ML20246A216
| ML20246A216 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/16/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-547, NUDOCS 8908220408 | |
| Download: ML20246A216 (4) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 16, 1989 U. S. Nuclear Regulatory Commission Serial No.89-547 Attention: Document Control Desk NAPS /JHL Washington, D. C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 HPF-7
' Gentlemen:
VIRGINIA ELECTRIC AND POWER CONPANY NDRTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT N05. 50-338/89-12 AND 50-339/89-12 REPLY TO THE NOTICE OF VIOLATION
.We have rev'iewed your letter of July 17, 1989, which referred to the inspection conducted at North Anna Power Station between April 12 14 and April 20
' 26, 1989 and reported in Inspection Report Nos. 50-338/89-12 and 50-339/89-12. The response to the Notice of Violation is attached.
We have no objection to this correspondence being made a matter of public record. If you have any further questions, please contact us.
Very truly yours, D.LW W. L. Stewart Senior Vice President - Power Attachment cc:
U. S. Nuclear Regulatory Commission 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station t
8908220408 890816 PDR ADOCK 05000338 Q
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RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN APRIL 12-14 AND APRIL 20-26, 1989 INSPECTION REPORT N05. 50-338/89-12 AND 50-339/89-12 NRC COPMENT During the Nuclear Regulatory Commission (NRC) inspection conducted on April 12-14 and April 20-26, 1989, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFP, Part 2, Appendix C (1989), the violation is.
listed below.
10 CFR 50, Appendix J. Paragraph III.C.1 states that Type C tests shall be performed by local pressurization. The pressure shall be applied in the same direction as that when the valve would be required to perform its safety function, unless it can be determined that the results from the test for a pressure applied in a different direction will provide equivalent or more conservative results.
Cor,trary to the above, two examples of non-conservative Type C testing of containment isolation valves were identified as follows:
a.
During the Unit 11987 refueling outage, six gate valves and seven globe valves on Unit I and, previous to the Unit 2 outage later that same year, fifteen valves on Unit 2 had been tested by not applying pressure in the same direction as that when the valves would be required to perform their safety function. The licensee has taken corrective action for this issue; consequently, a response is not required.
b.
Twenty-four globe valves in each unit, identified in the Licensee's Engineering Study 88-31 dated November 10, 1988, are Type C tested by applying test pressure in a direction different than the accident pressure and which tends to seat the valves.
The NRC review has concluded that this test is not equivalent or more conservative than applying test pressure in the accident direction which would tend to unseat the valves.
This is a Severity Level IV (Supplement I).
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FADNI'SSION OR DENIAL OF THE ALLEGED VIOLATION
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. The: violation is corre'ct as stated.
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REASON FOR THE' VIOLATION
- Subsequent Jto Jthe'~ decision 'to change the Type C testing methodology
- from ',the ' "leakJ by" to "make up" method,-
sufficient technical
-justification' was not provided:to justify Type C testing of containment Lisolation; valves' with test pressure' applied in the non-accident (directioniprior;to actually performing the testing.-
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J ORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS-ACHIEVED C
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- Engineering Study 88-31,
- and.a Justification for Continued Operation
- which addressed the non-conservative valve testing identified in item a)f of'the - violation, were approved after' testing in the non-accident
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idirection had already been performed.
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. Aistatistical-analysis. of Type C. test'results from three previous refueling outages for'each unit indicates that the direction in which the f test < pressure. is ?. applied has~ no direct effect on the -valve seat
- leakage.:.This statistical analysis supports the conclusions in the Justificatich for Continued Operation and Engineering Study 88-31.
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. CORRECTIVE' STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS i
Future Type C. testing will.be performed with test pressure applied in
- the accident direction in accordance with the requirements of 10 CFR 50, Appendix J.
This is consistent with the NRC position on Type C testing, as' stated in NRC Inspection Report 89-12.
As. discussed in a conference call between our staffs on August 14, 1989, future Type C' testing-methods can be altered in accordance with 7'
- 10. CFR '50, Appendix J to allow Type C testing with test pressure applied in the non-accident direction if adequate additional technical justification.is documented. Therefore, we are evaluating performing 1 Type C testing on each of the globe valves subject to the violation in both the accident and non-accident directions during the next Unit 2 T
refueling outage.
If performed, the test results will be evaluated to
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provide the additional justification of the equivalency of the two test directions.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Prior to the next. refueling outages, Unit I and 2 Type C test procedures will be revised to perform testing on each of the globe valves subject to the violation in the accident direction.
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