ML19340E974
| ML19340E974 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/29/1980 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19340E971 | List: |
| References | |
| IEB-79-27, NUDOCS 8101160424 | |
| Download: ML19340E974 (16) | |
Text
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DEC 2 91990 O
SAFETY EVALUATION EY THE OFFICE OF NUCLEAR REACTOR REGULATION IN SUPPORT OF CHANGES OF IMPLEMENTATION DATES IDENTIFIED IN CERTAIN LICENSE CONDITIONS SPECIFIED IN OPERATING LICENSE NPF-7, NORTH ANNA POWER STATION, UNIT NO. 2
1.0 INTRODUCTION
In a letter dated November 20, 1980, the Virginia Electric and Power Company (VEPCO) requested an amendment of Operating License NPF-7 for North Anna Power Station, nit No. 2.
In letters dated Decmeber 15 and 18,1980 VEPC0 provided additional information regarding their request.
The first proposed change is to revise the required implementatica dates for certain post-TMI requirements identified in the North Anna Unit No. 2 operating license to correspond to the implementation data requirements set forth for operating plants and applicants for operating licenses in NUREG-0737, " Clarification of TMI Action Plan Requirements." These items are:
LICENSE CONDITION PROPOSED
- ITEM TITLE DATE DATE I.D.1 Control Room Design Review August 21, 1981 complete review, using l
NRC Guidelines (NUREG-l 0700) to be issued in 1981, on a schedule that will be determined upon issuance of guidelines i
II.B.1 Reactor Coolant System VENTS December 31, 1981 July 1, 1982 II.B.2 Plant Shielding January 1, 1981 Plant modifications January 1,1982 Equipment Qualifications June 30, 1982 II.B.3 Post-Accident Sampling April 1, 1981 January 1,1982 l
II.D.1 Relief and Safety Valve July 1, 1981 July 1, 1981 Test Requirements II.E.4.1 Containment Dedicated January 1,1981 July 1, 1981 Penetrations II.F.1 Containment Pressure Monitor January 1, 1981 January 1,1982 Item (i)
- Proposed date in accordance with NUREG-0737 I
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DEC 2 91980 LICENSE CONDITION PROPOSED
- ITEM TITLE DATE DATE II.F.1 Containment Water Level January 1, 1981 January 1,1982 Item (ii) Monitoring II.F.1 Containment Hydrogen April 1, 1981 January 1,1982 Item (iii) Concentration Monitoring II.F.1 Containment Radiation January 1,1981 January 1, 1982 Item (iv) Monitor II.F.1 NOBLE Gas Monitor and July 31, 1981 January 1,1982 Item (v)
Iodine Particulate Sampling i
The changes in implementation dates is related to Conditions 2.C.(20) Item a, and 2.C.(21) Items c, d, e, f, h and i of Operating License NPF-7. The implementation dates presently stated in the operating license reflect the requirements specified at the time of license issuance. The required implementation dates for the identified items from NUREG-0660, "NRC Action Plan Developed as a Result of the TMI-2 Accident," have been changed by NUREG-0737.
VEPC0 further indicates that the implementation dates have been relaxed in NUREG-0737 for the entire industry due to revised technical requirements, clarifications and equipment q' alifications and procurement delays.
The second proposed change is related to Condition 2.C(12) of Operating License NPF-7 and NN;f.ests that the required implementation dates specified in the license m ".n. cations associated with IE Bulletin 79-27 " Lass-of-Non-Class regardin o
l IE Instrumentation and Control Power System Bus During Operation" be revised.
2.0 EVALUATION 2.1 TMI ACTION PLAN CONDITIONS l
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2.1.1 CONTROL ROOM DESIGN REVIEW (Item I.D.1)
Condition 2.C.(20) Item (a) of the North Anna Unit No. 2 Operating License NPF-7 requires that no later than one year from the date of issuance of
- Proposed date in accordance with NUREG-0737 L
DEC 2 91980
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the Unit No. 2 operating license, VEPCO shall submit an evaluation of the cenefits of installing data recording and logging equipment in the control room.
In their letter of November 20,1980, VEPC0 request tnat the implementation date for the suouittal of the evaluation be in accordance with the schedule requirements of NUREG-07.37.
In their letter of December 15, 1980, VEPC0 indicates that an evaluation of tne benefits of installing data recording and logging equipment needs to take into consideration the lorg term instrument and control upgrade of the control room to be perfonned in response to Section I.D.1 of NUREG-0737 and the fortncealing NUREG-0700, " Human Engineering Guide to Cantrol Room Evaluation." They further indicated that this was the intent of the present license condition. At the time the condition was imposed, there was no definition of tne long tena control room review program. A change in tne l
implementation aate to be in accordance with NUREG-0737 w;11 pennit an appropriate evaluation of the need for data recoroins equipment in the licensee's detailed control room design review report. The requested change makes the requirement reflect more recent develope nts in this area.
We have reviewed the information provided by VEPCO, and conclude tnat the schedule requirements of NUREG-0737 will result in an evaluation which will reflect more recent developments in control room design and therefore the change in tne implementat.on scheuule is acceptable.
2.1.2 REACTOR COOLANT SYSTEA VENTS (Item II.B.1)
Condition 2.C.(21) Item (c) of the North Anna Unit 2 Operating License NPF-7 requires thai. VEPC0 submit procecural 9uidelines and analytical bases for the reactor coolant system (RSC) vents. Tne reactor coolant vent l
system shall be installed no later than December 31, 1981. In their L
DEC 2 91980 letter of Novemoer 20, 1980, VEPCO proposes that the reactor coolant system vents shall be installe9 no later than the iiaplementation schedule of NUREG-0737; i.e., Jaly 1,1982.
their letter of December 15, 1980, VEPC0 indicates that there have been significant changes to the technical requirennents for the reactor coolant systems vents. All available design information on the reactor coolant system vents will be supplied in VEPCO's response to NUREG-0737. HUREG-0737 requires installation by July 1, 1982 but operating procedures are not to be impleniented ana valves are to be inoperable until NRC approval. Since installation of the RCS Vent connection requires approximately thirty days and removal of the reactor vessel head, VEPC0 proposes that this iaodification be installed at the first refueling outage of North Anna Unit 2 scheculed for the spring of 1982.
l Based on the requirements for the RCS vents which existed during the summer of 1980, the NRC staff concluded in Supplement 11 to the Safety Evaluation Report tnat installation of the vents during the first refueling outage was 1
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acceptable. Since this refueling is now scheduled for the spring of 1982, an extensior of the installation deacline to the NUREG-0737 schedule is consistent uith previous safety evaluations and therefore acceptaole.
l 2.1.3 PLAHT SHIELDING (Item II.B.2)
Condition 2.t..(21) Item (d) of the Nortn Anna Unit 2 Operating License l
HPF-7 reqires tnat VEPC0 shall complete arodifications to assure adequate access to vital areas and protection of safety equipment following an accident resulting in a degraced core no later than January 1,1981.
In their letter of Hoveaber 20, 1980, VEPCO requests that modifications re-garding the above be in accordance with the implementation schedule of
. DEC 2 91980 NUREG-0737, i.e., Plant modifications, January 1,1982, Equipment qualification June 30, 1982.
In their letter of December 16, 1980, VEPCO states tnat engineering related to plant shielcing is approximately 80 percent complete ano equipment replacement modifications are approxinetely 10 percent complete.
There have been some changes in scope resarding tne design of plant shielding si..ce the original requirements. Additional equipment modifications may be required by the NUREG-0737 required inclusion of High Energy Line Breaks in the shielding review. This review and subsequent modifications will be complete by the dVREG-0737 requireu implementation date.
The limiting material items for implementation of the remaining outage related shielding nodifications are as follows:
DATE PURCHASE ITEM ORDER PLACED PROMISED DELIVERY EXPECTED DELIVERY Direct Acting 4/22/80 By 12/31/80 1/19/81 Solencid Valves Air Operated 5/1/80 10/1/E0 12/31/80 Valves Air & Fire 11/11/80 3/1/81 3/1/81 Dampers Based on tiie original scope for the shielding review, VEPCO indicated that necessary niodifications could be complete prior to January 1,1981, depending on timely delivery of valves. As shown above, delivery of some valves will not be made in time to support the previous schedule.
Replacement of these valves will be made at the first outage of sufficient duration following delivery. Since these modifications are an enhancement
. DEC 2 91980 of plant capabilities following a postulatec accident, we conclude that a short delay in installation, consistent with current NRC requirements for all operating reactors is acceptable.
2.1.4 POST-ACCIDENT SAMPLING (Item II.B.3)
Condition 2.C.(21) Item (e) of the North Anna unit 2 Operating License NPF-7 requires that VEPC0 shall complete corrective actions needed to provide the capability to promptly obtain ana perform radioisotopic and chemical analysis of reactor coolant and containment atmosphere samples under degraded core conditions without excessive exposure no later than April 1, 1981.
In their letter of November 20, 1980, VEPC0 requests that the implementation of tne corrective actions related to the above be in accordance with the imple.nentation schedule of NUREG-0737, i.e.. January 1, 1982.
In their letter of December 15, 1980, VEPCO indicates that engineering of the post-accident samplins system is approximately 95 percer.L couplete.
Construction is in progress and is expected to be completed in the summer of 1981. The scneaule is based on delays in major equipment delivery as follows:
EQUIPMENT PROMISEU DELIVERY EXPECTED DELIVERY (1) Liquid Sample Panel 10/1/80 12/15/80 (2) Chemical Analysis 12/1/80 2/1/81 Panels (3'. Chemical Analysis 12/1/80 2/1/81 Control Panels (4) Process Control Panels 12/1/80 1/15/81 (5) Containment Air Sample 12/1/8,0 3/15/81 Control Panels (6) Metal dellows Pumps 12/1/80 12/12/80
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. DEC 2 91980 Upon completion of the construction, the system will be tested, and operators will be trained in order to obtain and analyze samples taken from reactor coolant and containment atmosphere. The system checkout and training is expected to take until January 1,1982. This system will meet the reviseo requirements ind clarifications included in NUREG-0737.
The new post-acciaent sampling system will ennance the current capability of the statioa for sampling and analysis. The short term post-accident sampling facility will continue to be used in the interim and until the improved system can ce installed. VEPCO will continue to use the interim procedure discussec in Section 22.2, Item II.8.3 of Supplement 11 of the Safety Evaluation Report for sampling and analysis. On this basis, we conclude that a delay in installation of the sampling system to be shared with Unit 1 is acceptable and is consistent with current NRC requirements for all operatin3 reactors.
2.1.5 RELIEF AND SAFETY VALVE TEST REQUIREMEhTS (Item 11.0.1)
Condition 2.C.(21) Item (f) of the North Anna Unit 2 Operating License NPF-7 requires that VEPC0 shall complete tests to qualify the reactor coolant system relief and safety valves unoer expected operating conditions for design basis transients and accidents no later than July 1,1981.
In their letter of Novemoer 20, 1980, VEPC0 requests that completion of tests to qualify the reactor coolant system relief and safety valves ce in accordance with tne implementation schecule of NUREG-0737, i.e., July 1,1981. As stated in Section 22.3 Item 11.0.1 of Supplement No.11 to the Safety Evaluation Report, VEPC0 is actively pursuing a joint effort with other members of the utility industry wnich would develop requirements for a generic test facility and program for reactor coolant system relief and safety valve prototypical testing.
J DEC 2 91980 In their letter of Decetaber 15, 1980, VEPC0 indicates that the EPHI testing programs in progress are attempting to meet the NUREG-0737 requirement dates which is the same as in Operating License NPF-7.
Therefore, tne requested change is inter.ded only to recognize the generic nature of these tests and is consistent with i3C requirements for operating reactors and is acceptiole.
?.1.6 CONTAINMENT DEDICATED PENETRATIONS (Item II.E.4.1)
Condition 2.C.(21) Item (h) of the North Anna Unit 2 Operating License NPF-7 requires that VEPC0 shall install redundant relaote manual actuated valves in series to isolate the containment vacuum pumps from the combustible gas control systera. VEPC0 snall also convert the ;aanual valves in the hydrogen recoatiner piping to rerote manual actuation no later than s'anuary 1,1981. In their letter of November 20, 1980, VtPC0 l
requests that tne implenentation of the above be in accoraance with the i
iraplenentation schedule of NUREG-0/57, i.e., July 1,1981.
j In their letter of December 15, 1980, VEPC0 inoicates that engineering l
regarding the above is approximately 90 percent complete and construction-l is scheduled for a spring outage. However, a study is underway _ to determine if any work can be accomplisnea pre-outage. The final design package is i
expected to be issued in early January 1981. Tr.ere have been no significant changes in scope since the original requirements. The limiting material items for implementation of the containment dedicated penetration l
modifications are as follows:
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' DEC 2 91980 DATE PURCHASE ITEM ORDER PLACED PROMISED DELIVERY EXPECTED DELIVERY Direct Acting 4/22/80 By 12/31/80 1/19/81 Solenoid Valves Air Operated 5/1/80 10/1/80 12/31/80 Valves In addition tne dedicated penetration modifications must be complete for Unit 1 and the Post-Accident Monitoring and Control Panels installed (scheduled for spring 1981) to allow final implementation ano testing.
This modification will be co.apleted by the NJREG-0737 required implementation date.
Tne existing license requireaent was based on the expectation tnat all necessary hardware would be delivered during December 1980. However, VEPCO's July 25, 1980 letter indicated that if delivery was late, installation would be celayed into 1981. The staff recognized this possibility in Supplement 11 to the Safety Evalaution Report. Since the modification is designed to further enhance station capabilities following a postulated accident, a delay in completion of implementation, consistent with current l
NRC requirements for all operating reactors is acceptable.
l 2.1.7 ADDITIONAL ACCIDENT NONITORING INSTRUMENTATION (Item II.F.1)
Condition 2.C.(21) Item (i) of the North Anna Unit 2 Operating License l
NPF-7 requires that VEPCO snall install and demonstrate the operability l
i of inst.uments for continuous indication in the control room of the following variables.
Eacn 4.em shall be completed by the specified date in the condition:
(i)
Containment pressure from 0 psia to three tiir,es the desi n 9
pressure 'of the containment no later than January 1,1981; i
DEC 2 91980
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(ii)
Containment water level from (1) the cottosa of the top of the containment sump, and (2) tne bottom of the containment to a level equivalent to 600,000 gallons of water no later than January 1,1981; (iii) Containment atmospnere hydrogen concentration froio O to 10 volume percent shall be installed no later than April 1, 1981; and the hydrogen sampling system to be used in the interim will be installeo no later than January 1,1981; 7
(iv)
Containment radiation up to 10 R/hr. no later than January 1, 1981; ano (v)
Noble cas effluent from eacn potential release point from 5
normal concentrations to 10 uCi/cc (Xe-133) no later than July 31, 1981.
VEPCO sliall also provide capability for continuous sampling and for onsite analysis of the radioiodine and particulate effluent samples no later than July 31, 1981.
Until the above installation is completed, VEPC0 shall use interim i
l monitoring procedures and equipment.
l With respect to monitoring containment pressure, VEPC0 in their letter of November 20, 1980, proposes to change the implementation date to be in accordance with the implementation schedule specified in NUREG-0737; I
i.e., January 1,1982.
i In their letter of December Ib,1980, VEPCO indicated that the modifications I
related to the i.:onitorin9 of containment pressure are complete with the exceptions of qualified indicators anc recorders.
The indicators are l
seneculed for celivery riarch 1981 and the recorders the fall of 1981.
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. DEC 2 91980 The modifications will be completed by the NUREG-0737 implementation date of January 1,1982 and will satisfy the revised requirements and clarifications.
The system is fully operational and capable of measuring and indicating containment pressure from 0 to 180 psia. Since the remaining work involves qualification of equipment to monitor plant conditions, we conclude that a short delay in installation of fully qualified equipment, consistent with current NRC requirecents for all operating eactors is acceptable.
With respect to the monitoring of containment water level, VEPC0 in their letter of December 18, 1980, proposes to change the implementation date to be in accordance with the implementation schedule of NUREG-0737; i.e.,
January 1, 1982.
In their letter of December 15, 1980, VEPC0, indicates that the modifications related to the mos.itoring of containment water level are complete with the exception of qualified wide range indicators and recorders. The indicators are scheduled for delivery April 1981 and the recorders the fall of 1981. The modifications will be completed by the NUREG-0737 implementation date of January 1,1982 and will satisfy the revised requirements and clarifications.
The system is fully operational and capable of measuring and indicating containment water level up to the elevation equivalent to 600,000 gallons.
Since the remaining work involves qualification of equipment to monitor plant conditions, we conclude that a delay in installation of fully qualified equipment, consistent with current NRC requirements for all operating reactors is acceptable.
DEC 2 91980 With respect to the monitoring of containment atmosphere hydrogen concentration, VEPC0 in their letter of November 20, 1980, proposes to change the implementation date to be in accordance with the implementatice schedule of NUREG-0737; i.e., January 1,1982.
In tneir letter of Decemoer 15, 1980, VEPCU indicates that the engineering related to the monitoring of containment hydrogen concentration is scheduled to be complete Feoruary 1981 ano all material is expected to be delivered by June 1981. This waterial had an original delivery date of late 1980.
Installation and testing is scheduled for the fall outage and will be operational by the NUREG-0737 required implementation date of January 1,1982. The system will satisfy the reviseo reqirements and clarifications of NUREG-0737.
A recundant N/drogen analyzer system tnat is not fully qualified is operational along with the capability of using a containment gas sample for analysis.
Since the parameters are nonitored in the interim, a delay in installation consistent with current NRC requirements for all operating reactors is acceptable.
With respect to the monitoring of containment radiation, VEPCO in their letter of November 20, 1980 proposes to change the implementation date to be in accordance with the implementation schedule of NUREG-0737;-1.e.,
January 1,1982.
In tneir letter of December IS,1980, VEPC0 indicates that the engireering related to the monitoring of containment radiation is 90 percent complete.
Detectors and cable are mounted in the containment but not electrically terminated. The vendor (Victoreen) in still qualifying the electrical termination rocedures. All remaining material is scheduled for delivery i
. DEC 2 91980 in April 1981. Outside containment work is scheduled to be completed the surmier of 1981. The remaining in-containment work could be completed at the first outage allowing five days of containment access after material j
delivery and procedure qualification. The modifications will be complete by the NUREG-0737 implementation date of January 1, 1982. On this basis, a delay in installation, consistent with current NRC requirements for all operating reactors, is acceptable.
With respect to the monitoring of noble gas, radiofodine and particulate, VEPC0 in their letter of November 20, 1980 proposes to change the implementation oate to be in accordance with the implementation schedule of NUREG-0737; i.e., January 1,1982.
In their 1 tter of December 15, 1980, VEPC0 estimates that detailed engineering is approximately 60 percent complete. Construction has not started.
It is expected that the system will not be installed and operating until January 1, 1982, because of major equipment availability problems.
VEPC0 has placed a purchase order with Kaman Science Corporation, Colorado Springs, Colorado for a vent stack and process vent high range effluent radiation monitoring system including noble gas monitors, iodine monitors and particulate monitors for which required delivery is 36 weeks.
It is expected that this system can be delivered no earlier than July 31, 1981. Installation and testing is scheduled for four months.
The system will satisfy the revised requirements and clarifications of NUREG-0737.
Until the system is fully operational, existing monitors and interim procedures will be used to monitor releases, as reviewed in Supplement 1
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DEC 2 91980.
10 of the Safety Evaluation Report. Pending complete implementation of the improved monitoring system, we conclude that the interim procedures and equipment are satisfactory. Final installation will be completed on a schedule consistent with current NRC requirements for all operating reactors and therefore, acceptable.
2.2 IE BULLETIN 79-27 Condition 2.C(12) of the North Anna Unit No. 2 Operating License NPF-7 requires that certain modificatior.s associatea with IE dulletin 79-27 must be implenented at the next outa9e of sufficient duration or within six a,onths of issuance of a full power operating license, whicnever comes first.
The modifications had been identified by VEPCO as desirable to improve the ability of the operators to evaluate plant status after loss of power to an instrument bus, but were not essential to satisfy the concerns of IE Bulletin 79-27.
By letter dated November 20,1980, VEPC0 -has requested an amendment to the operating license to permit a delay in implementing a portion of the modifications icentified as desirable pursuant to IE Bulletin 79-27,-
although most of the modifications were implemented in a tircely manner.
Specifically, VEPCO proposes delayin9 the required time for provision of diverse power supplies for the T and T (T and T ).
VEPC0's hot cold h
c request states that the NSS supplier, Westinghouse, identified several potential concerns relative to the interface of this modification with the reactor vessel level instrumentation now Deing designeo. The interface concerns cannot be fully resolved in time to procure equipment and implement the modification in advance of the installation schedule for the level instrunentation.
DEC 2 91980 The modification involving the T and T instruments was previously h
c determined to be desirable to improve safety but not imediately necessary for safe operation. Several related modifications were in fact implemented within schedular requirements. The original schedule for implementing the modification did not anticipate material procurement delays. There is valid reason for delay to ensure proper interface with the reactor vessel instrumentation.
On the basis of the above, we find the requested delay time to be acceptable.
VEPC0 has determined that the requested change does not involve an unreviewed safety question, and we conclude that it does not pose a significant hazards consideration. Accordir-ly, we find that requested change to the license condition, to require that provisions of diverse pcwer supplies for the T and T instruments be implemented prior to startup from the first h
c refueling outage, to be acceptable.
3.0 ENVIRONMENTAL CONSIDERATION
S We have determined that the amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. Having made this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of environmental impact, and pursuant to 10 CFR Section 51,l'd)(4), that an environmental impact statecer,t or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this amendment.
4.0 CONCLL'SION We have concluded, based on the considerations discussed above, that:
(1) because the amendment does not involve a significant increase in the
. DEC 2 91980 probability or consequences of accidents previously considered or a significant decrease in any safety margin, it does not involve a significant hazards consideration; (2) there is reasonable assurance the the health and safety of tne public will not be endangered by operation in the proposed manner; ano (3) such activities will be conducted in compliance with the Cosimission's regulations.
Thus, the issuance of this anenament to change the North Anna Power Station, Unit 2 Operating License NPF-7 related to the implementation dates of l
certain requirements as discussea in Section 2.0 of this report, will not 1
be inimical to the conanon defense and security or to the health and safety of the public. Also, we reaffirm our conclusions as otherwise stated in our Safety Evaluation Report and its Supplements.
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