ML20148E031
| ML20148E031 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/02/1978 |
| From: | Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Parr O Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7811060078 | |
| Download: ML20148E031 (15) | |
Text
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VIRGINIA Er,zc rRic AN D POWE H CO"WANY RicIIw ow n,Vz reo NIA 20261 November 2,1978 Mr. Harold R. Denton, Director Serial No. 597 Office of Nuclear Reactor Regulation P0/FT1:sej Attn:
Mr. O. D. Parr, Chief Docket No. 50-338 Light Water Reactors Branch No. 3 License No. NPF-4 Division of Project Management U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Denton:
REQUEST FOR RELIEF FROM CERTAIN REQUIREMENTS OF ASME XI FOR INSERVICE TESTING OF PUMPS AND VALVES FOR NORTH ANNA UNIT 1 PUMPS Our letter Serial No. 0520, dated September 29, 1977, proposed an inservice testing program for ASME Code Class 1, 2, and 3 pumps for North Anna Power Station, Unit 1.
Our letter detailed the tests to be performed on each of the applicable pumps, and requested relief in several cases from the requirements of Section XI of the ASME Code. The NRC Staff, by letter dated October 17, 1977 concluded that our proposed program was acceptable for the first 20 month period following commercial operation of Unit 1, and granted relief from ASME Code requirements.
Our testing program, as outlined in our letter, Serial No. 52D, das.3d September 29, 1977, stated that flow instrumentation of the component cooling pumps 1-CC-P-1A, 1B and of the service water pumps 1-SW-P-1A, IB was only accurate to +4% of full scale reading. Operating experience has shown that normal operating flows are approximately half or less than half of full scale flow. Thus accuracy of these gauges is at best +8% of normal operating flow.
This accuracy does not lend itself to satisfying the requirements of Table IWP-2100-2, where the acceptable range of flow is +2%-6% of reference flow.
In addition, varying the flow rates of these pumps to meet the reference flow interferes with normal plant operation since these flows have been balanced to meet the heat load requirements of the unit. Since these flow gauges were only designed to indicate relative flow and not to evaluate pump performance, an exception to the requirements of IWP-3100 is requested such that the flow and developed head of each pump will be recorded but will not be adjusted or compared to the reference value.
The component coollng pumps are not required following an accident.
Installation of more ar. curate t
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Mr. Harold R. Denton 2
flow gauges will be investigated during the first 20 months of commercial operation.
With the addition of the Casing Cooling System, two pumps should be added to the Attachment of our letter, Serial No. OS2D dated September 29, 1977. These pumps are the Casing Cooling Pumpo 1-RS-P-3A, 3B and will be tested per Subsection IWP to Section XI of the ASME Code - 1974 edition with addenda through Summer 1975.
The proposed changes to pump testing are attached and indicated by a vertical line in the right hand margin.
Pages 1 and 15 supercede pages 1 and 15 and page 13b supplements page 13 of the attachment to our letter, Serial No. OS2D, dated September 29, 1977.
VALVES Our letter Serial No. OS2C, dated August 10, 1977, requested relief from certain requirements of ASME XI for inservice testing of valves for North Anna Unit 1.
Included in this letter as an attachment was a state-ment of particulars and a tabulation listing all valves to be tested, their testing frequency and a statement of relief requested.
The NRC staff, by letter dated October 17, 1977, concluded that our proposed program was seceptable for the first 20 month period follwing commercial operation of Unit 1, and granted relief from ASME Code requirements. Upon further review, we find it necessary to revise this attachment.
The proposed changes to valve testing as listed below are attached and indicated by a vertical line in the right hand margin. Pages 1 of Attachment C.0; 2, 7, 9, 10, 11 of Attachment C.1; and 5 of Attachment C.2 supercede the corresponding pages of the attachments to our letter, Serial No. 052C, dated August 10, 1977. Page 12 of Attachment C.1 and page Sa of Attachment C.2 supplement our August 10 letter.
1.
Delete part stroke testing requirement for the main steam trip valves in Attachment C. O. as part stroking of these valves could cause a unit trip.
The valves will be tested for full closure time during each reactor shutdown but not more than unce per 92 days.
2.
MOV-1867A, B should be AMSE XI Cat. "B" rather than Cat.
"A" and MOV-1867C, D should be Cat. "A" rather than Cat.
"B".
This was a typographical error.
3.
Delete quarterly exercise testing requirements for MOV-1890A and B as explained in Note 27.
4.
RHR relief valve, RV-1721, has been replaced by two relief valves, RV-1721A and 17218. Include this change in attachment.
5.
1-SW-2 should be 1-SW-3.
This was a typographical error.
visoim Eucraic no Powen comx' '"
Mr. Harold R. Denton 3
6.
Delete 1-FW-125, 1-FW-95, 1-FW-63 and 1-FW-61 which are auxiliary feedwater check valves. These valves are located immediately upstream of manual valves which are to ba maintained closed and locked due to a design change.
Therefore, these valves are not required to be tested.
7.
Include 1-FW-279 which is a check valve in the discharge line from the steam driven auxiliary feedwater pump.
Testing of this valve will be the same as is performed on other check valves in the auxiliary feedwater header.
8.
Include MOV-RS-100A, B and MOV-RS-101A, B which are valves in the discharge line of the casing cooling pumps.
These will be tested as ASME XI Category A valves except leakage testing will be performed in accordance with 10 CFR 50 APP. J in lieu of subsection IWV.
9.
Delete 1-EG-272, 1-EG-284, 1-EG-289 and 1-EG-260 which are check valves in the discharge lines of Unit 2 emergency generator pumps and not required for Unit 1 operation.
10.
Include 1-RS-146, 1-RS-147, 1-SI-312 and 1-SI-315 which are manual valves in the cross connection between recire, spray and safety injection.
These will be tested as ASME XI category E valves with no exceptions to testing requirements.
11.
Include 1-RS-123 and 1-RS-138 which are check valves in the discharge line of the casing cooling pumps.
These check valves shall be exercised during refueling outages as stated in Note 28 on Attachment C.2.
Very truly yours, Y"
C. M. Stallings Vice President-Power Supply l
and Production Operctions Attachments cc:
Mr. James P. O'Reilly
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Attachment Page 1 of 20 COMPONENT COOLING PUMP Class 3 1-CC-P-1A 1-CC-P-1B MEASURED QUANTITIES Pj Monthly No exception
- AP Monthly **
Exception **
Q Monthly **
Exception to IWP - 4110 is required since the available flow instrument is only 4%
accurate.**
Monthly No exception V
Proper Lubricant Level or Pressure - Monthly No exception Tb Annually No exception NOTES:
These pumps are in a variable resistance system and are not required during an accident.
Values will be recorded monthly but not compared to reference values.
Additionally, motor current will be recorded for comparison purposes.
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Attachment Page 13b of 20 CASING COOLING PUMPS Class 3 1-RS-P-3A 1-kS-P-38 i
MEASURED QUANTITIES Pj Monthly No exception
- AP Monthly No exception
- Q Monthly ***
See IWP-1400 Monthly No exception V
Proper Lubricant Level or Pressure Monthly No exception j
Tb Annually No exception
- Not required but will be measured.
NOTE:
The Casing Cooling Pump recirculati n path is a fixed resistance i
system.
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c Page 15 of 20 SERVICE WATER PUMP Class 3 l-SW-P-1A j
1-SW-P-1B MEASURED QUANTITIES P
Exception
- See below AP Monthly **
Exception **
Monthly **
Exception to IWP-4110 is required Q
since flow instruments are only 4% accurate.**
Monthly No exception V
Proper Lubricant Level or Pressure Exception See below T
N t required See IWP-4310 b
NOTES:
The Service Water pump flow path is a variable resistance system.
Proper Lubricant Pressure or Level can not be observed since bearings are in the main flow path.
Reference is made to IWP-4310 which establishes exception to T for bearings within the main flow b
path.
Values will be recorded monthly but not compared to reference values.
Additionally, motor current will be recorded for comparison purposes.
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Attachment C.0 Page 1 of 2 STATEMENT OF PARTICULARS A review of class 1, 2, 3 valves has been completed for North Anna Unit 1 Systems. Attachment C.1 provides a tabulation of the valves that are subject to the testing requirements of ASME Boiler and Pressure Vessel Code, 1974 edition, subsection IWV with addenda through summer 1975. The table iden-tifies the valves to oc tested, valve code classes, and IWV category per IWV-2000.
Relief from the testing requirements of ASME XI is requested when they are determined to be impractical.
Specific information regarding the code require-ment determined to be impractical and alternate testing programs are noted in Attachment C.2 In addition to the valves listed in Attachment C.1, applicable contain-ment isolation valves shall be leak tested and cycled at each refueling.
North Anna Unit 1 Technical Specifications will list applicable valves and specify 10CF50 APP. J.
Leak Testing will be conducted in accordance with APP. J in lieu of subsection IWV.
There are no testable Category D valves in North Anna Unit 1 Systems. All Category E valves shall be tested in accordance with IWV-3700.
Any inspection requirements identified as impractical during the course of the inspection period will be noted and included in the inspection program at the time of the next r evision.
The main steam trip valves full closure time on any closure actuation signal will be verified while in HOT STANDEY during each reactor shutdown except that this verification need not be determined more often than once per 92 days for multiple shutdowns.
In the event of continued unit operation, a shutdown will not be required for the sole purpose of performing the full closure test.
The residual heat removal system relief valves shall be tested whenever
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Attachment C.1 Page 2 SYSTEM SI ASME ASME RELIEF TEST FREQUENCY ASME XI CODE III XI REQUESTED RELIEF REQUESTED VALVE FUNCTION CAT.
CAT.
EXERCISE LEAKAGE Boron Injection Tank MOV-1867 A, B II B
NO Every 3 Months NA NA Isolation Valves 4
4 Boron Injection Tank Each Every 3 Months MOV-1867 C, D II A
NO Isolation Valves Refueling NA (See Note 6)
High Head Safety Injection Off Each MOV-1869 A, B Charging Pump Header II AE YES Each Refueling Refueling NOTE 2 MOV-1836 Low Head Safety Injection To when in modes MOV-1890 A, B 4, 5, or 6 Each Hot Legs II AE yes (see Note 27)
M 27 Refueling Low Head Safety Injection To Each MOV-1890 C, D II A
YES Each Refueling tiOTE 3 Cold Legs Refueling Low Head Safety Injection Pump MOV-1860 A, B II A
YES Every 3 Months NONE NOTE 4 Suction From Containment Sump 1-51-185, 79 High Head Safety Injection Each Header Check Valves at II AC YES Each Refueling
_ol, 90 Containment Penetrations Refueling NOTE 5 c
Each
.-q 1-51-206, 207, low Head Safety Injection Header Refueling.
NOTE 7 Eheck Valves at Containment II AC YES Each Refueline (NOTE 8 applies 197, 195, 199 renetrations
]n107. 195,199,
Attachment C.1 i
rage 7 l
SYST171 CVCS, TUIR, QS ASt1E AS!1E RCt,IEr TI:S T P R1:QUntCY ASttC XI CODE III XI REQUESTEI' Rt:LII:P REQUESTI'll CAT.
CAT.
VA1,VE FUtICTIOtt EXERCISE LimtrAGE i
1 -C11-27 9, 267, Charging Pur,p Discharge Check Every 3 254 Valve II C
11 0 tion t m t3A
!!A RV-1203 Letdown Line Relief valve i
Inside Containment II C
!!O 110TE 1 11A t1A i
t1GV-1700, 1701, EllR Suction ar'd Discharge from Cold 1720A, 1720D Recctor Coolant System I
B YES Shutdown tiA ttOTE 16 FCV-lG05 IUIR Systen Flow and Throttle Every 3 FCV-1758 Valve II B
11 0 tionths
!!A 13A 1-Rit-7, 15 R11R Purp Discharge Check Valve I
C YES Cold 11A 130TE 16 l
Shutdown i
EV-1721 A, B RIIR Systen Relief Valve II C
11 0 110TE 26 t:A IIA l
.MOV-QS-101A, B Quench Spray rug Discharge and Every 3 Each Containment Isolation II A
fiO P1onths Refueling 1:A 1-QS-19, 11 Quench Spray Pump Discharge and Each Each Containment Isolation Check Valve II AC YES Ref uelitig Refueling t?OTE 17 4
2 1
9 4
Attachment C.1 rage 9 SYSTE!1,; g, p AST1C ASTIE RELIEr TEST FRINJUlUTCY AS!!E XI CODE III XI REQUESTED I'EI.IEF RrQUESTED CAT.
CAT.
VALVE FU!iCTIOf3 EXERCISE LEAYAGE l-SW-3, 10 Service Water Pumps Dincharge Every 3 2-SW-3, 10 Check Valve III C
NO Months tiA f1A 1-SW-ll4, 116 Service Water to Recirc. Spray Each IIcat Exchangers Check Valve III C
YES Refueling NA t;OTE 19 RV-SW-100A, D, Recire. Spray IIcat Exchanger III C
!!O t.OTE 1 NA NA C, D Telief Valve TV-!!S-101A, D, C 11ain Steam isolation Trip Valve Every 3 II D
11 0 t1onths NA NA (see IIOTE 21)
TV-MS-lllA, D Steam to Turbino Auxiliary Every 3 l
Feedwater Pump II D
!!O Months
!!A NA 1
s l-pts-119, 122, Main Steam to Turbine Auxiliary Every 3 124 Feedwater rump Check Valve II C
NO rionths
!!A NA l
SV-t15-101A, D, C Main Steam Safety Valves II C
!!O NOTE 1 flA flA 102A, D, C l
103A, D, C l
104A, B, C I
- 105A, D, C l
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A 1
Attachment C.1 Page 10 ASME ASME RELIEF TEST FREQUENCY ASME XI CODE RELIEF REQUESTED CAT.
CAT.
VEVE FUNCTION EXERCISE LEAKAGE HCV-FW-lOCA, B Auxiliary Feedwater Pump Discharge MOV-Fh'-100A, C Isolation III E
NO NONE NA NA 1
ECV-FN-lOOC Auxiliary Feedwater Pump Discharge MOV-FW-LOOB, D Check Valve III 3
YES Each Refueline NA NOTE 3 1-FW-47, 79, 111 Main Feedwater Check Valve at Containment Penetration II C
YES Each Refueline NA NOTE 22 1-FW-68, 100, 132 Auxiliary Feedwater Header Check
. 127, 93, 279 Valves to Main Feedwater Header III C
YES Each Refuelinc NA NOTE 23 1-FW-148, 165, Auxiliary Feedwater Pump Discharge 183, 150, 167, and Recirculation Check Valves III C
NO Every 3 MonthE NA NA 185 RV-FW-100 Turbine Auxiliary Feedwater Pump Discharge Relief Valve III C
NO NOTE 1 NA NA MOV-RS-156A, B Recirc. Spray Pump Discharge and II A
YES Each Refuelins Each Refueling NOTE 3 Containment Isolation Le1 NOV-R3-155A, B Recirc. Spray Pump Suction from II A
YES Each Refuelinc; NONE NOTE 3, 4 Containrent Srp
Attachment C.1 Page 11 SYSTE'1 RS, GW, EG, CC, SI ASME ASME RELIEF TEST FREQUE::CY ASME XI CODE III XI REQUESTEI RELIEF REQUESTED CAT.
CAT.
VALVE FUNCTION EXERCISE LEAKAGE MOV-RS-100A, B Casing Cooling Pump II A
NO Every 3 montho Each NA
^
MOV-RS-101A, B Discharge to RS pumps.
Refueling I
I Recirc. Spray Pump Discharge Check Each Valves at Containment Penetration II AC YES Each Refuelin:
Refueling NOTE 17 RV-GW-107A, B Waste Gas Decay Tanks and Gas III C
YES NOTE 24 NA NA 100, 104A,1 Stripper Equipment Relief Valves 103A,B,C,D 1C2A,B,C,D RV-EG-103A, B Emergency Generator Fuel Oil Pump 104A, B Discharge Relief Valve II C
NO NOTE 1 NA NA 105A, B 1CGA, B l-EG-26ti, 295 Emergency Fuel Oil Pump Discharge 254, 278 Check Valves II C
NO Every 3 months NA NA MOV-CC-100A, B Component Cooling Water to RHR IIcat III B
YES Cold Shutdow1 NA NOTE 25 Exchanger and Containment Isolation Each 1-CC-193, 198 Component Cooling Water to RHR Heat III AC YES Cold Shutdow1 NOTE 25 Exchanger and Containment Isolation U
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1-RS-146, 147 Recirc. Spray Pump-Safety Injection II E
NO NONE NA NA 3
1-SI-312,315 Pump Cross Connection
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Attachment C.2 Page 5 of 5 integrity.
This valve shall be exercised whenever the component cooling system for one unit is shutdown.
21.
Refer to Attachment C.0 which amplifies testing schedule.
22.
To exercise this normally open check vrive to the close position I
requires main feedwater flow to the steam generators to be secured and the initiation of auxiliary feedwater flow to back seat the disc. This valve shall be exercised when steam generator level and flow control is not required during a refueling outage.
23.
It is impractical to exercise this check valve during power operation or cold shutdown per INV-3520. The introduction of cold auxiliary feedwater to the steam generators induces unnecessary thermal stress on main fecdwater piping systems. This check valve shall be exercised at refueling outages using auxiliary feedwater flow.
24.
To prevent the release of radioactive contamination, relief valves on the waste gas decay tanks and gas stripper equipment shall be tested in accordance with IWV-3510 whenever these systems are out of service for maintenance and purged.
25.
Exercising this valve would decrease flow of component cooling water to major operational components during power operation.
It will be exer-cised during cold shutdown when flow is available to the RilR heat j
exchangers.
1 26.
These relief valves cannot be tested unless the entire RllR system is not required for service.
These valves will be tested when the system is out i
of service. The RIIR system must be availabic at all times during operation and refueling outages for core cooling capability.
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Att chment C.2 Page Sa of 5 27.
Technical Specification 4.5.2 requires these valves to remain closed with power to the operator removed while in HODES 1, 2, 3, and 4.
These vlavec shall be exercised whenever the unit is in MODES S or 6 but not more than once per 92 days.
28.
It is i.apractical to exercise this check valve during power operation per IW-3520. Opening the test volve would break containment vacuum.
The check valves shall be exercised at refueling outages.
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