1995 response did not address the results of our assessment for the combination of pump relief requests P-9 and P-12 as to their ability to assess the operational readiness of the pumps. As discussed under Anomalies 1 and 3 (above), the results of our assessment have been appropriately addressed. Also as discussed above, we have not specifically committed to replacing the existing instrumentation discussed in Relief Request P-13.
Additionally, the February 15,1996 letter specified that "the licensee has not addressed implementation of the seven guidelines identified in Section 2.4.1.1 of the TER
[ Technical Evaluation Report] for using reference curves." Our initial response did not l
l explicitly address the seven guidelines, because we intend to fully comply with those l
guidelines.
Records documenting the methods used to comply with the seven l
guidelines of Section 2.4.1.1 of the TER are available onsite for NRC inspection and review.
Anomalv 5 The NRC letter dated February 15,1996, rejects Nodh Anna's method for assigning the l
maximum allowable leakage rate to valves that are leak tested in groups (Relief i
Request V-59). Relief was initially granted pursuant to 10 CFR 50.55a (f)(6)(i) with the provision that the maximum group leakage rate limit be conservatively based on the smallest valve in the group. The North Anna methodology, as discussed in our letter dated October 18,1995, was to base the allowable leakage rate on the largest valve in the group.
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Relief request V-59 was written to the 1986 Code Edition. North Anna is conveding to the 1989 Code Edition, which references OM Part 10, OMa-1988, for valve testing. OM l
Part 10, para. 4.2.2.3 allows for the leakage testing of valve combinations. Because OM Part 10 does not require that valves be individually leak tested, we withdraw Relief Request V-59 for North Anna.
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l Anomalv 8 In their letter dated February 15,1996, the NRC agreed that non-intrusive testing of valves in relief requests V-33 and V-73 (74) is not practicable. The letter also states that "the licensee is still evaluating non-intrusive techniques for valves in Valve Relief Request V-42 (43). Final conclusions and methods of testing of these valves is subject to NRC inspection and review."
Relief Request V-42 (43) concerns the Safety injection (SI) accumulator discharge check valves. During the last outage, non-intrusive techniques were successfully used to test these check valves. Therefore, Relief Request V-42 (43) has been revised to indicate that just nonintrusive techniques will be used.
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ATTACHMENT 2 NORTH ANNA UNIT 1
SUMMARY
OF IST PROGRAM CHANGES The following summary describes the changes from Revision 7, Change 3 to Revision 7, Change 4 of the North Anna Unit 1 Inservice Testing (IST) Program Plan.
2.3 VALVE INSERVICE TESTING PROGRAM DESCRIPTION This section was revised to reference ASME Section XI 1989 Edition and OM Part 10, Edition OM-87, Addenda OMa-1988. North Anna was previously committed to ASME Section XI 1986 Edition.
2.3.4 VALVE INSERVICE TESTING TABLE
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UNIT 1 VALVE NUMBER PROGRAM CHANGE 1
1-CC-84 These containment isolation valves will be tested closed on the 1-CC-119 same interval as the 10CFR50. Appendix J, Option B leak test 1-CC-154 interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-3.
1-CC-193 These containment isolation valves will be tested closed on the 1-CC-198 same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-70.
j 1-CC-546 These containment isolation valves will be tested closed on the 1-CC-559 same interval as the 10CFR50, Appendix J, Option B leak test 1-CC-572 interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-62.
1-CH-322 These containment isolation valves will be tested closed on the 1-CH-330 same interval as the 10CFR50, Appendix J, Option B leak test 1-CH-402 interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-10.
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1 -CV-8 These check valves were added to Relief Request V-20 to be 1-CV-14 tested partially open every three months and full open every 18 months. They must open to allow the sampling of hydrogen. The l
technical basis is described in the summary to Relief Request V-20.
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1-FP-272 This containment isolation valve will be tested closed on the same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-16.
1-HC-14 These containment isolation valves will be tested closed on the 1-HC-18 same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-20.
1-IA-55 These containment isolation valves will be tested closed on the 1-IA-149 same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-21.
1-RC-149 This containment isolation valve will be tested closed on the same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-28.
1-SI-106 These containment isolation valves will be tested closed on the 1-SI-110 same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-40.
1-SI-79 These containment isolation valves will be tested closed on the 1-SI-90 same interval as the 10CFR50, Appendix J, Option B leak test 1-SI-185 interval which can be extended up to 60 months. Refer to the 1-SI-201 change summary for Relief Request V-43.
1-SI-206 1-SI-207 1-SI-125 Reference to using disassembly and inspection for verifying full-1-SI-127 stroke of the safety injection accumulator discharge check valves 1._l-142 was deleted from Relief Request V-42.
1-SI-144 1-SI-159 1-SI-161 1-VP-12 This containment isolation valve will be tested closed on the same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-46.
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2.3.5 VALVE INSERVICE TESTING PROGRAM RELIEF REQUESTS UNIT 1 RELIEF REQUEST PROGRAM CHANGE V-3 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 1-CC-84,119 and 154 was added to the relief request. These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, Appendix J program. North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9,1996 (TAC NOS. M94081 and M94082). Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interwl determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 manths. The proposed altemative will provide an acceptable level of quality and safety because:
1) the ppendix J, Option B, leakage test program is a penormance based program, 2) the valves will be added to the plant's check valve predictive maintenance program, and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakaga test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) as-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the j
requirements of draft OM Subsection ISTC, Appendix II, entitled i
' Check Valve Condition Monitoring Program," dated June,1995.
The predictive maintenance p7 gram requires that the check valves be grouped and analyzed m order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities. The results of the predictive maintenance 3
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1 program analyses will be considered on a valve by valve basis before the test intervals are extended.
V-10 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 1-CH-322,330 and 402 was added to the relief request. For a detailed description of the change, refer to Relief Request V-3.
V-16 Reference to using the leakage test intewal from Option B of 10 CFR 50, Appendix J for valve 1-FP-272 was added to the relief request. For a detailed description of the change, refer to Relief Request V-3.
V-20 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 1-HC-14 and 18 were added to the relief request. For a detailed description of this change, refer to Relief Request V-3.
Also, valves 1-CV-8 and 14 were added to the relief request.
These valves open to supply samples to the hydrogen analyzer l
system.
To test them either partially or full open requires a significant manipulation of the hydrogen recombiner system. In addition, should a containment pressurization event occur while operating the hydrogen recombiners, there is a possibility of exceeding the design pressure of the recombiner system, which may result in a loss of recombiner function.
The hydrogen recombiner is a low p: essure system intended for use after the containment depressurizes.
The valves can be tested to the partially open position every three months using the containment vacuum pumps while maintaining the recombiner system isolated from the containment atmosphere.
These valves will be tested to the partially open position every three months and tested to the full open position at least once every 18 months during the surveillance testing of the hydrogen recombiner system as required by Technical Specification Section 4.6.4.2.
The small increase in safety gained by testing during j
normal operation or cold shutdown does not justify the potential risk of overpressurizing the hydrogen recombiner system, or the added burden of disrupting normal plant operations to manipulate the recombiner system and performing the test on the more frequent basis.
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l V-21 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 1-IA-55 and 149 was added to the relief request. For a detailed description of the change, refer to j
Relief Request V-3.
V-28 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valve 1-RC-149 was added to the relief request. For a detailed description of the change, refer to Relief l
Request V-3.
l V-40 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 1-SI-106 and 110 was added to the relief request. For a detailed description of the change, refer to l
Relief Renuest V-3.
l V-42 Refere ing disassembly and inspection for verifying full-stroke J e.; safety injection accumulator discharge check valves l
was deleted from the relief request.
V-43 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 1-SI-79,90,1E5,201,206 and 207 l
was added to the relief request. For a detailed description of the l
change, refer to Relief Request V-3.
V-46 Reference to using the leakege test interval from Option B of 10 l
CFR 50, Appendix J for valve 1-VP-12 was added to the relief request. For a detailed description of the change, refer to Relief l
Request V-3.
V-59 This relief request is being withdrawn. Relief Request V-59 was written to the 1986 Code Edition. North Anna is converting to the 1989 Code Edition, which references OM Part 10, OMa-1988, for valve testing. OM Part 10, para. 4.2.2.3 allows for the leakage testing of valve combinations.
Because OM Part 10 does not require that valves be individually leak tested, North Anna is withdrawing Relief Request V-59.
V-66 This relief request is being withdrawn. By committing to OM Part 10 in its entirety, relief is no longer required to apply the stroke time l
provisions of OM Part 10.
I V-70 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 1-CC-193 and 198 was added to the relief request. For a detailed description of the change, refer to l
Relief Request V-3.
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r ATTACHMENT 3 NORT'" \\NNA UNIT 2
SUMMARY
OF IST PROGRAM CHANGES The following summary describes the changes from Revision 7, Change 3 to Revision 7, Change 4 of the North Anna Unit 2 Inservice Testing (IST) Program Plan.
2.3 VALVE INSERVICE TESTING PROGRAM DESCRIPTION This section was revised to reference ASME Section XI 1989 Edition and OM Part 10, Edition OM-87, Addenda OMa-1988. North Anna was previously committed to ASME Section XI 1986 Edition.
2.3.4 VALVE INSERVICE TESTING TABLE UNIT 2 VALVE NUMBER PROGRAM CHANGE i
2-CC-78 These containment isolation valves will be tested closed on the 2-CC-115 same interval as the 10CFR50, Appendix J, Option B leak test 2-CC-152 interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-3.
2-CC-194 These containment isolation valves will be tested closed on the 2-CC-199 same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months.- Refer to the change summary for Relief Request V-71.
2-CC-276 These containment isolation valves will be tested closed on the 2-CC-289 same interval as the 10CFR50, Appendix J, Option B leak test 1
2-CC-302 interval which can be extended up to 60 months. Refer to the i
change summary for Relief Request V-63.
2-CH-331 These containment isolation valves will be tested closed on the 2-CH-332 same interval as the 10CFR50, Appendix J, Option B leak test 2-CH-335 interval which can be extended up to 60 months. Refer to the change summary for h ef Request V-10.
2-CV-8 These check valves were added to Relief Request V-20 to be 2-CV-15 tested partially open every three months and full open every 18 l
months. They must open to allow the sampling of hydrogen. The technical basis is described in the summary to Relief Request V-20.
l 2-FP-79 This containment isolation valve will be tested closed on the same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change 1
summary for Relief Request V-16.
2-HC-15 These containment isolation valves will be tested closed on the 2-HC-20 same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-20.
2-IA-250 These containment isolation valves will be tested closed on the 2-IA-428 same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-21.
2-RC-162 This containment isolation valve will be tested closed on the same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change j
summary fer Relief Request V-28.
2-SI-132 These containment isolation valves will be tested closed on the 2-SI-136 same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change summary for Relief Request V-41.
2-SI-151 Reference to using disassembly and inspection for verifying full-2-SI-153 stroke of the safety injection accumulator discharge check valves 2-SI-168 was deleted from Relief Request V-43.
2-SI-170 2-SI-185 2-SI-187 2-VP-24 This containment isolation valve will be tested closed on the same interval as the 10CFR50, Appendix J, Option B leak test interval which can be extended up to 60 months. Refer to the change i
summary for Relief Request V-47.
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2.3.5 VALVE INSERVICE TESTING PROGRAM RELIEF REQUESTS UNIT 2.
P' ZF-REQUEST PROGRAM CHANGE V-3 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 2-CC-78,115 and 152 was added to the relief request. These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, Appendix J program. North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9,1996 (TAC NOS. M94081. and M94082). Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months. The proposed altemative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is a performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program, and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) as-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled
" Check Valve Cc,ndition Monitoring Program," dated June,1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities. The results of the predictive maintenance program analyses will be considered on a valve by valve basis i
before the test intervals are extended.
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V-10 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 2-CH-331,332 and 335 was added to the relief request. For a detailed descriraion of the change, refer to Relief Request V-3.
V-16 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valve 2-FP-79 was added to the relief request. For a detailed description of the change, refer to Relief Request V-3.
l V-20 Reference to using the leakage test interval from Option B of 10 l
CFR 50, Appendix J for valves 2-HC-15 and 20 were added to the relief request. For a detailed description of this change, refer to Relief Request V-3.
Also, valves 2-CV-8 and 15 were added to the relief request.
These valves open to supply samples to the hydrogen analyzer system.
To test them either partially or full open requires a significant manipulation of the hydrogen recombiner system. In addition, should a containment pressurization event occur while operating the hydrogen recombiners, there is a possibility of exceeding the design pressure of the recombiner system, which may result in a loss of recombiner function.
The hydrogen recombiner is a low pressure system intended for use after the containment depressurizes.
The valves can be tested to the partially open position every three months using the containment vacuum pumps while maintaining the recombiner system isolated from the containment atmosphere.
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These valves will be tested to the partially open position every three months and tested to the full open position at least once every 18 months during the surveillance testing of the hydrogen recombiner system as required by Technical Specification Section 4.6.4.2.
The small increase in safety gained by testing during normal operation or cold shutdown does not justify the potential risk of overpressurizing the hydrogen recombiner system, or the added burden of disrupting normal plant operations to manipulate the i
reco.r.b!ner system and performing the test on the more f ecuent basis.
V-21 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 2-IA-250 and 428 was added to the relief request. For a detailed description of the change, refer to Relief Request V-3.
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V-28 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valve 2-RC-162 was added to the relief request. For a detailed description of the change, refer to Relief Request V-3.
V-41 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 2-SI-132 and 136 was added to the relief request. For a detailed description of the change, refer to Relief Request V-3.
V-43 Reference to using disassembly and inspection for verifying full-stroke of the safety injection accumulator discharge check valves was deleted from the relief request.
V-47 Reference to using the leakage test inter i from Option B of 10 l
CFR 50, Appendix J for valve 2-VP-24 was added to the relief request. For a detailed description of the change, refer to Relief Request V-3.
V-59 This relief request is being withdrawn. Relief Request V-59 was written to the 1986 Code Edition. North Anna is converting to the 1989 Code Edition, which references OM Part 10, OMa-1988, for valve testing. OM Part 10, para. 4.2.2.3 allows for the leakage testing of valve combinations.
Because OM Part 10 does not require that valves be individually leak tested, North Anna is withdrawing Relief Request V-59.
V-63 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 2-CC-276,289 and 302 was added to the relief request. For a detailed description of the change, refer to Relief Request V-3.
V-67 This relief request is being withdrawn. By committing to OM Part 10 in its entirety, relief is no longer required to apply the stroke time provisions of OM Part 10.
V-71 Reference to using the leakage test interval from Option B of 10 CFR 50, Appendix J for valves 2-CC-194 and 199 was added to the relief request. For a detailed description of the change, refer to Relief Request V-3.
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= u L4.w_a ATTACHMENT 4 NORTH ANNA UNIT 1 REPLACEMENT PAGES TO THE IST PROGRAM
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2.3 VALVE INSERVICE TESTING PROGRAM DESCRIPTION 2.3.1 PROGRAM DEVELOPMENT PHILOSOPHY i
1 The North Anna Unit i Valve Inservice Testing (IST)
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Program has been established to meet the requirements of the 10CFR50, Section XI of the ASME Boiler and Pressure Vessel Code, Subsection IWV and Technical Specifications.
North Anna Unit 1 Technical Specification 4.0.5 states that Inservice Testing of ASME Code Class 1, 2 and 3 2
valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and j
applicable addenda as required by 10CFR50, Section 50.55a(f), except where specific written relief has been granted by the commission pursuant to 10CFR50, Section 50.55a(f) (6) (i).
10CFR50, Section 50.55a(f) (4) (iv) states that inservice l
examinations of components, test of pumps and valves, i
and system pressure tests, may meet the requirements set forth in subsequent editions and addenda of ASME
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Section XI that have been approved by the NRC, subject to Commission approval.
North Anna Unit 1 will test those valves that fall under the scope of ASME Section XI using Subsection IWV of the 1989 Edition.
The 1989 j
Edition of-Subsection IWV references OM Part 10, Edition OM-87, ASME/ ANSI, Operation and Maintenance of Nuclear Power Plants, Addenda OMa-1988.
The scope of the program includes ASME Section XI Class 1, 2 and 3, and certain non-Code class valves that are requiren to perform a specific function in shutting down the reactor or in mitigating the consequences of an accident.
OM Part 10 defines the rules and requirements of inservice testing of code class 1
,2, and 3 valves and states that each specific valve to be tested by the rules of this subsection shall be identified by the owner and listed in the plant records.
The purpose of the IST program is to identify the valves that are considered by Virginia Electric and t
Power Company as having a safety function and are therefore subject to the testing requirements of OM Part 10.
The intent of the Code is to assess operational readiness and detect potentially adverse changes in the mechanical condition of these valves.
The relief requests for the Valve Inservice Test Program identify Code requirements considered to be impractical, provide technical basis for the request 2-37 N1PVR7 Revision 7 April 15, 1996
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and propose alternate testing when warranted.
Leak rate testing for containment isolation valves is performed in accordance with 10CFR50, Appendix J, which imposes specific requirements, and in accordance with l
OM Part 10, Paragraphs 4.2.2.3(e) and 4.2.2.3(f).
Appendix J satisfies the testing requirements of OM Part 10, Paragraph 4.2.2.2.
I 2.3.2 PROGRAM IMPLEMENTATION The 7alve Inservice Testing Program will be executed as
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l part of the normal plant surveillance program which is implemented by periodic tests.
j The operability Tests will verify:
1)
The valve responds to control commands.
2)
The valve stroke time is within specific limits.
3)
Remote valve position indication accurately reflects the valve position.
Failsafe valves will be tested by observing valve operation upon loss of actuating power.
In most cases, this can be accomplished using normal control circuits.
Safety and relief valve setpoints are tested in accordance with OM Part 1, 1987 Edition.
i Those valves which are scheduled to be exercised during cold shutdown are subject to the requirements of OM Part 10, Paragraph 4.2.1.2(f) which states that:
" valve exercising during cold shutdown shall commence within 48 hr of achieving cold shutdown, and continue until all testing is complete or the plant is ready to return to power.
For extended outages, testing need not be commenced in 48 hr provided all valves required to be tested during cold shutdown will be tested prior to plant startup.
However, it is not the intent of this Part to keep the plant in cold shutdown in order to complete cold shutdown testing."
i certain valves cannot be full stroke exercised during normal operation following maintenance.
These valves are described in the relief requests 2-38 N1PVR7 Revision 7 April 15, 1996 i
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i and cold shutdown justifications.
If maintenance cannot be deferred to a shutdown condition, then an engineering evaluation must be performed prior to the maintenance to determine the effect of the maintenance on valve operability.
If the evaluation shows that operability will not be affected, then no post maintenance testing will be required.
A partial stroke test will be performed if possible.
2.3.3 PROGRAM ADMINISTRATION The Engineering staff at North Anna is responsible for the administration of the Valve Inservice Testing Program.
The Operations staff is responsible for performing the periodic tests as required by this program.
The Valve Inservice Testing Program is implemented by Station Periodic Test Procedures.
2.3.4 VALVE INSERVICE T3 STING TABLE The Valve Inservice Testing Table provides a list of North Anna Unit 1 ASME Section XI valves and their testing requirements.
The following is a brief explanation of the table headings and abbreviations.
Valve Nnnher - Each valve has a unique i
identification number.
Drawina Number - Classification Boundary Drawing Number.
Sheet Number - Classification Boundary Drawing Sheet Number.
Dwa Coor - Drawing Coordinate of valve.
Valve Tvoe - The type of valve.
Some abbreviations are used for valve type which are explained below.
- air operated SO
- solenoid operated 4
DIA
- diaphragm MO
- motor operated MAN
- manual BFLY - butterfly 2-39 N1PVR7 Revision 7 April 15, 1996
Valve Size - Valve size.
Valve Function - A brief description of the function of the valve.
ASME Class - ASME Code Class of each valve.
j Note:
NC is for non-class valves.
ASME XI IWV Cateaory - Categories as defined by l
Categories determine test i
l requirements.
Valves marked with an "E" are
}
passive valves.
l Test Position - The following abbreviations are j
used to describe normal valve positions to which l
the valves are tested (including the valve safety position):
}
l 0
- open C
- closed OC - open and closed Isolation valve Tvos - Valves that are assigned a i
maximum leakage.
The following abbreviations are j
used to describe the isolation valve types:
CIV - Containment Isolation Valve subject to j
Appendix J leakage testing i
j PIV - Pressure Isolation Valve which protects low pressure safety related piping from RCS pressure C&P - Valves that serve both CIV and PIV functions l
Test Reauired - Testing requirements identified i
for the valves are identified here.
i l
ST - Stroke times shall be measured per OM Part 10, Paragraph 4.2.1.4 or as modified by a specific l
relief request.
EV - Exercise valve for operability at least once every 3 months per OM Part 10, Paragraph 4.2.1.4
{
or as modified by a specific cold shutdown or j
reactor refueling justification which is allowed j
by OM Part 10, Section 4.2.1.2.
i j
LT - Leak test shall be performed per OM Part 10, l
Section 4.2.2 or as modified by specific relief i
request.
1-1 l
2-40 1
N1PVR7 Revision 7 April 15, 1996 l
l
CV - Check valves shall be exercised at least once every 3 months per OM Part 10, Paragraph 4.3.2.1 or as modified by a specific cold shutdown or reactor refueling' justification which is allowed by OM Part 10, Section 4.2.2.2.
VP - Valve position indication shall be verified per OM Part 10, Paragraph 4.1 or as modified by a specific relief request.
SP - Set points of safety and relief valves shall be tested per OM Part 1, 1987 Edition or as modified by a specific relief request.
FS - Valves with fail-safe actuators shall be tested by observing the operation of the valves upon loss of the actuator power at least once every 3 months per OM Part 10, Paragraph 4.2.1.6 or as modified by a specific cold shutdown or reactor refueling justification which is allowed by OM Part 10, Section 4.2.1.2.
Relief Reauest - The relief requests corresponding to the numbers in the table are in Section 2.3.5.
Cold shutdown Justification - The cold shutdown justifications corresponding to the numbers in the table are in Section 2.3.6.
Non-Code Alternative Testina Description - The non-Code alternative testing descriptions corresponding to the numbers in the table are in Section 2.3.7.
1 2-41 N1PVR7 Revision 7 April 15, 1996
3 THIS PAGE IS INTENTIONALLY BLANK.
I l
2-42 N1PVR7 Revision 7 April 15, 1996
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VIRGINIA POWER COMPANY PAGE:
9 0F 78 WORTH ANNA UNIT 1 REVISION: 07 SECOND INSPECTIOh INTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM - VALVE TABLE NC l
ISO REL CS ALT VALVE DRAWING SHEET DRWG VALVE VALVE ASME IW VALVE TEST TEST REQ JUST TEST NUMSER NUMBER NLMBER COOR TYPE
$1ZE CLASS CAT TYPE TYPE POS V-CSV-VCN-1-CH 279 11715-CBM-0958 2 0F 2 D6 CHECK VALVE 3.000 2 C
CV C
47 0
47 "C" CHARGING PUMP DISCHARGE CHECK VALVE 1-CH-322 11715-CeM 095C 1 0F 2 D4 CHECK VALVE 3.000 2 AC CIV CV C
10 LT C
MAIN CHARGING SUPPLY HEADER, INSIDE CONTAIN-MENT ISOLATION CHECK VALVE 1-CH-330 11715 CeM-095C 1 0F 2 A6 CHECK VALVE 2.000 1 AC CIV CV C
10 6T C
CHARGING SUPPLY 70 LOOP FILL HEADER, INSIDE CONTAINMENT ISOLATION CHECK VALVE l
1 CH-336 11715-cam-095C 2 0F 2 B8 CHECK VALVE 2.000 1 C
CV C
10 i
"A" RC PUMP SEAL WATER SUPPLY, INSIDE CONTAINMENT ISOLATION CHECK VALVE 1
I 1 CH-358 11715 CBM-095C 2 0F 2 87 CHECK VALVE 2.000 1 C
CV C
10 i
I "B" RC PUMP SEAL WATER SUPPLY, INSIDE CONTAINMENT ISOLATION CHECK VALVE 1 CH-380 11715 CBM 095C 2 0F 2 B5 CHECK VALVE 2.000 1 C
CV C
to "C" RC PUMP SEAL WATER SUPPLY, INSIDE CONTAlWMENT ISOLATION CHECK VALVE 1-CH-402 11715 CDM 095C 2 0F 2 F4 CHECK VALVE
.750 2 AC Civ CV C
10 LT C
RC PUMP SEAL WATER RETURN, INSIDE CONTAINMENT ISOLATION CHECK VALVE 1-CH 649 11715 CBM-0958 1 0F 2 B6 CHECK VALVE 2.000 2 AC CV C
72 0
38 LT C
CHARGING PLMP RECIRC AND RCP SEAL WATER RETURN LINE ISOLATION CHECK VALVE 1 CH-FCV-1113A 11715 CBM 095B 1 0F 2 C3 A0 GATE 1.000 3 B
EV 0
FS 0
ST 0
VP OC ALTERNATE EMERGENCY SORATION LINE FLOW CONTROL VALVE 1 CH FCV-1114A 11715 CBM-0958 1 0F 2 D4 A0 GLosE 1.000 3 8
EV C
FS C
ST C
VP OC PRIMARY GRADE WATER FLOW CONTROL VALVE l
1 CH FCV-1160 11715-CsM-095C 1 0F 2 A4 A0 GLost 2.000 2 AE CIV LT C
VP OC
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NORTH ANNA UNIT 1 REVISION: 07 SECOND INSPECTION INTERVAL DATE: 04/15/96 INSERVICE TESTIhG PROGRAM VALVE TABLE NC l
ISO REL CS ALT VALVE DRAWING SHEET DRWG VALVE VALVE ASME IW VALVE TEST TEST RE0 JUST TEST NUMBER NUMBER NUMBER COOR TYPE
$1ZE CLASS CAT TYPE TYPE POS V-CSV-VCN-CHARGING PUMP RECIRCULATION HEADER ISOLATION VALVE 1-CH-MOV 1380 11715-CSM 095C 2 0F 2 F4 M0 GATE 3.000 2 A CIV EV C
9 l
LT C
ST C
9 VP OC REACT 00 COOLANT PLMP SEAL WATER RETURN, INSIDE L91TAINMENT ISOLATION VALVE 1 CH Mov-1381 11715-CeM-0958 1 0F 2 C8 M0 GATE 3.000 2 A CIV EV C
9 l
LT C
ST C
9 VP OC REACTOR COOLANT PUMP SEAL WATER RETURN, OUT-SIDE CONTAINMENT ISOLATION VALVE l
i 1 CH RV 1203 11715 CWM-095C 1 0F 2 F4 RELIEF VALVE 2.000 2 C
SP O
LETDOWN RELIEF VLV DOWNSTREAM OF REGEN HX, RV DISCHARGE TO PRESSURIZER RELIEF TANK 1-CH-RV-1382B 11715-CBM 0955 10F 2 C7 RELIEF VALVE 2.000 2 C
SP O
SEAL WATER.'AT EXCHANGER RELIEF VALVE, RV DISCHARGE TO VodME CONTROL TANK 1 CH TV 1204A 11715 cam-095C 1 0F 2 E3 A0 CLOBE 2.000 2 A CIV EV C
5 FS C
5 LT C
ST C
5 VP OC LETDOWN CONTROL FROM REGEN MX, INSIDE CONTAINMENT ISOLATION VALVE 1-CH-TV-1204B 11715-CBM-095A 4 0F 4 C3 A0 GLOBE 3.000 2 A CIV EV C
5 F5 C
5 LT C
ST C
5 VP OC LETDOWN CONTROL FROM REGEN NX, QUTSIDE CONTAINMENT ISOLATION VALVE l
l l
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14 0F 78 NORTH ANNA UNIT 1 REVISION: 07 SECOND INSPECTION INTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM - VALVE TABLE NC ISO REL CS ALT VALVE DRAWING SHEET DRWG VALVE VALVE ASME IW VALVE TEST TEST REQ JUST TEST NUMBER NUMBER NLMBER COOR TYPE SIZE CLASS CAT TYPE TYPE POS V-CSV-VCh-1-CV-004 11715 CeM 092A 2 0F 2 A5 MANUAL GATE 8.000 2 AE CIV LT C
CONTAINMENT VACUUM EJECTOR SUPPLY, OUTSIDE CONTAINMENT ISOLATION VALVE l
1-CV-08 11715 CBM-092A 2 OF 2 53 CHECK VALVE 2.000 2 C
CV 0
20 CnNTAINMENT VACUUM SYSTEM ISOLATION CHECK bT l
1 CV-14 11715-CeM 092A 2 0F 2 C3 CHECK VALVE 2.000 2 C
CV 0
20 CONTAINMENT VACUUM SYSTEM ISOLAfl0N CHECK VALVE 1-CV-TV-100 11715-CeM-092A 2 OF 2 A3 A0 SFLY 8.000 2 AE CIV LT C
VP OC CONTAINMENT VACULM EJECTOR, INSIDE CONTAIN-MENT ISOLATION VALVE 1-CV TV 150A 11715 COM-092A 2 0F 2 84 A0 GLOBE 2.000 2 A Civ EV C
FS C
LT C
ST C
54 VP OC "A" CONTAINMENT VACULM PLMP SUCTION ISOLATION VALVE, QUTSIDE CONTAINMENT ISOLATION VALVE 1 CV-TV 1508 11715-cam 092A 2 0F 2 B5 A0 GLOBE 2.000 2 A CIV EV C
FS C
LT C
ST C
54 VP OC "A" CONTAINMENT VACUUM PUMP SUCTION ISOLATION VALVE, QUTSIDE CONTAINMENT ISOLATION VALVE 1-CV-TV-150C 11715-CsM-092A 2 0F 2 C4 A0 GLost 2.000 2 A CIV EV C
FS C
LT C
ST C
54 VP OC "B" CONTAINMENT VACUUM PUMP SUCTION ISOLATION VALVE, OUTSIDE CONTAINMENT !$0LATION VALVE 1-CV-TV 1500 11715-CBM-092A 2 0F 2 C5 A0 GLOBE 2.000 2 A CIV EV C
FS C
LT C
ST C
54 VP OC "B" CONTAINMENT VACUUM PUMP SUCTION !$0LATION VALVE, CUTSIDE CONTAINMENT ISOLATION VALVE
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NORTH ANNA UNIT 1 REVISION: 07 SECOND INSPECTION INTERVAL DATE: 04/15/96 l
INSERVICE TESTING PROGRAM - VALVE TABLE NC l
ISO REL CS ALT VALVE DRAWING SHEET DRWG VALVE VALVE ASME IWV VALVE TEST TEST REQ JUST TEST NUMBER WUMBER NUMBER C00R TYPE SIZE CLASS CAT TYPE TYPE POS V-CSV-VCN-1-HV MOV 100A 11715 cas-006A 1 0F 3 D7 M0 BFLY 36.000 2 AE CIV LT C
VP OC CONTAINMENT PURGE SUPPLY, INSIDE CONTAINMEN)
ISOLATION VALVE 1-HV MOV-1000 11715 CSS-006A 1 0F 3 D7 M0 BFLY 36.000 2 AE CIV LT C
l VP OC CONTAINMENT PURGE SUPPLY, QUTSIDE CONTAINMENT ISOLATION VALVE 1-HV-MOV-100C 11715 CBS 006A 1 0F 3 C7 M0 BFLY 36.000 2 AE CIV LT C
w E
i CONTAINMENT PURGE EXHAUST, INSIDE CONTAIMENT ISOLATION VALVE 1 HV-MOV-1000 11715 Cte 006A 1 0F 3 C7 No BFLY 36.000 2 AE Civ LT C
l VP OC CONTAINMENT PURGE EXHAUST, OUTSIDE CONTAIN-MENT ISOLATION VALVE 1 HV MOV-101 11715 CBS-006A 10F 3 C7 M0 BFLY 8.000 2 AE CIV LT C
l VP OC CONTAINMENT PURGE BYPASS, OUTSIDE CONTAINMENT ISOLATION VALVE g
1 HV-Mov-102 11715-CBB-006A 1 0F 3 D7 MO BFLY 18.000 2 AE CIV LT C
l YP OC CONTAINMENT PURGE ALTERNATE SUPPLY, OUTSIDE CONTAINMENT ISOLATION VALVE 1-HV MOV-111A 11715-Cas 040C 10F 3 E8 M0 GATE 4.000 3 B
EV 0
ST 0
VP OC CONTROL ROOM CHILLER ISOLATION VALVE 1-HV MOV-111B 11715 CBB-040C 1 0F 3 C8 M0 GATE 4.000 3 8
EV 0
l ST 0
CONTROL ROOM CHILLER ISOLATION VALVE i
1 1 HV-MOV 111C 11715-CBS 040C 1 0F 3 D8 M0 GATE 4.000 3 B
EV 0
ST 0
CONTROL ROOM CHILLER ISOLATION VALVE 1 HV-MOV 113A 11715-CBB-040D 1 0F 3 E3 M0 GATE 4.000 3 8
EV O
ST 0
VP OC CONTROL ROOM CONDENSER WATER SYSTEM ISOLATION VALVE l
1 HV MOV-1135 11715-Cas-0400 1 0F 3 83 MO GATE 4.000 3 B
EV 0
ST 0
i VIRGIN!A POWER COMPANY PAGE:
62 0F 78 NORTH ANNA UNIT 1 REVISION: 07 SECONO INSPECTION INTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM - VALVE TABLE NC ISO REL CS ALT VALVE DRAWING SHEET DRWG VALVE VALVE ASME IW VALVE TEST TEST RE0 JUST TEST NUMBER NLMBER NUMBER COOR TYPE
$1ZE CLASS CAT TYPE TYPE POS V-CSV-VCN-BORON INJECTION TANK HIGH HEAD SI INLET VALVE 1 SI MOV 1867C 11715-cam-096A 3 or 3 E7 MO GATE 3.000 2 A CIV EV C
0 LT C
ST C
o VP OC BORON INJECTION TANK OUTLET TO RCS COLD LEG, OUTSIDE CONTAINMENT ISOLATION VALVE 1 SI-MOV-1867D 11715 CeM-0964 3 0F 3 D7 M0 GATE 3.000 2 A CIV EV C
0 LT C
ST C
0 VP OC BORON INJECTION TANK OUTLET TO RCS COLD LEG, OUTSIDE CONTAINMENT ISOLATION VALVE 1 SI-MOV 1869A 11715-CBM-096A 3 0F 3 C8 No GATE 3.000 2 A CIV EV C
23 0
23 LT C
ST C
23 0
23 VP OC HIGH NEAD $1 FROM CHARGING HEADER TO RCS NOT LEGS, CUTSIDE CONTAINMENT ISOLATION VALVE 1 SI-MOV-18698 11715-CBM-096A 3 0F 3 88 M0 GATE 3.000 2 A CIV EV C
23 0
23 LT C
ST C
23 0
23 VP OC HIGN HEAD $1 FROM CHARGING NEADER TO RCS NOT LEGS, OUTEIDE CONTAINMENT ISOLATION VALVE 1-$1-MOV-1885A 11715-CBM 096A 2 0F 3 C3 MO GLOBE 2.000 2 A
EV C
LT C
75 ST C
VP OC "A" LOW NEAD SI PUMP MINIMUM FLOW / TEST LINE ISOLATION 1-SI MOV-1885B 11715-cam-096A 2 0F 3 B3 No GLOBE 2.000 2 A
EV C
l LT C
75 l
ST C
VP JC "B" LOW HEAD $1 PUMP MINIMUM FLOW / TEST LINE ISOLATION 1-51 MOV 1885C 11715-CeM-096A 2 0F 3 03 MO GLOBE 2.000 2 A
EV C
LT C
75 ST C
VP OC
1 l
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VIRGINIA POWER COMPANT PAGE:
63 0F 78 NORTH ANNA UNIT 1 REVISION: 07 SECOND INSPECTION INTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM - VALVE TABLE NC ISO REL CS ALT VALVE DRAWING
$NEET DRWG VALVE VALVE ASME IW VALVE TEST TEST REQ JUST TEST NLMBER NUMBER NUMBER C00R TTPE
$1ZE CLASS CAT TTPE TTPE POS V-CSV-VCN-
"A" LOW NEAD St PLMP MINIMUM FLOW / TEST LIhE ISOLATION 1 SI MOV 18850 11715 cam-N 2 0F 3 B3 MO GLOBE 2.000 2 A
EV C
LT C
75 ST C
VP OC "B" LOW NEAD $1 PLMP MININLM FLOW / TEST LINE ISOLATION 1 $1 MOV-1890A 11715 CBM-096A 2 0F 3 07 M0 GATE 10.000 2 A CIV EV C
23 0
23 LT C
ST C
23 0
23 VP OC "A" LOW NEAD St PLMP NOT LEG DISCHARGE STOP VALVE, OUTSIDE CONTAINMENT ISOLATION VALVE 1-SI-MOV 1890s 11715. cam-096A 2 0F 3 D7 M0 GATE 10.000 2 A CIV EV C
23 0
23 LT C
ST C
23 0
23 VP OC "B" LOW NEAD SI PUMP NOT LEG DISCHARGE STOP VALVE, OUTSIDE CONTAINMENT ISOLATION VALVE 1-$1-MOV 1890C 11715 CBM 096A 2 0F 3 C8 No GATE 10.000 2 A CIV EV C
0 LT C
ST C
0 VP OC LOW NEAD $1 PUMPS COLD LEG DISCHARGE STOP VALVE, OUTSIDE CONTAINMENT ISOLATION VALVE 1-SI-MOV 1890D 117?S4.2M 096A 2 0F 3 C7 M0 GATE 10.000 2 A CIV EV C
0 l
LT C
ST C
0 VP OC LOW NEAD $1 PUMPS COLD LEG DISCHARGE STOP VALVE, OUTSIDE CONTAINMENT ISOLATION VALVE 1 SI RV 1845A 11715 cam-D96A 2 0F 3 D6 RELIEF VALVE
.750 2 C
SP O
"A" LOW NEAD $1 PUMP DISCHARGE RELIEF VALVE, l
RV DISCHARGE TO SAFEGUARDS AREA SUMP 1 51 RV 18458 11715-CBM 096A 2 0F 3 CT RELIEF VALVE
.750 2 C
SP 0
i LOW NEAD $1 NEADER TO COLD LEG RELIEF VALVE, RV O!$ CHARGE TO SAFEGUARDS AREA SUMP 1 SI RV 184hc 11715-CBM 096A 2 0F 3 C6 RELIEF VALVE
.750 2 C
SP 0
l l
l
RELIEF REQUEST V-3 l
I.
IDENTIFICATION OF COMPONENTS System
- Component Cooling i
Valve (s): 1-CC-84 1-CC-119 l
1-CC-154 l
Class
- 2 I
Category: AC Function: Containment Isolation Check Valves for the CC Supply to the Reactor Coolant Pump Thermal Barrier Coolers II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-1 stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valves are located inside containment and their systems are required during power operation, they cannot-be tested every three months.
Performing a leakage /back pressure test requires isolating the component cooling water supply line and installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated i
February 9, 1996 (TAC NOS. M94081 and M94082).
(
l 2-45 N1PVR7 Revision 7 April 15, 1996
i i
l RELIEF REQUEST V-3 (Cont.)
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowanle administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the Initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
)
l 2-45a N1PVR7 Revision 7 April 15, 1996
i i
i RELIEF REQUEST V-10 I.
IDENTIFICATION OF COMPONENTS
[
System
- Chemical & Volume Control Valve (s): 1-CH-322 1-CH-336 1-CH-380 1-CH-330 1-CH-358 1-CH-402 Class
- 1 for 1-CH-330, 336, 358 and 380 2 for 1-CH-122 and 402 4
l Category: AC for 1-CH-322, 330 and 402 C
for 1-CH-336, 358 and 380 Function: Charging Supply and Return Isolation Check j
Valves
]
]
II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and 3
cold shutdowns, part-stroke at cold shutdowns and full-l stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only method to verify closure is to perform a leakage /back pressure test.
Since the valves are located inside containment and their systems are required during power operation, they cannot be tested every three months.
Valves 1-CH-336, 358 and 380 are in the RCP seal water supply lines.
Seal flow is used during cold shutdown to reduce RCS leakage and to float the RCP seals, therefore, these valves cannot be tested closed during cold shutdowns.
These valves will be back pressure tested every reactor refueling.
Valve 1-CH-322 is in the normal charging line to the RCS.
This line cannot be drained during short cold shutdowns because charging flow is often maintained.
Valve 1-CH-402 is in the RCP seal water return line.
As stated above, seal flow is maintained during cold shutdowns.
Valve 1-CH-330 is the charging supply to loop fill header, inside containment isolation valve.
A leakage / backseat test inside containment is required 2-48 N1PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-10 (Cont.)
to verify closure for valve 1-CH-330.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled
" Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
Valves 1-CH-322, 330 and 402 are containment isolation valves and are leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for j
the containment isolation valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the Appendix J, Option B,
)
program, which can be up to a test interval of at least i
once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extenced, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test l
results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month 4
periodic test frequency.
The plant's predictive maintenance program meets the i
requirements of draft OM Sunsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
i dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying L
inservice testing, examination, and preventative i
2-49 i
N1PVR7 Revision 7 April 15, 1996
~.
.~
1 i
RELIEF REQUEST V-10 (Cont.)
maintenance activities.
The results of the predictive maintenance program analysea will be considered on a valve by valve basis before the test intervals are extended.
'r IV.
ALTERNATE TESTING Valves 1-CH-336, 358 and 380 will be exercised to the closed position every reactor refueling.
Valves 1-CH-322, 330 and 402 will be exercised to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
i 1
2-49a N1PVR7 Revision 7 April 15, 1996
I i
RELIEF REQUEST V-16 I.
IDENTIFICATION OF COMPONENTS System
- Fire Protection valve (s): 1-FP-272 i
Class
- 2 Category: AC i
Function: Containment Isolation Check Valve for the Fire Protection Supply Line II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF This check valve must seat upon reversal of flow in order to fulfill it's safety function.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valve is located inside containment, it cannot be tested every three months.
Valve 1-FP-272 is in the containment fire protection system.
Testing this valve will render the fire protection system inoperable.
Performing a leakage /back pressure test requires isolating the fire protection supply line and installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test i
Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
This valve serves a containment isolation function and is leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for this l
valve will be allowed to increase from the Code allowed 2-51 3
N1PVR7 Revision 7 April 15, 1996 l
1 i
l RELIEF REQUEST V-16 (Cont.)
reactor refueling test interval to the leakage test interval determined by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valve will be added to the plant's check valve predictive maintenance program and 3) the valve must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program require 3 that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's ellowable administ.ative limits.
If the leakage test r
results are unacceptable in subsequent tests, the test frequency will revt.rt back to the initial 24 month l
periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING j
Exercise to the closed position during the Appendix J, 1
Option B leakage test but not less frequently then once every 60 months.
2-51a l
N1PVR7 Revision 7 1
April 15, 1996
i i
i l
RELIEF REQUEST V-20 I.
IDENTIFICATION OF COMPONENTS i
System
- Post Accident Hydrogen Removal
)
Valve (s): 1-CV-8 1-HC-14 l
1-CV-14 1-HC-18 l
l Class
- 2 l
Category: AC for 1-HC-14 and 18 i
C for 1-CV-8 and 14 i
Function: Hydrogen Control System Supply and Return Isolation Check Valves II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke
]
exercising is impractical during power operation and 1
cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold i
shutdowns, full-stroke exercise during raactor refuelings.
III. BASIS FOR RELIEF i
Check valves 1-CV-8 and 14, 1-HC-14 and 18 must open to sample hydrogen to fulfill their safety functions.
To test valves 1-HC-14 and 18 either partially or full open, and to test valves 1-CV-8 and 14 full open requires a significant manipulation of the hydrogen recombiner system.
In addition, should a containment pressurization event occur while operating the hydrogen recombiners, there is a possibility of exceeding the design pressure of the recombiner system, which may result in a loss of recombiner function.
The hydrogen recombiner is a low pressure system intended for use after the containment depressurizes.
Valves 1-CV-8 and 14 can be tested to the partially open position every quarter using the containment vacuum pumps while maintaining the recombiner system isolated from the containment atmosphere.
These valves will be verified open at least once every 18 months during the surveillance testing of the hydrogen recombiner system as required by Technical Specification Section 4.6.4.2.
The small increase in l
safety gained by testing during normal operation or cold shutdown does not justify the potential risk of 2-53 N1PVR7 Revision 7 April 15, 1996
i RELIEF REQUEST V-20 (Cont.)
overpressurizing the hydrogen recombiner system, or the added burden of disrupting normal plant operations to i
manipulate the recombiner system and performing the test on the more frequent basis.
l Check valves 1-HC-14 and 18 provide containment i
isolation.
These check valves must seat upon reversal of flow in order to fulfill their safety functions.
i The only exercise method to verify closure is to i
perform a leakage /back pressure test.
Since the valves are located inside containment, they cannot be tested i
avery three months.
Performing a leakage /back pressure i
test requires installing temporary leakage test i
equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
These valves serve a containment isolation function and are Isakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as j
determined by the plant's Probabilistic Safety Analysis (PSA).
]
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two 2-54 N1PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-20 (Cont.)
1 consecutive periodic (24 month) as-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, l
entitled " Check Valve Condition Monitoring Program,"
l dated June, 1995.
The predictive maintenance program l
requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Check valves 1-HC-14 and 18 will be exercised to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
Check valves 1-CV-8 and 14, 1-HC-14 and 18 will be i
exercised to the full open position at least once every 18 months.
Valves 1-CV-8 and 14 will be exercised to the partially open position once every three months.
l 2-54a N1PVR7 Revision 7 April 15, 1996
i RELIEF REQUEST V-21 i
I.
IDENTIFICATION OF COMPONENTS System
- Instrument Air Valve (s): 1-IA-55 1-IA-149 Class
- 2 Category: AC Function: Instrument Air Supply and Return Line Containment Isolation Check Valves II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and i
cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor i
refuelings.
III. BASIS FOR RELIEF These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valves are located inside containment, they cannot be tested every three months.
Valve 1-IA-55 is in the instrument air supply line to containment.
Testing this valve renders the instruments and components supplied by instrument air inside containment inoperable.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for check Valves Verified Closed by Leak Testing."
These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated 2-55 N1PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-21 (Cont.)
i February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from i
i the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the i
Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable 4
level of quality and safety because:
J l
1) the Appendix J, Option B, leakage test program is i
performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and I
l 3) the valves must have a low risk significance as j
determined by the plant's Probabilistic Safety Analysis j
(PSA).
i As stated above, the Appendix J, Option B, leakage test l
program is performance based.
Before the leakage test j
interval can be extended, the program requires that a j
containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where i
the results of each test are within a licensee's allowable administrative limits.
If the leakage test
[
j results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month i
periodic test frequency.
i l
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed i
in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
2-55a N1PVR7 Revision 7 April 15, 1996 H
RELIEF REQUEST V-28 I.
IDENTIFICATION OF COMPONENTS System
- Reactor Coolant Valve (s): 1-RC-149 Class
- 2 Category: AC Function: Containment Isolation Check Valve for the l
Primary Grade Water Supply Line II. IMPRACTICAL. CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF This check valve must seat upon reversal of flow in order to fulfill it's safety function.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valva is located inside containment, it cannot be tested every three months.
Valve 1-RC-149 is in the primary grade water supply line to pressurizer relief tank (PRT) and the #2 seal stand pipes.
This line canrot be drained during short cold shutdowns because the PRT is required during normal cold shutdowns.
Standpipe level must be maintained when the reactor coolant system is pressurized to control leakage.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
This valve serves a containment isolation function and is leakage tested as required by the 10 CFR 50, 2-58 N1PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-28 (Cont.)
Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by J etter dated l
February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for this valve will be allowed to }ncrease from the Code allowed reactor refueling test liWerval to the leakage test interval determined by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valve will be added to the plant's check valve predictive maintenance program and 3) the valve must have a low risk significance as detarmined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
2-58a N1PVR7 Revision 7 April 15, 1996
l RELIEF REQUEST V-40 i
I.
IDENTIFICATION OF COMPONENTS i
System
- Safety Injection Valve (s): 1-SI-106 i
1-SI-110 Class
- 2 Category: AC Function: Accumulator Nitrogen Supply and Make Up Lines Containment Isolation Check Valves II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2 (d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valves are located inside containment, they cannot be tested every three months.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the 2-65 N1PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-40 (Cont.)
I Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
l The proposed alternative will provide an acceptable level of quality and safety because:
l
)
1) the Appendix J, Option B, leakage test program is 4
performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test L
results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
-IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
2-65a N1PVR7 Revision 7 April 15, 1996
_m_
.. _ _ _ -.. _ ~ _.
i-l RELIEF REQUEST V-42 4
1 I.
IDENTIFICATION OF COMPONENTS System Safety Injection l
l Valve (s):
1-SI-125 1-SI-144 1
1-SI-127 1-SI-159 1-SI-142 1-SI-161 I
Class 1
Category:
C l
Function:
Accumulator Discharge check Valves i
II. IMPRACTICAL CODE REQUIREMENTS OM Part 10, Section 4.3.2.4(a) - This section states in i
part that, "The necessary valve obturator movement shall be demonstrated by exercising the valve and observing that either the obturator travels to the seat on cessation or reversal of flow, or opens to the a
position required to fulfill its function, as specified i
in para.
1.1, or both.
Observation may be by observing i
a direct indicator such as a position indicating i
device, or by other indicator (s) such as changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means."
This section implies that the techniques used to verify obturator 1
movement be applied to every valve on a test frequency j
that is practical.
i III. BASIS FOR RELIEF l
l These valves cannot be partial or full flow tested i
during normal operation because the accumulator j
pressure (600 to 650 puig) is below Reactor Coolant System pressure and the injection of borated water j
would upset the reactor coolant chemistry.
I During cold shutdown, the RCS pressure may still prevent full flow testing.
Also, discharging the i
accumulators would challenge the Low Temperature Overpressure Protection System.
i A partial flow test is not practical during cold j
shutdowns.
The flow from the accumulator is dependent j
on the pressure differential between the accumulator and the RCS.
The pressure differential cannot be 1
controlled to the fine degree necessary to preclude i
dumping too much water into the pressurizer, thus 2-67 N1PVR7 Revision 7 April 15, 1996 l
RELIEF REQUEST V-42 (Cont.)
making it difficult to control pressurizer level while pressure is being reduced during cooldown.
Also, the RCS temperature is high during short cold shutdowns.
Dumping cold accumulator water into the RCS could thermally shock the system.
Non-intrusive techniques are used to verify obturator movement for the SI accumulator discharge check valves.
These techniques provide a " positive means" for verifying obturator movement, however, due to the burden of applying these techniques in the field, a sampling program will be used as described in the alternate testing section.
The accumulators must be isolated to verify closure using back flow for valves 1-SI-127, 144 and 161.
The small increase in safety gained by performing the back seat check valve tests every cold shutdown versus every reactor refueling does not justify the added burden of the iner *, sed test frequency.
IV. ALTERNATE TESTING During the first refueling outage where nonintrusive j
techniques are used, all valves in the group will be tested to verify that the techniques verify valve obturator movement.
During subsequent refueling 1
outages, flow testing will be performed on all valves in the group, but the nonintrusive techniques will be applied only to one sample valve in each group, on a rotating basis, unless indications of problems are identified.
In this case, all valves in the group will be subjected to the nonintrusive techniques.
Valves 1-SI-127, 144 and 161 are closest to the reactor coolant i
system and will be in one group, and valves 1-SI-125, 142 and 159 will be in the other group.
This sampling plan will follow the recommended alternative testing method described in NUREG 1482, Section 4.1.2.
The flow test will consist of discharging the accumulator from an initial pressure that is less than 600 psig.
Discharging the accumulator at a lower initial pressure reduces the severity of the transient and the risk of adverse effects on the reactor coolant system.
The low pressure test should provide enough flow to force the disk to the full open position.
Valves 1-SI-127, 144 and 161 will'be confirmed closed every reactor refueling.
2-68 N1PVR7 Revision 7 April 15, 1996
l
)
I f
i I
RELIEF REQUEST V-43 i
I.
IDENTIFICATION OF COMPONENTS System
- Safety Injection Valve (s): 1-SI-79 1-SI-185 1-SI-211 1-SI-90 1-SI-201 1-SI-213 1-SI-95 1-SI-206 l
1-SI-99 1-SI-207 l
1-SI-103 1-SI-209 Class
- 1 for 1-SI-90, 95, 99, 103, 201, 209, 211 and 213 2 for 1-SI-79, 185, 206, 207 Category: AC for 1-SI-79, 90, 185, 201, 206 and 207 C
for 1-SI-95, 99, 103, 209, 211 and 213 Function: Valves 1-SI-79, 90, 185, 201, 206 and 207 -
Containment Isolation Check Valves Valves 1-SI-95, 99, 103, 209, 211 and 213 -
Hot Leg Admission Check Valves II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF These safety injection check valves must open and close to fulfill their safety functions.
They cannot be full or part-stroke exercised to the open position during power operation because this would cause safety injection flow into the reactor coolant system which would thermally shock the injection system and cause unnecessary plant transients.
Flow cannot be established in the low head injection lines during normal plant operation.
During cold shutdown, the reactor coolant system pressure still prevents full design flow.
Also, a partial or full stroke test could cause an overpressurization of the reactor coolant 4
system and force a safety system to function.
With low head pump flow, the hot leg injection valves 1-SI-95, 99, 103, 209, 211 and 213 will be 2-69 N1PVR7 Revision 7 April 15, 1996
{
l-RELIEF REQUEST V-43 (Cont.)
nonintrusively monitored to the open position using a sampling plan every reactor refueling.
The sampling plan will follow the recommended alternative testing method described in NUREG 1482, Section 4.1.2.
During subsequent testing, nonintrusive verification will be performed for only one valve of the group on a rotating l
schedule mach time the testing is performed, and the balance of the group will be flow tested.
If problems are found with the sample valve that are determined to affect the operational readiness of the valve, all valves in the group must be tested using nonintrusive techniques during the same outage.
The check valves in this relief request must also seat upon reversal of flow in order to fulfill their safety functions.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valves are located inside containment and their systems are required during power operation, they-cannot be tested every three months.
Performing a leakage /back pressure test requires draining the safety injection lines and installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
valves 1-SI-79, 90, 185, 201, 206 and 207 serve a containment isolation function and are leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. Mv4081 and M94082).
Per this relief request, the closure test interval for the containment isolation valves listed above will be allowed to increase from the code allowed reactor refueling test interval to the leakage test interval determined for each valve by the i
Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2-69a N1PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-43 (Cont.)
2) the
.1ves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis
?
(PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a i
containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where i
the results of each test are within a licensee's l
allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test i
frequency will revert back to the initial 24 month l
periodic test frequency.
The plant's predictive maintenance program meets the 4
}
requirements of draft OM Subsection ISTC, Appendix II, j
entitled " Check Valve Condition Monitoring Program,"
l dated June, 1995.
The predictive maintenance program j
req' tires that the check valves be grouped and analyzed in order to establish the basis for specifying i
inservice testing, examination, and preventative maintenance activities.
The results of the predictive 4
i maintenance program analyses will be considered on a j
valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING i
Valves 1-SI-79, 90, 185, 201, 206 and 207 will be exercised to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months, and will be exercised to the open position every reactor refueling.
Valves 1-SI-95, 99, 103, 209, 211 and 213 will be exercised to the open and closed positions every reactor refueling.
2-69b N1PVR7 Revision 7 April 15, 1996
l l
l RELIEF REQUEST V-46 l
I.
IDENTIFICATION OF COMPONENTS System
- Vacuum Priming
}
Valve (s): 1-VP-12 f
Class
- 2 Category: AC 4
Function: Containment Isolation Check Valve for the Condenser Air Removal Discharge Line l
II. IMPRACTICAL CODE REQUIREMENTS l
OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke
[
exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdewns and full-strobe during reactor refuelings, of if any exercising j
is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor l
refuelings.
l III. BASIS FOR RELIEF This check valve must seat upon reversal of flow in order to fulfill it's safety function.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valve is located inside containment, it cannot be tested every three months.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitlel " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
This valve serves a containment isolation function and is leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for this valve will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined by the Appendix J, Option B, program, which can be up to a test interval of at least 2-72 N1PVR7 Revision 7 April 15, 1996
. - _... _ _..._. _ _... ~.
RELIEF REQUEST V-46 (Cont.)
once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valve will be added to the plant's check valve l
predictive maintenance program and 3) the valve must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
i As stated above, the Appendix J, Option B, leakage test l
. program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where i
the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test j
frequency will revert back to the initial 24 month periodic test frequency.
l The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, l
entitled " Chock Valve condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the c'.teck valves be grouped and analyzed in order to establish the basis for specifying i
inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING l
l Exercise to the closed position during the Appendix J, l
Option B leakage test but not less frequently then once every 60 months.
l l
2-72a N1PVR7 Revision 7 April 15, 1996 l
RELIEF REQUEST V-59 Relief Request Withdrawn
~
N1PVR7 Revision 7 April 15, 1996
l l
j l
1 THIS PAGE IS INTENTIONALLY BLANK.
l I
l l
2-84 N1PVR7 Revision 7 April 15, 1996
I l
RELIEF REQUEST V-62 l
l l
I.
IDENTIFICATION OF COMPONENTS System
- Component Cooling Valve (s): 1-CC-546 1-CC-559 1-CC-572 Class
- 2 Category: AC Function: Component Cooling Water Supply to Recirculation Air Cooling coils Containment Isolation Check Valves II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings, i
III. BASIS FOR RELIEF l
These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only
)
exercise method to verify closure is to perform a leakage /back pressure test which would involve isolating the containment air cooling coils.
The containment recirculation air cooling coils are required for normal operation to maintain containment temperature below technical specification limits.
Therefore, these valves cannot be tested every three months.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling i
Outage for Check Valves Verified closed by Leak Testing."
i i
2-87 N1PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-62 (Cont.)
These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test' interval to the leakage test interval determined for each valve by the l
Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and t
3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
j As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
2-87a N1PVR7 Revision 7 April 15, 1996
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RELIEF REQUEST V-62 (Cont.)
l IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
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N1PVR7 Revision 7 April 15, 1996 l
.... ~. -.... -. - ~. -. -.. - -... -..... _ -. - -. - -... - - -. -... -. - - - _. -... ~..
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l RELIEF REQUEST V-66 i
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r Relief Request Withdrawn I
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2-92 N1PVR7 Revision 7 April 15, 1996 i
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I RELIEF REQUEST V-70 I.
IDENTIFICATION OF COMPONENTS System
- Component cooling Valve (s) : 1-CC-193 1-CC-198 Class
- 2 Category: AC 1
Function: Component Cooling Water Supply to RHR Heat Exchanger Containment Isolation Check Valves x
II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke 1
exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-j stroke during reactor refuelings, of if any exercising i
is impractical during power operations and at cold I
shutdowns, full-stroke exercise during reactor 1
refuelings.
III. BASIS FOR RELIEF Valves 1-CC-193 and 1-CC-198 are check valves in the component cooling lines to the RHR heat exchangers and must clcse for containment isolation and open to allow RHR flow.
To establish full flow through Valves 1-CC-193 and 198 for testing to the full open position, increased component cooling flow must be directed i
through the RHR heat exchangers.
During cold shutdown and reactor refueling when fuel is in the vessel, increased flow to the RHR heat exchangers reduces the volume of the RCS inventory by reducing the RCS temperature.
This reduction in volume can be large enough as to cause excessive makeup demands to the RCS.
Therefore, the full flow test should be performed during reactor refueling when the vessel is defueled.
The vessel is defueled every refueling outage.
The only exercise method to verify closure is to perform a leakage /back pressure test.
These lines cannot be drained for back pressure testing because the RHR system is needed during cold shutdown to control the RCS temperature.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
2-97 N1PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-70 (Cont.)
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, l
Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 montha.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying 2-97a N1PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-70 (Cont.)
inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months, and exercise to the open position every reactor refueling.
i l
i 2-97b N1PVR7 Revision 7 April 15, 1996
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i ATTACHMENT 5 1
i NORTH ANNA UNIT 2 REPLACEMENT PAGES TO THE IST PROGRAM i
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I 4
1
2.3 VALVE INSERVICE TESTING PROGRAM DESCRIPTION 2.3.1 PROGRAM DEVELOPMENT PHILOSOPHY The North Anna Unit 2 Valve Inservice Testing (IST)
Program has been established to meet the requirements j
of the 10CFR50, Section XI of the ASME Boiler and i
Pressure-Vessel Code, Subsection IWV and Technical Specifications.
l North Anna Unit 2 Technical Specification 4.0.5 states l
that Inservice Testing of ASME Code Class 1, 2 and 3 valves shall bs performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10CFR50, Section i
50.55a(f), except where specific written relief has been granted by the Commission pursuant to 10CFR50, Section 50.55a (f) (6) (i).
10CFR50, Section 50.55a(f) (4) (iv) states that inservice examinations of components, test of pumps and valves, and system pressure tests, may meet the requirements set forth in subsequent editions and addenda of ASME Section XI that have been approved by the NRC, subject to Commission approval.
North Anna Unit 2 will test those valves that fall under the scope of ASME Section XI using Subsection IWV of the 1989 Edition.
The 1989 Edition of Subsection IWV references OM Part 10, 1
Edition OM-87, ASME/ ANSI, Operation and Maintenance of Nuclear Power Plants, Addenda OMa-1988.
The scope of the program includes ASME Section XI Class 1, 2 and 3,
)
l and certain non-Code class valves that are required to i
perform a specific function in shutting down the reactor or in mitigating the consequences of an accident.
OM Part 10 defines the rules and requirements of inservice testing of Code Class 1
,2, and 3 valves and i
states that each specific valve to be tested by the rules of this subsection shall be identified by the owner and listed in the plant records.
The purpose of the IST program is to identify the valves that are considered by V!.rginia Electric and Power Company as having a safety function and are therefore subject to the testing requirements of OM Part 10.
The intent of the code is to assess operational readiness and detect potentially adverse changes in the mechanical condition of these valves.
The relief requests for the Valve Inservice Test l
Program identify Code requirements considered to be j
l impractical, provide technical basis for the request j
i l
2-37 I
N2PVR7 Revision 7 April 15, 1996 1
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and propose alternate testing when warranted.
Leak rate testing for containment isolation valves is performed in'accordance with 10CFR50, Appendix J, which imposes specific requirements, and in accordance with OM Part 10, Paragraphs 4.2.2.3(a) and 4.2.2.3(f).
Appendix J satisfies the testing requirements of OM Part 10, Paragraph 4.2.2.2.
5 2.3.2 PROGRAM IMPLEMENTATION The Valve Inservice Testing Program will be executed as part of the normal plant surveillance program which is implemented by periodic tests.
The Operability Tests will verify:
1)
The valve responds to control commands.
2)
The valve stroke time is within specific limits.
l 3)
Remote valve position indication accurately reflects the valve position.
Failsafe valves will be tested by observing valve operation upon loss of actuating power.
In most cases, this can be accomplished using normal control circuits.
l Safety and relief valve setpoints are tested in l
accordance with OM Part 1, 1987 Edition.
Those valves which are scheduled to be exercised during cold shutdown are subject to the requirements of OM i
Part 10, Paragraph 4.2.1.2 (f) which states that:
" valve exercising during cold shutdown shall commence within 48 hr of achieving cold shutdown, and continue until all testing is complete or the plant is ready to return to power.
For extended outages, testing need not be commenced in 48 hr provided all valves required to be tested during cold shutdown will be tested prior to plant startup.
However, it is not the intent of this Part to keep the plant in cold shutdown in order to j
complete cold shutdown testing."
Certain valves cannot be full stroke exercised during normal operation following maintenance.
l These valves are described in the relief requests 2-38 N2PVR7 Revision 7 April 15, 1996
~ _ ~
l i
j and cold shutdown justifications.
If maintenance l
cannot be deferred to a shutdown condition, then l
an engineering evaluation must be performed prior to the maintenance to determine the effect of the maintenance on valve operability.
If the i
evaluation shows that operability will not be affected, then no post maintenance testing will be l
l required.
A partial stroke test will be performed i
if possible, i
l l
2.3.3 PROGRAM ADMINISTRATION The Engineering staff at North Anna is responsible for the administration of the Valve Inservice Testing Program.
The Operations staff is responsible for performing the periodic tests as required by this program.
The Valve Inservice Testing Program is implemented by Station Periodic 3
l Test Procedures.
2.3.4 VALVE INSERVICE TESTING TABLE 1
i The Valve Inservice Testing Table provides a list of North Anna Unit 2 ASME Section XI valves and l
their testing requirements.
The following is a l
brief explanation of the table headings and I
abbreviations.
c valve Nn=her - Each valve has a unique identification number.
Drawina Number - Classification Boundary Drawing Number.
Sheet Number - Classification Boundary Drawing Sheet Number.
Dwa Coor - Drawing Coordinate of valve.
Valve Tvoa - The type of valve.
Some abbreviations are used for valve type which are explained tilow.
l AO
- air operated SO
- solenoid operated DIA
- diaphragm MO
- motor operated MAN
- manual i
BFLY - butterfly i.
2-39 N2PVR7 Revision 7 April 15, 1996 l
j Valve Size - Valve size.
1 Valve Punction - A brief description of the function of the valve.
1
{
ASME Class - ASME Code Class of each valve.
Note:
NC is for non-class valves.
ASME XI IWV Cateaorv - Categories as defined by j
Categories determine test requirements.
Valves marked with an "E" are passive valves.
Test sosition - The following abbreviations are used to describe normal valve positions to which the valves are tested (including the valve safety position):
0
- open C
- closed OC - open and closed Isolation valve Tyne - Valves that are assigned a maximum leakage.
The following abbreviations are used to describe the isolation valve types:
CIV - Containment Isolation Valve subject to
.Rppendix J leakage testing PIV - Pressure Isolation Valve which protects low pressure safety related piping from RCS pressure C&P - Valves that serve both CIV and PIV functions Test Reauired - Testing requirements identified for the valves are identified here.
ST - Stroke times shall be measured per OM Part 10, Paragraph 4.2.1.4 or as modified by a specific relief request.
EV - Exercise valve for operability at least once every 3 months per OM Part 10, Paragraph 4.2.1.4 or as modified by a specific cold shutdown or reactor refueling justification which is allowed by OM Part 10, Section 4.2.1.2.
LT - Leak test shall be performed per OM Part 10, Section 4.2.2 or as modified by specific relief request.
2-40 N2PVR7 Revision 7 April 15, 1996
. - - =.
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I CV - Check valves shall be exercised at least once
)
every 3 months per OM Part 10, Paragraph 4.3.2.1 or as modified by a specific cold shutdown or reactor refueling justification which is allowed by OM Part 10, Section 4.2.2.2.
VP - Valve position indication shall be verified per OM Part 10, Paragraph 4.1 or as modified by a specific relief request.
l SP - Set points of safety and relief valves shall l
be tested per OM Part 1, 1987 Edition or as modified by a specific relief request.
FS - Valves with fail-safe actuators shall be l
l tested by observing the operation of the valves l
upon loss of the actuator power at least once l
every 3 months per OM Part 10, Paragraph 4.2.1.6 or as modified by a specific cold shutdown or reactor refueling justification which is allowed by OM Part 10, Section 4.2.1.2.
l l
Relief Reauest - The relief requests corresponding to the numbers in the table are in Section 2.3.5.
Cold shutdown Justification - The cold shutdown justifications corresponding to the numbers in the table are in Section 2.3.6.
1 I
Non-Code Alternative Testina Descrintion - The I
I i
non-code alternative testing descriptions corresponding to the numbers in the table are in Section 2.3.7.
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N2PVR7 Revision 7 l
April 15, 1996 l
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2-42 N2PVR7 Revision 7 April 15, 1996
l VIRGINIA POWER COMPANY PAGE:
9 0F 79 NORTH ANNA UNIT 2 REVISION: 07 l
SECOND INSPECTION INTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM - VALVE TABLE l
VALVE DRAWING SHEET DRWG VALVE VALVE ASME IW VALVE TEST TEST REQ JUST TEST i
NUMBER NUMBER WUMBER COOR TYPE
$1ZE CLASS CAT TYPE TYPE POS V-CSV-VCN-I 2 CH-208 12050-CsM 0958 2 0F 2 D7 CHECK VALVE 3.000 2 C
cv c
48 0
48 1
1 "C" CHARGING PUMP DISCHARGE CHECK VALVE 2-CH-260 12050-cam 095C 2 0F 2 58 CHECK VALVE 2.000 1 C
CV C
to I
"A" RC PLMP SEAL WATER SUPPLY, INSIDE CONTAINMENT ISOLATION CHECK VALVE 2-CH 284 12050-cam 095C 2 0F 2 87 CHECK VALVE 2.f40 ~
C CV C
10 "B" RC PLMP SEAL WATER SUPPLY, INSIDE i
CONTAINMENT ISOLATION CHECK VALVE 2 CH-308 12050-CtM-095C 2 0F 2 35 CHECK VALVE 2.000 1 C
CV C
10 "C" RC PLMP SEAL WATER SUPPLY, INSIDE
)
CONTAINMENT ISOLATION CHECK VALVE 2-CH-331 12050-C5M-095C 2 0F 2 F4 CHECK VALVE
10 LT C
RC PUMP SEAL WATER RETURN, INSIDE CONTAINMENT i
ISOLATION CHECK VALVE 1
2-CH-332 12050 ceM-095C 1 0F 2 A5 CHECK VALVE 2.000 1 AC CIV CV C
10 LT C
CHARGING SUPPLY TO LOOP FILL HEADER, INSIDE CONTAINMENT ISOLATION CHECK VALVE 2 CH 335 12050-COM 095C 1 0F 2 D4 CHECK VALVE 3.000 2 AC CIV CV C
10 LT C
MAIN CHARGING SUPPLY HEADER, INSIDE CONTAIN-MENT ISOLATION CHECK VALVE 2-CH-495 12050-tam-0958 1 0F 2 86 CHECK VALVE 2.000 2 AC CV C
73 0
39 CHARGING PUMP RECIRC AND RCP SEAL WATER RETURN LINE !$0LAT10N CHECK VALVE 2-CH-FCV-2113A 12050-CSM-0958 1 0F 2 C3 A0 GATE 1.000 3 8
EV O
FS 0
ST 0
VP DC ALTERNATE EMERGENCY BORATION LINE FLOW CONTROL VALVE 2-CH FCV-2114A 12050-CBM-095B 1 0F 2 D4 A0 GLOBE 1.000 3 B
EV C
FS C
ST C
l VP OC PRIMARY GRADE WATER FLOW CONTROL VALVE l
2-CH-FCV-2160 12050-CBM 095C 1 0F 2 A4 A0 GLOBE 2.000 2 AE CIV LT C
[
VP OC
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VIRGINIA POWER COMPANY PAGE:
13 0F 79 l
NORTH ANNA UNIT 2 REVIS10N: 07 SECONO INSPECTIDW IkTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM VALVE TABLE 1
VALVE DRAWING SHEET DRWG VALVE VALVE ASME IWV VALVE TEST TEST REQ JUST TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT TYPE TYPE POS V.
CSV-VCN-CHARGING PUMP RECIRCULATION HEADER ISOLATION VALVE 2-CH-MOV 2380 12050 COM-095C 2 0F 2 F4 M0 GATE 3.000 2 A CIV EV C
9 LT C
ST C
9 VP OC REACTOR COOLANT PUMP SEAL WATER RETURN, INSIDE CONTAINMENT ISOLATION VALVE 2 CH-MOV 2381 12050-CBM-0955 1 0F 2 C8 M0 GATE 3.000 2 A CIV EV C
9 LT C
ST C
9 VP OC REACTOR COOLANT PUMP SEAL WATER RETURN, OUT.
SIDE CONTAINMENT ISOLATION VALVE 2 CH-RV-2203 12050-CSM-095C 1 0F 2 F3 RELIEF VALVE 2.000 2 C
SP O
l LETDOWN RELIEF VLV DOWNSTREAM OF REGEN MX, RV i
j DISCRARGE TO PRESSURIZER RELIEF TANK 2-CH RV 2382B 12050-CBM-0958 1 0F 2 C7 RELIEF VALVE 2.000 2 C
SP 0
(
SEAL WATER HEAT EXCHANGER RELIEF VALVE, RV DISCKARGE TO VOLUME CONTROL TANK 1
2 CH-TV-22D4A 12050-CBM-095C 1 0F 2 E3 A0 GLOBE 2.000 2 A CIV EV C
5 FS C
5 LT C
ST C
5 VP OC LETDOWN CONTROL FROM REGEN NX, INSIDE CONTAINMENT ISOLATION VALVE 1
1 2-CH TV 22D4B 12050 CBM-095A 2 0F 2 C3 A0 GLOBE 3.000 2 A CIV EV C
5 FS C
5 i
LT C
ST C
5 VP OC LETDOWN CONTROL FROM REGEN HX, OUTSIDE CONTAINMENT ISOLATION VALVE I
r i
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VIRGINIA POWER COMPANY PAGE:
14 OF 79 NORTH ANNA UNIT 2 REVISION: 07 SECOND INSPECTION INTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM - VALVE TABLE I
1 NC i
150 REL CS ALT VALVE DRAWING SHEET DeWG VALVE VALVE ASME IWV VALVE TEST TEST REQ JUST TEST NUMSER NUMBER NUMBER C00R TYPE SIZE CLASS CAT TYPE TYPE POS V-CSV-VCN-2-CV 004 12050-cam-092A 2 0F 2 A5 MANUAL GATE 8.000 2 AE Civ LT C
CONTAINMENT VACUUM EJECTOR SUPPLY, OUTSIDE CONTAINMENT ISOLATION VALVE 2-CV 08 12050-cam-092A 2 0F 2 B3 CHECK VALVE 2.000 2 C
CV O
20 l
CONTAINMENT VACUUM STSTEM ISOLATION CHECK VALVE 2 CV 15 12050 CBM-092A 2 0F 2 C3 CHECK VALVE 2.000 2 C
CV o
20 CONTAINMENT VACULM SYSTEM ISOLATION CHECK VALVE 2-CV TV-200 12050 CsM-092A 2 0F 2 A3 A0 BFLY 8.000 2 AE CIV LT C
VP OC CONTAINMENT VACUUM EJECTOR, INSIDE CONTAIN-MENT ISOLATION VALVE 2-CV TV-250A 12050-CSM-092A 2 0F 2 B4 A0 GLosE 2.000 2 A CIV EV C
FS C
LT C
ST C
55 VP OC "A" CONTAINMENT VACULM PUMP SUCTION ISOLATIDW VALVE, OUTSIDE CONTAINMENT ISOLATION VALVE 2 CV-TV 250s 12050-CBM-092A 2 0F 2 85 A0 GLOBE 2.000 2 A CIV EV C
FS C
LT C
ST C
55 VP OC "A" CONTAINMENT VACVA PUMP SUCTION ISOLATION VALVE, OUTSIDE CON *AINMENT ISOLATION VALVE 2-CV TV-250C 12050 CBM-092A 2 0F 2 C4 A0 CLOBE 2.000 2 A CIV EV C
FS C
LT C
ST C
55 VP OC "B" CONTAINMENT VACUUM PUMP SUCTION ISOLATION VALVE, OUTSIDE CONTAINMENT ISOLAfl0N VALVE 2-CV-TV 2500 12050-CBM 092A 2 0F 2 C5 A0 GLOBE 2.000 2 A CIV EV C
FS C
LT C
ST C
55 VP OC "B" CCWTAINMENT VACUUM PUMP SUCTION ISOLATION VALVE, OUTSIDE CONTAINMENT !$0LATION VALVE t
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VIRGIN!A POWER COMPANY PAGE:
3? 0F 79 WORTH ANNA UNIT 2 REVISION: 07 SECOND INSPECTION INTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM - VALVE TABLE NC
!$0 REL CS ALT VALVE DRAWING SHEET DRWG VALVE VALVE ASME IW VALVE TEST TEST REQ JUST TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT TYPE TYPE POS V-CSV-VCN-2-HV MOV-200A 11715 CBB 006A 2 0F 3 D3 M0 BFLY 36.000 2 AE CIV LT C
VP OC CONTAINMENT PURGE SUPPLY, INSIDE CONTAINMENT ISOLATION VALVE g
2-HV MOV 2008 11715 CBB-006A 2 OT 3 03 M0 BFLY 36.000 2 AE CIV LT C
l VP OC CONTAINMENT PURGE SUPPLY, OUTSIDE CONTAINMENT ISOLATION VALVE 2 HV-MOV-200C 11715-CBB-006A 2 0F 3 C3 M0 BFLY 36.000 2 AE CIV LT C
VP OC CONTAINMENT PURGE EXHAUST, INSIDE CONTAINMENT ISOLATION VALVE 2 HV MOV-2000 11715-CBS 006A 2 0F 3 C3 No BFLY 36.000 2 AE CIV LT C
VP OC CONTAINMENT PURGE EXHAUST, OUTSIDE CONTAIN-MENT ISOLATION VALVE 2-HV-MOV-201 11715 CBB-006A 2 0F 3 C3 M0 BFLY 8.000 2 AE Civ LT C
l CONTAINMENT PURGE BYPASS, OUTSIDE CONTAINMENT
!$0LATION VALVE 2 HV-M9V-202 11715-CBB-006A 2 0F 3 D3 M0 BFLY 18.000 2 AE CIV LT C
VP OC CONTAINMENT PURGE ALTERNATE SUPPLY, OUTSIDE CONTAINMENT ISOLATION VALVE l
2-HV-MOV-211A 11715-CBB-040C 2 0F 3 E8 M0 GATE 4.000 3 B
EV 0
ST 0
VP OC CONTROL ROOM CHILLER ISOLATION VALVE 2-HV-MOV-2118 11715 CBB-040C 2 0F 3 C6 M0 GATE 4.000 3 8
EV 0
l ST 0
CONTROL ROOM CHILLER ISOLATION VALVE i
i 2-HV Mov-211C 11715-CBB-040C 2 0F 3 D8 M0 GATE 4.000 3 B
EV 0
ST 0
CONTROL ROOM CHILLER ISOLATION VALVE l
t l
l 2-HV-MOV-213A 11715-CBB-0400 2 OF 3 E3 M0 GATE 4.000 3 B
EV O
ST 0
W K
l i
CONTROL ROOM CONDENSER WATER SYSTEM ISOLATION VALVE 2-HV-MOV-2138 11715-CBB-0400 2 0F 3 B3 M0 GATE 4.000 3 B
EV 0
u ST 0
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1 VIRGINIA POWER COMPANY PAGE:
62 0F 79 j
NORTH ANNA UNIT 2 REVISION: 07 l
SECOND INSPECTION INTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM - VALVE TABLE NC ISO REL CS ALT VALVE DRAWING SHEET DAWG VALVE VALVE ASME IW VALVE TEST TEST REQ JUST TEST NUMBER NUMBER NUMBER COOR TYPE SIZE CLASS CAT TYPE TYPE POS V-CSV-VCN-j i
"C" ACCupRJLATOR DISCHARGE ISOLATION VALVE TO RCS COLD LEG 2 SI-MOV 2867A 12050 cam-0964 3 0F 3 04 NO GATE 3.000 2 s
EV C
0 l
ST C
0 VP OC BORON INJECTION TANK NIGH NEAD SI INLET VALVE 2-SI MOV 28675 12050-cam 096A 3 0F 3 04 M0 GATE 3.000 2 5
EV C
0 ST C
D VP OC BORON INJECTION TANK HIGH HEAD SI INLET VALVE 2-SI-MOV 2867C 12050-CSM-0964 3 0F 3 E7 M0 GATE 3.000 2 A C&P EV C
37 0
37 LT C
ST C
37 0
37 VP OC BORON INJECTION TANK OUTLET TO RCS COLD LEG, OUTSIDE CONTAINMENT ISOLATICW VALVE 2 SI MOV-2867D 12050-COM-096A 3 0F 3 D7 No GATE 3.000 2 A C&P EV C
37 0
37 LT C
ST C
37 0
37 VP oc 1
BORON INJECTION TANK OUTLET TO RCS COLD LEG, OUTS!DE CONTAINNENT ISOLATION VALVE 2 SI-MOV-2869A 12D50-CBM-096A 3 OF 3 C8 M0 GATE 3.000 2 A C&P EV C
35 0
35 LT C
ST C
35 0
35 VP OC HIGH HEAD SI FROM CHARGING HEADER TO RCS NOT LEGS, OUTSIDE CONTAINMENT ISOLATION VALVE 2-SI MOV-28698 12050-CeM-0964 3 0F 3 88 M0 GATE 3.000 2 A C&P EV C
35 0
35 LT C
ST C
35 i
0 35 VP OC I
HIGH HEAD SI FROM CHARGING HEADER TO RCS HOT l
LEGS, QUTSIDE CONTAINMENT ISOLATION VALVE l
2-SI-MOV-2885A 12050 cam-096A 2 0F 3 C3 M0 GLOBE 2.000 i EV C
LT C
76
VIRGIN!A POWER COMPANY PAGE:
63 0F 79 WORTH ANNA UNIT 2 REVISION: 07 SECOND INSPECTION INTERVAL DATE: 04/15/96 INSERVICE TESTING PROGRAM - VALVE TABLE NC l
VALVE DRAWING SHEET DRWG VALVE VALVE ASME IW VALVE TEST TEST REQ JUST TEST WUMBER NUMBER NUMBER C00R TYPE
$!ZE CLASS CAT TYPE TYPE POS V-CSV-VCN-2-SI-MOV 2885A 12050 ceM-096A 2 0F 3 C3 No GLOBE 2.000 2 A
ST C
VP OC "A" LOW NEAD $1 PUMP MINIMUM FLOW / TEST LINE ISOLATION 1
2 SI-MOV-28858 12050 CsM-096A 2 0F 3 B3 No GLOSE 2.000 2 A
EV C
LT C
76 ST C
VP OC "B" LOW NEAD St PLMP MINIInm FLOW / TEST LINE ISOLATION 2-SI MOV 2885C 12050-COM-096A 2 0F 3 03 M0 GLOSE 2.000 2 A
EV C
LT C
76 ST C
VP OC "A" LOW HEAD SI PUMP MINIMUM FLOW / TEST LINE ISOLATION 2 SI MOV-2885D 12050 COM-096A 2 0F 3 R3 MO GLOBE 2.000 2 A
EV C
l LT C
76 ST C
VP OC l
"B" LOW NEAD St PUMP MINIMUM FLOW / TEST LINE ISOLATION 2 SI MOV-2890A 12050-ceM-096A 2 0F 3 D7 MO GATE 10.000 2 A C&P EV C
35 0
35 LT C
ST C
35 0
35 VP OC "A" LOW HEAD SI PUMP NOT LEG DISCHARGE STOP VALVE, OUTSIDE CONTAINMENT ISOLATION VALVE 2-SI-Mov-2890s 12050 CBM-096A 2 0F 3 D7 M0 GATE 10.000 2 i
C&P EV C
35 0
35 LT C
ST C
35 0
35 VP OC l
l "B" LOW HEAD St PUMP HOT LEG DISCHARGE STOP l
VALVE, OUTSIDE CONTAINMENT ISOLATION VALVE l
2-SI-Mov-2890C 12050-CBM-096A 2 0F 3 C8 M0 GATE 10.000 2 A C&P EV C
37 0
37 LT C
ST C
37 0
37 VP OC LOW HEAD St PUMPS COLD LEG DISCHARGE STOP VALVE, OUTSIDE CONTAINMENT ISOLATION VALVE 2-SI-MOV-28900 12050-CBM-096A 2 0F 3 C7 M0 GATE 10.000 2 A C&P EV C
37 0
37 LT C
ST C
37 i
1 i
i RELIEF REQUEST V-3 l
I.
IDENTIFICATION OF COMPONENTS l
)
l System
- Component Cooling l
Valve (s) : 2-CC-78 l
2-CC-115 2-CC-152 Class
- 2 Category: AC Function: Containment Isolation Check Valves for the CC Supply to the Reactor Coolant Pump Thermal Barrier Coolers II. IMPRACTICAL CODE REQUIREMENTS l
OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valves are i
located inside containment and their systems are l
required during power operation, they cannot be tested l
every three months.
Performing a leakage /back pressure test requires isolating the component cooling water supply line and installing temporary leakage test equipment.
Because of the effort involved, it is 1
impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check valves Verified Closed by Leak Testing."
]
These valves serve a containment isolation function and 1
are leakage tested as required by the 10 CFR 50, j
Appendix J program.
North Anna received approval from i
the NRC to use Appendix J, Option B, by letter dated j
February 9, 1996 (TAC NOS. M94081 and M94082).
2-45 N2PVR7 Revision 7 April 15, 1996
l RELIEF REQUEST V-3 (Cont.)
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval i
to the leakage test interval determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable l
t l
level of quality and safety because:
1) the Appendix J, Option B, leakage test program is l
performance based program, l
l l
2) the valves will be added to the plant's check valve j
i predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the l
requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, option B leakage test but not less frequently then once every 60 months.
l 1
l 2-45a N2PVR7 Revision 7 April 15, 1996 l
I 1
l RELIEF REQUEST V-10 I.
IDENTIFICATION OF COMPONENTS System
- Chemical & Volume Control Valve (s): 2-CH-260 2-CH-308 2-CH-332 2-CH-284 2-CH-331 2-CH-335 Class
- 1 for 2-CH-260, 284, 308 and 332 2 for 2-CH-331 and 335 Category: AC for 2-CH-331, 332 and 335 C
for 2-CH-260, 284 and 308 Function: Charging Supply and Return Isolation Check kalves II. IMPRACTICAL CODE REQUIREMENTS i
OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF These check valves must seat upon reversal of flow in order to fulfill their safety functions. -The only method to verify closure is to perform a leakage /back pressure test.
Since the valves are located inside containment and their systems are required during power operation, they cannot be tested every three months.
Valves 2-CH-260, 284 and 308 are in the RCP seal water supply lines.
Seal flow is used during cold shutdown i
to reduce RCS leakage and to float the RCP seals, therefore, these valves cannot be tested closed during cold shutdowns.
These valves will be back pressure tested every reactor refueling.
Valve 2-CH-335 is in the normal charging line to the RCS.
This line cannot be drained during short cold shutdowns because charging flow is often maintained.
Valve 2-CH-331 is in the RCP seal water return line.
As stated above, seal flow is maintained during cold i
shutdowns.
Valve 2-CH-332 is the charging supply to loop fill header, inside containment isolation valve.
l A leakage / backseat test inside containment is required i
(
2-48 l
N2PVR7 Revision 7 April 15, 1996 1
RELIEF REQUEST V-10 (Cont.)
to verify closure for valve 2-CH-332.
Becaurs of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled
" Extension of Test Interval to Refueling Outage for check Valves Verified closed by Leak Testing."
Valves 2-CH-331, 332 and 335 are containment isolation valves and are leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the containment isolation valves listed above will be allowed to increase from the code allowed reactor refueling test interval to the leakage test interval determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative 2-49 N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-10 (Cont.)
maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV.
ALTERNATE TESTING Valves 2-CH-260, 284 and 308 will be exercised to the closed position every reactor refueling.
Valves 2-CH-331, 332 and 335 will be exercised to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
l 2-49a N2PVR7 Revision 7 April 15, 1996
4 RELIEF REQUEST V-16 I.
IDENTIFICATION OF COMPONENTS System
- Fire Protection Valve (s): 2-FP-79 Class
- 2 Category: AC Function: Containment Isolation Check Valve for the Fire Protection Supply Line II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns;. part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical durjng power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF I
This check valve must seat upon reversal of flow in order to fulfill it's safety function.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valve is located inside containment, it cannot be tested every three months.
Valve 2-FP-79 is in the containment fire protection system.
Testing this valve will render the fire protection system inoperable.
Performing a leakage /back pressure test requires isolating the fire protection supply line and installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
This valve serves a containment isolation function and is leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for this valve will be allowed to increase from the Code allowed 2-51 N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-16 (Cont.)
reactor refueling test interval to the leakage test interval determined by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable l
level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valve will be added to the plant's check valve predictive maintenance program and 3) the valve must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month j
periodic test frequency.
l The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed 1
in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
2-51a N2PVR7 Revision 7 April 15, 1996 i
RELIEF REQUEST V-20 I. IDENTIFICATION OF COMPONENTS System
- Post Accident Hydrogen Removal Valve (s): 2-CV-8 2-HC-15 2-CV-15 2-HC-20 Class
- 2 Category: AC for 2-HC-15 and 20 C
for 2-CV-8 and 15 Function: Hydrogen Control System Supply and Return Isolation Check Valves II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF Check valves 2-CV-8 and 15, 2-HC-15 and 20 must open to sample hydrogen to fulfill their safety functions.
To test valves 2-HC-15 and 20 either partially or full open, and to test valves 2-CV-8 and 15 full open requires a significant manipulation of the hydrogen recombiner system.
In addition, should a containment pressurization event occur while operating the hydrogen recombiners, there is a possibility of exceeding the design pressure of the recombiner system, which may result in a loss of recombiner function.
The hydrogen recombiner is a low pressure system intended for use after the containment depressurizes.
Valves 2-CV-8 and 15 can be tested to the partially open position every quarter using the containment vacuum pumps while maintaining the recombiner system isolated from the containment atmosphere.
These valves will be verified open at least once every 18 months during the surveillance testing of the hydrogen recombiner system as required by Technical Specification Section 4.6.4.2.
The small increase in safety gained by testing during normal operation or cold shutdown does not justify the potential risk of 2-53 N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-20 (Cont.)
overpressurizing the hydrogen recombiner system, or the added burden of disrupting normal plant operations to manipulate the recombiner system and performing the test on the more frequent basis.
Check valves 2-HC-15 and 20 provide containment isolation.
These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valves are located inside containment, they cannot be tested every three months.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistant with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, t
Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the i
leakage test interval determined for each valve by the Appendix J, Option.B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be. extended, the program requires that a containment isolation valve successfully complete two 2-54 N2PVR7 Revision 7
)
April 15, 1996
RELIEF REQUEST V-20 (Cont.)
consecutive periodic (24 month) as-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II,-
entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance prograe requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Check valves 2-HC-15 and 20 will be exercised to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
Check valves 2-CV-8 and 15, 2-HC-15 and 20 will be exercised to the full open position at least once every 18 months.
Valves.p-CV-8 and 15 will be exercised to the partially open position once every three months.
2-54a N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-21 I.
IDENTIFICATION OF COMPONENTS System
- Instrument Air Valve (s): 2-IA-250 2-IA-428 Class
- 2 Category: AC Function: Instrument Air Supply and Return Line I
containment Isolation Check Valves II. IMPRACTICAL CODE REQUIREMENTS l
OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-i stroke during reactor refuelings, of if any exercising l
is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valves are located inside containment, they cannot be tested every three months.
Valve 2-IA-250 is in the instrument air supply line to containment.
Testing this valve renders the instruments and components supplied by instrument air inside containment inoperable.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified closed by Leak Testing."
These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated 2-55 N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-21 (Cont.)
February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
1 1
2-55a N2PVR7 Revision 7 April 15, 1996
i RELIEF REQUEST V-28 I.
IDENTIFICATION OF COMPONENTS System
- Reactor Coolant Valve (s): 2-RC-162 Class
- 2 Category: AC Function: Containment Isolation Check Valve for the Primary Grade Water Supply Line II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF This check valve must seat upon reversal of flow in order to fulfill it's safety function.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valve is located inside containment, it cannot be tested every three months.
Valve 2-RC-162 is in the primary grade water supply line to pressurizer relief tank (PRT) and the #2 seal stand pipes.
This line cannot be drained during short cold shutdowns because the PRT is required during normal cold shutdowns.
Standpipe level must be maintained when the reactor coolant system is pressurized to control leakage.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
This valve serves a containment isolation function and is leakage tested as required by the 10 CFR 50, 2-57 N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-28 (Cont.)
Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for this valve will be allowed to increase frca the Code allowed reactor refueling test interva) to the leakage test interval determined by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
i 1) the Appendix J, Option B, leakage test program is j
performance based program, 2) the valve will be added to the plant's check valve predictive maintenance program and i
3) the valve must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency, i
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
l IV. ALTERNATE TESTING l
Exercise to the closed position during the Appendix J, i
Option B leakage test but not less frequently then once every 60 months.
2-57a N2PVR7 Revision 7 April 15, 1996
1 a
I RELIEF REQUEST V-41 I.
IDENTIFICAJION OF COMPONENTS System
- Safety Injection Valve (s): 2-SI-132 2-SI-136 Class
- 2 Category: AC Function: Accumulator Nitrogen Supply and Make Up Lines Containment Isolation Chv"k Valves II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and~(e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only exercise method to verify closure is to perform a leakage /back pressure test.
Since the valves are located inside containment, they cannot be tested every three months.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This i
technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
These valves serve a containment isolation function and are leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the 2-67 N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-41 (Cont.)
Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
l l
2-67a N2PVR7 Revision 7 April 15, 1996 w
+s
RELIEF REQUEST V-43 I.
IDENTIFICATION OF COMPONENTS System Safety Injection Valve (s):
2-SI-151 2-SI-170 2-SI-153 2-SI-185 2-SI-168 2-SI-187 Class 1
l Category:
AC j
Function:
Accumulator Discharge check Valves II. IMPRACTICAL CODE REQUIREMENTS i
l OM Part 10, Section 4.3.2.4 (a) - This section states in 3
part that, "The necessary valve obturator movement j
shall be demonstrated by exercising the valve and l
observing that either the obturator travels to the seat i
on cessation or reversal of flow, or opens to the j
position required to fulfill its function, as specified j
in para.
1.1, or both.
Observation may be by observing a direct indicator such as a position indicating i
device, or by other indicator (s) such as changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means."
This section i
implies that the techniques used to verify obturator i
movement be applied to every valve on a test frequency j
that is practical.
l 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.
A partial flow test is not practical during cold shutdowns.
The flow from the accumulator is dependent on the pressure differential between the accumulator and the RCS.
The pressure differential cannot be controlled to the fine degree necessary to preclude dumping too much water into the pressurizer, thus 2-69 N2PVR7 Revision 7 April 15, 1996
i l
RELIEF REQUEST V-43 (Cont.)
t
?
I j
making it difficult to control pressurizer level while pressure is being reduced during cooldown.
Also, the e
{
RCS temperature is high during short cold shutdowns.
j Dumping cold accumulator water into the RCS could thermally shock the system.
i Ncn-intrusive techniques are used to verify obturator movement for the SI accumulator discharge check valves.
4 These techniques' provide a " positive means" for verifying obturator movement, however, due to the burden of applying these techniques in the field, a sampling program will be used as described in the alternate testing section.
l The accumulators must be isolated to verify closure j
using back flow for valves 2-SI-153, 170 and 187.
The i
small increase in safety gained by performing the back i
seat check valve tests every cold shutdown versus every j
reactor refueling does not justify the added burden of the increased test frequency.
l IV. ALTERNATE TESTING During the first refueling outage where nonintrusive i
1 j
techniques are used, all valves in the group will be tested to verify that the techniques verify valve j
obturator movement.
During subsequent refueling outages, flow testing will be performed on all valves in the group, but the nonintrusive techniques will be applied only to one sample valve in each group, on a j
rotating basis, unless indications of problems are 1
identified.
In this case, all valves in the group will be subjected to the nonintrusive techniques.
Valves 2-j SI-153, 170 and 187 are closest to the reactor coolant system and will be in one group, and valves 2-SI-151,
}
168 and 185 will be in the other group.
This sampling plan will follow the recommended alternative testing i
method described in NUREG 1482, Section 4.1.2.
I The flow test will consist of discharging the j
accumulator from an initial pressure that is less than i
600 psig.
Discharging the accumulator at a lower j
initial pressure reduces the severity of the transient j
and the risk of adverse effects on the reactor coolant i
system.
The low pressure test should provide enough j
flow to force the disk to the full open position.
Valves 2-SI-153, 170 and 187 will be confirmed closed every reactor refueling.
I I
2-70 N2PVR7 Revision 7 April 15, 1996
___.. ~ _ _ _..
1 l
i i
i i
RELIEF REQUEST V-47 l
i I.
IDENTIFICATION OF COMPONENTS System
- Vacuum Priming i
j Valve (s): 2-VP-24 J
j Class
- 2 Category: AC i
Function: Containment Isolation Check Valve for the j
Condenser Air Removal Discharge Line 3
l l
II. IMPRACTICAL CODE REQUIREMENTS
]
l OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and j
cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising i
is impractical during power operations and at cold i
shutdowns, full-stroke exercise during reactor
{
refuelings.
l III. BASIS FOR RELIEF 4
2 This check valve must seat upon reversal of flow in j
order to fulfill it's safety function.
The only j
exercise method to verify closure is to perform a i
leakage /back pressure test.
Since the valve is located inside containment, it cannot be tested every three months.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
}
Because of the effort involved, it is impractical to perform this test during cold shutdowns.
This j
technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section i
4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
This valve serves a containment isolation function and 4
j is leakage tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated i
February 9, 1996 (TAC NOS. M94081 and M94082).
Per j
this relief request, the closure test interval for this i
valve will be allowed to increase from the code allowed j
reactor refueling test interval to the leakage test interval determined by the Appendix J, Option B, j
program, which can be up to a test interval of at least 2-74 N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-47 (Cont.)
once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valve will be added to the plant's check valve predictive maintenance program and 3) the valve must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
2-74a N2PVR7 Revision 7 April 15, 1996
I l
RELIEF REQUEST V-59 Relief Request Withdrawn l
2-84 N2PVR7 Revision 7 April 15, 1996 1
I
THIS PAGE IS INTENTIONALLY BLANK.
I l
j 2-85 N2PVR7 Revision 7 j
April 15, 1996 l
l
i I
RELIEF REQUEST V-63 I.
IDENTIFICATION OF COMPONENTS System
- Component Cooling l
Valve (s): 2-CC-276 2-CC-289 2-CC-302 Class
- 2 Category: AC Function: Component Cooling Water Supply to l
Recirculation Air Cooling Coils Containment Isolation Check Valves II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke I
exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising l
is impractical during power operations and at cold 1
l shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF j
]
These check valves must seat upon reversal of flow in order to fulfill their safety functions.
The only exercise method to verify closure is to perform a i
leakage /back pressure test which would involve l
isolating the containment air cooling coils.
The containment recirculation air cooling coils are j
required for normal operation to maintain containment temperature below technical specification limits.
Therefore, these valves cannot be tested every three months.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of'the effort involved, it is impractical to perform this test during cold shutdowns.
This technical basis is consistent with the NRC position on this subject that is described in NUREG-1482, Section 4.1.4, i
entitled " Extension of Test Interval to Refueling l
Outage for Check Valves Verified closed by Leak Testing."
l i
t 2-89 N2PVR7 Revision 7 April 15, 1996 l
l
RELIEF REQUEST V-63 (Cont.)
These valves serve a containment isolation function and are leaka.ge tested as required by the 10 CFR 50, Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the code allowed reactor refueling test interval to the leakage test interval determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, 2) the valves will be added to the plant's check velve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, entitled " Check Valve condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
2-89a N2PVR7 Revision 7 April 15, 1996
1 RELIEF REQUEST V-63 (Cont.)
i IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months.
~
N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-67 Relief Request Withdrawn 1
1 2-94 N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-71 I.
IDENTIFICATION OF COMPONENTS System
- Component Cooling Valve (s): 2-CC-194 2-CC-199 Class
- 2 Category: AC Function: Component Cooling Water Supply to RHR Heat Exchanger Containment Isolation Check Valves II. IMPRACTICAL CODE REQUIREMENTS OM-10, Paragraph 4.3.2.2(d) and (e) - If full-stroke exercising is impractical during power operation and cold shutdowns, part-stroke at cold shutdowns and full-stroke during reactor refuelings, of if any exercising is impractical during power operations and at cold shutdowns, full-stroke exercise during reactor refuelings.
III. BASIS FOR RELIEF Valves 2-CC-194 and 2-CC-199 are check valves in the component cooling lines to the RHR heat exchangers and must close for containment isolation and open to allow RHR flow.
To establish full flow through Valves 2-CC-194 and 199 for testing to the full open position, increased component cooling flow must be directed through the RHR heat exchangers.
During cold shutdown and reactor refueling when fuel is in the vessel, increased flow to the RHR heat exchangers reduces the volume of the RCS inventory by reducing the RCS temperature.
This reduction in volume can be large enough as to cause excessive makeup demands to the RCS.
Therefore, the full flow test should be performed during reactor refueling when the vessel is defueled.
The vessel is defueled every refueling outage.
The only exercise method to verify closure is to perform a leakage /back pressure test.
These lines cannot be drained for back pressure testing because the i
RHR system is needed during cold shutdown to control the RCS temperature.
Performing a leakage /back pressure test requires installing temporary leakage test equipment.
Because of the effort involved, it is l
impractical to perform this test during cold shutdowns.
2-99 N2PVR7 Revision 7 April 15, 1996
RELIEF REQUEST V-71 (Cont.)
I l
This technical basis is consistent with the NRC l
position on this subject that is described in NUREG-1482, Section 4.1.4, entitled " Extension of Test Interval to Refueling Outage for Check Valves Verified Closed by Leak Testing."
3 These valves serve a containment isolation function and l
are leakage tested as required by the 10 CFR 50, l
Appendix J program.
North Anna received approval from the NRC to use Appendix J, Option B, by letter dated February 9, 1996 (TAC NOS. M94081 and M94082).
Per this relief request, the closure test interval for the valves listed above will be allowed to increase from the Code allowed reactor refueling test interval to the leakage test interval determined for each valve by the Appendix J, Option B, program, which can be up to a test interval of at least once every 60 months.
The proposed alternative will provide an acceptable level of quality and safety because:
1) the Appendix J, Option B, leakage test program is performance based program, l
i 2) the valves will be added to the plant's check valve predictive maintenance program and 3) the valves must have a low risk significance as determined by the plant's Probabilistic Safety Analysis (PSA).
As stated above, the Appendix J, Option B, leakage test program is performance based.
Before the leakage test interval can be extended, the program requires that a containment isolation valve successfully complete two consecutive periodic (24 month) As-found tests where the results of each test are within a licensee's allowable administrative limits.
If the leakage test results are unacceptable in subsequent tests, the test frequency will revert back to the initial 24 month periodic test frequency.
The plant's predictive maintenance program meets the requirements of draft OM Subsection ISTC, Appendix II, l
entitled " Check Valve condition Monitoring Program,"
dated June, 1995.
The predictive maintenance program requires that the check valves be grouped and analyzed in order to establish the basis for specifying l
l l
2-99a N2PVR7 Revision 7 April 15, 1996 l
3 l
RELIEF REQUEST V-71 (Cont.)
l l
inservice testing, examination, and preventative maintenance activities.
The results of the predictive maintenance program analyses will be considered on a valve by valve basis before the test intervals are extended.
IV. ALTERNATE TESTING Exercise to the closed position during the Appendix J, Option B leakage test but not less frequently then once every 60 months, and exercise to the open position every reactor refueling.
i 2-99b N2PVR7 Revision 7 April 15, 1996
.