ML20154G361
| ML20154G361 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/07/1998 |
| From: | Kuo P NRC (Affiliation Not Assigned) |
| To: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| RTR-REGGD-01.174, RTR-REGGD-01.175, RTR-REGGD-1.174, RTR-REGGD-1.175 TAC-M96683, TAC-M96684, NUDOCS 9810130134 | |
| Download: ML20154G361 (6) | |
Text
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9g pep Mr. J. P. O'Hanlon Senior Vice President Virginia Electric and Power Company 5000 Dominion Boulevard Glen Allen, VA 23060
SUBJECT:
REVIEW OF RESPONSES TO ANOMAllES IN SAFETY EVALUATION AND REVISED RELIEF REQUESTS FOR THE PUMP AND VALVE INSERVICE TESTING PROGRAM FOR NORTH ANNA POWER STATION, UNITS 1 AND 2 (TAC NOS. M96683 AND 96684)
Dear Mr. J. O'Hanlon:
in a letter 6ated October 18,1995, Virginia Electric and Power Company (VEPCO) responded to 10 ano.nalies identified in an NRC Safety Evaluation Report (SER) dated September 24,1995, for the North Anna Power Ststion, Units 1 and 2, Inservice Testing (IST)
Progrrim. In its letter dated February 15,1996, NRC discussed actions taken by VEPCO regarding the anomalies, and requested additional clarification and documentation of information. In its letter of July 22,1996, VEPCO clarified its position on Anomalies 1,3, 4,5, and 8, and indicated that relevant documentation would be available on-site for NRC inspection.
In the same July 22 letter, you withdrew Relief Request V-59 conceming leak testing for certain groups of containment isolation valves, and revised Relief Requests V 42 for Unit 1 and V 43 for Unit 2 to reflect the use of non-intrusive techniques for testing safety injection accumulator discharge check valves. The staff reviewed the actions taken and clarification conceming the anomalies and finds them acceptable. All actions, clarification, and commitments conceming the anomslies are subject to further review through NRC inspection activities.
In its July 22 letter, VEPCO also submitted a number of revised relief requests conceming closure testing of certain containment isolation (Cl) check velves. The current North Anna IST program was developed to the requirements of Section XI of the 1989 Edition of the ASME Boiler snd Pressure Vessel Code which references the OM-10 standard for valve inservice testing. Section 4.3.2 of OM-10 requires an exercise test for check valves on a quarterly basis, and, if the test is impractical, at cold shutdowns or refueling outages. Because the m.bject valves also function as containment isolation valves (CIVs), Section 4.2.2.2 requires that local-I leakage-rate tests be performed in accordance with the provisions in 10 CFR Part 50, Appendix l
J. Presently, the closure testing of the Cl check valves is performed in conjunction with a leakage-rate test at each refueling outage, because the quarterly exercise test has been found impractical to perform during power and at cold shutdown.
By NRC letter dated February 9,1996, North Anna received approval to use Option B of Appendix J for localleak testing of CIVs. Option B of Appendix J allows a performance-based test interval of up to 5 years between tests. Increasing the leak test interval from 2 years to 5 years is allowed by Section 4.2.2.2 of OM-10 and does not require relief. However, an exercise j
test required by Section 4.3.2 of ASME Code OM-10 cannot exceed one refueling cycle without a relief request. An exercise test is required to ensure the operational readiness and i
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i functiona!ity of the valve. Performing the closure (exercise) test of the subject valves during power and cold shutdown has been found impractical but performing the test during refueling i -
outage is feasible especially when measurement of leakage is not required. Therefore, the staff
' found that the relief request for extending the exercise test interval from 2 to 5 years could not ba justified using, as a basis, the argument that imposing Code requirements would result in hardship without a compensating increase in the level M quality and safety. Recognizing this, VEPCO provided the following justification and contended that the proposed extended test interval for the subject valves would provide an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i). The licensee stated the following.
(1) Option B of the Appendix J leakage test program for North Anna has been approved for use.
(2) The subject valves will be added to the plant's check valve predictive maintenance program.
(3) The subject valves must have a low risk significance as determined by the plant's P,obabilistic Safety Analysis (PSA).
As noted atnve, the use of Option B of Appendix J was approved only for application to leakage tess 4ervals, not for ensuring the operational readiness and functionality of the valves.
Valve exerciss tests are normally performed every 3 months, whereas valve leakage tests are usually performed every 2 years. Therefore, the staff finds that approva! of Option B is not an acceptable justification for allowing the closure (exercise) test interval to be extended beyond one refueling cycle.
VEPCO indicates that the subject valves will be added to the plant's check valve predictive maintenance program and states that the plant's predictive maintenance program meets the requirements of OM Subsection ISTC, Appendix II, entitled " Check Valve Condition Monitoring Program," dated June 1995, a draft issue. At the present time, the information submitted has been overtaken by recent events. Subsequent to your submittal, ASME OMa Code-1996 was published. Subsection ISTC 4.5.5 and Appendix 11 of the OMa-1996 Code contains specific provisions for implementing a condition monitoring program (CMP), and indicates that the CMP is an attemative to a valve exercise test. It should be noted that the purpose of this program is both to improve valve performance and to optimize the testing. The staff has since accepted the use of Appendix il to the OM Code (1996 Addenda) for the Wolf Creek Generating Station in a letter dated November 26,1997, with certain conditions and limitations. The staff encourages VEPCO to review the staff's conditions and limitations and pursue the use of Appendix 11 for the North Anna Power Station for the subject valves accordingly.
4 With regard to VEPCO's statement that the subject valves must have a low risk significance as determined by the plant's PSA, the staff has not been able to initiate its evaluation of the PSA approach because (1) VEPCO did not provide sufficient information for the staff to determine the risk significance of the proposed extended test interval, and (2) it is unclear how VEPCO's approach satisfies recent NRC guidance regarding use of the risk-informed inservice testing.
Recently, NRC issued Regulatory Guide (RG) 1.174, "An Approach for using Probabilistic Risk i
j Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," and
e 4
Mr. J. P. O'Hanlon North Anna Power Station j
Virginia Electric & Power Cornpany Units 1 and 2 J
cc:
Mr. J. Jeffrey Lunsford Regional Administrator, Region ll County Administrator U.S. Nuclear Regulatory Commission Louisa County Atlanta Federal Center P.O. Box 160 61 Forsyth St., SW, Suite 23T85 Louisa, Virginia 23093 Atlanta, Georgia 30303 Michael W. Maupin, Esquire Mr. W. R. Matther.s Hunton and Williams Sitt. Vice President Riverfront Plaza, East Tower North Anna Power Station 951 E. Byrd Street P. O. Box 402 Richmond, Virginia 23219 Mineral, Virginia 23117 Dr. W. T. Lough Mr. R. C. Haag Virginia State Corporation U.S. Nuclear Regulatory Commission Commission Atlanta Federal Center Division of Energy Regulation 61 Forsyth St., SW, Suits 23T85 P. O. Box 1197 Atlanta, Georgia 30303 Richmond, Virginia 23209 Mr. E. S. Grecheck Old Lr., inion Electric Cooperative Site Vice President 4201 Dominion Blvd.
Surry Power Station Glen Allen, Virginia 23060 Virginia Electric and Power Company 5570 Hog Island Road Mr. J. H. McCarthy, Manager Surry, Virginia 23883 Nuclear Licensing & Operations Support Robert B. Strobe, M.D., M.P.H.
Virginia Electric and Power Company State Health Commissioner Innsbrook Technical Center Office of the Commissioner 5000 Dominion Blvd.
Virginia Department of Health Glen Allen, Virginia 23060 P.O. Box 2448 Richmond, Virginia 23218 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Senior Resident inspector North Anna Power Station U.S. Nuclear Regulatory Commission 1024 Haley Drive Mineral, Virginia 23117
a 3
RG 1.175, "An Approach for F?lant-Specific, Risk-Informed Decisionmaking: Inservice Testing.'
These two documents provide guidance on how to apply probabilistic risk assessment methods i
to regulatory activities in general and to inservice testing of pumps and valves in particular.
VEPCO should review these two documents and determine the extent to which the proposed approach meets staff guidance and resubmit appropriate documentation to support the risk-informed IST approach if it intends to pursue such an approach.
In conclusion, VEPCO's responses to anomalies identified by staff in SER dated September 24, 1995, are acceptable and subject to NRC inspection. As discussed above, the request for relief from valve quarterly tests and the proposal to extend the test interval up to 5 years is not acceptable based on a lack of information. VEPCO, however, is encouraged to pursue this relief request by providing more information on its check valve CMP and/or proposing a risk-informed inservice testing program to allow extended test intervals for the check valves using the staff's guidance in RG 1.175.
On this basis, the staff considers TAC Nos. M96683 and M96684 to be closed.
Sincerely,
/
~
P. T. Kuo, Acting Director Project Directorate ll-1 Division of Reactor Projects - 1/II Office of Nuclear Reactor Regulations Docket Nos. 50-338 and 50-339 cc: See next page 4
October 7.1998 3
RG 1.175, "An Approach for Plant-Specific, Risk-Informed Decisionmaking: Inservice Testing."
These two documents provide guidance on how to apply probabilistic risk assessment methods to regulatory activities in general and to inservice testing of pumps and valves in particular.
VEPCO should review these two documents and determine the extent to which the proposed approach meets staff guidance and resubmit appropriate documentation to support the risk-informed IST approach if it intends to pursue such an approach.
In conclusion, VEPCO's responses to anomalies identified by staff in SER dated September 24, 1995, are acceptable and subject to NRC inspection. As discussed above, the request for relief from valve quarterly tests and the proposal to extend the test interval up to 5 years is not acceptable based on a lack of information. VEPCO, however, is encouraged to pursue this relief request by providing more information on its check valve CMP and/or proposing a risk-informed inservice testing program to allow extended test intervals for the check valves using the staff's guidance in RG 1.175.
On this basis, the staff considers TAC Nos. M96683 and M96684 to be closed.
Sincerely, Original signed by:
P. T. Kuo, Acting Director Project Directorate ll-1 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulations Docket Nos. 50-338 and 50 339 cc: See next page Distribution:
Docket File PUBLIC PDil/1 RF J. Zwolinski OGC ACRS J. Huang (Principal Contributor)
FILENAME: g:\\noanna\\m96883-4.cis PM:PDil-1 h LA:PDil-1 g D:PDil-1, g OFFICE NAME NKalyanam EDunnington PTKuo M f / 22/98 9 / # 27 / 9 8 l0/7/98
/
/98 DATE COPY hlNo h)No Yes / No Yes / No OFFICIAL RECORD COPY
,c.
m _. _ _ _ _ _ _ _ _ _ _ _.
o.'. m **
October 7,1998 3
RG 1.175, "An Approach for Plant-Specific, Risk-informed Decisionmaking: Inservice Testing."
These two documents provide guidance on how to apply probabilistic risk assessment methods to regulatory activities in general and to inservice testing of pumps and valves in particular.
VEPCO should review these two documents and determine the extent to which the proposed approach meets staff guidance and resubmit appropriate documentation to support the risk-informed IST approach if it intends to pursue such an approach.
In conclusion, VEPCO's responses to anomalies identified by staff in SER dated September 24, 1995, are acceptable and subject to NRC inspection. As discussed above, the request for relief from valve quarterly tests and the proposal to extend the test interval up to 5 years is not l
acceptable based on a lack of information. VEPCO, however, is encouraged to pursue this l
relief request by providing more information on its check valve CMP and/or proposing a risk-informed inservice testing program to allow extended test intervals for the check valves using the staff's guidance in RG 1.175.
i On this basis, the staff considers TAC Nos. M96683 and M96684 to be closed.
I Sincerely, Original signed by:
P. T. Kuo, Acting Director l
Project Directorate ll-1 l
Division of Reactor Projects -l/ll Office of Nuclear Reactor Regulations Docket Nos. 50-338
- and 50-339 i
j-cc: See next page Distnbution-l
{BibehetMi PUBLIC PD!l/1 RF J. Zwolinski OGC ACRS J. Huang (Principal Contributor)
FILENAME: g:\\noanna\\m96883-4.cls PM:PDll-1 h LA:PDil-1 g D:PDil-1, g)
OFFICE I
NAME NKalyanam EDunnington PTKuo l.
DATE
/ 22/98 9/M/98 l0 / 7 /98
/
/98 h/No kJNo Yes / No Yes / No COPY
[
OFFICIAL RECORD COPY
.-