ML20248E910
| ML20248E910 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/03/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20248E914 | List: |
| References | |
| 89-285, GL-89-04, GL-89-4, NUDOCS 8910060101 | |
| Download: ML20248E910 (18) | |
Text
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VIRGINIA ELECTRIC AND POWER COMPANY RICIIMOND, VIRGINIA 23261 october 3, 1989 L U.S. Nuclear Regulatory Commission Serial No.89-285 Attention: Document Control Desk PES /ISI/EWT R1 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 CONFORMANCE OF THE ASME SECTION XI INSERVICE TESTING PROGRAM FOR PUMPS AND VALVES TO NRC GENERIC LETTER 89-04 By letter dated April 3,1989, the NRC issued Generic Letter 89-04 which identified a number of generic deficiencies that could potentially affect plant safety. Attachment 1 to the Generic Letter described these deficiencies and explained the NRC technical positions regarding the associated ASME Section XI and Technical Specification requirements. Several of these NRC positions had been discussed with Virginia Electric and Power Company prior to issuance of the Generic Letter. Accordingly, we had submitted a revision for the North Anna Units 1 and 2 Inservice Testing Programs earlier this year. However, for closer compliance with the NRC technical positions in the Generic Letter, another program revision is required.
The North Anna Units 1 and 2 ASME Section XI Inservice Testing Programs for Pumps and Valves have been revised (Revision 5) to more closely incorporate the technical positions presented in NRC Generic Letter 89-04. With this submittal, Virginia Electric and Power Company intends to comply with the guidance provided in the NRC Generic Letter with the following exceptions: 1) implementation of the revised programs will take longer than recommended by the schedule provided in the Generic Letter and 2) contrary to NRC Technical Position 10, we intend to provide an engineering evaluation alternative to the repair or replacement requirements of paragraph IWV-3427(a).
As stated above, Virginia Electric and Power Company submitted Revision 4 of the Inservice Testing Programs by letter dated January 16,1989. In this submittal, we committed to revise the affected quarterly test procedures for Units 1 and 2 to the new program requirements by December 31, 1989. Those procedures required to be performed on a cold shutdown or refueling frequency were to be revised prior to the next refueling outages. Virginia Electric and Power Company intends to maintain this implementation schedule for changes required by Revision 5 of the Inservice Testing Programs.
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Upon completion of the required procedure revisions and plant modifications to be made during the next refueling outages, the North Anna Units 1 and 2 Inservice Testing Programs for Pumps and Valves will conform to NRC Generic Letter 89-04 with
- the exceptions noted above.
Enclosed find ten (10) copies of the revised Inservice Testing Programs for Pump and Valves (Revision 5) for your review. In addition, Attachment 1 to this letter is a discussion of our implementation schedule and the NRC technical positions presented in the Generic Letter. Additionally, to facilitate your review of this program submittal, Attachment 2 provides a summary of the program changes between Revisions 4 and
- 5. Finally, as discussed with the NRC Project Manager, two (2) sets of drawings for
, North Anna Unit 1 have been sent under separate cover to support the review of these programs; i.e., one set of drawings to Mr. Leon Engle, the NRC Project Manager, and the other set to Mr. Clair Ransom, the EG&G Idaho reviewer.
Should you require any additionalinformation regarding the changes to our Inservice Testing Programs, please contact us.
Very truly yours, 5*
W. L. Stewart Senior Vice President - Power Enclosures .
North Anna Unit 1 Inservice Testing Program, Revision 5 (10 copies)
North Anna Unit 2 Inservice Testing Program, Revision 5 (10 copies)
Attachment 1) Discussion of Schedule and the NRC Technical Positions Attachment 2) Summary of Changes between Revisions 4 and 5
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fF - oc: U.S. Nuclear Regulatory Commission-Region ll
- 101 Marietta Street, N.W.
- Suite 2900' Atlanta, Georgia . 30323
- Mr. J.' L. Caldwell NRC Senior Resident inspector North Anna Power Station Mr. L. B. Engle -
4 NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852
- Mr. Clair Ransom EG&G Idaho -
~ 1520 Sawtelle' Drive.
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ATTACHMENT 1 SECTION XI IST PUMP AND VALVE PROGRAM PLAN l-IN RESPONSE TO NRC GENERIC LETTER 89-04 NORTH ANNA UNITS 1 AND 2 CONFORMANCE STATUS BACKGROUND On June 3, 1988, the NRC met with Virginia Electric and Power Company to discuss NRC questions and comments pertaining to the North Anna Units 1 and 2 ASME Section XI Inservice Testing (IST)
L program. As a result of these meetings and their review of our IST program, the NRC requested responses to questions and comments provided in a letter dated June 9, 1988. Virginia Power responded
- i. to the request by submitting revised IST programs (Revision 4) for Units 1 and 2 on January 16, 1989. The guidelines provided by the NRC for the preparation of the revised IST submittals for the most part paralleled the technical positions provided in NRC Generic Letter (GL) 89-04. Some NRC positions have either changed or have received further clarification, therefore, changes to the January 16, 1989 submittals were necessary for full conformance.
IMPTiFMPNTATION SCHEDULE The January 16, 1989 submittals included an implementation schedule that stated the Periodic Test (PT) procedures performed on a quarterly basis would be revised by December 31, 1989, and PT procedures performed on a cold shutdown or reactor refueling basis would be revised and in place by the next refueling outages. The GL conformance date of October 3, 1989 includes the PT procedures.
l The NRC suggested in regional meetings held in June, 1989 and in the ASME/NRC Symposium on Inservice Testing held in Washington D.C. in August, 1989, that a reasonable implementation schedule for GL 89-04 would be acceptable. This matter was supposed to be addressed in meeting minutes that were to be published after the regional meetings. As of this writing, no meeting minutes are available.
Virginia Power and Electric Compevi intends to maintain the original implementation schedule iaentified in the January 16, l 1989 submittals (Revision 4). Having all program and implementing procedure revisions completed by October 3, 1989 is an unachievable request.
l The IST Program has been reviewed against the technical positions in the GL and revised to bring the program into conformance with the GL. Quarterly PT procedures are currently being revised.
EOUTPMENT MODIFICATIONS Several instrument modifications must be completed to implement the revised IST Program. The modifications and completion 1
ATTACHMENT 1 schedules' described below are for North Anna Unit 1 components and apply to like components for Unit 2.
- 1. Emergency- Diesel Generator Fuel Oil Pumps (1-EG-P-lHA, lHB, 1JA, 1JB) and Discharge Check Valves (1-EG-254, 266, 278, and 295)' -_ Inlet pressure and flow instrumentation will be installed during the next refueling outages.
1 1 2. Boric Acid - Transfer Pumps (1-CH-P-2A, B) - Strap on flow instrumentation' will be used to measure flow on the recirculation lines. If the strap. on instruments provide
. stable and accurate test results, they will be in place by December 31, 1989. If the strap on instruments do not provide acceptable results, more permanent flow instrumentation' will be instC 4 during the next refueling outage. Inlet. pressure it- .ntation and permanently
' mounted vibration transducers .211 be installed by the next refueling outage.
- 3. High Head Safety Injection Check Valves (1-SI-190, 192 and 194) - The flow instrumentation currently installed does not provide adequate accuracy for testing these valves. New instrumentation will be installed by the next refueling outage.
- 4. Low /High Head Safety Injection Check Valves (1-SI-83, 86, 89, 95, 99, 103, 195, 197, 199, 209, and 213) - These valves are on parallel lines that branch from common headers. Either temporary or permanent flow instrumentation that will measure flow in each line will be installed by the next refueling outage.
- 5. Charging Pump Discharge Recirculation Line Check Valves (1-CH-252, 264, and 277) - Strap on flow instrumentation will be installed by December 31, 1989. This instrumentation will be evaluated for adequacy in quarterly Section XI testing of Charging Pumps 1-CH-P-1A, 1B, and IC. Relief Request P-2 states that flow will be measured every reactor refueling when a flow path to the RCS can be established.
GL 89-04 ATTACHMENT 1 The following status references the applicable items in Attachment 1 of the GL:
- 1. Full Flow Testing of Check Valves Check valves subject to exercise testing to the open position in the IST Program Plan will be full flow tested unless an l
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ATTACHMENT 1 alternate testing method is identified in a relief request.
The full flow; testing methods and flow criteria will conform 3 to Technical Position 1 in GL 89-04. The schedule for completing theLrevisions to the PT procedures is given above.
The alternate testing method used for valves that cannot be full- flow tested is disassembly except for the Safety Injection Accumulator Discharge Check Valves (1-SI-125, 127, 142, 144, - 159 and 161) . The alternate testing method for the accumulator discharge check valves is described in Relief Request V-42 The procedure to perform the alternate testing will be completed by the next refueling outage along with the documentation needed to satisfy the requirements given. in Technical Position 1 and Item B (Programs Currently Under NRC Review) in the body of GL 89-04.
- 2. Alternative to Full Flow Testino of Check Valves Relief Requests V-33, 37, 50, 53, 55, 64, and 67 describe groups of valves subject to disassembly. Partial flow testing will be implemented where possible.
The valve disassembly sample size and interval are identified in the relief requests and conform to Technical Position 2.
The disassembly procedures will be in place by the next refueling outage.
- 3. Back Flow Testing of Check Valves Back flow testing methods were reviewed and will be revised as necessary to conform with Technical Position 2. Relief requests and cold shutdown justifications identify valves that cannot be exercised to the closed position every quarter.
Technical Position 2 of the GL lists check valves that may perform a safety function in the closed position and are frequently left out of IST programs. One check valve listed is the CVCS volume control tank discharge check valve. This valve (1-CH-215 for Unit I and 2-CH-153 for Unit 2) is currently not in the North Anna IST Program because isolation is provided upstream by motor operated valves. The CVCS VCT isolation valves 1-CH-MOV-1115C and E isolate on a Safety Injection Signal. The other valves in the list are included in the IST Program.
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ATTACHMENT 1
- 4. Pressure Isolation Valves Pressure' Isolation Valves (PIV) identified in the' Technical Specification are individually leak tested. The IST Program and.PT procedures conform to Technical Position 4.
- 5. Limiting Values of Full-Stroke Times for Power Operated Valves North Anna has established maximum stroke times based on-valve performance as described in Technical Position 5.
- 6. Stroke Time Measurements for Rapid - Acting Valves Relief Request V-54 describes " rapid acting" valves. A maximum limiting value of full stroke time of two (2) seconds has been assigned to these valves. The IST Program conforms to this item.
Relief Request .V-67 was added to eliminate the 'need for establishing alert ranges for power operated valves as required by IWV-3410 (c) (3) and to use OM-10 as the basis for valve strcke time measurements. OM-10 has been approved for use by~the 1986 Edition, Addenda through 1988.
- 7. Testing Individual Control Rod Scram Valves in Boiling Water Reactors (BWRs)
Not applicable to North Anna Power Station.
- 8. Starting Point for Time-Period in TS ACTION Statements The PT procedures will be revised to conform to Technical Position 8.
- 9. Pump Testing Using Minimum-Flow Return Line With or Without Flow Measuring Devi_ce.s The pump testing relief requests were revised in Revision 4 using the guidelines described in Technical Position 9.
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l ATTACHMENT 1
- 10. . Containment Isolation valve Testing Appendix J Containment -Isolation Valves (CIVs) have been included in the IST Program as Category A or A/C valves.
Relief ' Request V-69 was added to Revision 5 ' requesting that in addition to repair or replacement, corrective action can include an engineering evaluation to demonstrate that containment-integrity will be maintained'until the next Type C-test.
The second paragraph of Technical Position 10 states that the usefulness of additional requirements in IWV-34 27 (b) do not justify the burden of complying with the requirements.
. Relief Request V-60 was added to eliminate .the additional requirements of IWV-3427 (b) .
- 11. IST Program Scope 4
Technical Position 11 identifies pumps and valves that are frequently and erroneously omitted from the IST Programs.
Two types of components that are not in the current North I Anna IST Program and are included in this list are:
control room chilled water system pumps and-valves,
.and'
- accumulator motor operated isolation valves or accumulator vent valves.
The control room chilled water system (condenser and chilled water sides) and the accumulator isolation and. vent valves have been added to the program.
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ATTACHMENT 2 j SECTION XI IST PUMP AND VALVE PROGRAM PLAN IN RESPONSE TO NRC GENERIC LETTER 89 NORTH ANNA UNITS 1 AND 2 CHANGES BETWEEN REVISIONS 4 AND 5 i.
JThe..following' summary references pages in the North Anna
,. : Unit 1 Inservice Testing Program Plan, Revision 5, that have F been' revised. The changes given below apply to North' Anna o'
Unit 2.for like. components. Additional changes to Unit 2
'are summarized at the end'of this attachment. Revision 5 changes are highlighted by a revision bar in the right hand o
margin in the.IST Program Plans.
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L Pace
'iii Reference to NRC Generic Letter 89-04 was added' .
Reference to NRC Generic Letter 89-04 was added.
- 2-3:
- 2-8 Pumps for.the Control Room Chiller system were added. These include
1-HV-P-20A, B-and C for the chilled water side and 1-HV-P-22A, B and C for the condenser side.
p ~2-12 The above mentioned pumps were added to the pump table. 'These pumps will be tested on a quarterly basis with no relief from measuring'Section XI quantities'except for bearing temperature.
2-15 . Reference to Draft 11 of OM-6 was deleted. OM-6 has been approved'by the ASME main committee and replaces'Section IWP in the 1988 addenda of Section-XI.
.2-29 Clarification was added for pumps with differential pressure calculations.
. 2-33 Reference to the requirements in IWV-3410(c) (3) were' deleted. Determining an alert range for power operated valves will no longer be required as described in Relief Request V-66. OM-10 requires an operability range based on established reference values for valve stroke times. This eliminates the need to determino an alert range based on the previous test value.
2-34 OM-10, Paragraph 4.2.1.2 allows a plant to startup from cold shutdown before all cold shutdown testing is completed provided that testing commences within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of shutdown. This paragraph was added to the program.
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w i f ATTACHMENT 2
' Valve Table Chances
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2 _ Relief Request V-59 was removed from all valves on j'. this page. V-59 refers to leak testing valves in groups instead of individually as required by IWV.
3, ; 4- : Valve 1-CC-60 was deleted from the program. When one component cooling train is out of service, the upstream manual isolation valve is closed.
Because 1-CC-60 only needed to close when the Unit.
l' component cooling train was out of service and the manual valve performs that function, 1-CC-60 has'no safety' function to close.
Valves .1-CC-111, 146 and 181, and 1-CC-RV-125A, B and C were added to the program. These valves provide protection for low pressure piping from RCS pressure in the event of a rupture in the RCS pump thermal. barrier. A leak test is required to verify valve closure as described ir Relief Request V-65'.
Cold Shutdown Justification CSV-28 was added for Valves 1-CC-193 and 198. These valves cannot be full flow tested during normal operation because normal operating cooling loads may not be met.
Relief Request V-62 replaces Cold shutdown Justification CSV-2 for valves 1-CC-546, 559 and 572. The small increase in safety gained by performing a leak rate test to verify closure every cold shutdown versus every reactor refueling does not justify the added burden.
5 Relief Request V-59 was removed from all valves on this page. V-59 refers to leak testing valves in groups instead of individually as required by IWV.
-6 Relief Request V-59 was removed from valves 1-CC-TV-102C, D, E and F.
7 Relief Request V-59 was removed from valves 1-CC-TV-105A, B and C.
p 8 Valves 1-CD-161, 182 and 209 were added to the program. These valves are part of the control room chilled water system which has been added to the program.
l 13, 14 Cold Shutdown Justification CSV-9 was replaced by Relief Request V-9. The reactor coolant pumps must be secured and reactor pressure must be above 100 psig before valves 1-CH-MOV-1380 and 1381 can 2
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ATTACHMENT 2 L-be exercised. These conditions may not be met L every cold shutdown.
.. The VP test was removed from relief valve 1-CH-RV-
- 1203. This valve position indication test was erroneously placed against the valve in Revision 4.
Relief Request V-59 was removed from valves 1-CH-TV-1204A and B.
15 Relief Request V-59 was removed from all valves on this page.
16,'17 Relief Request V-59 was removed from valves 1-DA-39 and 40, 1-DA-TV-100L and B and 1-DG-TV-100A and B.
21 The Category AC was changed to C and the leak test requirement was removed from Valve 1-FP-272. This valve is in the Technical Specification table for Type C valves, however it is not subject to lehk testing.
22 Cold Shutdown Justification CSV-29 was added for Valves 1-FW-61, 63, 95 and 125. These alternate path auxiliary feedwater valves cannot be flow tested during normal operation because the dedicated flow paths would have to be isolated.
Relief Request V-61 was added to disassemble valves 1-FW-68, 100 and 132. To back seat these valves with flow to verify closure would require venting the lines. If these valves did leak by, test personnel would be endangered by high energy feedwater.
23 Relief Request V-56 was removed to disassemble valves 1-FW-526, 527 and 528 and replaced by Cold Shutdown Justification CSV-25. These valves are in the flow paths with the auxiliary feedwater pump lube oil coolers. The lube oil coolers can be isolated for a short period of time with no damage to the pumps. Testing for closure requires that the dedicated auxiliary feedwater line and the two standby lines be sequentially isolated.
These lines are required for normal operation.
24 Cold Shutdown Justification CSV-31 was added for valves 1-FW-HCV-100A, B and C. These valves are controlled by a potentiometer which requires several turns to fully stroke the valve.
Isolating actuator power is the only way to stroke the valves consistently. The valves must be 3
ATTACHMENT,2.
available during normal operation in the event of i; a' reactor trip.
[' 25 ColdcShutdown' Justification CSV-32nwas added for valves 1-FW-PCV-159A and B. These valves must be in service during normal operation to control auxiliary feedwater pressure.
27,.28. ~ Relief Request V-51 was withdrawn for valves 1-HC-62, 62 and 64. These 0.375 inch valves can be
. exercised every quarter by partial disassembly and
. direct movement of the' gate.
Relief Request V-59 was removed for' valves'1-HC-TV-100A, B, 101A, B, 103A, B and 104A and B.
29 Relief Request V-59 was removed from'all valves on this page.
30 Relief Request V-59 was removed for valve 1-HC-TV-108B.
.31 to 34 Valves 1-HV-MOV-111A, B , . C, 113A, B, C, 115-1, -2, 116-1,--2, 1-HV-PCV-1235A1, 2, B1, 2, C1, 2, 1-HV-RV-1200, 1, 1202A, B, 1205A, B, C, 1302A and B were added. These valves are part of the control croom chilled' water system which has been added to
'the-program.
35, 36 Instrument air valves 1-IA-925, 926, 934, 935, 944, 948,' 952, 959, 963, 967, 971 and 975, and 1-IA-SV-105A to H were added to the program in response to NRC Generic Letter 88-14 which deals with instrument air systems necessary to support safety related systems.
40 Cold Shutdown Justification CSV-26 was withdrawn for Valves 1-MS-19, 58 and 96. This justification referred to partial and full stroking of the check valves. These valves'are only required to close which can be verified every quarter.
42 Relief Request V-25 was withdrawn for Valves 1-MS-TV-101A, B and C. This relief request concerned the use of the alert range. Relief Request V-66 addresses this for all power operated valves.
7 43 Cold Shutdown Justification CSV-33 was added to valves 1-MS-TV-113A, B and C. Steam condenses in the main steam bypass lines during normal operation. Opening these valves would introduce a water slug to the turbine.
Valve 1-MS-TV-115 was renamed from 1-MS-115.
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- j h ATTACHMENT 2 f 1
45 Cold. Shutdown Justification CSV-17 was removed from valves 1-QS-11 and 19, and Relief Request V- ,
67 was added. These valves cannot be flow tested '
because water would be sent to the spray arrays and the containment would be saturated. They will be disassembled.
46 Relief Request V-59 was removed for valves 1-RC-176 and 178.
The Section XI category for valves 1-RC-PCV-1455C and 1456 was changed from B to BC and a setpoint test (SP) was added.
49 Relief Request V-59 was removed for valves 1-RH-36 and 37.
51 Relief Request V-59 was removed for valves 1-RM-TV-100C and D.
52 Relief Request V-59 was removed from all valves on this'page.
53 Cold Shutdown Justification CSV-21 was removed from valves 1-RS-18 and 27, and Relief Request V-67 was added. These valves cannot be flow tested because water would be sent to the spray arrays and the containment would be saturated. They will be disassembled.
56 The closure requirement for Valve 1-SI-47
_(charging pump suction from the RWST) was deleted.
Valves 1-SI-MOV-1115B and D provide isolation in downstream piping during suction transfer from the RWST to the containment sump.
59 Valves 1-SI-HCV-1853A, B and C were added to the program. These valves are in the SI accumulator vent system. They will be tested every reactor refueling per Relief Request V-68 because the accumulator tanks must remain pressurized and in service during normal operation and cold shutdowns.
60 Relief Request V-59 was removed for valve 1-SI-HCV-1936. !
61, 62 Relief Request V-59 was removed for valves 1-SI-MOV-1867C and D.
64 Relief Request V-59 was removed for valves 1-SI-TV-101, 1842 and 1859.
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h ATTACHMENT 2 L-n 65, 66- Relief Request V-59 was removed from all valves on
{,. these pages.
69,f70- Relief. Request V-63 was added for Valves 1-SW-3,.
L
~10.and 22. These valves cannot be full. flow tested without flowing to the Recirculation Spray Heat Exchangers. Water cannot be introduced to i
, these heat exchangers without draining them.which U
is impractical during-normal operation or cold shutdown.
'1..
Valves 1-SW-364, 386 and 420 were added to the program. These valves are on lines which supply service' water to the control room condensers.
h Cold-Shutdown Justification CSV-34 was added to Q
valves 1-SW-MOV-101A, B, C and D. During' normal operation, the lines between the service water supply header isolation valves mentioned above and W the recirculation heat exchanger isolation valves are maintained dry to ensure that no service water enters the heat exchangers.. These. lines would have to be drained after each test which is impractical during normal operation.
71, 7:2 - Cold Shutdown Justification CSV-34 was added to
. valves 1-SW-MOV-105A, B, C and D.- During normal.
operation, the' lines between the service water return header isolation valves mentioned above and the recirculation heat exchanger ~ isolation valves are maintained dry to ensure that no service water enters the heat exchangers. These lines would have to be drained after each test which is impractical during' normal operation.
1
'73 The test position for valves 1-SW-MOV-121A and B was changed from C to 0.
Valves.1-SW-MOV-122A and B were moved from the Unit 2 program to the Unit 1 program.
75 Relief Request V-59 was removed for valves 1-VG-TV-100A and B.
77 Relief Request V-58 was removed for valves 1-WT-38, 50 and 66. A test method will be used that limits the hazard of hydrazine to test personnel.
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ATTACHMENT 2 p
- Chances to Relief Recuests i.
2-41~ Notes were added'to the relief requests detailing-if the relief-request was' submitted before the-isruance of Generic Letter 89-04 ' (April . 3, 1989) and if the alternate testing' conforms to the technical positions in the GL. The NRC requested
? 'thislinformation during the June 8, 1989 Atlanta meeting.
2-47 Relief Request V-9 replaces Cold Shutdown Justification CSV-9 (see discussion for Page 13 of the valve table).
2-63 Relief' Request.V-25 was withdrawn (see discussion 4 for Page 42 of the valve table).
'2-77 Reference to closure testing was deleted in Relief-Request V-39. Valve 1-SI-47 does not have a safety-function to close (see discussion for Page L
56 of the valve table).
2-80, 81' Relief Request V-42'was' revised to indicate that 1 Valves 1-SI-125, 127, 142, 144, 159 and 161 would be' individually back seat tested every reactor k refueling.
2-82 Relief Request.V-43 was revised to indicate that
' Valves.1-SI-95, 99, 103, 209, 211 and 213 would be individually back seat tested every reactor refueling..
L 2-83 Relief Request V-44 was revised to indicate that Valves 1-SI-190, 192 and'194 would be individually back seat tested every reactor refueling.
2-89 Relief Request V-50 was revised to disassemble valve 1-HC-5. The alternate testing in Revision 4 does not meet the requirements of the GL.
2-90 Relief Request V-51 for Valves 1-HC-62, 63 and 64 was withdrawn (see discussion for Page 27 of the valve table).
2-91 Relief Request V-52 was revised from disassembly to verify closure to the performance of a leak test.
l 2-92 Full flow testing was added to Relief Request V-53 for valves 1-SI-4 and 21, 2-96 Relief Request V-55 was revised to disassemble Valves 1-EB-15, 34, 65 and 84. The alternate 7
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1 ATTACHMENT 2
' testing'in' Revision 4 does'not meet the ,
requirements of the GL.
2-971 Relief Request.V-56 was withdrawn for Valves 1-FW- I
.526, 527 and 528. Current instrumentation will be used to measure flow.for a' full flow test.
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2-99 . Relief Request'V-58 was withdrawn for Valves 1-WT-38, 50'and 66 (see discussion for PageI77 of the valve table).
2-101 Several valves were removed from Relief Request V-
- 59. These valves are identified in the discussions under the valve table pages.
2-102 Relief Request V-60 was added to eliminate the additional leak-rate tent requirements of IWV-3420 (g) (1) as' allowed by the GL.
'2-103 Relief Request V-61 was added (see discussion for
-Page 22 of the valve table).
2-104 Relief Request V-62 was added (see discussion for Pages 3 and 4 of the valve table).
2-105 Relief Request V-63 was added (see discussion for Page 69 of the valve table).
2-106 R'liefTRequest e V-64 was added to disassemble Valves 1-IA-925, 926, 934 and 935 (see discussion for Page 35 of the valve table concerning instrument air). Valves 925 and 926 are in series with no vent.in between as are 934 and 935.
Therefore, it is not possible to individually back seat these valves with flow.
2-107 Relief Request V-65 was added to back seat using a leak test Valves 1-CC-111, 146 and 181 every reactor refueling (see discussion for Page 3 of the valve table concerning these valves).
2-108 Relief Request V-65 was added (see discussion for Page 2-33).
2-109 Relief Request V-67 was added to disassemble valves 1-RS-18 and 27, and 1-QS-11 and 19 (see discussion for Pages 45 and 53 of the valve table L concerning these valves).
2-110 Relief Request V-68 was added for valves 1-SI-HCV-1853A, B and C(see discussion for Page 59 of the valve table concerning these valves).12-111 Relief Request V-69 was added for containment 8
c.
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ATTACHMENT 2
' isolation valves subject to Appendix J, Type C testing. In addition to repair or replacement as corrective action, an evaluation can be performed that demonstrates that even if a valve exceeds its permissible leakage rate, the overall containment
< leakage will be maintained below 0.6La until-the-next Type C tests.
' Chances to Cold Shutdown Justifications 2-114L Cold Shutdown Justification CSV-2 was replaced by Relief' Request V-62 (see discussion for Pages-3 and 4'of the valve table).
2-121 Cold Shutdown Justification CSV-9'was replaced by Relief Request V-9-(see discussion for Page 13 of the valve table).
2-129 Cold Shutdown Justification CSV-17:was replaced by Relief Request V-67 (see discussion for Page 45 of the valve table).
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'2-133 . Cold Shutdown Justification CSV-21 was replaced by Relief Request V-67 (see discussion for Page 5,3 of the valve table).
2-137 The technical basis for Cold Shutdown Justification CSV-25~was enhanced.
2-138 Cold Shutdown Justification CSV-26 was withdrawn (see discussion for Page 40 of the valve table).
2-140 Cold Shutdown Justification CSV-28 was added for valves 1-CC-193 and 198 (see discussion for Page 3 of the valve table).
2-141 Cold Shutdown Justification CSV-29 was added for valves 1-FW-61, 63, 95 and 125 (see discussion for Page 22 of the valve table).
2-142 Cold Shutdown Justification CSV-30 was added for valves 1-IA-944, 948, 952, 959, 963, 967, 971 and 975. To back seat these valves, the instrument I air system must be isolated and the lines vented.
I The instrument air system is needed during normal
[ operation.
I 2-143 . Cold Shutdown Justification CSV-31 was added for valves 1-FW-HCV-100A, B, C and D (see discussion for Page 24 of the valve table).
t 2-144 Cold Shutdown Justification CSV-32 was added for valves 1-FW-PCV-159A and B (see discussion for Page 25 of the valve table).
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ATTACEMENT~2-
'2-145' ~ Cold Shutdown Justification CSV-33 was added for l TA .valvesi1-MS-TV-113A, Bfand'C (see: discussion ~for Page 43.of'the. valve table).
.2-146 ' Cold Shutd'own: Justification CSV-34 was added for valves 1-SW-MOV-101A, B, C and D, and.105A,=B, C and D.(see discussion-for Pages 69, 70, 71 and 72 of the valve table).
l-Additional Chanaes-to North Anna' Unit 2 Valve 1 Table ~ Changes I+ Pace 56 The category for valves.2-SI-92, 100 and 106 was
, changed from AC to C, the isolation valve. type of PIV removed and the leak rate test (LT) also removed. These valves were' erroneously labled-pressure isolation valves in Revision 4.
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