ML18141A506

Reaffirms Schedule for Implementation of All Reg Guide 1.97 Items by Second Refueling Outage in Jul 1985.List of Items, Excluding in-core Thermocouples,Requiring Addl Work to Achieve Compliance Encl

ML18141A506
Person / Time
Site:	Surry, North Anna, 05000000
Issue date:	02/21/1984
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Eisenhut D Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.097, RTR-REGGD-1.097 088, 88, NUDOCS 8402280214
Download: ML18141A506 (7)

Text

r

! e

• VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND~ VIRGINIA 23261 W. L. STEWART VICE PRESIDENT NucLEAll OPERATIONS February 21, 1984 Mr. Harold R. Denton, Director Serial No. 088 Office of Nuclear Reactor Regulation NO,EC/DWL,PEC:jab Attn: Mr. Darrell G. Eisenhut, Director Docket Nos. 50-280 Division of Licensing 50-281 U. S. Nuclear Regulatory Commission 50-338 Washington, D. C. 20555 50-339 License Nos. DPR-32 DPR-37 NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY CLARIFICATION OF REGULATORY GUIDE 1.97 IMPLEMENTATION SCHEDULE On January 31, 1984, Vepco submitted letters (Serial Nos. 053 and 054) advising you of an implementation schedule for Regulatory Guide 1. 97, which was the second refueling after July, 1985. This schedule for implementation of all Regulatory Guide 1.97 items is still firm in our view. However, all items identified in Attachments 1 and 2 of this letter will be installed to the intent of Regulatory Guide 1.97 by the completion of the first refueling outage after July, 1985, which is presently scheduled in 1986 for each of our nuclear units. Attachments 1 and 2 represent the list of Regulatory Guide 1.97 items for North Anna and Surry, respectively, which require additional work in order to comply with Regulatory Guide 1.97.

Attachments 1 and 2 do not include incore thermocouples. As per our review of Regulatory Guide 1.97, the incore thermocouple system will also require upgrading to meet the intent of the Regulatory Guide. This system upgrade effort is encountering significant problems and may not be upgraded until the second refueling after July, 1985. In addition ~the problems and schedules-~-'

outlined in Attachment 3, the procurement lead times (approximately twelve

[12] months or longer) leaves us unable to commit at this time to the 1986 refueling dates. North Anna Units 1 and 2, and Surry Unit 1 have refueling outages in the first 4 months of 1986 which leads to the possibility of the required material not being on-site. It is our intent to notify the NRC by August 1, 1984, of our proposed schedule for implementing an upgraded incore thermocouple system.

It should be emphasized that the existing incore thermocouple systems at our plants are operational and have generally demonstrated good reliability over the years. Also, Vepco will have installed, qualified reactor vessel level monitors for the detection of inadequate core cooling conditions which account for a large portion of the thermocouple system functional basis.

fe4n22ao214 840221 enR*

• 1 f\oo\

~ \~

1 P

AnocK 050002ao PDR 'x

e VIRGINIA ELEcTmc AND PowER CoMPANY To Mr. Harold R. Denton In summary, Vepco will make every reasonable attempt to upgrade the existing incore thermocouple system in 1986 and will firmly commit to completion of other Regulatory Guide 1.97 items during the 1986 refueling outages.

cc: Mr. James P. O'Reilly Regional Administrator Region* II Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Mr. James R. Miller, Chief Operating Reactors Branch No. 3 Division of Licensing Mr. Don J. Burke NRC Resident Inspector Surry Power Station Mr. M. W. Branch NRC Resident Inspector North Anna Power Station

l ATIACHMENT 1 NORTH ANNA POWER STATION REGULATORY GUIDE 1.97 MODIFICATIONS

- ITEM NUMBER VARIABLE A-4 RCS Cold Leg Water Temperature A-5 RCS Hot Leg Water A-7 RCS Wide Range Pressure A-8 HPSI Flow A-10 Refueling Water Storage Tank Level A-11 PORV Position Indication A-12 Pressurizer Liquid Temp.

A-15 Containment Intennediate Range Pressure B-1 Neutron Flux B:-12A Containment Sump Water Level (Narrow)

B-12B Containment Sump Water Level (Wide)

B-14 Containment Isolation Valve Position D-6 Boric Acid Charging (Flow)

D-8 Flow in LPI System D-12 Pressurizer Level D-17 Steam Generator Level D-19 Main Steam Safety-Relief Valve Positions D-24 Heat Removal by the Containment Fan Heat Removal System D-25 Containment Atmosphere D-27 Makeup Flow-in

Attachment 1 N.th Anna Power Station ITEM NUMBER VARIABLE D-28 Letdown Flow-out D-29 Volume Control D-30 Component Cooling Water Temperature to ESF System D-31 Component Cooling Water Flow to ESF System D-33 Radioactive Gas Holdup Tank Pressure D-34 Emergency Ventilation Damper Position E-9 All other Identified Release Points E-12 Plant and Environs Radiation (portable instrumentation)

E-16 Estimation of Atmospheric Stability

ATTACHMENT 2 SURRY POWER STATION REGULATORY GUIDE 1.97 MODIFICATIONS ITEM NUMBER VARIABLE A-4 RCS Cold Leg Water Temperature A-5 RCS Hot Leg Water Temperature A-8 H.P.S.I. Flow A-11 PORV Position Indication A-12 Pressurizer Liquid Temp.

B-1 Neutron Flux 0-6 Boric Acid Charging (Flow}

0-12 Pressurizer Level 0-17 Steam Generator Level .

0-19 Safety-Relief Valve Positions 0-24 Heat Removal by the Containment Fan Heat Removal System 0-25 Containment Atmosphere 0-27 Makeup Flow-in 0-28 Letdown Flow-Out 0-29 Volume Control Tank Level 0-30 Component Cooling Water Temperature to ESF Systems 0-31 Component Cooling Water Flow to ESF Systems 0-33 Radioactive Gas Holdup Tank Pressure 0-34 Emergency Ventilation Damper Position E-12 Plant and Environs Radiation (portable instrumentation)

e ATTACHMENT 3 The present incore thermocouple system is installed commercial grade quality external to the reactor vessel for all four units. Both NUREG-0737 Section II.F.2, Attachment l and Regulatory Guide 1.97 have requirements to make a minimum of sixteen thermocouples Class lE and expand the existing ranges by a factor of three.

In September,. 1983, Vepco issued a request for quotations for a direct replacement thermocouple system to upgrade the existing system inside containment. Bids were received in late October from 2 separate vendors.

Both bids were found to be technically unacceptable at that time *

. The technical problems encountered were:

1. Replacement equipment was not compatible with existing equipment *

. 2. Interfaces to existing plant equipment were not addressed. The existing thermocouple system interfaces with the plant computer, emergency response facilities and core sub-cooling monitors.

3.

• One vendor's system is not presently environmentally qualified.

Subsequently, these bids were rejected. Vepco is proceeding with the necessary review and engineering to select, schedule, procure and implement an upgraded incore thermocouple system. The following aspects of this upgrade are being evaluated:

a. An upgrade of the entire thermocouple system external to the reactor vessel, not just the sixteen required by NUREG-0737 or Regulatory Guide 1.97, is being considered. This will have the advantages of avoiding maintenance, operational, and replacement parts problems associated with an intermixed. lE and commercial grade system.

Additionally, by upgrading the entire system, dependent upon which vendor is selected, there exist possibilities that the existing core sub-cooling monitors and reactor vessel level monitor cabinets could be replaced creating more space in the station and reducing the number of items to be maintained and spare part requirements.

b. The present incore system is installed top ent.ry into the reactor vessel. Vepco is presently evaluating upgrading the incore system by using either a top or bottom entry system. The advantages *and.

disadvantages of each type system are presently being evaluated with*

respect to cost, schedule, ALARA, installation, and maintenance*

factors.

c~ Significant problems are being encountered in the area of interfacing a new thermocouple system to existing plant systems. Since none of the new systems being evaluated readily interface to existing plant systems, this is *a particularly difficult problem to resolve.

ATTACHMENT 3 (Continued)

The schedule to complete our evaluation of items a, b, and c above is as follows:

Conceptual engineering and vendor evaluations completed by 6/1/84.

Construction costs and engineering and construction schedules and ALARA impacts completed by 6/22/84.

Recommendation to Vepco management prepared by 7/1/84.

Vepco management makes decision on which system to use by 7/15/84.

NRC notified by letter of thermocouple upgrade implementation schedule by 8/1/84.