ML20050A834

Application to Amend License NPF-7,allowing Util to Test RCS Narrow & Wide Range Resistance Temp Detectors Each Calendar Quarter by Use of Loop Current Step Response Method

ML20050A834
Person / Time
Site:	North Anna
Issue date:	03/30/1982
From:	Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Clark R, Harold Denton Office of Nuclear Reactor Regulation
References
163, NUDOCS 8204020313
Download: ML20050A834 (5)

Text

_ _ _ _ _ _ . ._

.P \

\@ lM/

f\

VIItGINIA HLI CTitIC AND l' owl:It CObtI%NY' s g, YD HICIIMOND, VINGINIA 20 061 /:,' 'j' 'g [ 4

                                                                                     -          ,3                                 9 I

APR 011982* _ March 30, 1982 - It. it. Lu nn e no g $ ra,m. y wwutwMt y v ,< . i.u a. ., . . - r2 Ns:ctuam OramArso a $ g fh" 0 iG Mr. liarold R. Denton, Director Serial No. . Office of Nuclear Reactor Regulation N0/JHL:aca Attn: Mr. Robert A. Clark, Chief Docket No. 50-339

Operating Reactors Branch No. 3 License No. NPF-7 4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Gentlemen

AMENDMENT TO OPERATING LICENSE NPF-7 NORTil ANNA POWER STATION UNIT NO. 2 PROPOSED OPERATING LICENSE AMENDMENT Pursuant to 10 CFR 50.90, the Virginia Electric and Power Company requests an amendment to Operating License NPF-7 for North Anna Power Station Unit No. 2. This proposed license amendment requests a change in North Anna Unit 2 license condition 2.C(4)(c). This change requests that North Anna Unit 2 be allowed to test the reactor coolant system narrow and wide range resistance temperature detectors each calender quarter by the use of the Loop Current Step Response method until a long-term qualified resistance temperature detector is available. Vepco will replace the resistance temperature detectors if unsatisfactory Loop Current Step Response test results are acquired. The proposed amendment is enclosed in Attachment 1. A discussion of the proposed change is provided in Attachment 2. This request has been reviewed and approved by the Station Nuclear 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 as defined in 10 CFR 50.59. We have evaluated this request in accordance with the criteria in 10 CFR 170.22. Since this request involves a safety issue which the Staff should be able to determine does not pose a significant hazard consideration for Unit 2, a Class III license amendment fee is required for Unit 2. Accordingly, a voucher check in the amount of $4000.00 is enclosed in payment of the required fees. Very trul' yo s, R. H. Leasburg 8204020313 820330 ' DR ADOCK 05000339 PDR g(

t 1 f liarold R. Denton Vinotwar Er.rcinic avo Powrw Couraxy to l

l I

1 Attachments

l. Proposed Operating License Amendment

2. Discussion of Proposed Operating License Amendment

3. Voucher Check No. 13270 for $4000.00 i

cc: ffr. James P. O'Reilly i Regional Administrator l Region II 4 4 i l-s l 4 I f

                                                                                                      - _ . -       __._._._._-L_.___      . _ - . _

COMMONWEALTH OF VIRGINIA )

                                              )

CITY OF RICHMOND ) The foregoing document was acknowledged before me, in and for the City and Commonwealth aforesaid, today by R. H. Leasburg, who is Vice President-Nuclear Operations, of the Virginia Electric and Power Company. He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief. Acknowledged before me this Jo M day of ) M , 19 M A . My Commission expires: 4 - .2. 6 , 19 p.s ,

                                                                                     %        d  h*h Notary Public (SEAL) l l

l l l

a

 .       .                                                                                   <                    (3)      Initial Test Prc, gram VEPCO shall conduct the post-fuel-loadfug initial test program (set forth in Section 14 of VEPCO's Fical Safety Analysis Report, as amended) without making any major mcMifications of this program unless modifications have been identified and have received prior Commission approval. Major modifications are a defined as:                                                                    4
                                                                           .r<

a. Elimination of any test identified,in Section 14 of VEPCO's Final Safety Analysis Report, as amended, as i. essential;

                 /                            b. Modification of test objectives, methods or acceptance criteria for any test identified in Section 14 of VEPCO's Final Safety Analysis Report, as amended, as es6ential;

c. Performance of any test at a power level different from there described; and

d. Failure to complete any tests included in the described program

                   .                                (planned or scheduled for power levels up to the authorized
             -                                      power level).

(4) VEPCO shall take the following remedial actions, or alternative actions, acceptable to the Commission, with regard to the t environmental qualificacian requirements for Class lE equipment: ao No later than November 1, 1980, VEPCO shall submit information

                            ,-                      to show compliance with the requirements of NUREG-0588,
                                                    " Interim Staff Position on Envirdnmental Qualification of                           <

Safety-Related E'.ict/fcal Equipment," for safety-related e equipment exposed to;a harsh environment;

b. NolaterthanJune30,'s19b,VEPC0shallreplaceRosemount pressure transmitters % d differential presrure transmitters, and pressure transmitters' and dif ferential pressure trans-mitters from Barten lot I with suitably qualified devices; and t

c. VEPC0 shall test the narrow and wide-range gesistance temperature detectors for the reactor coolant-system by the

               ,r                                   Loop Current Step Response c.ethod eachfcalender quarter until a long-term qualified resistance temperature detector is avail-
                     >                              able. Resistance temperature detectors will be replaced if un-satisfactory Loop Current Step Response

• test re,sults are acquired. ..

                                                 -.                                                  P

e. ,. ..

                                                                                          +          r
                        /
                                                                                                                                                    ^ ~

• ew m-

                                                                                                                                         ,      <u.b-7 _                                _

g a S amQ'q f j , u { _f

                                                                                                     /                  +                         .

DISCUSSION OF PROPOSED OPERATING LICENSE AMENDMENT i

    -v License Condition 2.C(4)(c) states that, "No later than June 30, 1982, the wide-range resistance temperature detectors for the reactor coolant system shall be qualified for radiation exposure for the 40-year plant life and appropriate exposure condition due to design basis accidents.            Pending
 ,-          completion of such qualification and acceptance by the Commission, VEPCO shall replace each of these detectors at each refueling outage". VEPC0 provided a response regarding RTD replacement to the NRC Safety Evaluation Report for environmental qualification of safety-related electrical equipment. In the license condition for Unit 2 and our commitments on environmental qualification for both North Anna 1 and 2, VEPCO committed to replace RTD's during each refueling outage until a long-term qualified RTD is available.

The Electric Power Research Institute (EPRI) has developed an accurate method for measuring RTD time response c.alled the Loop Current Step Response (LCSR) method. Vepco has evaluated, At,alysis and Measurement Services Corporation (AMS) test equipment, the LCSR method and found it to be a viable method for obtaining reasonably accurate results. In addition, it is VEPCO's

          ' understanding that the NRC has reviewed the AMS LCSR methodology and finds it to be reliable and adequate to measure the RTD time constant and time response. Based on the above discussion on the improved accuracy of RTD time response testing, Vepco intends to test (LCSR method) the Reactor Coolant System (RCS) Narrow and Wide Range RTD's in Units 1 and 2 cach quarter until a long-tern qualified RTD is available.      We do not intend to replace the RCS RTD's during      the Spring 1982 rafueling outages, unless we acquire unsatisfactory LCSR test results on Individual Rosemount RTD's. VEPCO feels this is a trasonable approach based on the results of the NRC and EPRI studies.

The probability of occurrence or the consequences of a malfunction of equipment important to safe;y and previously evaluated in the FSAR is not increased because the Loop Current Step Response test method in no way increases the probability that a resistance temperature detector will fail. The possibility of a different type of accident or malfunction than was previously evaluated in the FSAR has not been created because no physical modifications to the system will be made and all resistance temperature detectors will remain in service.

      . The margin of safety as described in the BASIS section of any part of the Technical Specifications is not reduced because the reactor coolant system resistance temperature detectors will be tested each calender quarter until a long-term qualified resistance temperature detector is available.

l

                                                                                      -}}