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| author name = Khanna M
| author name = Khanna M
| author affiliation = NRC/NRR/DORL/LPLII-1
| author affiliation = NRC/NRR/DORL/LPLII-1
| addressee name = Dennig R L, McMurtray A C, Ulses A P
| addressee name = Dennig R, Mcmurtray A, Ulses A
| addressee affiliation = NRC/NRR/DE/EPTB, NRC/NRR/DSS/SCVB
| addressee affiliation = NRC/NRR/DE/EPTB, NRC/NRR/DSS/SCVB
| docket = 05000338, 05000339
| docket = 05000338, 05000339
Line 16: Line 16:


=Text=
=Text=
{{#Wiki_filter:Kulesa, G!oria E From: Sent: To: Cc:  
{{#Wiki_filter:Kulesa, G!oria E
From:                       Khanna, Meena Sent:                       Friday, September 09, 2011 11:09 AM To:                         Ulses, Anthony; McMurtray, Anthony; Dennig, Robert; Mendiola, Anthony; Pelton, David; Fairbanks, Carolyn; Lupold, Timothy; Mitchell, Matthew; Pham, Bo; Murphy, Martin; Casto, Greg Cc:                         Kulesa, Gloria; Martin, Robert; Wood, Kent; Clifford, Paul; Bedi, Gurjendra; Cheruvenki, Ganesh; Manoly, Kamal; Wilson, George; McCoy, Gerald; Franke, Mark; Holian, Brian; Glitter, Joseph; Galloway, Melanie; Evans, Michele; Lubinski, John; Howe, Allen; Lund, Louise;


==Subject:==
==Subject:==
Attachments:
Ruland, William; Bahadur, Sher North Anna Seismic Issue - Path Forward for Restart Attachments:                The KK report .pdf; Untitled Importance:                High Based on Bob's email that was sent to several folks, as provided below, I'd like to share a few things that may be helpful in coming up with the list that Bob has requested. First of all, there is a link attached that includes the KK report (see pages 42 and on) that provides some useful insights that may be helpful to us in addition to the EPRI guidelines. I've also attached George Wilson's initial thoughts on what needs to be addressed in accordance with the EPRI guidelines as well as lists that he came up with as a result of speaking to several of the NRR BCs. Bob has requested that we each provide a list of questions that you need responses to from the licensee in support of the restart effort (short term and long term) by the 13th.
Importance:
Bob plans to set up a meeting early next week to address this initiative. Thanks for all of the support.
Khanna, Meena Friday, September 09, 2011 11:09 AM Ulses, Anthony; McMurtray, Anthony; Dennig, Robert; Mendiola, Anthony; Pelton, David;Fairbanks, Carolyn; Lupold, Timothy; Mitchell, Matthew; Pham, Bo; Murphy, Martin; Casto, Greg Kulesa, Gloria; Martin, Robert; Wood, Kent; Clifford, Paul; Bedi, Gurjendra; Cheruvenki, Ganesh; Manoly, Kamal; Wilson, George; McCoy, Gerald; Franke, Mark; Holian, Brian; Glitter, Joseph; Galloway, Melanie; Evans, Michele; Lubinski, John; Howe, Allen; Lund, Louise;Ruland, William; Bahadur, Sher North Anna Seismic Issue -Path Forward for Restart The KK report .pdf; Untitled High Based on Bob's email that was sent to several folks, as provided below, I'd like to share a few things that may be helpful in coming up with the list that Bob has requested.
Here are the tac nos:
First of all, there is a link attached that includes the KK report (see pages 42 and on) that provides some useful insights that may be helpful to us in addition to the EPRI guidelines.
TACS ME7050, ME7051 are for North Anna seismic issue.
I've also attached George Wilson's initial thoughts on what needs to be addressed in accordance with the EPRI guidelines as well as lists that he came up with as a result of speaking to several of the NRR BCs. Bob has requested that we each provide a list of questions that you need responses to from the licensee in support of the restart effort (short term and long term) by the 13th.Bob plans to set up a meeting early next week to address this initiative.
Thanks, Meena From: Martin, Robert Sent: Friday, September 09, 2011 10:28 AM To: Khanna, Meena
Thanks for all of the support.Here are the tac nos: TACS ME7050, ME7051 are for North Anna seismic issue.Thanks, Meena From: Martin, Robert Sent: Friday, September 09, 2011 10:28 AM To: Khanna, Meena  


==Subject:==
==Subject:==
KK report link Following today's meeting with Dominion Resources, I propose a process for the forthcoming review of the licensee's basis for restarting the two North Anna units. The discussions today indicate that many staff have given thought to the issue and currently have questions that will require an answer to support the restart review.I propose that we ask every branch in DSS, DCI, DE, DRA and the appropriate branch in DLR to forward any questions they have that are related to restart to DORL by September 13, cob. Many of these questions appear to be already written up or could be shortly. We would issue them to the licensee and then conduct meetings with the licensee, resolve issues in the meetings, followed by licensee documentation of the resolution.
KK report link Following today's meeting with Dominion Resources, I propose a process for the forthcoming review of the licensee's basis for restarting the two North Anna units. The discussions today indicate that many staff have given thought to the issue and currently have questions that will require an answer to support the restart review.
We would meet with the licensee each Thursday for example, and resolve issues as rapidly as licensee resources would support.We may need management support in getting a dedicated 33 person conference room each Thursday, for example. It can take hours and hours of effort to get a large conference room. The process used for today's meeting is too expensive for a series of multiple meetings.
I propose that we ask every branch in DSS, DCI, DE, DRA and the appropriate branch in DLR to forward any questions they have that are related to restart to DORL by September 13, cob. Many of these questions appear to be already written up or could be shortly. We would issue them to the licensee and then conduct meetings with the licensee, resolve issues in the meetings, followed by licensee documentation of the resolution. We would meet with the licensee each Thursday for example, and resolve issues as rapidly as licensee resources would support.
Just the administrative support costs about 3 PM days of time.
We may need management support in getting a dedicated 33 person conference room each Thursday, for example. It can take hours and hours of effort to get a large conference room. The process used for today's meeting is too expensive for a series of multiple meetings. Just the administrative support costs about 3 PM days of time.
Holding meetings at the site may not be practical or productive unless there is a site-specific issue to be addressed.  
 
'Its said that there a scaricity of motels near the site. Dominion's engineers are near Richmond.
Holding meetings at the site may not be practical or productive unless there is a site-specific issue to be addressed. 'Its said that there a scaricity of motels near the site. Dominion's engineers are near Richmond. It may be useful to hold one meeting in the vicinity of the site at the conclusion of the series of meetings noted above.
It may be useful to hold one meeting in the vicinity of the site at the conclusion of the series of meetings noted above.2 Initial Tests Follow Up Tests NOTE: THESE ACTIONS ARE PERFORMED ONLY IF OBE IS EXCEEDED OR DAMAGE FOUND (SEE FIG. 3-1)
2
Analysis flow path (1. 2, OR .3 I No ACCEPTABILITY BASED ON; ACCEPTAOILJTY 806ED ON:-VISUAL INSPECTIONS  
 
-VISUAL INSPECTIONS
Initial Tests Follow Up Tests NOTE: THESE ACTIONS ARE PERFORMED ONLY IF OBE IS EXCEEDED OR DAMAGE FOUND (SEE FIG.3-1)
-OPERABILITY TESTS -FUNCTIONALITY
 
-NONDESTRUCTIVE EVALUATIONS EXAMINATIONS  
Analysis flow path (1.       2, OR .3 I                 No ACCEPTABILITY   BASED ON;         ACCEPTAOILJTY 806ED   ON:
-- OPERABILITY TESTS-NONDESTRUCTIVE EXAMINATIONS
        - VISUAL INSPECTIONS             -   VISUAL INSPECTIONS
-- REPAJR OR REPLACEMENT OF DAMAGED AREAS L-CONDITIONS:
        - OPERABILITY TESTS             -   FUNCTIONALITY
: 1. TRS EXCEEDS FLOOR RESPONSE SPECTRA BASED ON ACTUAL EARTHQUAKE RECORD.2. GERS DMDED BY 1.3 EXCEEDS FLOOR RESPONSE SPECTRA BASED ON ACTUAL EARTHQUAKE RECORD.3. QUALIFIED ON BASIS OF SEISMIC EXPERIENCE DATA.
        - NONDESTRUCTIVE                       EVALUATIONS EXAMINATIONS                 -- OPERABILITY TESTS
Testing Requirements 0 Measurement of the opening and closing times of motor-operated va* Measurement of the closing time and leak rate of containment isol val yes.a Measurement of the flow and discharge pressure of pumps and fans.o Measurement of the concentration, pressure, temperature, and fluid level of Lanks and heal exchangers.
                                          -   NONDESTRUCTIVE EXAMINATIONS
o Verification of automatic startup of standby components and systems (e.g. , emergency core cooling pumps, diesel generatoy-s, etc .)0 Testing and calibration of instrumentation.
                                            -- REPAJR OR REPLACEMENT OF DAMAGED AREAS L
* Monitoring of reactor coolant system leakage.* Visual inspection and disassembly of components.
  -
0 Verification of the control logic in reactor protection systems and engineered safety systems.o Measurement of scram insertion times of control rods.(Lessons learned KK plant 2007 in Japan)Snubbers North Anna Units 1 and 2 "Code of Record" for fourth 10-year inservice inspection program is 2004 Edition of ASME Section X1 for snubber examination and testing.ASME Section Xl, Article IWF-5000 references ASME/ANSI OM Part 4 (OM-4), 1987 Edition with OMa-1988 Addenda.Currently North Anna Units 1 and 2 are using Technical Requirement Manual (TRM)Section 3.7.5 for snubber examination and testing in lieu of the ASME Section Xl requirements.
* CONDITIONS:
The use of alternative TRM 3.7.5 were approved by NRC as relief requests submitted by North Anna 1 and 2.ASME Code's Snubber Testing requirements are as follows: 10% testing sample plan or 37 snubber sample plan for snubber testing is to be used.If there is failure in test, additional sample of 5% sample or 19 snubbers (depending upon plan selected) shall be tested until no failure (test) achieved.Or North Anna 1 and 2 can use the NRC approved relief requests alternative for snubber testing which are equivalent to the Code requirements.
: 1. TRS EXCEEDS FLOOR RESPONSE SPECTRA BASED ON ACTUAL EARTHQUAKE RECORD.
Vessel Internals Since the design basis seismic loading exceeded during the seismic event dated August 23, 2011, the licensee should provide an evaluation of the structural integrity of the following RVI components which were originally designed using seismic loadings e.g., SSE and DBE as a part of its design basis (Reference-Westinghouse Report-WCAP-14577, 2001). These are considered "Primary" components that require routine inspections during every ISI interval.(a) Lower Support Forging; (b) Baffle Former Assembly; (c) Upper Core Plate; (d) Guide Tube; and (e) Core Barrel Assembly.Fuel Plan to talk with AREVA today about fuel. Note North Anna has AREVA fuel now, but will load Westinghouse fuel during the reload (Evaluate fuel to the fuel seismic rating)TWO issues regarding the fuel.1 -Seismic (structural) performance  
: 2. GERS DMDED BY 1.3 EXCEEDS FLOOR RESPONSE SPECTRA BASED ON ACTUAL EARTHQUAKE RECORD.
-the fuel is analyzed to behave in a safe manner (structurally) in the event of a OBE/SSE. If OBE/SSE is exceeded, fuel vendor warranties and regulatory analysis judgments are considered void until proven otherwise.
: 3. QUALIFIED ON BASIS OF SEISMIC EXPERIENCE DATA.
2- Thermal Hydraulic performance  
 
-Possibility of mixing flow vane damage could challenge the thermal margin performance of the fuel as well as the accident analyses of the core.EPRI guidance for vessel internals and fuel* Check each control rod drive mechanism for operability.
Testing Requirements 0     Measurement               of       the     opening             and       closing           times       of       motor-operated               va
0 Check in-core instrumentation readouts for changes.* Check primary coolant radiation monitors For changes.a Check primary coolant *Flow, temperature, and pressuro for chanqes.a Check loose parts monitoring equipment for changes in roise signatuLres.
* Measurement               of       the     closing             time       and     leak       rate       of     containment           isol val yes.
* Compare primary coolant sample chemistry with pre-earthquake samples.
a     Measurement               of       the     flow       and       discharge               pressure           of     pumps       and fans.
Spent Fuel There is some confusion over whether or not North Anna is crediting Boraflex.
o     Measurement               of       the     concentration,                       pressure,             temperature,                 and fluid       level         of       Lanks and heal                     exchangers.
NAPS UFSAR Rev 46 Section 9.1.2 indicates they are still crediting Boraflex for sub-criticality.
o     Verification                 of       automatic             startup             of     standby         components               and systems           (e.g.       ,   emergency               core       cooling           pumps,         diesel           generatoy-s, etc . )
There is a LAR from September 27, 2000, (ML003758403) that was removing the credit for the Boraflex.
0     Testing         and       calibration                 of     instrumentation.
There have been indications at other sites that Boraflex can shift during normal operations, let alone an earthquake.
* Monitoring             of       reactor           coolant             system         leakage.
If they are crediting Boraflex they should not move any fuel in the SFP it can be evaluated.
* Visual         inspection                 and     disassembly                   of   components.
The storage racks should be inspected for any damage or deformation that would affect cooling water flow or the criticality analysis.Containment We believe that the licensee likely has a list of IST tests scheduled to be performed if a shutdown will exceed 72 hours. These tests would provide an adequate sample of valve functionality, absent any visible evidence of damage.We recommend a general visual inspection of the containment consistent with Appendix J and industry guidance, NEI 94-01 and ANSI/ANS 56.8.Welds If any part exceeded design then do UT of those welds Typical Systems PWR Control Rod System Protective Instrumentation Containment Spray System Safety Valves and PORVs Reactor Coolant System Isolation Valves High Pressure Injection System Low Pressure Injection System Shutdown Cooling System Containment Isolation Valves Containment Vacuum Relief Valves Shock Suppressors (Snubbers)
0     Verification                 of     the     control           logic         in   reactor           protection               systems and engineered                     safety         systems.
Emergency Ventilation System Control Room Ventilation System Al arms Emergency AC and DC Power Supplies Diesel Generators Fire Detection and Suppression Remote Shutdown Panel Radioactive Effluent Treatment and Instrumentation Accident Monitoring Instrumentation Auxiliary Feedwater Service Water Component Cooling Water Reactor Protection System}}
o     Measurement               of     scram         insertion               times         of     control           rods.
(Lessons learned KK plant 2007 in Japan)
Snubbers North Anna Units 1 and 2 "Code of Record" for fourth 10-year inservice inspection program is 2004 Edition of ASME Section X1 for snubber examination and testing.
ASME Section Xl, Article IWF-5000 references ASME/ANSI OM Part 4 (OM-4), 1987 Edition with OMa-1988 Addenda.
Currently North Anna Units 1 and 2 are using Technical Requirement Manual (TRM)
Section 3.7.5 for snubber examination and testing in lieu of the ASME Section Xl requirements. The use of alternative TRM 3.7.5 were approved by NRC as relief requests submitted by North Anna 1 and 2.
ASME Code's Snubber Testing requirements are as follows:
10% testing sample plan or 37 snubber sample plan for snubber testing is to be used.
If there is failure in test, additional sample of 5% sample or 19 snubbers (depending upon plan selected) shall be tested until no failure (test) achieved.
Or
 
North Anna 1 and 2 can use the NRC approved relief requests alternative for snubber testing which are equivalent to the Code requirements.
Vessel Internals Since the design basis seismic loading exceeded during the seismic event dated August 23, 2011, the licensee should provide an evaluation of the structural integrity of the following RVI components which were originally designed using seismic loadings e.g.,
SSE and DBE as a part of its design basis (Reference-Westinghouse Report-WCAP-14577, 2001). These are considered "Primary" components that require routine inspections during every ISI interval.
(a) Lower Support Forging; (b) Baffle Former Assembly; (c) Upper Core Plate; (d) Guide Tube; and (e) Core Barrel Assembly.
Fuel Plan to talk with AREVA today about fuel. Note North Anna has AREVA fuel now, but will load Westinghouse fuel during the reload (Evaluate fuel to the fuel seismic rating)
TWO issues regarding the fuel.
1 - Seismic (structural) performance - the fuel is analyzed to behave in a safe manner (structurally) in the event of a OBE/SSE. If OBE/SSE is exceeded, fuel vendor warranties and regulatory analysis judgments are considered void until proven otherwise.
2- Thermal Hydraulic performance - Possibility of mixing flow vane damage could challenge the thermal margin performance of the fuel as well as the accident analyses of the core.
EPRI guidance for vessel internals and fuel
* Check       each       control             rod     drive     mechanism     for     operability.
0     Check       in-core           instrumentation                 readouts     for     changes.
* Check       primary         coolant             radiation         monitors     For     changes.
a     Check       primary         coolant             *Flow,     temperature,         and     pressuro         for chanqes.
a     Check loose               parts         monitoring           equipment     for     changes           in roise signatuLres.
* Compare           primary           coolant         sample       chemistry     with       pre-earthquake             samples.
 
Spent Fuel There is some confusion over whether or not North Anna is crediting Boraflex. NAPS UFSAR Rev 46 Section 9.1.2 indicates they are still crediting Boraflex for sub-criticality.
There is a LAR from September 27, 2000, (ML003758403) that was removing the credit for the Boraflex. There have been indications at other sites that Boraflex can shift during normal operations, let alone an earthquake. If they are crediting Boraflex they should not move any fuel in the SFP it can be evaluated.
The storage racks should be inspected for any damage or deformation that would affect cooling water flow or the criticality analysis.
Containment We believe that the licensee likely has a list of IST tests scheduled to be performed if a shutdown will exceed 72 hours. These tests would provide an adequate sample of valve functionality, absent any visible evidence of damage.
We recommend a general visual inspection of the containment consistent with Appendix J and industry guidance, NEI 94-01 and ANSI/ANS 56.8.
Welds If any part exceeded design then do UT of those welds
 
Typical Systems PWR Control         Rod     System Protective             Instrumentation Containment               Spray       System Safety         Valves         and     PORVs Reactor           Coolant         System         Isolation         Valves High       Pressure           Injection             System Low     Pressure           Injection           System Shutdown           Cooling         System Containment               Isolation             Valves Containment               Vacuum         Relief         Valves Shock       Suppressors               (Snubbers)
Emergency           Ventilation               System Control           Room Ventilation                   System Al arms Emergency           AC     and     DC   Power         Supplies Diesel         Generators Fire       Detection             and     Suppression Remote         Shutdown             Panel Radioactive               Effluent           Treatment           and Instrumentation Accident           Monitoring             Instrumentation Auxiliary             Feedwater Service           Water Component             Cooling         Water Reactor Protection System}}

Latest revision as of 08:58, 12 November 2019

E-mail from M. Khanna, NRR to A. Ulses, NRR Et Al Re North Anna Seismic Issue - Path Forward for Restart
ML12053A089
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 09/09/2011
From: Meena Khanna
Plant Licensing Branch II
To: Dennig R, Anthony Mcmurtray, Ulses A
Component Performance and Testing Branch, NRC/NRR/DSS/SCVB
References
FOIA/PA-2011-0357
Download: ML12053A089 (10)


Text

Kulesa, G!oria E

From: Khanna, Meena Sent: Friday, September 09, 2011 11:09 AM To: Ulses, Anthony; McMurtray, Anthony; Dennig, Robert; Mendiola, Anthony; Pelton, David; Fairbanks, Carolyn; Lupold, Timothy; Mitchell, Matthew; Pham, Bo; Murphy, Martin; Casto, Greg Cc: Kulesa, Gloria; Martin, Robert; Wood, Kent; Clifford, Paul; Bedi, Gurjendra; Cheruvenki, Ganesh; Manoly, Kamal; Wilson, George; McCoy, Gerald; Franke, Mark; Holian, Brian; Glitter, Joseph; Galloway, Melanie; Evans, Michele; Lubinski, John; Howe, Allen; Lund, Louise;

Subject:

Ruland, William; Bahadur, Sher North Anna Seismic Issue - Path Forward for Restart Attachments: The KK report .pdf; Untitled Importance: High Based on Bob's email that was sent to several folks, as provided below, I'd like to share a few things that may be helpful in coming up with the list that Bob has requested. First of all, there is a link attached that includes the KK report (see pages 42 and on) that provides some useful insights that may be helpful to us in addition to the EPRI guidelines. I've also attached George Wilson's initial thoughts on what needs to be addressed in accordance with the EPRI guidelines as well as lists that he came up with as a result of speaking to several of the NRR BCs. Bob has requested that we each provide a list of questions that you need responses to from the licensee in support of the restart effort (short term and long term) by the 13th.

Bob plans to set up a meeting early next week to address this initiative. Thanks for all of the support.

Here are the tac nos:

TACS ME7050, ME7051 are for North Anna seismic issue.

Thanks, Meena From: Martin, Robert Sent: Friday, September 09, 2011 10:28 AM To: Khanna, Meena

Subject:

KK report link Following today's meeting with Dominion Resources, I propose a process for the forthcoming review of the licensee's basis for restarting the two North Anna units. The discussions today indicate that many staff have given thought to the issue and currently have questions that will require an answer to support the restart review.

I propose that we ask every branch in DSS, DCI, DE, DRA and the appropriate branch in DLR to forward any questions they have that are related to restart to DORL by September 13, cob. Many of these questions appear to be already written up or could be shortly. We would issue them to the licensee and then conduct meetings with the licensee, resolve issues in the meetings, followed by licensee documentation of the resolution. We would meet with the licensee each Thursday for example, and resolve issues as rapidly as licensee resources would support.

We may need management support in getting a dedicated 33 person conference room each Thursday, for example. It can take hours and hours of effort to get a large conference room. The process used for today's meeting is too expensive for a series of multiple meetings. Just the administrative support costs about 3 PM days of time.

Holding meetings at the site may not be practical or productive unless there is a site-specific issue to be addressed. 'Its said that there a scaricity of motels near the site. Dominion's engineers are near Richmond. It may be useful to hold one meeting in the vicinity of the site at the conclusion of the series of meetings noted above.

2

Initial Tests Follow Up Tests NOTE: THESE ACTIONS ARE PERFORMED ONLY IF OBE IS EXCEEDED OR DAMAGE FOUND (SEE FIG.3-1)

Analysis flow path (1. 2, OR .3 I No ACCEPTABILITY BASED ON; ACCEPTAOILJTY 806ED ON:

- VISUAL INSPECTIONS - VISUAL INSPECTIONS

- OPERABILITY TESTS - FUNCTIONALITY

- NONDESTRUCTIVE EVALUATIONS EXAMINATIONS -- OPERABILITY TESTS

- NONDESTRUCTIVE EXAMINATIONS

-- REPAJR OR REPLACEMENT OF DAMAGED AREAS L

-

  • CONDITIONS:
1. TRS EXCEEDS FLOOR RESPONSE SPECTRA BASED ON ACTUAL EARTHQUAKE RECORD.
2. GERS DMDED BY 1.3 EXCEEDS FLOOR RESPONSE SPECTRA BASED ON ACTUAL EARTHQUAKE RECORD.
3. QUALIFIED ON BASIS OF SEISMIC EXPERIENCE DATA.

Testing Requirements 0 Measurement of the opening and closing times of motor-operated va

  • Measurement of the closing time and leak rate of containment isol val yes.

a Measurement of the flow and discharge pressure of pumps and fans.

o Measurement of the concentration, pressure, temperature, and fluid level of Lanks and heal exchangers.

o Verification of automatic startup of standby components and systems (e.g. , emergency core cooling pumps, diesel generatoy-s, etc . )

0 Testing and calibration of instrumentation.

  • Monitoring of reactor coolant system leakage.
  • Visual inspection and disassembly of components.

0 Verification of the control logic in reactor protection systems and engineered safety systems.

o Measurement of scram insertion times of control rods.

(Lessons learned KK plant 2007 in Japan)

Snubbers North Anna Units 1 and 2 "Code of Record" for fourth 10-year inservice inspection program is 2004 Edition of ASME Section X1 for snubber examination and testing.

ASME Section Xl, Article IWF-5000 references ASME/ANSI OM Part 4 (OM-4), 1987 Edition with OMa-1988 Addenda.

Currently North Anna Units 1 and 2 are using Technical Requirement Manual (TRM)

Section 3.7.5 for snubber examination and testing in lieu of the ASME Section Xl requirements. The use of alternative TRM 3.7.5 were approved by NRC as relief requests submitted by North Anna 1 and 2.

ASME Code's Snubber Testing requirements are as follows:

10% testing sample plan or 37 snubber sample plan for snubber testing is to be used.

If there is failure in test, additional sample of 5% sample or 19 snubbers (depending upon plan selected) shall be tested until no failure (test) achieved.

Or

North Anna 1 and 2 can use the NRC approved relief requests alternative for snubber testing which are equivalent to the Code requirements.

Vessel Internals Since the design basis seismic loading exceeded during the seismic event dated August 23, 2011, the licensee should provide an evaluation of the structural integrity of the following RVI components which were originally designed using seismic loadings e.g.,

SSE and DBE as a part of its design basis (Reference-Westinghouse Report-WCAP-14577, 2001). These are considered "Primary" components that require routine inspections during every ISI interval.

(a) Lower Support Forging; (b) Baffle Former Assembly; (c) Upper Core Plate; (d) Guide Tube; and (e) Core Barrel Assembly.

Fuel Plan to talk with AREVA today about fuel. Note North Anna has AREVA fuel now, but will load Westinghouse fuel during the reload (Evaluate fuel to the fuel seismic rating)

TWO issues regarding the fuel.

1 - Seismic (structural) performance - the fuel is analyzed to behave in a safe manner (structurally) in the event of a OBE/SSE. If OBE/SSE is exceeded, fuel vendor warranties and regulatory analysis judgments are considered void until proven otherwise.

2- Thermal Hydraulic performance - Possibility of mixing flow vane damage could challenge the thermal margin performance of the fuel as well as the accident analyses of the core.

EPRI guidance for vessel internals and fuel

  • Check each control rod drive mechanism for operability.

0 Check in-core instrumentation readouts for changes.

  • Check primary coolant radiation monitors For changes.

a Check primary coolant *Flow, temperature, and pressuro for chanqes.

a Check loose parts monitoring equipment for changes in roise signatuLres.

  • Compare primary coolant sample chemistry with pre-earthquake samples.

Spent Fuel There is some confusion over whether or not North Anna is crediting Boraflex. NAPS UFSAR Rev 46 Section 9.1.2 indicates they are still crediting Boraflex for sub-criticality.

There is a LAR from September 27, 2000, (ML003758403) that was removing the credit for the Boraflex. There have been indications at other sites that Boraflex can shift during normal operations, let alone an earthquake. If they are crediting Boraflex they should not move any fuel in the SFP it can be evaluated.

The storage racks should be inspected for any damage or deformation that would affect cooling water flow or the criticality analysis.

Containment We believe that the licensee likely has a list of IST tests scheduled to be performed if a shutdown will exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. These tests would provide an adequate sample of valve functionality, absent any visible evidence of damage.

We recommend a general visual inspection of the containment consistent with Appendix J and industry guidance, NEI 94-01 and ANSI/ANS 56.8.

Welds If any part exceeded design then do UT of those welds

Typical Systems PWR Control Rod System Protective Instrumentation Containment Spray System Safety Valves and PORVs Reactor Coolant System Isolation Valves High Pressure Injection System Low Pressure Injection System Shutdown Cooling System Containment Isolation Valves Containment Vacuum Relief Valves Shock Suppressors (Snubbers)

Emergency Ventilation System Control Room Ventilation System Al arms Emergency AC and DC Power Supplies Diesel Generators Fire Detection and Suppression Remote Shutdown Panel Radioactive Effluent Treatment and Instrumentation Accident Monitoring Instrumentation Auxiliary Feedwater Service Water Component Cooling Water Reactor Protection System