ML20041A646

Application to Amend License NPF-7,modifying Keep Warm Sys & Installing Separate Day Tank High Level Alarm for Each Emergency Diesel Generator Fuel Oil Day Tank.Forwards Fee

ML20041A646
Person / Time
Site:	North Anna
Issue date:	02/17/1982
From:	Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Clark R, Harold Denton Office of Nuclear Reactor Regulation
References
079, 79, NUDOCS 8202220375
Download: ML20041A646 (4)

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P-VIBUINIA ELECTMIC AND Powna COMPANY g Rrcuxoxn,VsmonxzA 20261. p h F* f[g,D994 Vacu Pasesonst February 17, 1982 //

Nuctuam oramaroons g Mr. Harold R. Denton, Director Serial h '

Office of Nuclear Reactor Regulation N0/GSS:acm Attn: Mr. Robert A. Clark, Chief Docket No. 50-339 Operating Reactor Branch Noi 3 License r). NPF-7 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Gentlemen:

PROPOSED AMENDMENT TO OPERATING LICENSE NPF-7 NORTH ANNA POWER STATION UNIT 2 Pursuant to 10CFR50.90, the Virginia Electric and Power Company requests an amendment to Operating License NPF-7 for North Anna Power Station Unit No. 2.

The proposed change is enclosed.

The proposed change is to revise License Conditions 2.C.(15)(h) and 2.C.(17) by deleting 2.C.(15)(h).2, by adding 2.C.(17)b, replacing 2.C.(15)(h)4 sad renumbering items 1 through 5 under 2.C. (15)(h) . The diesel generator ven. lor does not concur with the NRC's requiremnents and hns provided an alternate proposal. This proposal would modify the keep warm system to serve the same lubricating purpose. According to Colt Industries, changing the operation of the prelube pump to de as specified by the NRC would allow oil to go into the piston cylinders and create the possibility of a hydraulic lock or smokey starts. Also, it does not appear that a de motor is available in the time frame required.

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The proposal, based on field tests, is to take the oil from the engine sump utilizing the existing 10 gpm lube oil circulating pump, through a heat

. exchanger and a lube oil heater and connect to a point after the engine driven lube oil pump, ahead of the lube oil filter. The oil will then pass through the lube oil filter, lube oil cooler, lube oil strainer and to the engine l'2be oil system, keeping the engine prelubed for emergency starting.

Because the oil will now be flowing through the skid piping system and other components, calculations indicate an additional electric lube oil heater will be-required, this will also necessitate a contactor for the heater. The other requirements are to add a check valve in the keep warm line near the point.

where it enters the main oil piping and a time delay relay to prevent the keep warm pump from starting for ten minutes after the engine is stopped.

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Colt believes the benefits of ttis modification will be much greater than the operation of a de driven 20 gpm prelube pump for 10 to 15 seconds through the starting cycle.

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F Vinotwas Eucturc asu itvra Cour4xy To liarold R. Denton The license condition 2.C.(15)(h)4 requires for rerouting of the Emergency Diesel Generator fuel oil day tank overflow line to the seven day fuel oil storage tank. Ilowever, an evaluation of existing piping systems and equipment layout has shown that it is not possible to install an overflow line on the day tank that would adequately ;eturn excess fuel to the seven day tank.

The overflow line could not be routed in a straight line because of interferences such as r_ie Refueling Water Storage Tank, the Condensate Storage Tank and Auxiliary Peedwater Pump House. An underground routing would have as many interferenecs and the installation of a separate overflow tank would also require its own overflow protection and be inadequate for the same reasons.

Also, the routing of an overflow line to the seven day t ..n k could create additional safety concerns.

It is requested that, in order to preclude day tank overflow, a separate day tank high level alarm be installed for each tank. From a human factors engineering standpoint, the separate annunciation in the control room increases the degree of plant safety by alerting the operator to this specific condition, whereas the original requirement creates further additional safety concerns as stated above.

This request has been reviewed by the Station Nuc1 car Safety and Operating Committee and the Safety Evaluation and Control staff. 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 10CFR170.22.

It has been determined that this request requires a Class III amendment fee.

Accordingly, a voucher check in the amount of $4,000. is enclosed in payment of the required fee.

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Very ri yo s,

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f R . Leasburs Attachments:

1. Proposed Modification to License Conditions 2.C. (15)(h) and 2.C. (1).

2. Voucher Check No. 9718 for $4,000.00.

cc: Mr. James P. O'Reilly, Regional Administrator Office of Inspection and Enforcement Region II l

(15) Prior to resuming power operation following the first refueling outage:

(a) VEPCO shall submit the details of the inspe: tion program for control rod guide thimble tube wall wear for Commission approval; (b) VEPC0 shall install inspection ports in the steam generators; (c) VEPCO shall remove and inspect the recirculation spray pumps inside containment and replace pump bearings if necessary. A similar inspection shall be performed at least once every five years thereafter; (d) VEPCO shall install leak test connections on the RHR isolation valves; (e) VEPCO shall demonstrate by test the backup depressurization capability of the PORV's using the same shutdown procedure as described in VEPCO's procedure 2-OP-3.2 dated 07/23/80; (f) VEPCO shall submit for Commission approval, the results of the tests applicable to North Anna Power Station, Unit 2, of a study concerning mixing of added borated water and enoldown under natural circulation conditions; (g) VEPC0 shall retest all engineered safety. features reset control actions to verify proper reset action; and (h) VEPC0 shall implement the following design and procedural modifications with respect to diesel generator reliability:

1) Complete a formal training program for all the mechanical and electrical maintenance and quality control personnel, including supervisors, who are responsible for the maintenance and availability of the diesel generators. The depth and quality of this training program shall be at least equivalent to that of training programs normally conducted by major-diesel engine manufacturers; 1

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2) The diesel generator operating procedures shall be modified to require loading the engine up to 50 to 75 percent of full load for one hour after eight hours of continuous no load operation;

3) The diesel generator day tank shall be provided with a separate high level alarm in the control room;

4) Each seven day fuel oil storage tank shall be provided with'a seismic Category I, tornado missile, and flood protected emergency fill line. Each fill line shall have a shut-off valve, a strainer, and a truck fill connection consisting of a hose coupling with cap and chain; and

5) With respect to vibration of Instruments and Controls, VEPCO shall either provide test results and results of analyses which qualify the engine skid mounted control cubicles for the severe vibrational stress that will be encountered during engine operation, or floor mount the skid counted panels and control equipment presently furnished with the diesel generators.

(16) Within 90 days following issuance of the pending revision of Regulatory Guide 1.97 " Instrumentation for Light-Water-cooled Nuclear Power Plants to Assess PLANT Conditions During and Following an Accident". VEPCO shall provide a schedule acceptable.

to the NRC for bringing this facility in compliance with Regulatory Guide 1.97, as revised.

(17)a. Prior to resuming power operation following the second refueling outage, VEPCO shall subject the low pressure turbines to an inservice inspection. The inspection shall consist of visual and volumetric examinations. The visual examination shall be applied to 100 percent of all the accessible surface of the rotors, discs and blading. The volumetric examination shall use an ultrasonic technique to fully examine the bore and keyway region of the discs in each low pressure turbine.

The inspection results and evaluation of this inservice inspection shall be reported to the NRC and shall be accepted by the Commission prior to startup following the second refueling outage.

The subject of the generation of turbine missiles for this facility is pending before the Atomic Safety and Licensing Appeal Board.

The license condition imposed herein shall be subject to modification based on the resolution of this pending turbine missile issue,

b. Prior to resume power operation following the second refueling outage, VEPCO shall modify the diesel generator lube oil keep warm system so that it will provide lubrication to prevent dry starting of the diesel generators under emergency conditions.

(18) No later than five years from the date of issuance of this license, VEPCO shall demonstrate to the satisfaction of the Commission that its examination techniques provide a reliable means of detection and

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