ML20117K879
| ML20117K879 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/10/1996 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 95-602A, NUDOCS 9606130052 | |
| Download: ML20117K879 (8) | |
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VIHGINIA ELucnic ANu Poren CoxmNY HICIIMOND,VIHOINIA 032 61 l
June 10, 1906 U.S. Nuclear Regulatory Commission Serial No.: 95-602A Attention: Document Control Desk Docket No.: 50-338 Washington, D.C. 20555 50-339 I
License No.:NPF-4 NPF-7 1
l Gentlemen:
VI_RGINIA ELECTRIC AND POWER COMPANY
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NORTH ANNA POWER STATION UNIU 1 & 2 l
SECOND INTERVAL INSERVICEINSP' CTION PROGRAMS d
REQUEST FOR ADDITIONAL IN"ORMATION By letter dated December 7,1935 (Serial No.95-602), Virginia Electric and Power Company requested the use of Code Cases N-522, " Pressure Testing of Containment Penetration Piping," and N-535, "Altemative Requirements for Inservice Inspection l
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Intervals." In addition, by letter dated February 7,1996 (Serial No.96-031), we submitted j
l Revision 1 of relief request NDE-16 for the North Anna Unit 2 pressurizer nozzle inner j
radius examination for NRC review and approval.
Several aspects of these submittals were discussed by telephone with the NRC staff and j
its contractor, Idaho National Engineering Laboratory, on March 28,1996. As a resu!t of j
the telephone conference call, relief request NDE-16 for Unit 2 and our request for use of l
Code Case N-535 for Units 1 and 2 are being withdrawn. The request for use of Code Case N-522 has been revised, and is being submitted as relief request SPT-16 for Unit 2.
l Relief request SPT-16 for Unit 2 is provided as Attachment 1. The similar request for use of N-522 for Unit 1 was determined not to be neccessary for the third period and is being withdrawn.
l Should you have any questions or require additional information, please contact us.
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l Very truly yours, w
James P. O'Hanlon Senior Vice President - Nuclear Attachment l
9606130052 96061o PDR ADOCK 05000338 G
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United States Nuclear Regulatory Commission Regional Administrator j
Region 11 101 Marietta Street, N. W.
3 Suite 2900 l
Atlanta, Georgia 30323 Mr. R. D. McWhorter NRC Senior Resident inspector North Anna Power Station t
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North Anna Unit 2 Relief Request SPT-16 l
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Virginia Electric & Power Company North Anna Unit 2 Second 10-Year Interval Request for Relief No. SPT-16 1.
IDENTIFICATION OF COMPONENTS i
l Class 2 piping that penetrates the containment vessel where the piping and l
isolation valves are part of the containment system but the balance of the piping is l
outside of the scope of Section XI.
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Drawing Test boundary Penetration Number 11715-SPB-006A-2 36"-AR-491-151-02 between 1-HV-91 SH. 2 MOV-202,1-HV-MOV-200A, and 1-HV-l MOV-2008 11715-SPB-006A-2 36"-AR-490-151-Q2 between 1 -HV-90 SH. 2 MOV-201,1-HV-MOV-2000, and 1-HV-MOV-200D 11715 SPM-106A-2 M-HC-75-ICN6-02 between 2-HC-TV-98 SH.1 200A and T.-HC-TV-2008 11715-SPM-106A-2 M-HC-411-ICN6-02 between 2-HC-TV-31 SH.1 201B and 2"-HC-2-154-02 and 2"-HC-2-154-Q2 between 2-HC-TV-205B and 2-HC-15 11715-SPM-106A-2 M-HC-461-ICN6-Q2 between 2-HC-TV-105 i
SH. 2 202A and 2-HC-TV-202B 11715-SPM-106A-2 M-HC-413-ICN6-02 between 2-HC-TV-109 SH. 2 203B and 2-HC-3-154-02, and 2%-HC-440-154-02 between 2"-HC-3-154-Q2 j
and 2-HC-TV-207B, and 2-HC-3-154-O2 11715-SPM-106A-2 M-HC-467-ICN9-02 between 2-HC-TV-98 SH.3 208A and 2-HC-TV-208B i
12050-SPB-104B-2 4" line between 2-FP-79 and 2-FP-82 34 j
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I Drawing Test boundary Penetration Number 12050-SPM-072A 2 6"-AJ/.-410-151-02 between 2-VP-24 89 SH. 2 and 2-SV-TV-202-1 12050-SPM-082A-2 2"-ACC-421-153A-Q2 between 47 SH.1 penetration 47 and 2-IA-250 12050-SPM-082B-2 2"-ACC-421-153A-Q2 between 47 SH.1 penetration 47 and 2-IA-TV-202B 12050-SPM-082B-2 1"-ARC-402-153A-Q2 between 2-RM-44 SH. 2 TV-200B and 2-RM-TV-200C 12050-SPM-0828-2 1"-ARC-401-153A-02 between 2-RM-43 SH. 2 TV-200D and 2-IA-428
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11715-SPM-088A-2 6"-RP-454-152-02 and 6"-RP-444-103 SH. 3 153A-Q2 11715-SPM-088A-2 6"-RP-449-152-Q2 104 SH. 3 12050-SPM-090A-2 1%"-VG-406-153A-Q2 between 2-VG-48 SHj TV-200A and 2-VG-W-200B 12050-SPM-090A-2 2"-VA-457-154-Q2 between 2-DA-7 54 SH. 3 and 2-DA-9
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12050-SPM-090A-2 2"-DA-449-153A-Q2, %"-DA-450-153A-111 SH. 3 O2, %"-DA-451-153A-02, 2"-DA-452-153A-Q2, between 2-DA-48 and 2-DA-TV-203B 12050-SPM-090B-2 2"-DA-445-153A-Q2 between 2-DA-TV-38 SH.1 200A and penetration 38 12050-SPM-092A-2 2"-CV-410-154-02 between 2-CV-TV-92 SH. 2 250D and 2-CV-15,2"-HC-433-154-Q2, and 2%-HC-434-154-02 to 2-HC-TV-204B 12050-SPM-092A-2 2"-CV-409-154-Q2 between 2-CV-TV-93 SH. 2 250B and 2-CV-8, 2"-HC-437-154-Q2, l
and 2%-HC-438-154-Q2 to 2-HC-TV-206B 12050-SPM-092A-2 8"-CV-411-151 -02 between 2-CV-4 94 i
SH. 2 and 2-CV-TV-100
I-l Drawing Test boundary Penetration Number l
12050-SPM-093B-2 3"-RC-452-153A-Q2 between 2-RC-45 SH. 2 2519A to 2-RC-162 12050-SPM-096A-2 1"-SI-413-602-02 between penetration 20 SH.1 20 and 2-SI-47 12050-3PM-096B-2 1"-SI-413-602-02 between 2-SI-136 20 SH.1 and penetration 20 12050-SPM-096B-2 1"-SI-498-601-Q2 between 2-SI-HCV-50 SH.1 2936 and 2-SI-TV-201 l
12050-SPM-096B-2 1"-SI-517-1501-02 between 2-SI-132 53 SH.1 and 2-SI-TV-200 12050-SPM-102B-2 3"-SGD-413-601-02, 2"-SGD-422-601-32 SH.1 02, and 2"-SGD-425-601-02 13075-SPM-102C-2 3"-SGD-414-601-02, 2"-SGD-423-601-100 SH.1 02, and 2"-SGD-426-601-Q2 13075-SPM-10EC-2 3"-SGD-415-601-02, 2"-SGD-424-601-108 SH.1 02, and 2"-SGD-427-601-02 II.
IMPRACTICABLE CODE REQUIREMENTS Table IWC-2500-1, Examination Category C-H, items C7.30 and C7.70 requires a system pressure test each inspection period and items C7.40 and C7.60 requires a system hydrostatic test each inspection interval.
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CODE REQUl3EMENT FROM WHICH RELIEF IS REQUESTED Relief is requested from performing the Code-required hydrostatic test at the end of the inspection interval and the Code required system pressure test during each period 1or the containment penetrations listed.
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l IV. BASIS FOR RELIEF The sole safety function of the p; ping and associated valves listed is to provide containment isolation. The components listed are part of the containment system.
The containment penetrations are classified as Class 2 per ANSI 18.2, " Nuclear Sarety Criteria for the Design of Stationary Pressurized Water Reactor Plants",
section 2.3.1.2 (1). For the subject penetrations the connecting piping beyond the containment isolation valves serves no safety function and is classified as nonclass by the classification criteria used by Virginia Electric and Power Company for North Anna Unit 2.
The ASME Section XI pressure testing requirements verify leak-tight integrity by an over pressure test every ten years and a nominal operating test every inspection period. The 10-year hydrostatic tests are considered inordinately burdensome for the marginal benefit in safety they provide and have been eliminated by Code Case N-498, " Alternative Rules for 10-year Hydrostatic Pressure Testing for Class 1 and 2 Systems,Section XI, Division 1", which has been approved W Regulatory Guide 1.147, inservice inspection Code Case Acceptability ASME 3ection XI Division 1.
The subject penetrations are Type C pressure tested to a peak containment intemal pressure of greater than or equal to 44.1 psig. This test is performed to satisfy Technical Specification Surveillance Requirement 4.6.1.2 which requires all containment penetrations to be leak rate tested as required by 10 CFR 50, Appendix J, Option B, as modified by approved exemptions, and in accordance with the guideline contained in Regulatory Guide 1.163, dated September 1995.
l The testing frequency of 10 CFR 50, Appendix J, Option B is performance based and can vary from 2 years to 5 years or three refueling cycles. This frequency will not coincide with the inspection period frequency required in Table IWC-2500-1 for system pressure tests. Therefore, the ASME Code in effect at North Anna will require additional leak tightness testing.
The ASME Section XI Code has acknowledged that testing of these components beyond the requirements of Appendix J is not necessary and issued Code Case N-i 522, " Pressure Testing of Containment Penetration Piping", to define its position.
l NUREG-1493, " Performance-Based Containment Leak-Test Program", concluded l
that prescriptive leak rate testing could be replaced with performance based requirements with only a marginal and acceptable impact on safety. The total cost of Type B (electrical penetrations) and Type C testing all containment penetrations (approximately 90 penetrations) was estimated to be $87,500 per outage for North Anna as reported in NUREG-1493. NUREG-1493 estimates that 5% of the total cost of Type B & C testing could be saved if the acceptance criteria were relaxed.
The marginal benefits of performing ASME Section XI pressure testing in excess of the requirements of 10 CFR 50, Appendix J, Option B testing are not commemsurate with the cost of the additional testing.
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PROPOSED ALTERNATIVE l
As an alternative to the testing frequency and pressures required by Table IWC-2500-1, Examination Category C-H, items C7.30, C7.40, C7.60, and C7.70, the subject penetrations and associated piping and valves, will be pressure tested to the requirements of 10 CFR Appendix J, as allowed by Code Case N-522. Testing will be performed in accordance with Technical Specification Surveillance Requirement 4.6.1.2 which requires all containment penetrations to be leak rate tested as required by 10 CFR 50, Appendix J, Option B, as modified by approved i
exemptions, and in accordance with the guideline contained in Regulatory Guide 1.163, dated September 1995.
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IMPLEMENTATION SCHEDULE The Technical Specifications were reeed on 2/9/96 to incorporate 10 CFR 50, Appendix J, Option B. The subject coMainment penetrations will be Type C tested in the second period. The last refueling outage of the second period is scheduled to start on 9/7/96. The third period starts on 12/14/97. Test interval.s for valves having two consecutive periodic "as-found" Type C tests where the results are within the allowable administrative limits may be increased up to a maximum of 60 l
months. Some valves demonstrating adequate performance after testing during l
the 1996 refueling outage may not require additional testing during the third period.
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