ML19308A304
| ML19308A304 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/13/1979 |
| From: | Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Parr O Office of Nuclear Reactor Regulation |
| References | |
| 142, NUDOCS 7903200350 | |
| Download: ML19308A304 (7) | |
Text
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VintatxrA E r,1:cT saic Ax n l'ow s:It Co bt PA NY Hicnwoun, vino N I A u M 2 (s l March 13, 1979 Mr. Harold R. Denton, Director Serial No. 142 Office of Nuclear Reactor Regulation P0/DLB:scj Attn:
Mr. O. D. Parr, Chief LQA/ESG Light Water Reactors Branch No. 3 Docket No.:
50-338 Division of Project Management License No.:
NPF-4 U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Denton:
AMENDMENT TO OPERATING LICENSE EXEMPTIONS TO TECHNICAL SPECIFICATIONS AND 10 CFR 50 APPENDIX J NORTH ANNA POWER STATION UNIT 1 Pursuant to 10CFR 50.90 and 50.12, the Virginia Electric and Power Company hereby requests an amendment, in the form of exemptions from certain requirements of the Technical Specifications and 10CFR50 Appendix J Section D, to Operating License NPF-4 for the North Anna Power Staton, Unit No. 1.
The specific exemptions involve the deferral of several surveillance require-ments, as described below.
This request supercedes our initial request forwarded in our letter of March 7, 1979 (Serial No. 120).
We have recently completed a review of the Technical Specification surveillance requirements for North Anna Unit 1 and of the preoperational testing associated with the startup of that unit.
It has been determined that, due to the protracted nature of the preoperational test program, certain surveillance requirements will become due for performance before the anticipated refueling date of September, 1979.
The surveillance requirements in question fall into four categories:
- 1) Type a and C leakage testing, 2) reactor protection and engineered safety features response time, 3) safety injection and containment depressuri-zation actuation, and 4) instrument calibration.
North Anna Unit 1 is presently scheduled to be shutdown on March 24, 1979 for a one week snubber inspection. We have made every effort to schedule. as many of the refueling surveillance requirements as possible during the snubber inspection outage. However, the performance of all such tests which are due before September, 1979 would require an extension of the outage by several weeks. Accordingly, we have evaluated the implications of deferring certain of the surveillance requirements until September 30, h
1979. We have concluded that the deferral of a small portion of the surveill-ance requirements would have no significant effect on the ability of the
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plant systems to respond and perform in the event of an accident. Those 7903200S$o 3
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surveillance items for which deferral is planned are listed in the attachment, with the dates of last performance and current due dates. Note that many of the items listed will not be late if performed by mid September, based on the 25% scheduling flexibility permitted by T.S. 4.0.2.
As explained below, in certain cases, alternate or abbreviated testing will be performed. The tests for which deferral is planned represent only a small but time consuming portion of the refueling test requirements in each category. We request your approval of the deferral of those items listed in the attachment.
Following, for each of the four test categories, are discussions of the implications of test deferral and, where applicable, explanations of alternate testing to be performed.
- 1) Type B & C Testing The Type B and C leakage tests completed prior to unit startup demonstrated that the North Anna Unit 1 containment was exceptionally leak tight. The total Type B ar.d C leakage was 384.34 SCFD with 110.74 SCFD from Type B and 273.6 SCFD fr~m Type C.
This total was less than 9% of the allowable limit of 4395.0 SCFD.
To demonstrate that the North Anna Unit 1 containment remains satisfactorily leak tight we intend to perform an abbreviated Type C leak test during the snubber inspection outage. The purpose of the abbreviated test will be to determine, based on a sampling of penetrations, if Type C leak tightness has deteriorated significantly since the preoperational tests.
The sample of penetrations to be tested will include all penetrations which leaked at a rate greater than 6 SCFD during the initial testing. This sampling criteria includes all penetra-tions which leaked at even a moderate rate during initial testing.
During the initial Type C tests, the proposed sample contributed 85% of the total leak rate.
This approach will prevent a 3 to 4 week outage extension by deferring the testing of the large majority of valves which showed zero or negligible leakage during the initial tests.
The test of the sample penetrations will be in accordance with established Type C testing procedures. A new total leakage for the sample group will be determined. The total leakage for the sample will be divided by the initial Type C test total for the sample to yield a ratio, "R",
representative of the degree of leakage increase. The total initial Type C leakage will then be multiplied by "R" to determine an estimated current total leakage.
If the estimated current Type C leakage is greater than 3077 SCFD (70% of the limit), the leakage testing program will be expanded to include the entire Type C test program.
Regarding Type B testing, the initial Type B total was only 2.5%
of the limit. The only Type B penetration which has been disturbed since the initial test are the personnel hatches, which are tested in accordance with T.S. 4.6.1.3.
Due to their outstanding performance to
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date and the nearly new condition of the penetration seals, we have concluded that the deterioration of the Type B penetrations has been negligible.
We consider the abbreviated Type C test program to be a prudent and conservative means to assure containment integrity and more than adequate justification for deferral of a portion of the leakage testing requirements for three months.
- 2) Reactor Protection and Engineered Safety Features Response Timec Technical Specifications require that one train and a fraction of the number of channels be tested every 18 months such that response times of both logic trains of the Reactor Protection and Engineered Safeguards Features (ESF) systems are measured every 36 months. As part of the preoperational test program, both trains and all channels of protection and ESF junctions were checked and found to be in tolerance (typically 10-40% below limits).
We intend to test both trains and all channels of protection and ESF functions during the September refueling. This exceeds the requirement of testing each train every 36 months. The rotating test sequence permitted by Technical Specifications will be followed in subsequent refuelings. Since most of the extensions requested are short compared to the allowable 36 months, and in view of the comprehensive testing to be performed during the first refueling, we consider the short extensions to be justified.
- 3) Safety Injection and Containment Depressurization Actuation The tests in this category involve cycling of valves and energizing pumps in response to test signals. Each of the valves and pumps responded satisfactorily to test signals during preoperational testing. Pursuant to T.S. 4.0.5. many of the valves and all of the pumps involved are functionally tested on a greater frequency than 18 months to assure operability.
In addition, the reactor trip and ESF Actuation System logic is iested monthly in accordance with T.S. 4.3.1.1.2 and 4.3.2.1.2.
Based on this information and the fact that the average extension is only about I week, the deferral of these tests is considered reasonable.
The list also includes station blackout functions, under T.S.
4.8.1.1.2.C.3.
It was demonstrated that the diesel generator would start from ambient conditions and pick up the bus from blackout conditions during unit startup procedures in May 1978. This test functionally tested many of the time delay relays and some of the ESF equipment (charging pumps).
In additon, the diesel is full load tested monthly to verify operability. We therefore consider diesel operability during a station blackout to have been sufficiently demonstrated such that these tests can be deferred until the refueling outage.
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4)
Instrument Calibration The two instrument calibration items include calibration of the station reserve under voltage relays and of the seismic instrumentation.
In the case of the UV relays the calibration can probably be completed by 9/13/79, within the allowable extension of 25%.
The calibration of the seismic instrumentation is performed by a consultant. The consultant has indicated that personnel will be avail-able to perform the calibration during the outage.
However, in the event that unforeseen scheduling difficulties make performance of this calibration impossible without an outage extension, we request permission for deferral of this calibration until September 30, 1979. We do not believe that an extension of approximately 3 menths will affect the a'oility of these instruments to perform their intended function.
We have made every effort to schedule as many of the refueling surveill-ance requirements as possible during the snubber inspection outage. We will perform an abbreviated Type C leakage test to verify containment integrity.
As summarized above, the deferral of these few surveillance requirements will have no significant effect on the ability of the systems to respond and perform under accident conditions. Accordingly, an extension of the upcoming outage by several weeks in order to perform these tests would result in sigidficant expense and use of alternate fuels with no commensurate benefits.
This proposed change has been reviewed and approved by the Station Nuclear Safety and Operating Committee and the System Nuclear Safety and Operating Committee.
It has been determined that this request does not involve an unreviewed safety question.
We have evaluated this request in accordance with the criteria in 10CFR 170.22.
As noted above, the requested deferrals of some surveillance requirements will have no significant effect on the ability of the systems to perform under accident conditions. The Staff should be able to conclude, therefore, that this request does not involve a significant hazard considera-tion. Accordingly, this request has been determined to be Class III, and a check in the amount of $4,000 is enclosed in payment of the amendment fee.
Your timely response to this request would be greatly appreciated.
Very truly yours, C. M. Stallings Vice President-Power Supply and Production Operations cc:
Mr. James P. O'Reilly, Directcr Office of Inspection and Enforcement Region II
COMMONWEALTH OF VIRGINI A
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CITY OF RICHMOND
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Before me, a Notary Public, in and for the City and Common-weal th aforesaid, today personally appeared C. M. Stallings, who being duly sworn, made oath and said (1) that he is Vice President-Power Supply and Production Operations, of the Virginia Electric and Power Company, (2) that he is duly authorized to execute anc file the fore-going Amendment in behalf of that Company, and (3) that the statements in the Amendment are true to the best of his knowledge and belief.
Given under my hand and notarial seal this i.
y>, day of d, r./.
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My Commission expires
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Notary Public (SEAL)
ATTACHMENT e
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Attachment
- 1) Type B and C Testing 1.s.
psT Dom:
24M 4.6.1.2.d (Typ~ n) 6/28/77 6/28/79 (Type C) 6/6/77 6/6/79
- 2) Time Respoo w Testing I,AST DONE 18M DATE 18:1 + 25% DATE
..S.
4.3.1.1.3 an:1 4.3.2.1.3 (Except for Turbine Trip-Reactor Trip)
(Sensors) 10/11/77 4/11/79 8/26/79 (Circuit) 10/13/77 4/13/79 8/28/79 (Slave Relays) 10/19/77 4/19/79 9/4/79 (UV Coil) 12/15/77 6/15/79 11/1/79 4.3.2.1.3 (Turbine Trip -
1:eactor Trip) 11/2/77 5/2/79 9/17/79
- 3) Safety Injection, Containment Depressurization Actuat, Station Blackout T.S.
LAST D0!:E 18M DATE 18M + 25*' DATE 4.6.2.1.C 10/25/77 4/25/79 9/10/79 4.6.2.2.1.C 10/25/77 4/25/79 9/10/79 4.6.2.3.C 10/25/77 4/25/79 9/10/79 4.6.3.1.2.a 10/20/77 4/20/79 9/5//9 4.6.3.1.2.h 10/25/77 4/25/79 9/10/79 4.7.4.1.d.2 10/25/77 4/25/79 9/10/79 4.7.8.1.d.2 10/25/77 4/25/79 9/10/79 4.7.1.2.b.2 10/25/77 4/25/79 9/10/79 4.8.1.1.2.C.3 6/30/77 12/30/78 4/15/79
- 4) Instrument Calibrations T.S.
LAST TONE 18M DATE 18M + 257. DATE 4.3.2.1.1 (Channel 10/28/77 4/28/79 9/13/79 Calibration Item 6C) 4.3.3.3.1 (Calibration 7/12/77 1/12/79 5/27/79 Only)