ML19351E818

Forwards Addl Info Re Util 801120 Proposed Amend to License NPF-7,in Response to NRC Request.Impact of Changes & Equipment Delays on Implementation Dates for TMI Requirements & Plant Mods Per IE Bulletin 79-27 Discussed

ML19351E818
Person / Time
Site:	North Anna
Issue date:	12/15/1980
From:	Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Youngblood B Office of Nuclear Reactor Regulation
References
980, IEB-79-27, NUDOCS 8012190378
Download: ML19351E818 (7)

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ra December 15, 1980 Mr. Harold R. Denton, Director Serial No. 980 Office of Nuclear Reactor Regulation N0/RWC:jmjU1 Atta:

Mr. B. Joe Youngblood, Chief Docket No. 50-339 Licensing Branch No. 1 License No. NPF-7 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Denton:

ADDITIONAL INFORMATION PROPOSED AMENDMENT TO OPERATING LICENSE NPF-7 NORTH ANNA POWER STATION UNIT NO. 2 This letter is in response to your staff's request for additional information concerning our letter dated November 20, 1980 (Serial No. 914) requesting an amendment to Operating License NPF-7 for North Anna Power Station Unit No. 2.

The first proposed ch.inge was to revise the required implementation dates for certain post-TMI requirements identified in the North Anna Unit No. 2 Operating License to correspond to the implementation date requirements set forth in NUREG-0737.

The implementation dates have been relaxed in NUREG-0737 for the entire industry due to revised technical requirements, clarifications and equipment qualification and procurement delays.

Attached is a discussion of how these changes and equipment delays impact the implementation of the require-ments at North Anna Unit 2.

The second proposed change was to clarify and revise the required implement-ation dates for modifications associated with IE Bulletin 79-27.

Additional info rmation concerning the delay in implementation of the diversification of power supplies for T and T is attacheo.

h Since some of the proposed changes involve January 1,1981 requirement dates, we would appreciate your prompt review and approval of our request.

If you require any additional informatior., please contact us.

Very truly yours, 9

80 B. R.

ylvia Manager - Nuclear Operations and Maintenance Attachment ec:

Mr. James P. O'Reilly, Director Office of Inspection and Enforcement Region II E 1.0 0..

Attschment Page 1 of 6 (C20) TMI ACTION PLAN CONDITIONS (a) Control Room Detign Review (Section 22.2 Items I.D.1)

An evaluation of the benefits of installing data recording and logging equipment needs to take into consideration the long term instrument and control upgrade of the control room to be performed in response to Section I.D.1 of NUREG-0737 and the forthcoming NUREG-0700. This was the intent of the present license condition.

At the time the condition was imposed, there was no definition of the long term control room review program. When this definition is finalized, an appropriate evaluation of data recording can be made.

There would be little value in performing tt's evaluation prior to the overall review; this was recognized previously. The requested change makes the requirement reflect more recent developments in this area.

(C21)

TMI ACTION PLAN DATED CONDITIONS (c) Reactor Coolant System Vents (Section 22.2 Item II.B.1)

There have been significant changes to the technical requirements for this item. All available design information on the Reactor Coolant System Vents will be supplied in our response to NUREG-0737.

NUREG-0737 requires installation by July 1, 1982 but operating procedures are not to be implemented and 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, this modification will be installed at the first refueling outage of North Anna Unit 2 scheduled for the Spring of 1982.

Based on the requirements for the RCS vents which existed during Summer 1980, the NRC Staff concluded in Supplement 11 to the SER that installation of the vents during the first refueling outage was acceptable. Since this refueling is now scheduled for the Spring of 1982, an extension of the installation deadline to the NUREG-0737 schedule is consistent with previous safety evaluations.

(d) Plant Shielding (Section 22.3 Item II.B.2)

Engineering is approximately 80% complete and equipment replacement modifications are approximately 10% complete.

There have been some changes in scope since 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 NUREG-0737 required implementation date. The limiting material items for implementation of the remaining outage related shielding modifications are as follows:

Attechment Page 2 of 6 ITEM P.O. NO.

DATE PLACED PROMISED DEL.

EXPECTED DEL.

Direct Acting 34670 4/22/80 By 12/31/80 1/19/81 Solenoid Valves Air Operated 35085 5/1/80 10/1/80 12/31/80 Valves Air & Fire 50151 11/11/80 3/1/81 3/1/81 Dampers Based on the original scope for the shielding review, Vepco indicated that necessary modifications 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 of plant capabilities following a postulated accident, a short delay in installation, consistent with current NRC requirements for all operating reactors, is considered acceptable.

(e) Post Accident Sampling System (Section 22.3 Item II.B.3)

Engineering is approximately 95% complete. Construction is in progress and is expected to be complete in the Summer of 1981. The schedule is based on delays in major equipment delivery as follows:

Equipment Purchase Order No.

Promised Del.

Expected Del.

(1) Liquid Sample 29086 10-1-80 12-15-80 Panel l

(2) Chemical Analysis 42434 12-1-80 2-1-81 Panels i

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(3) Chemical Analysis 42434 12-1-80 2-1-81 Control Panels (4) Process Control 47334 12-1-80 1-15-81 l

Panels l

(5) Containment Air Not Available 12-1-80 3-15-81 Sample Control Panels (6) Metal Bellows 37807 12-1-80 12-12-80 Pumps 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 l

The system checkout and training is expected to take until January 1,1982.

This system will meet the revised requirements and clarifications included in NUREG-0737.

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Attachment Page 3 of 6 The new post-accident sampling system will enhance the current capability of the station for sampling and analysis. The short term post-accident sampling facility will continue to be used in the interim. A delay in installation of the sampling system to be shared with Unit 1 is considered acceptable and is consistent with current NRC requirements for all operating reacters.

(f) Relief and Safety Valve Test Requirement (Section 22.3 Item II.D.1)

The EPRI testing programs in progress are attempting to meet the NUREG-0737 requirement dates.

The requested change is intended simply to recognize the generic nature of these tests.

(g) Auxiliary Feedwater Initiation and Indication (Section 22.3 Item 22.3 Item II.E.2)

The modification to upgrade the safety grade indications of AFW flow from semi-vital bus power to vital bus power is complete for North Anna Unit 2.

An extension to the January 1, 1981 require-ment is no longer necessary.

(h) Containment Dedicated Hydrogen Penetration (Section 22.3 Item II.E.4.1)

Engineering is approximately 90% complete and construction is scheduled for a spring outage. However, a study is underway to determine if any work can be accomplished pre-outage.

The final Design Package is expected to be issued in early January.

There have been no l

significant changes in scope since the original requirements. The limiting material items for implementation of the containment -

dedicated penetration modifications are as follows:

ITEM P.O. NO.

DATE PLACED PROMISED DEL.

EXPECTED DEL.

j Direct Acting 34670 4/22/80 By 12/31/80 1/19/81 Solenoid Valves Air Operated 35085 5/1/80 10/1/80 12/31/80 i

Valves In addition the dedicated penetration modifications must be complete for Unit I and the Post Accident Monitoring and Control Panels installed (scheduled for Spring 1981) to allow final buplementation I

and testing.

The modification will be completed by the NUREG-0737 required implementation date.

The existing license requirement was based on the expectation that all necessary hardware would be delivered during December 1980.

l However, our July 25, 1980 letter indicated that if delivery was.

late, installation would be delayed into 1981. The Staff recognized i

this possibility in Supplement 11 to the SER.

Since the modification is designed to further enhance station capabilities following a postulated accident, a delay in completion of implementation, consistent with current NRC requirements for all operating reactors, is considered acceptable.

Attachment Page 4 of 6 (1) Additional Accident Monitoring Instrumentation (Section 22.3 It em II. F.1)

(i)

Containment Pressure The modifications are cocplete with the exceptions of qualified indicators and recorders. The indicators are scheduled for delivery March 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 i

the revised requirements and clarifications.

i The system is fully operational and capable of measuring and indicating containment pressure from 0 to 180 psia.

Since the temaining work involves qualification of equipment to monitor plant conditions, a short delay in installation of j

fully qualified equipment, consistent with current NRC requirements for all operatng reactors, is considerad accept-able.

(ii)

Containment k'ater Level i

The modifications 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 Laplementation 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 l

equivalent to 600,000 gallons.

Since the remaining work involves qualification of equipment to monitor plant condi-(

tion a delay in installation of fully qualified equip-ment, consistent with current NRC requirements for all operating reactors, is considered acceptable.

(iii) Containment Hydrogen Concentration Engineering is scheduled to be complete February,1981 and all material is expected to be delivered by June, 1981. This material 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 revised requirements and clarifications of NUREG-0737.

A redundant hydrogen analyzer system that is not fully l

qualified is operational along with the capability of using a containment gas sample for analysis.

Since the parameters are monitored in the interim, a delay in installation consistent with current NRC requirements for all operating reactors, is considered acceptable.

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Attachment Page 5 of 6 (iv)

Containment Radiation Monitor Engineering is 90% complete.

Detectors and cable are mounted in the containment but not electrically terminated.

The vendor (Victorcen) is still qualifying the electrical termination procedures.

All remaining material is scheduled for delivery in April, 1981. Outside containment work is scheduled to be completed the Summer of 1981. The remaining in-containment work could be completed at the first outage allowing five days of containment access after material delivery and procedure qualification.

The modifications will be complete by the NUREG-0737 implementation date of January 1,1982.

A delay in installation, consistent with current NRC requirements for all operating reactors, is considered acceptable.

(v)

Noble Gas, Radioiodine and Particulate Vepco estimates that detailed engineering is approximately 60% 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.

Vepco 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 SER Supplement 10.

Pending complete implemen-tation of the improved monitoring system, the interim procedures and equipment are considered to be satisfactory.

Final installation will be completed on a schedule consistent with current NRC requirements for all operating reactors.

(j)

Inadequate Core Cooling Instruments (Section 22.3 Items II.F.2)

NUREG-0737 requires the implementation of the reactor vessel level systems by January 1, 1982 and the documentation associated with these systems by January 1, 1981.

Present schedules show that the Westinghouse reactor vessel level monitoring system along with the supporting analyses will be available June of 1981 at the earliest.

The balance of plant engineering and strass analysis will require apprnyimately three months following receipt of the Westinghouse reactor-vessel level monitoring system design. This places the installation of the reactor vessel level system in the Fall of 1981 at the earliest.

Installation will require an approximate two-month outage and the removal of the reactor vessel head. Therefore, Vepco intends to install the reactor vessel level monitoring systems in North Anna Unit 2 during the first refueling outage.

Attachment Page 6 of 6 4

(Cl2) Loss of Non-Class IE Instrumentation and Control Power System Bus During Operation Following the initial review of our proposed design for the Westinghouse stated they diverse power supply of T felt +.hatnochangetothebe*s"ignwasdarranted. The design for ho cold diverse power supply interfaces with the requirements of the Westinghouse reactor vessel level system. Several potential concerns associated with the interface have been raised by Westinghouse. However, Westinghouse has given a preliminary acceptance to our design for engineering and procurement but is withholding their final approval pending final design of the level system. Vepco has proceeded with purchasing equipment and two long lead items have been identified:

isolators (26 weeks) and recorders (52 weeks).

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