ML20034D863
| ML20034D863 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/17/1993 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20034D864 | List: |
| References | |
| 93-067, 93-67, NUDOCS 9302240280 | |
| Download: ML20034D863 (4) | |
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,c VIROINIA ELECTHIC ANI' Powen COMPANY RICHMOND. VIRGINI A 232G1 February 17, 1993 U.S. Nuclear Regulatory Commission Serial No.93-067 e
Attention: Document Control Desk NL&P/JBL:
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Washington, D.C. 20555 Docket Nos.
50-338 L
50-339 License Nos. NPF-4 NPF-7 L
Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY.
NORTH ANNA POWER STATION UNITS 1 ANQ_2 EXEMPTION REQUEST FROM THE REQUIREMENTS OF GDC-2 l
SERVICE WATER SYSTEM RESTORATION PROJECT - PHASE I. STAGE 3 By letters dated May 18 and July 16,1992 (Serial Nos.92-287 and 32-450), Virginia Electric and Power Company informed the NRC of plans to perform extensive L
. refurbishment activities for restoration of certain portions of the service water system at North Anna Power Station.- Our July 16,1992 letter requested a temporary exemption from the requirements of 10 CFR Part 50, Appendix A, Criterion 2 (GDC-2)," Design basis for-protection against natural phenomena," to allow excavation of certain portions of the se:vice water piping during Phase I of the project. The NRC approved the Phase I, Stage i exemption request on December 3,1992. 'The purpose of thb letter is to provide the basis for the temporary exemptior, requested for Phase I, Stage 3 of the project.
Phase I, Stage 3 of the project will provide for repair and/or replacement of sections of the 24-inch service water piping to the Unit 2 containment recirculation spray beat exchangers. Several repair and construction approaches, as well as the scope of the project, are being evaluated for Stage 3 of the project to determine the least impact-method of refurbishing these service water lines. The primary focus of this evaluation is to minimize the safety s'gnificance of the construction activities whi' s:so minimizing the regulatory relief that might be necessary to accomplish our goals.
Based on the preliminary conclusions of our evaluation, the Phase I, Stage 3 construction approach is proposed to be very similar to that d. scribed in our Stage 1 submittal for Unit 1 (July 16,1992). Implementation of the Stage 3 effort with this approach will require a temporary exemption from GDC-2 for a period of time beginning approximately 30 days prior to and ending approximately 30 days following the Unit'2 outage scheduled to begin in September of 1993. For planning purposes, this refueling outage is currently scheduled to be 74 days in duration. Implementation of the Stage 3 effort will also involve four entries into the 168-hour Action Statement of Technical Specification 3.7.4.1 associated with service water upgrades for North nna h
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Units 1 and 2. Information supporting this exemption request for Phase I, Stage 3 of the project is provided in the enclosure to this letter.
The provisions of 10 CCR' 50.12 provide that specific exemptions from the requirements of 10 CFR Part 50 may be granted provided the exemptions are authorized by law, are consistent with the common defense and security, are accompanied by special circumstances, and do not present an undes risk to the public health and safety. Virginia Electric and Power Company concludes that the activities sought to be conducted under this exemption request are clearly authorized by law and are consistent with the common defense and security.
As described in 10 CFR 50.12(a)(2), special circumstances must be present for the-NRC to consider granting an exemption. Three examples of special circumstances -
stated in the regulation apply in this case. The first special circumstance is that compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted. The second special circumstance is that the completion of the project as proposed would result in an overall benefit to the public health and safety that compensates for any decrease in safety that may result from the granting of the exemption.
The third special circumstance is that the exemption provides only temporary relief irom the applicable regulation and that the licensee has made good faith efforts to comply with he regulation. A description of these special circumstances is provided in the enclosure to this letter.
7 in addition, in order to implement the service water system restoration project. we also intend to rely on Technical Specifichtion 3/4.7.4.1 that permits us tc amove one service water header from service for up to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> in support of service water upgrade activities. Our restoration plan will require four entries into the 168-hour Action Statement during the third stage of the project (i.e., during the Un;t 21993 refuelinq outage).
Becauw multiple entries into the 168-hour Action Statement will be required, we have ;
developed appropriai' compensatory actions and contingency mcasures to ensure -
availability of requirec s ifety functions. These compensatory actions and contingency-measures are discussed in the attached evaluation. As part of our evaluation supporting the restoration project, we have confirmed that the analyses and assumptions supporting Technical Specification 3/4.7.4.1 remain valid for all stages of the Phase I restoration project.
The enclosure to this letter provides detailed information and the basis for the exemption request for Phase I, Stage 3 of the project. The detailed discussion addresses the proposed scope of work to be performed in conjunction with the North Anna Unit 2 refueling outage and the activities that require exemption for the period
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beginning approximately thirty days prior to the outage and ending approximately thirty days after the outage. The enclosure provides an evaluation that ensures the effects resulting from the implementation of this temporary exemption will be acceptable.
This evaluation includes compensatory actions and contingency measures to provide added assurance of the safe operation of the facility during the exemption period.
t The changes to the facility as a result of work performed in Phase I, Stage 3 of the service water system restoration project have been evaluated in accordance with the L requirements of 10 CFR 50.59. The changes to the facility will be in the form of repairs to the piping and coating of piping to prevent further degradation. Conditional on the acceptance of this exemption request, it has been determined that the changes to the service water system as described in the enclosure do not involve an unreviewed safety question. This exemption request has been reviewed and approved.by the Station Nuclear Safety and Operating Committee and has been reviewed by the 1
Management Safety Review Committee.
In as much as the criteria established by 10 CFR 51.21 may require the NRC to -
perform an environmental assessment for the regulatory action of granting this
. temporary exemption request, we have reviewed the proposed work activities and temporary plant modifications and determined that they will have no significant effect on the quality of the human environment. A discussion of our evaluation is provided in
+he enclosure.
North Anna Unit 2 is currently scheduled to conclude this cycle of operatior and begin a refueling outage on September 4,1993. To support the current project and outage schedules, we request your approval of this temporary exemption request from GDC-2 for Phase I, Stage 3 of the service water system restoration project by August 4,1993.
l Phase i, Stage 4 of the project will include repair and/or replacement of buried and l
concrete encased portions of the two 24-inch auxiliary service. water lines from Lake Anna. New access manways in the auxiliary service water lines will also be added as part of this effort. This work is scheduled to be performed during the concurrent operating period beginning in January of 1994 and ending prior to the Unit 1 refueling outage scheduled to start in October of 1994. Because missile shielding will be temporarily removed from portions of the auxiliary service water lines, a temporary exemption from the requirements of GDC-2 will also be required for this stage of the project. However, at this time, we anticipate that no Action Statement entries will be required for implementation of this stage of the project.
Detailed information supporting the exemption request for Phase I, Stage 4 of the project will be submitted no later than June 30,1993 and NRC approval will be requested by December 31, 1993.
If you have any questions or require additionalinformation, please contact us.
t Very truly yours,
{
W. L. Stewart Senior Vice President - Nuclear Enclosure l
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U.S. Nuclear Regulatory Commission Region ll 101 Marietta Street, N.W.
. Suite 2900~
Atlanta, Georgia 30323
-l Mr. M. S. Lesser NRC Senior Resident inspector North Anna Power Station i
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