ML19326D694
| ML19326D694 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/30/1980 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Harold Denton, Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0660, RTR-NUREG-660 560, NUDOCS 8007030151 | |
| Download: ML19326D694 (12) | |
Text
gym Vino trTIA E r.nc rutc Ann l'own u Co.w vAsv R reirw on o,vina an rA 2aue s June 30, 1980 Mr. Ilarold R. Denton, Director Serial No. 560 Of fice of Nuclear Reactor Regulation LQA/ ESC:rab Attn:
Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Docket No. 50-339 Livision of Licensing License No. NPF-7 U. S. Nucicar Regulatory Commission Washington, D.C.
20555
Dear Mr. Denton:
NUREG-0660 FULL POWER AND 1980 DATED REQUIREMENTS NORTil ANNA UNIT NO. 2 We have reviewed the listing of full power licensing re-quirements f ro:n NUREG-0660, which was provided to us during our meeting with the Staf f on June 19, 1980. A summary of our response to each of these items is provided in Attachment 1. provides similar responses for each of the approved and proposed dated requirements which indicate implementacion dates during 1980.
These items, all of which apply to operator training and licensing, have been implemented in accordance with the requirements.
Work is also proceeding on completing the itecis with January 1, 1981 implementation dates. A status report crt these items will be provided to you separately.
Very truly yours,
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ylvia Manager-Nuclear Operations and Mainternance Attachments i
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e ATTACHMENT 1 NUREC-0660 FULL POWER REQUIREMENTS NORTH ANNA UNIT NO. 2 1.C.7 NSSS VENDOR REVIEW OF PROCEDURES Certain NSSS vendor review of power ascension test and emergency procedures to further verify their adequacy.
This requirenent must be met before issuance of a full power license.
RESPONSE
The NSSS vendor for North Anna Unit 2, Westinghouse Electric Corpora-tion,.has reviewed the emergency procedures which were submitted to the Commission on Iby 30, 1980, in accordance with License Condition 2.D(6)a.
Westinghouse has also reviewed the power ascension test procedures and has provided Vepco with the results and conclusions of that review.
We will incorporate appropriate changes resulting from this review.
1.C.8 FILOT MONITORING OF SELECTED EMERGENCY PROCEDURES FOR NEAR-TERM OPERATING LICENSE APPLICANTS l '
Correct energency procedures, as necessary, based on the NRC audit of selected plant emergency operating procedures (e.g., small-break LOCA, loss of feedwater, restart of engineered safety features following a loss of ac power, steam-line break, or steam-generator tube rupture).
This action will be completed prior to issuance of a full-power license.
RESPONSE
The emergency procedures were submitted for Staff review by our letter of bby 30,1980 (Serial No. 484). The procedures for loss of main feedwater
- was submitted by our le,tter Serial No 395, dated May 1,1980.
We have met with members of the Staff at the North luuaa site to discuss these procedures. Changes agreed upon during this meeting will be incorporated into the procedures. The NRC Staff review group is currently scheduled to walk through the revised procedures at our Surry simulator facility on July 2 and 3, 1980, followed by another walk through in the North Anna control room on July 7, 1980.
-Following the completion of these reviews, the revised procedures will be prepared in final form and approved by the Station Nuclear Safety and Operating Committee.
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1.G.1 TRAINING DURING LOW-POWER TESTING Supplement operator training by completing the special low-power test program. Tests may be observed by other shif ts or repeated on othar shifts to provide training to the operators.
This requirement shall be met before issuance of a full-power license.
RESPONSE
The training plan for shif t personnel during conduct of the low-power tests was described in our letter Serial No. 559, dated June 24, 1980.
Each licensed operator will be required to participate in at least test 2-ST-9.
In addition, each licensed operator will be required to observe at least two o ther tests f rom the group 2-ST-6, 2-ST-8, or 2-ST-ll, ll.B,1 REACTOR COOLANT SYSTEM VENTS Provide a description of the design of reactor coolant system and reactor l
vessel head high point vents that are remotely operable f rom the control room and supporting analyses. This requirement shall be met before issuance of a full-power license (See Enclosure 1 to letters of September 27 and November 9, 1979).
RESPONSE
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l By our letter Serial No. 015, dated January 10, 1980, we provided the l
conceptual design for the reactor vessel and pressurizer vent systems. The system is designed such that no single failure will prevent reactor vessel or prevent vent isolation. The vessel vent orifice restricts l
pressurize venting,
't the flow rate from a pipe break downstream of the orifice to within the make-up capacity of one charging pump.
This design meets the Category A requirements.
l II.B.2 PLANT SHIELDING Provide (1) a radiation and shielding design review that identifies the location of vital areas and equipment in which personnel cecupancy may be unduly limited or safety equipment may be unduly degraded by radiation during operations following an accident resulting in a degraded core, and (2) a description of the types of corrective actions needed to assure adequate access to vital areas and protection of safety equipment This requirement shall be met before issuance of a full-power license.
(See NUREG-0678, Section 2.1.5b, and letters of September 27 and November 9, 1979).
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RESPONSE
Shielding Review A design review was conducted using the Stone and Webster Engineering Corpora-t ion "Ac tivity-2" and " Radioisotopic" computer codes. The NRC specified source terms were used. All systems designed to function af ter an accident were considered as sources, including Safety Injection, Recirculation Spray, Ilydrogen Recombiner, Sampling, Auxiliary building sump and drain lines. The letdown portion of the CVCS was excluded because it is isolated and because its use in the post-accident situation would be unacceptable. All vital areas were identified and evaluated. Areas where continuous occupancy is required are the control room, the technical support center, counting room, operational support center and security control center.
Limited access is needed to such places as emergency power supplies and sampling stations.
The need for modifications was identified in our letter dated January 10, 1980 and detailed in our letter of April 1,1980.
All the NUREG-0578 Category A requirements have been satisfied at North Anna Units 1 6 2.
An updated listing of modifications required to meet the Category B requirements is being prepared and will be furnished in a separate letter.
Equipment Qualification i
The evaluation of radiation environmental qualification of equipment is proceeding slowly because of the difficulty in obtaining vendor data on older plants. The mechanical equipment review is complete for North Anna.
Vepco has committal to reporting the results of the electrical equipment review as I
they are available and in conjunction with the responses to I.E.Bulletin 79-01 and NUREG-0588. Any necessary modifications will be made as they are identified.
A list of modifications identified to date is being prepared and will be furnished separately.
II.B.3 POSTACCIDENT SAMPLING Provide (1) a design and operational review of the capability to promptly obtain and perform radioisotopic and chemical analyses of reactor coolant and containment atmosphere samples under degraded core accident condi-tions without excessive exposure, (2) a description of the types of corrective actions needed to provide this capability, and (3) procedures for obtaining and analyzing these samples with the existing equipment.
This requirement shall be met before issuance of a full-power license.
(See NUREG-0578, Section 2.1.8a and letter of September 27 and November 9, 1979).
RESPONSE
A design review of the capability to provide post accident sampling has been conducted.
Interim procedures have been written and minor modifications have been made to provide sampling capability of both the reactor coolant and containment atmosphere und' r post accident conditions.
Further details ara e
provided in our January 10,1980, April 28,1980 (Serial No. 37'6) and May 28, 1980 (Serial No. 470) letters. All the short term lessons learned Category A requircsents for this item have been satisfied for North Anna Units 1 and 2.
In addttion, Vepco has committed to satisfying the Category B re-quirements for an improved post-accident sampling system.
II.B.4 TRAINING FOR MITIGATING CORE DAMAGE Complete the training of all operating personnel in the use of installed ~
systems to monitor and control accidents in which the core may be severely damaged.
This requirement shall be met before issuance of a full-power license.
RESPONSE
Training of operating personnel in the use of installed systems to monitor.and control accidents in which the core may be damaged is currently in progreas. This training incorporates the topics specified in License Condition 2 3. (5); including incore instrumentation, excore nucle ar instru-mentation, vital instrumentation, primary chemistry, radiation monitoring, and gas generation.
Estimated completion of the initial training for all participants is July 12,1980.
f si II.E.I.I AUXILIARY FEEDWATER SYSTEM RELIABILITY EVALUATION (1) Provide a simplified auxiliary feedwater system reliability analysis that uses event-tree and fault-tree logic techniques to determine the potential for AFWS f ailure following a main feedwater transi27.t, with particular emphasis on potential failures resulting from human errors, common causes, single point vulnerability, and test and maintenance outage.
(2) Provide an evaluation of the AFWS using the acceptance criteria of Standard Review Plan Section 10.4.9.
(3) Describe the design basis accident and tran'sients an corresponding acceptance criteria for the AFWS.
(4) Based on the analyses performed modify the AFWS, as necessary.
These requirements shall be met before issuance of a full-power license.
RESPONSE
Out letters Serial No. 151 (February 26,1980) and 259/031080 (March 24, 1980) noted that the results of the NRC reliability analysis for North Anna Unit 1 also applied to Unit 2, and that modifications made to Unit I as a result of this study would also be made on Unit 2.
Our letter Serial No. 550, dated June 23, 1980, confirmed that the auxiliary feedwater systems for the two' units are essentially identical.
We have performed an evaluation of the North Anna 2 AFUS using the acceptance criteria of Standard Review Plan 10.4.9.
The results of this evaluation were submitted with our letter of June 23, 1980.
The design basis accident and transient information is currently under development for both Units 1 and 2.
We anticipate we will be able to provide this information for ;our review by July 3,1980.
As noted in our June 23, 1980 letter, installation of a redundant level transnitter for the Unit 2 Emergency Condensate Storage Tank has been completed, satisfying all short-term system modifications identified as necessary by the reliability s'tudy.
II.E.3.1 EMERGENCY POWER FOR PRESSURIZER HEATERS Install the capability to supply from emergency power buses a sufficient number of pressurizer heaters and associated controls to establish and maintain natural circulation in hot standby conditions.
This requirement shall be met before issuance of a full-power license.
(See NUREG-0578, Section 2.1.1, and letters of September 27 and November 9, 1979).
RESPONSE
j The Westinghouse Owner's Group analysis has determined that to main-tain natural circulation in a three loop plant with a pressurizer volume of 1400 cubic feet, a heater of 125 kw capacity sE sid be available within one hour. Two backup heater groups rated at 270 kw each and their associated controls are energized f rom redundant emergency buses which are capable of being f ed f rom either' offsite power or onsite diesel generators (D-G).
The Class IE interfaces for motive and control power are protected by safety grade circuit breakers.
The pressurizer heaters are not automatically loaded or to the bus following the occurrence of a safety injection (SI) actuation signal or loss of offsite power. The continuous rating of the diesel generator indicates that following automatic sequence loading of. emergency loads there. is insufficient D-G capacity to allcr loading of the pressurizer heaters without first load i
shedding selected loads. Procedures are in force to instruct the operator in load shedding sequences and in the use of pressurizer heaters to establish and maintain natural circulation.
Further details concerning provision of emergency power to the pressurizer heaters may be found in our letters of October 25, 1979, November 26, 1979 and January 10, 1980.
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i II.E.4.2 CONTAINMENT ISOLATION DEPENDABILITY Provide (1) containment isolation on diverse signals, such as con-tainnent pressure or ECCS actuation, (2) automatic isolation of nonessential systems (in ' 'ing the bases for specifying the non-essential systems), (3) ao automatic reopening of containment isolation valves when the isolation signal is reset.
l Inese requirements shall be met b~efore issuance of a full-power license.
~ (See NdnEG-0578,' Section 2.1.4, and letters of September 27 and November 9,1979).
RESPONSE
All containment isolation valves (CIVs) in non-essential systems that were originally designed to close upon receipt of an automatic isolation signal meet the lessons learned position on diversity.
A diverse safety l
injection signal is provided for these valves, with the exception of the main l
steam isolation valve (MSIVs). Diverse parameters are used to initiate MSIV i
closure. All Category A and 3 requirements have been satisfied at North Anna l
Units 1 and 2 for containment isolation diversity.
The North Anna design precludes automatic reopening of containment isolation valves upon reset of the isolation signal. However, the automatic isolation valve in the condenser air ejector vent line would reopen after
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reset if a high radiation condition eMists in the condenser.
Theretore, administrative controls are in effect to discble the high radiation interlock
,4 on this valve prior to resetting the containment isolation signal if contain-i ment high pressure exists.
Vepco has committed to modifications to both units by January 1, 1981 l
to prevent the condenser air ejection isolation valve from reopening without delib cate operator action. All other Category A and B requirements have been satisfied.
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j II.K.3 FINAL RECOMMENDATIONS OF B&O TASK' FORCE C.3.3 Assure that any f ailure of a PORV or safety valve to close will j
be reported to the NRC promptly. All challenges to the PORVs or safety valves should be documented in the annual report.
This requirement shall be met before issuance of a full-power license.
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RESPONSE
i A' program is being established to ensure that all failures of, or challenges to, PORVs or safety valves are identified and recorded.
Failures -
of the valves will be reported to the NRC promptly.
Challenges to the PORVs or safety valves will"be documented at least annually.
Changes to the
. Technical Specifications to include tho e requirements are being prepared.
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III.D.1.1 PRIMARY COOLANT SOURCES OUTSIDE CONTAINMENT Reduce leakage from systems outside containment that would or could contain highly radioactive fluids during a serious transient or acci-dent to as-low-as-practical levels, measure actual leak rates and establish a program to maintain leakage at as-low-as-practical levels and monitor leak rates.
This requirement shall be met before issuance of a full-power license.
(See NUREG-0578, Section 2.B.5a, and letters of September 27 and November 9, 1979).
RESPONSE
Our January 10, 1980 letter described our leakage evaluation leak reduction programs for North Anna Units 1 and 2.
In addition, our June 9, 1980 letter (Serial No. 490) provided the results of leakage tests recently conducted on Unit 2 systems.
The leakage evaluation effort required by item III.D.l.1 has been completed. In addition, a preventative maintenance program, including periodic leak tests, has been established.
III.A.l.1 UPGRADE EMERGENCY PREPAREDNESS Provide an emergency response plan in substantial compliance with f-NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (which.nay be modified af ter May 13, 1980 based on public comments) except that only a description of and completion schedule for the means for providing prompt notification to the population (App. 3), the staf fing for emergencies in addition to that already required (Table B.1), and an upgraded meteorological program (App. 2) need be provided. NRC will give substantial weight to FEMA findings on offsite plans in judging the adequacy against NUREC-0654. Perform an emergency response exercise to test the integrated capability and a major portion of the basic elements existing within emergency pre-paredness plans and organizations.
This requirement shall be met before issuance of a full-power license.
RESPONSE
The North Anna Emergency Plan has been revised to meet the criteria of NUREG-0654 (See Letters dated April 29,1980, June 6,1980 and June 20, 1980).
The means for providing prompt notification to the public is described in the Emergency Plan. Equipment, location, and cpopletion dates are under develop-ment and will be in accordance with the final rule. The staffing for emergencies has been upgraded and described in the Emergency Plan to meet the criteria of Table B.1, NUREG-0654. The meteorological program changes are under development and will be implemented in accordance with the final rule.
An annual emergency response exercise ~has-been conducted involving the station, state and local
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governments, and independent organizations. The most recent exercise was conducted in October 1979, less than one year ago. An exercise of the new Corporate Emergency Response Plan is scheduled to take place within the next 2 weeks. The exercise scheduled for this Fall will utilize the revised emergency plans at all levels. The emergency plan revisions thus far do not substantially change the conduct of the exercise f rom that conducted in October 1979.
III.D.3.4 CONTROL ROOM HABITABILITY Identify and evaluate potential hazards in the vicinity of the site as described in SRP Sections 2.2.1, and 2.2.3, confirm that operators in the control room are adequately protected from these hazards and the release of radioactive gases as described in SRP Section 6.4, and, if l
necessary, provide the schedule for modifications to achieve compliance with SRP Section 6.4.
j This requirement shall be met by issuance of a full-power license.
RESPONSE
By letters dated February 25,1980 (Serial No.155) and March 17, 1980 l
(Serial No.155A), we submitted the results of our review of the design of the North Anna Units 1 and 2 Control Room to determine its compliance with applicable l
sections of the Standard Review Plan and Regulatory Guides 1.78 and 1.95.
In addition, in response to a specific concern by the Staff and License Condition j
2.D.(7), the habitability impact of the battery room ventilation system ex-hausting into the control room was evaluated by our letter dated June 10, 1980 l
(Serial No. 504).
l The results of the analysis indicate that no modifications to plant i
systems will be required to ensure that the control room operators are adequately l
protected from the evaluated hazards. Based on the reviews of control room l
habitability in accordance with Standard Review Plan sections 2.4.1, 2.2.2, i
2.2.3, and 6.4, and Regulatory Guides 1.78 and 1.95, as described in our letters referenced above, we conclude that the North Anna Units 1 and 2 Control Room meets the specifications and guidance in these SRP sections and Regulatory l
Guides.
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ATTACIIMENT 2 1980 DATED REQUIREMENTS I.A.2.1 IMMEDIATE UPGRADING OF OPERATOR AND SENIOR OPERATOR TRAINING AND QUALIFICATION Applicants for SRO license shall have 4 years of responsible power plant experience, of which at least 2 years shall be nuclear power plant experience (including 6 months at the specific plant) and no more than 2 years shall be academic or related technical training.
Certifications that operator license applicants have learned to operate the controls shall be signed by the highest level of corporate management for' plant operation.
These requirements shall be met on or after May 1,1980. (See March 28, 1980 letter.)
Revise training programs to include training in heat transfer, fluid flow, thermodynamics, and plant transients.
This ' requirement shall be met by August 1,1980.
(See March 28, 1980 letter.)
RESPONSE
The experience requirements for new applicants for SRO applicants has been impicmented, and all new applicants will meet these requirements. Certifi-cations that operator license applicants have learned to operate the controls will be signed by the Manager-Nuclear Operations and Maintenance.
Training programs have been revised to include training in heat transfer, fluid flow, thermodynamics, and plant transients.
I. A.2.3 ADMINISTRATION OF TRAINING PROGRAMS FOR LICENSED OPERATORS Training instructors who teach systems, integrated responses, transient and simulator courses shall successfully complete an SRO examination.
Applications shall be submitted by August 1,1980.
(See March 28, 1980 letter.)
Instructors shall attend appropriate retraining programs that address,
. as a minimum, current oper ati,ng history, problems and changes to pro-cedures and administrative limitations. In the event an instructor is a licensed SRO, his retraining shall'be the SRO requalification program.
Programs shall be initiated by Fby 1,1980.
(See March 28, 1980 letter.)
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RESPONSE
I Three instructors at North Anna Power Station have applied for SRO licenses, and are scheduled for examinations this month. All instructors review current operating history, changes to procedures and limitations, and plant modifications. They will participate in the SRO requalification program.
I.A.3.1 REVISE SCOPE AND CRITERIA FOR LICENSING EXAMS Applicants for operator licenses will be required to grant permission to the NRC to inform their f acility management regarding the results of examinations.
l Contents of the licensed operator requalification program snall be j
modified to include instruction in heat transfer, fluid flow, thermo-dynamics, and mitigation of accidents involving a degraded core.
These requirements shall be met by May 1,1980.
(See March 28, 1980 letter.)
The criteria for. requiring a licensed individual to participate in accelerated - requalification shall be modified to be consistent with the new passing grade for issuance of a license.
l This requirement shall apply to all annual requalification examinations l
conducted af ter March 28, 1980.
(See March 28, 1980 letter.)
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Requalification programs shall be modified to require specific reactivity l
control manipulations. Normal control manipulations, such as plant or i
reactor startups, must. be performed.
Control manipolations during ab-l normal or emergency operations shall be walked through and evaluated l
by a member of the training staf f.
An appropriate c ;."-late - may be used to satisfy the requirements for control manipulations.
i This requirement shall be met by August 1,1980.
(See March 28, 1980 l
letter.)
RESPONSE.
The operator license application letter used by Vepco license applicants has incorporated the granting of permission to the NRC to inform station manage-ment of the examination results. The licensed operator requalification program has been modified to include instruction in heat tranafer, fluid flow, thermo-dynamics, and mitigation of accidents involving a degraded core.
The criteria for requiring accelerated requalification have been up-dated, but the revised program has not yet been submitted to the NRC.
The new criteria will apply to the'1980 annual comprehensive examination.
Specific reactivity control manipulations have been incorporated into the requalification program, as required above.
I.A.3.1 REVISE SCOPE AND CRITERIA FOR LICENSING EXAMINATIONS Simulator examinations will be included as part of the licensee examina-tion.
'This requirement will apply by June 1,1980 to applicants where a simulator is located at the f'acility.
Starting in FY81, simulator examinations will be conducted as part of the licensee examination for applicants where simulators are not available at the facility, depending on availability and suitability of simulators.
RESPONSE
The Surry simulator has already been used for NRC license examinations for Surry license applicants. We intend to comply with the FY81 requirement for North Anna applicants, h
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