ML20079G182

Proposed Change to Tech Spec 6.13 Providing Environ Qualification of safety-related Class IE Electrical Equipment No Later than Second Refueling Outage Beginning After 820331 for Both Units

ML20079G182
Person / Time
Site:	North Anna
Issue date:	06/04/1982
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20079G172	List: ML20079G169 ML20079G182
References
NUDOCS 8206080341
Download: ML20079G182 (5)

Text

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4 ATTACIOiENT 1 PROPOSED TECHNICAL SPECIFICATION CHANGE - UNIT 1 e

8206080341 820604 PDR ADOCK 05000338 P ppg

ADMINISTRATIVE CONTROLS 6.13 ENVIRONMENTAL QUALIFICATION 6.13.1 By no later than the second refueling outage beginning after March 31, 1982 all safety-related electrical equipment in the facility shall be "

qualified in accordance with the provisions of: Division of Operating Reactora " Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Reactors" (DOR Guidelines); or NUREG-0588,

" Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment". December 1979. Copies of these documents are attached to Order for Modification of License NPF-4 dated October 24, 1980.

6.13.2 By no later than December 1, 1980, complete and auditable records must be available and maintained at a central location which describe the environ-mental qualification method used for all safety-related electrical equipment in sufficient detail to document the degree of compliance with the D0R Guide-lines or NUREG-0588. Thereafter, such records should be updated and maintained current as equipment is replaced, further tested, or otherwise further qualified.

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NORTil ANNA - UNIT 1 6-23 i .

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ATTACHMENT 2 PROPOSED OPERATING LICENSE AMENDMENT - UNIT 2 l

s "By no later than December 1, 1980, complete and auditable

. (d) rcccrde must be available and maintained at a central location which describe the environmental qualification method used for all safety-related elec'trical equipment in sufficient detail to document the degree of compliance with the DOR Guidelines or NUREG-0588. Thereafter, such records should be updated and maintained current as equipment is replaced, further tested, or otherwise further qualified to document complete compliance by June 30, 1982."

(c) "By no later than the second refueling outage beginning after March 31, 1982, all safety-related electrical equipment in the facility shall be qualified in accordance with the provisions cf:

Division of Operating Reactors " Guidelines for Evaluating Environmental Qualifications of Class 1E Electrical Equipment in Operating Reactors" (DOR Guidelines): or NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," December 1979. Copies of these documents are attached to Order for Modification of License NPF-7 dated November 7, 1980.

(5) Prior to operating the facility at a power level above 25 percent, VEPC0 shall develop a surveillance program for fiberglass spray pond l piping and supports that is in compliance with the regulatory position  !

in Revision 2 of Regulatory Guide 1.72, or an alternative position acceptable to the Commission.

(6) Prior to operating the facility at a power level above 90 percent, VEPCO shall perform secondary flow stability tests which have been approved by the Commission. VEPCO shall provide at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification to Office of Inspection and Enforcement (OIE) prior to conducting such approved tests so that these tests may be witnessed by the Commission.

The exceptions to Technical Specifications 3.3.2.1(a), 3.3.2.1(b),

3.5.2, 3.7.1.2, and 3.7.1.3, issued with Amendment No. 2 to the Fuel-Load and Low-Power Testing License dated August 1980 shall be in effect until these are completed. -

(7) Prior to operating the facility at a power level above 90 percent, VEPCO shall demonstrate to the satisfaction of the NRC that the actual in-plant measurements of transformer tap settings are in agreement with their analysis.

(8) Prior to operating above 90 percent power, VEPCO shall complete the visual verification of operability of the 37 feedwater system hydraulic snubbers, designated in VEPCO's letter dated August 7, 1980, at operating temperature to the satisfaction of the OIE.

(9) VEPCO is authorized to perform steam generator moisture carryover studies at the North Anna Station. These studies involve the use of an aqueous tracer solution of two (2) curies of sodium-24. The licensee personnel will be in charge of conducting these studies and be knowledgeable in the procedures. VEPCO will impose personnel exposure limits, posting, and survey requirements in conformance with those in 10 CFR Part 20 to minimize personnel exposure and contamination during the studies. Radiological controls will be established in the areas of the chemical feed, feedwater, steam,

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ATTACHMENT 3 1 DISCUSSION OF PROPOSED CHANCES i

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DISCUSSION OF PROPOSED CHANGES North Anna Unit No. 1 Technical Specification 6.13 and North Anna Unit No. 2 License Condition 2.C(4)(e) currently read, "By no later than June 30, 1982 all safety-related electrical equipment in the facility shall be qualified in accordance with the provisions of: Division of Operating Reactors, Guidelines for Evaluating Environmental Qualification of Class IE Electrical Equipment in Operating Reactors (DOR Guidelines); or NUREG-0588, Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment, December, 1979. Copies of these documents are attached to Order of Modification of License NPF-4 dated October 24, 1980 and NPF-7 dated November 7, 1980."

The proposed change is to provide environmental qualification of safety-related Class 1E electrical equipment no later than the second refueling outage beginning after March 31, 1982 for both North Anna Unit Nos.

I and 2. This proposed change is consistent with the deadline as promulgated by the NRC in a Federal Register Proposed Rule dated January 20, 1982.

The NRC Staff issued an SER for North Anna Power Station setting forth the results of its analysis on Vepco's submittals regarding the environmental qualification of Class 1E equipment. The SER listed several issues that were unsatisfactory in qualification documentation according to the NRC Staff.

These issues were related to DOR Guidelines and NUREG-0588 interpretations.

Despite the unsettled technical positions, the SER did not contain any items which needed immediate corrective action.

Vepco has been working to resolve the environmental qualification issues that were raised. Vepco is preceeding on an orderly schedule to provide adequa e documentation or replace equipment. The schedule is based upon realistic assessments of equipment availability, procurement times, and plant refueling I

cycles.

If the proposed change for North Anna Unit Nos. 1 and 2 is provided, Vepco will continue to pursue the resolution of the remaining outstanding items in the SER, thereby providing the NRC with the continuing assurance that progress on overall resolution of the environmental qualification matter is being made.

The continued operation of North Anna Unit Nos. I and 2, pending resolucion of the environmental qualification matter is justified based on Vepco's responses dated August 24, 1981 and September 4, 1981 to the Staff's Equipment Evaluation Reports dated May 20, 1981 and June 3, 1981 and upon the results reflected in the SER. The interim operation of North Anna Unit Nos. I and 2 will not endanger public health or decrease the margin of safety.

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